Consumer Health Data Privacy Policy

For Washington residents, as required by the Washington My Health My Data Act (RCW 19.373).
Effective Date: April 15, 2026.

Current scope. Wiser Workplace presently accepts submissions only from California residents. Our intake forms gate out residents of Washington and other states, and we do not market the Services to Washington residents. This policy is published and maintained as a safeguard, so that the commitments below apply in the unlikely event consumer health data from a Washington resident is nevertheless received.

This policy is separate from our general Privacy Policy. If, despite our intake-gating, we receive consumer health data about a Washington resident, the provisions below apply as required by RCW 19.373.030. For everything else, please see our Privacy Policy.

1. Who we are

Wiser Workplace LLC (the "Company," "we," "us") is a California limited liability company. We operate wiserworkplace.com, a technology platform that provides a structured, confidential channel between California employees and California employers: the employee submits a workplace concern, the platform routes it to the employer the employee identifies, and the parties use the platform to exchange messages and documents while the concern is open. Wiser Workplace is not a law firm. At Q3 2026 launch, the parties can engage independent California mediators bilaterally selected through the platform.

We are a "regulated entity" under RCW 19.373.010(20) when we collect, process, share, or sell consumer health data about Washington residents.

2. What "consumer health data" means in this policy

Consumer health data means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status, as defined in RCW 19.373.010(8). For our service, this includes, without limitation:

Information about disabilities, medical conditions, and requests for reasonable accommodation;
Information about mental-health conditions, treatment, or medications;
Information about pregnancy, reproductive or sexual health, or gender-affirming care;
Information about substance use or substance-use treatment;
Information contained in narrative descriptions of workplace concerns that references any of the above (for example, a disability-discrimination narrative or a medical-leave retaliation narrative);
Precise geolocation data that could reasonably indicate attempts to obtain health services (we do not collect precise geolocation);
Inferences drawn from any of the above.

3. Categories of consumer health data we collect

We collect the following categories of consumer health data directly from Washington residents who use our intake form:

Narrative descriptions of workplace concerns that reference health status, disability, accommodation, medical leave, or treatment;
The category label you select when classifying your concern (for example, "disability accommodation" or "leave and accommodation");
Dates of leave, accommodation requests, or medical appointments that you choose to disclose;
Identifiers associated with the data, including your name, email address, phone number, and, in some cases, the name of your employer or supervisor.

We do not purchase consumer health data from data brokers. We do not collect precise geolocation data. We do not infer health status from browsing behavior.

Geofencing. Wiser Workplace does not use geofencing of any kind. We specifically do not implement, use, or contract for any geofence around an entity that provides in-person health-care services for any of the purposes prohibited by RCW 19.373.090, including identifying or tracking consumers seeking health-care services, collecting consumer health data from such consumers, or sending notifications, messages, or advertisements to such consumers related to their consumer health data or health-care services.

4. Sources of consumer health data

We collect consumer health data directly from you when you submit our intake form or otherwise communicate with us about your concern. We do not receive consumer health data from data brokers, affiliates, or third-party advertisers.

5. How we use consumer health data

We use consumer health data solely for the following purposes:

To route your submission to the employer you identify;
To track the employer's response window and enable message and document exchange between you and the employer through the platform;
To communicate with you about your matter;
To comply with our legal obligations, including responding to valid legal process;
To defend or pursue legal rights, including our own, when necessary.

We do not use consumer health data for targeted advertising, for profiling for decisions that produce legal or similarly significant effects, or for any purpose beyond operating the Services.

6. How we share consumer health data

We share consumer health data only with:

Our own employees, contractors, and case-management staff who need the data to operate the Services, subject to contractual confidentiality obligations;
The employer you identify in your submission, so that the employer can review and respond to the concern, subject to the confidentiality obligations in our Terms of Service;
Our processors (including Airtable for secure case storage and Brevo for transactional email) under written contracts that restrict their use to providing services for us;
Government authorities when required by law or valid legal process, and only to the extent required.

We do not sell consumer health data. We have not sold consumer health data in the preceding twelve months and have no plans to do so.

We do not share consumer health data with third parties for their own commercial purposes.

7. Your rights under the My Health My Data Act

If you are a Washington resident, you have the following rights under RCW 19.373.040 and RCW 19.373.050:

Right to confirm. You may confirm whether we are collecting, sharing, or selling your consumer health data and access that data.
Right to delete. You may request that we delete your consumer health data, including data stored by our processors. We will honor deletion requests within forty-five (45) days of receipt and will notify our processors.
Right to withdraw consent. You may withdraw consent to our collection and sharing of your consumer health data at any time, with effect going forward.
Right to appeal. If we decline to act on a request, you may appeal our decision within a reasonable time. If your appeal is denied, you may complain to the Washington Attorney General at atg.wa.gov/file-complaint.

To exercise any of these rights, submit a request through our privacy request form or email us at privacy@wiserworkplace.com. We will verify your identity before acting on requests for access, deletion, or correction. We will not discriminate against you for exercising any right under the My Health My Data Act.

8. Consent

When you submit consumer health data through our intake form, you are providing consent to our collection of that data for the purposes described in Section 5. This consent is separate from your agreement to our general Privacy Policy and Terms of Service.

We do not share consumer health data except with the processors and recipients identified in Section 6, which fall within the service-delivery exceptions of the Act. If we ever propose to share consumer health data outside these categories, we will obtain your separate, affirmative, opt-in "valid authorization" that meets the specific requirements of RCW 19.373.020(4) before doing so.

We do not sell consumer health data and accordingly do not request "valid authorization" for sale under RCW 19.373.030. If that ever changes, we will obtain separate valid authorization meeting the statutory requirements before any sale occurs.

9. Security

We maintain administrative, technical, and physical safeguards designed to protect consumer health data against unauthorized access, disclosure, alteration, or destruction, consistent with the duty of care in RCW 19.373.060 and applicable breach-notification requirements in RCW 19.255.010. Employees and contractors with access to consumer health data are bound by confidentiality obligations, and access is limited to those who need the data to deliver the services.

10. Retention

We retain consumer health data only for as long as necessary to provide the services you requested, or as required by law. Specific retention periods are set out in Section 4 of our Privacy Policy. When a retention period ends, we delete or de-identify the data.

11. Children

Our services are intended for adults (eighteen or older). We do not knowingly collect consumer health data from individuals under thirteen without verifiable parental consent as required by COPPA, and we do not knowingly collect consumer health data from individuals under sixteen without their affirmative consent as required by RCW 19.373.020(2).

12. How to contact us about this policy

Consumer Health Data Privacy Contact:
Wiser Workplace LLC
Attn: Privacy Contact
1801 Century Park East, Suite 2400
Los Angeles, CA 90067
privacy@wiserworkplace.com

To file a complaint with the Washington Attorney General, visit atg.wa.gov/file-complaint.

13. Changes to this policy

We will post any material changes to this policy on this page and update the Effective Date at the top. We will archive prior versions with a content hash for audit.