Opportunity Flywheel LLC
Grocket consumer health data privacy policy
This policy is published by Opportunity Flywheel LLC ("we", "us", "our") in accordance with the Washington My Health My Data Act and the Nevada consumer health data law (SB 370). It supplements the Grocket privacy policy.
The protections in sections 3 to 6 apply to every user of Grocket. The rights and procedures in section 8 are those conferred by statute on residents of Washington and Nevada.
1. Consumer health data we collect
One category: dietary preferences, restrictions, and allergies that you elect to enter, together with the number of people in your household where you provide it.
Allergies and certain dietary restrictions may indicate an underlying medical condition. We therefore treat the entire category as consumer health data rather than distinguishing between entries that do and do not disclose a condition.
2. Sources
This information is obtained solely from you, through entry into the application. We do not purchase it, obtain it from data brokers or other third parties, or derive it from any other source.
3. Purposes of collection and use
Two purposes: filtering the recipes, products, and substitutions Grocket suggests to you, and calculating quantities appropriate to your household. We do not use consumer health data for any other purpose.
4. Inferences
Grocket does not infer, derive, or record health conditions or health status from your purchases, receipts, shopping locations, or shopping patterns. We do not assign nutritional scores to baskets or label them by dietary or medical category.
Should we introduce a feature that derives health-related information, this policy will be amended before that feature is released and the feature will require your affirmative opt-in.
5. Disclosure and sale
We do not sell consumer health data, whether for monetary or other valuable consideration.
We disclose consumer health data only to our hosting and infrastructure provider, which stores it on our behalf under written terms prohibiting its use for that provider's own purposes, and where disclosure is required by law or legal process. We will not disclose it to any other third party without your separate, specific, and affirmative consent obtained for that disclosure.
Consumer health data is excluded from the shared price database described in the Grocket privacy policy, and from any aggregated or de-identified data set we produce or make available to another party.
6. Consent and withdrawal
Grocket requests your consent before collecting consumer health data. The information is optional, no feature of the application is conditioned on providing it, and consent to this policy does not constitute consent to any disclosure described in section 5.
You may withdraw consent at any time by clearing the relevant fields in the application or by contacting us. Withdrawal stops further collection and use.
7. Retention
Consumer health data is retained while your account remains open and the corresponding fields remain populated. Clearing the fields deletes it. Deleting your account deletes it within 30 days, as described in the Grocket privacy policy.
8. Your rights
Residents of Washington and Nevada have the right to:
- confirm whether we collect, share, or sell consumer health data concerning them, and access that data, including a list of the third parties with which it has been shared;
- withdraw consent to our collection and sharing of that data;
- have that data deleted, including by any third party with which we have shared it; and
- not be discriminated against for exercising any of these rights.
Requests may be submitted to privacy@opportunityflywheel.com. We will respond within 45 days of receipt, or within such further period as the applicable statute permits where we notify you of the extension. If we decline a request, you may appeal by replying to our response; we will provide a written decision on the appeal within 45 days.
Washington residents may submit a complaint to the Washington State Attorney General at atg.wa.gov/file-complaint. Nevada residents may submit a complaint to the Nevada Attorney General.
Users resident elsewhere may make the same requests, and we will honour them; the statutory response and appeal periods above are those applicable to Washington and Nevada residents.
9. Geofencing
We do not operate a geofence around any facility providing health care services, and do not use location data to identify or track any person, or to send any communication, on the basis of proximity to such a facility. Location collected by Grocket is approximate, optional, and used solely to identify grocery stores near you.
10. Changes to this policy
We may amend this policy. Amendments apply to consumer health data collected on or after the effective date stated above. Where an amendment would permit handling of consumer health data already collected in a manner not permitted by the policy in force when it was collected, we will obtain your consent before doing so.
11. Contact
Opportunity Flywheel LLC, Appleton, Wisconsin, United States
privacy@opportunityflywheel.com