Consumer Health Data Privacy Policy

Last updated: June 8, 2026

This Consumer Health Data Privacy Policy (“Policy”) supplements the Fledge Privacy Policy and applies only to individuals who are residents of U.S. states with consumer health data laws (including Washington (My Health My Data Act, RCW 19.373), Nevada (Consumer Health Data Privacy Law, SB 370), Connecticut (CTDPA, as amended in 2024 to add consumer-health-data provisions), and any other state that adopts similar laws) when those laws apply to our processing of their information (“you”).

If there is any conflict between this Policy and our main Privacy Policy regarding Consumer Health Data, this Policy controls for that subject.

Fledge is not a healthcare provider, health plan, or healthcare clearinghouse, and we are not a "covered entity" or "business associate" subject to HIPAA (45 C.F.R. Parts 160 and 164). HIPAA does not apply to the information we collect through the Services. These state laws apply to certain health-related data we collect outside of traditional medical contexts.

1. What is “Consumer Health Data”?

For purposes of this Policy, “Consumer Health Data” (CHD) means personal information that is linked or reasonably linkable to you and that identifies or is used to identify your past, present, or future physical or mental health status, as defined by applicable law in your state (for example, Washington’s My Health My Data Act and Nevada’s Consumer Health Data Privacy Law).

Depending on the law, this can include medical information and non-medical information that indicates your physical or mental health status (for example, inferences about mental state, reproductive health, or sexual health drawn from your activity).

2. Categories of Consumer Health Data We May Collect

Depending on what you choose to share on Fledge, the following may be treated as CHD:

  • Information about mental or emotional well-being (e.g., if you mention stress, anxiety, etc.).
  • Information about sexual life or sexual health (e.g., orientation, preferences, boundaries, or health-related details you decide to provide).
  • Information about physical health or disabilities you choose to share in your profile or messages.
  • Inferences drawn from this information when used to reflect aspects of your physical or mental health.

If you do not want this information processed, please do not include it in your profile, prompts or messages.

3. How We Collect Consumer Health Data

We may collect CHD from the following sources:

  • Directly from you
  • when you create or edit your profile;
  • when you send messages, participate in prompts or other interactive features;
  • when you contact us (for example, support requests mentioning health issues, trauma, or abuse).
  • usage data (for example, interactions with specific features) that may be used to infer certain health-related preferences or sensitivities if configured that way.
  • where they process your information on our behalf (for example, safety, moderation, analytics), they may generate or process inferences that qualify as CHD under applicable law.

We do not collect CHD from healthcare providers or electronic health records systems.

4. Purposes for Collecting and Using Consumer Health Data

We collect, use and disclose CHD only as necessary to provide the services you request or with your consent, as required by Washington and Nevada law.

Depending on your use of Fledge, we may use CHD for the following purposes:

  • Providing and personalizing Fledge (operating your account, showing your profile and recommended matches based on what you choose to share).
  • Safety and enforcement (detecting and responding to harassment, threats, sexual violence, self-harm indications, fraud or other violations of our Terms).
  • Communications and support (responding to questions, helping with account issues).
  • Legal compliance (responding to legal obligations or protecting rights and safety).

We do not use CHD for targeted advertising or marketing in a way that is inconsistent with the necessity and consent requirements of Washington and Nevada consumer health data laws.

5. How We Disclose Consumer Health Data

We may disclose CHD to the following categories of recipients, only for the purposes listed above and in line with this Policy and applicable law:

  • Service providers and processors
  • companies that host our services, provide security, fraud detection, moderation, analytics, customer support or development services;
  • they are contractually required to use CHD only on our instructions and not for their own purposes.
  • companies within our group that support Fledge operations (for example, infrastructure, product, legal, compliance), subject to similar privacy safeguards.
  • CHD that you intentionally include in your profile, messages or other user-visible content will be visible to other users according to your settings.
  • when we believe disclosure is required by law, regulation or legal process;
  • when we believe it is necessary to protect the rights, property or safety of you, other users, Fledge, or the public.
  • in connection with a merger, acquisition, restructuring or sale of assets, subject to continuity of protections for CHD as required by law.

We do not disclose CHD to data brokers.

6. Sale of Consumer Health Data

Fledge does not sell your Consumer Health Data.

If we ever wished to “sell” CHD in the sense defined by these state laws, we would first obtain your separate, written, signed authorization, specifying the categories of CHD being sold, the purpose and the third-party recipients, as required by Washington and Nevada law.

7. Consent, Withdrawal of Consent and Limiting Use

Where the collection or use of CHD is not strictly necessary to provide a product or service you requested, we will obtain your affirmative consent before collecting or using such CHD, or we will not collect it.

You may:

  • Withdraw your consent to our collection or use of specific CHD at any time, subject to legal requirements;
  • Limit our use and disclosure of CHD to the purposes allowed by law (for example, to provide requested services, maintain security, prevent fraud and comply with legal obligations).

To do this, you can:

  • adjust relevant settings in the Fledge app (where available); and/or
  • contact us using the methods described in Section 10 (“How to Exercise Your Rights”).

If you withdraw consent or limit use, some features that depend on that CHD (for example, specific matching preferences or safety features) may become limited or unavailable.

8. Your Rights Regarding Consumer Health Data

Subject to certain exceptions and verification requirements, residents of Washington, Nevada and other states with similar laws may have the following rights in relation to CHD:

  • Right to confirm and access
  • to confirm whether we are collecting or sharing your CHD;
  • to access the CHD, we hold about you;
  • to receive a list of third parties and affiliates with whom we have shared your CHD.
  • to request deletion of CHD we have collected about you, subject to legal exceptions (for example, to complete transactions you requested, maintain security, prevent fraud or comply with law).
  • to withdraw consent or limit our collection, use or disclosure of CHD to certain permitted purposes.
  • to receive a copy of certain CHD in a portable, readily usable format, where technically feasible.
  • if we decline to act on your request (in whole or in part), you can submit an appeal;
  • we will explain our decision and how you can contact the relevant state authority if you are not satisfied with our response.

We will not discriminate against you for exercising any of these rights, though certain features may not function without some data.

9. Security and Retention of Consumer Health Data

We implement reasonable administrative, technical and physical safeguards designed to protect CHD from unauthorized access, use or disclosure, as required by applicable law.

We keep CHD only for as long as reasonably necessary to:

  • provide the services you request;
  • support legitimate business needs (for example, security, fraud prevention, recordkeeping);
  • comply with legal, regulatory or contractual obligations;
  • resolve disputes and enforce our agreements.

Retention periods may vary depending on the type of CHD, the context in which it was collected, and our legal obligations. When CHD is no longer needed, we will delete it or de-identify it in accordance with applicable law and our internal policies.

10. How to Exercise Your Consumer Health Data Rights

If you live in Washington, Nevada or another state with consumer health data laws, you can exercise your CHD rights by:

  • In the app
  • Use the Help / Support or Privacy section and select a privacy or consumer health data request (where available).
  • Contact us at: support@fledge.love
  • Please indicate that your request relates to Consumer Health Data and your state of residence.

We may need to verify your identity before processing your request, which may involve requesting certain information from you. You may also authorize an agent to act on your behalf, subject to verification procedures required by law.

If we deny your request in whole or in part, we will provide an explanation and information on how to appeal our decision. If you remain unsatisfied, you may have the right to contact your state attorney general or other regulator.

11. Changes to This Policy

We may update this Consumer Health Data Privacy Policy from time to time, for example when:

  • laws or regulatory guidance change;
  • we introduce new features or data uses that affect CHD;
  • we make changes to our privacy program.

When we make material changes, we will update the Effective Date at the top of this Policy and may provide additional notice as required by law.

If you have questions about this Policy or our handling of Consumer Health Data, you can contact us at support@fledge.love or via the Help / Support section in the app.