Consumer Health Data Privacy Notice
Last Updated: 4 March 2026
The Sword Consumer Health Privacy Notice supplements Sword’s Privacy Statement and applies only to our users in Washington (under Washington’s My Health, My Data Act), Nevada (under Nevada Consumer Health Data Privacy Act) and Connecticut (under Connecticut Data Privacy Act).
What does the Sword Consumer Health Data Privacy Notice cover
This Notice applies only to “consumer health data,” meaning personal information that identifies your past, present or future physical or mental health status, as defined by applicable law.
Consumer health data does not include protected health information subject to HIPAA, publicly available information or deidentified information.
Categories of Consumer Health Data We May Collect:
- Information or data regarding
- Individual health conditions, treatment, status, disease or diagnosis;
- Information identifying a health-related surgery or procedure.
- Social, physiological, behavioral and medical interventions;
- Bodily functions, vital signs, symptoms or measurements;
- Diagnosis or diagnostic testing
- Wearable sensor data and biometric data (including health-related measurements)
- Information that identifies an individual’s intention to seek health care services.
- Information inferred from data that is not consumer health data but is used to associate an individual to the information listed above.
What is the Purpose for Collecting Consumer Health Data
- To provide and deliver our services through the Dawn App, including improving and personalizing the services you receive.
- To provide customer service and respond to your requests and inquiries.
- To operate our business, including billing, accounting, improving our internal operations.
- To make our systems secure, detecting illegal, fraudulent and suspicious activity, including technical notices, updates, security updates.
- To provide you information, such as confirmations, reminders, support, and general administrative information.
- To meet our legal obligations.
- For other purposes with your consent.
What are the Categories of Sources From Which We Collect Your Consumer Health Data:
- Provided directly by you when you sign up for the Dawn App
- Collected from your devices and connected wearables that you choose to use with the Dawn App
- Collected from our affiliates where you use other services we provide (as applicable)
How we share Consumer Health Data:
- We may share consumer health data with our service providers and affiliates only as necessary to provide the Services, maintain security, prevent fraud, and comply with law.
- Where required by applicable law, we will obtain your consent before we share your consumer health data with third parties for purposes other than providing the Services you request.
Categories of Third Parties and Affiliates with whom We May Share Consumer Health Data:
- Our service providers acting as processors on our behalf to provide the Services you request
- Corporate transactions such as a merger, financing, acquisition, bankruptcy, dissolution or sale or transfer of all or a portion of our business or assets.
- Governmental agencies
- Affiliates of Sword: Sword Health SA
Your Rights:
- Right to Know
- Right to Request Correction or Deletion
- Right to Withdraw Consent (where we process consumer health data based on your consent)
How to Exercise Your Rights
You may exercise the rights described above by using the information in the Contact Us section at the bottom of the main Privacy Notice. We will respond within the timeframe required by applicable law.
You may also withdraw consent (where we rely on consent) by contacting us in the Contact Us section at the bottom of the main Privacy Notice.
Appeals
If we deny your request, you may appeal by contacting us using the information in the Contact Us section at the bottom of the main Privacy Notice with the subject line “Privacy Appeal.” Please include your name, the state where you reside, and the request you are appealing. We will respond to your appeal within the timeframe required by applicable law. We will respond to your appeal within the timeframe required by applicable law.
For Connecticut residents, this Notice addresses consumer health data only; other Connecticut privacy rights are described in our Privacy Notice.
Note: If you have a Sword Account you can access your account information anytime and edit, or close and Sword will deactivate your account, and delete data.
Contact Us
If you have any questions or comments regarding this Privacy Notice, please contact us at:
Sword Health, Inc.
ATTN: Privacy Office
169 Madison Ave
Suite 15501
New York, New York 10016
Or
Last Updated and Effective Date: March 4, 2026
Copyright © 2026 Sword Health Technologies, Inc. All rights reserved.