This Consumer Health Data Privacy Policy is published by Trust Life Solutions (a d/b/a of Ihler Ventures LLC) pursuant to the Washington My Health My Data Act, RCW 19.373 ("MHMDA"). It is posted as a separate and distinct link on the homepage of our website to comply with RCW 19.373.030(1)(b).
In plain English: Most of the health-related information we collect from you — for example, information you share on a life insurance quote or application — is handled under the federal Gramm-Leach-Bliley Act (GLBA) and Washington's insurance privacy rules. Washington's My Health My Data Act specifically exempts that information. For any other "consumer health data" we may process outside of insurance activities, this policy describes how we handle it.
1. What Is "Consumer Health Data"?
Under RCW 19.373.010, "consumer health data" means personal information linked or reasonably linkable to a consumer that identifies the consumer's past, present, or future physical or mental health status, including information such as diagnoses, treatments, medications, measurements, biometric data, gender-affirming or reproductive information, precise location information that could reasonably indicate an attempt to receive health services, and similar data.
2. MHMDA Exemptions That Apply to Us
The MHMDA expressly exempts certain categories of information from its scope, including:
- GLBA-governed information: Information subject to the federal Gramm-Leach-Bliley Act (RCW 19.373.020(2)(g))
- Washington insurance rules: Information collected, used, or disclosed in accordance with the privacy rules adopted by the Washington Office of the Insurance Commissioner under chapter 48.02 or 48.43 RCW
- HIPAA-governed information (which is not typically applicable to us since we are not a HIPAA-covered entity, but cited here for completeness)
- Fair Credit Reporting Act (FCRA) information where applicable
As a licensed insurance producer, the vast majority of health-related information we collect from you — for example, tobacco use, height, weight, medical history, prescription medications, and medical conditions you share as part of a life-insurance quote, underwriting, or application — falls within these exemptions. This information is handled under our Privacy Policy and our GLBA Notice of Privacy Practices (contained therein).
3. Scope of This Policy
This Consumer Health Data Privacy Policy governs any consumer health data we may process that does not fall within the GLBA or Washington insurance-rule exemptions. Examples could include:
- Health-related information submitted outside the context of an insurance quote or application (e.g., general wellness-related inquiries)
- Any future product or feature we may offer that involves health data not governed by GLBA or state insurance rules
If you are unsure whether a particular communication or submission is covered by this policy or our general Privacy Policy, contact us and we will clarify.
4. Categories of Consumer Health Data We May Collect
Outside of the exempt insurance context above, we do not actively solicit consumer health data. If we do collect any, it is limited to information you voluntarily provide through inquiries or correspondence and may include:
- General health or lifestyle information you volunteer in email or chat
- Health-related context you share to explain why you are seeking coverage
We do not use tracking technologies, adtech, or geofencing to collect or infer consumer health data.
5. Sources
We only receive consumer health data covered by this policy directly from you. We do not obtain it from third parties, data brokers, affiliates, or inference from non-health data.
6. Purposes of Collection and Use
Any consumer health data covered by this policy is used only to:
- Respond to your specific inquiry or request
- Comply with applicable law
- Detect or prevent fraud or security incidents
We do not use consumer health data for advertising, profiling, automated decisioning, or to train machine-learning models.
7. How We Share Consumer Health Data
Affiliates
Trust Life Solutions is a d/b/a of Ihler Ventures LLC. We do not share consumer health data with affiliates for marketing purposes. The specific affiliates that could have access to consumer health data are limited to: Ihler Ventures LLC (our parent legal entity).
Categories of third parties
We may share consumer health data only with the following categories of third parties:
- Service providers (processors) that operate secure email, CRM, and hosting infrastructure under written contracts limiting their use to providing services to us
- Legal, regulatory, or law-enforcement authorities as required or permitted by law
What we do not do
- We do not sell consumer health data.
- We do not share consumer health data with third parties for their own marketing or advertising.
- We do not engage in geofencing around any in-person health care facility.
8. Consent
We do not collect consumer health data outside of what is strictly necessary to respond to an inquiry or service you have specifically requested. If in the future we need to collect or share consumer health data for any secondary purpose, we will obtain your separate, opt-in, informed consent before doing so, consistent with RCW 19.373.030.
9. Sale of Consumer Health Data
We do not sell consumer health data and have no current or planned sale of consumer health data. If we were ever to consider such a sale, we would first obtain a valid, signed written authorization from you that complies with the strict requirements of RCW 19.373.110.
10. Your Rights
As a Washington consumer, you have the following rights regarding any consumer health data we hold about you:
- Right to confirm & access: Confirm whether we are collecting, sharing, or selling your consumer health data, and access that data.
- Right to a list of third parties: Receive a list of all third parties and affiliates with whom we have shared or sold your consumer health data, along with a contact method for each.
- Right to withdraw consent: Withdraw consent for continued collection or sharing of your consumer health data.
- Right to delete: Have your consumer health data deleted from our systems, including archives and backups, and from any affiliates or processors to whom we have disclosed it.
- Right to appeal: Appeal a denial of any request, with a written response.
- Right to non-discrimination: We will not discriminate against you for exercising any right under this policy or MHMDA.
We will respond to your verified request within 45 days of receipt. We may extend this period by an additional 45 days when reasonably necessary, with notice to you. Requests are free up to twice per 12-month period.
11. How to Exercise Your Rights
To exercise any right, contact us using any of the following methods:
- Email: privacy@trustlifesolutions.com
- Phone: (425) 567-9668
- Mail: Trust Life Solutions, Attn: Privacy Officer, 310 W 3rd St, Moscow, ID 83843-2205
We may ask you to verify your identity before processing your request. We will not require you to create an account to exercise any right.
12. Appeals
If we deny a request, you may appeal by replying to our written response or by contacting privacy@trustlifesolutions.com with "Appeal" in the subject line. We will provide a written decision on your appeal within 45 days. If your appeal is denied, you may contact the Washington Attorney General's Office at https://www.atg.wa.gov/file-complaint.
13. Data Security
We implement administrative, technical, and physical safeguards designed to protect consumer health data, including encryption in transit and at rest, role-based access controls, multi-factor authentication, and written confidentiality agreements with service providers.
14. Changes to This Policy
We may update this Consumer Health Data Privacy Policy from time to time. The "Last updated" date at the top will reflect any revisions. Material changes affecting how we handle consumer health data will trigger a new consent request or other appropriate notice.
15. Contact
Privacy Officer
Trust Life Solutions (a d/b/a of Ihler Ventures LLC)
310 W 3rd St
Moscow, ID 83843-2205
Email: privacy@trustlifesolutions.com
Phone: (425) 567-9668