Consumer Health Data Privacy Policy
Last Updated: October 4, 2024
This Consumer Health Data Privacy Policy provides information regarding how Welltower OP LLC (“Welltower”, “we,” “our,” or “us”) process “consumer health data” as defined by Washington’s My Health My Data Act (“WMHMDA”) and other applicable consumer health privacy laws.
In the event of a conflict between Welltower’s Privacy Policy and this Consumer Health Data Privacy Policy, this Consumer Health Data Privacy Policy will control with respect to the processing of consumer health data. Note that this policy does not apply to personal information that is not subject to the WMHMDA, including to information that is specifically exempt from the WMHMDA, which includes, among other things, protected health information subject to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations. In the event of a conflict between our residential properties’ HIPAA Notice of Privacy Practices and this Consumer Health Data Privacy Policy, the HIPAA Notice of Privacy Practices shall control, where applicable, with respect to protected health information. This Consumer Health Data Privacy Policy does not apply with respect to consumer health data collected on websites operated by Welltower’s third-party property managers.
Consumer health data we collect
We collect consumer health data in connection with certain of our products and services, such as when you visit our websites or engage and interact with our residential properties or services provided thereby (collectively, the “Services”). The type of consumer health data depends on the Service and your interactions with us. Examples of consumer health data that we collect may include:
How we use consumer health data
We primarily collect and use consumer health data as necessary to provide you with products or services that you request or for other purposes for which we obtain your consent as required by applicable law. This may include the following:
We may also collect and use consumer health data as necessary to protect the rights and safety of us, our affiliates, you, or others, such as to:
We may deidentify consumer health data so that it cannot reasonably be reidentified by us or by another person, and we may use this deidentified data for any reason permitted by applicable law. If we deidentify information that was originally based on consumer health data, we maintain and use that information in deidentified form and will not attempt to reidentify the data, except as otherwise permitted under applicable law.
Sources of consumer health data
We collect consumer health data directly from you and automatically as you interact with our Services.
The specific sources of consumer health data depend on the Service and your interaction with us.
How we share consumer health data
We may share each of the categories of consumer health data described in this Consumer Health Data Privacy Policy as necessary to provide you with a product or service you request, with your consent, or for certain security-related purposes, as described in the “How we use consumer health data” section above. We may also share consumer health data:
Third parties and affiliates with which we share consumer health data
As necessary for the purposes described above, we share consumer health data with the following categories of third parties and affiliates:
How to exercise your rights
Under the WMHMDA, subject to certain exceptions, you may have the right to access or delete consumer health data about you, or receive a list of third parties and affiliates with whom your consumer health data was shared. You also may have the right, subject to certain exceptions, to withdraw consent relating to the use and sharing of your consumer health data. To exercise these rights, you may email us at privacy@welltower.com or submit a request through our online webform. We will use information you provide in your request to verify your identity, and we may request additional information if necessary to complete the verification process.
If your request to exercise a right under the WMHMDA is denied, you may appeal that decision by contacting us as described below. If your appeal is unsuccessful, you can lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
If you have questions about this Consumer Health Data Privacy Policy or would like to make a complaint to Welltower you can contact us at 877-670-0070, privacy@welltower.com, or write us at:
Welltower OP LLC
4500 Dorr Street
Toledo, Ohio 43615-4040
Attn: Data Privacy Officer
Supplement to Consumer Health Data Privacy Policy for Nevada consumers
This supplement applies only with respect to Nevada consumers and provides additional information required by Nevada’s consumer health privacy law.
Requesting Changes to Consumer Health Data. You may request a change to your consumer health data by contacting us by email us at privacy@welltower.com. We will use information you provide in your request to verify your identity, and we may request additional information if necessary to complete the verification process. If your request to change your consumer health data is denied, you may appeal that decision by contacting us as described above.
Third Party Collection of Consumer Health Data. Third parties do not collect consumer health data over time and across different websites or online services when you use Welltower’s websites.
Changes to this Consumer Health Data Privacy Policy. We may modify or update this Consumer Health Data Privacy Policy from time to time. We encourage you to visit this Consumer Health Data Privacy Policy regularly to learn about any changes to the way we collect, use, or share your consumer health data. If we make a material change to this Consumer Health Data Privacy Policy, we will take reasonable steps to notify you as required by applicable law.