CompassCare Global LLC

Effective Date: June 9, 2026   |   Last Updated: June 9, 2026

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This Consumer Health Data Privacy Policy (“CHD Policy”) explains how CompassCare Global LLC (“CCG,” “we,” “us,” or “our”) collects, uses, shares, and protects “consumer health data” as defined under the Washington My Health My Data Act, RCW 19.373 (“MHMDA”). It supplements our general Privacy Policy. To the extent this CHD Policy and our general Privacy Policy differ with respect to consumer health data, this CHD Policy controls.

 

CCG is an international healthcare coordination and concierge travel facilitation company. CCG is a coordination and facilitation service only — not a healthcare provider — and is not a HIPAA covered entity. However, certain information we collect, such as the procedure or treatment you express interest in and the fact that you are seeking international healthcare coordination, may qualify as consumer health data under MHMDA. This policy describes our practices for that information.

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1. What Consumer Health Data Is

Under MHMDA, “consumer health data” is personal information linked or reasonably linkable to a consumer that identifies the consumer’s past, present, or future physical or mental health status. This can include information about a health condition or treatment, and information that identifies a consumer seeking to acquire or receive health services or supplies.

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2. Categories of Consumer Health Data We Collect

In connection with a health-related inquiry, we may collect:

• The procedure, treatment, or health service you express interest in

• The fact that you are seeking, or have sought, international healthcare coordination services

• Your desired treatment or travel timeline

• Your name, email, and phone number, to the extent linked to the health-related information above

• General geographic location, if you voluntarily provide it

• Inferences we draw from the above solely to assess whether our coordination services fit your needs

We do not collect, store, or process: formal medical records, clinical diagnoses, laboratory or test results, Protected Health Information as managed by your providers, insurance or billing information, or Social Security or government-issued identification numbers. All clinical records and health information remain exclusively with the licensed providers and internationally accredited or quality-vetted hospitals with whom you choose to engage.

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3. Categories of Sources

We collect consumer health data from the following sources:

• Directly from you — through website inquiry and contact forms (hosted on Wix), Google Ads lead forms, chatbot interactions, and email or phone inquiries you initiate

• Automatically from your device — limited technical and analytics information, which we treat as consumer health data only where it reasonably indicates that you are seeking health services

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4. How and Why We Use Consumer Health Data

We use consumer health data only for the following purposes:

• To respond to your inquiry about international healthcare coordination

• To assess whether CCG’s coordination services fit your needs

• With your separate consent, to coordinate with an internationally accredited or quality-vetted partner hospital to schedule a consultation

• To communicate with you about your inquiry and any coordination you request

• To maintain business records, comply with legal obligations, and protect the rights and safety of you, CCG, and others

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5. Consent — Collection and Sharing

Collection. We collect your consumer health data either (a) with your consent, or (b) as necessary to provide a product or service you have requested.

Sharing. We obtain your separate and distinct consent before sharing your consumer health data, unless the sharing is necessary to provide a service you have requested. For example, we will not share your information with a partner hospital until you authorize that referral.

Withdrawal. You may withdraw your consent at any time as described in Section 8. Withdrawal may limit or prevent our ability to provide coordination services.

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6. Consumer Health Data We Share, and With Whom

We share consumer health data only in these limited circumstances:

• Partner hospitals — with your explicit, separate consent, we share your name, contact information, and stated procedure of interest with the partner hospital you select, for the purpose of scheduling a consultation. We do not transmit medical records.

• Service providers / processors — we use third-party tools to operate our website and manage inquiries, in the following categories: website hosting (Wix), workflow automation (Zapier), and advertising, lead forms, and cloud productivity (Google). These providers process data on our behalf under terms that restrict use of the data to our purposes.

• Legal, compliance, and safety — when required by law or legal process, or to protect rights and safety.

Third parties and affiliates. The categories of third parties with whom we may share consumer health data are the partner hospitals you authorize and the service providers named above. CCG does not currently share consumer health data with any affiliated entity. A current list of the specific third parties and affiliates with whom we have shared your consumer health data, with an active contact for each, is available on request (see Section 8).

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7. We Do Not Sell Consumer Health Data

CCG does not sell your consumer health data and does not exchange it for valuable consideration. We will not sell your consumer health data without first obtaining your valid, separate written authorization that meets the requirements of MHMDA.

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8. Your Rights

With respect to your consumer health data, you have the right to:

• Confirm whether we are collecting, sharing, or selling your consumer health data, and access that data

• Obtain a list of all third parties and affiliates with whom we have shared or sold your consumer health data, together with an active contact for each

• Withdraw your consent to our collection and sharing of your consumer health data

• Request deletion of your consumer health data. Upon a valid request, we will delete it from our records and notify our service providers and any third parties with whom we have shared it to delete it as well

• Not be discriminated against for exercising any of these rights

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9. How to Exercise Your Rights, and Appeals

Submitting a request. Email us at info@compasscareglobal.com. We will respond within 45 days of receipt. Where reasonably necessary, we may extend this period once by an additional 15 days and will notify you of the extension. We may need to verify your identity before fulfilling a request.

Appeals. If we decline to act on your request, you may appeal by replying to our response or by emailing info@compasscareglobal.com with “Appeal” in the subject line. We will respond to your appeal within a reasonable period. If your appeal is denied, you may submit a complaint to the Washington State Attorney General at www.atg.wa.gov/file-complaint.

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10. Data Retention

We retain consumer health data only as long as reasonably necessary for the purposes described in this policy — generally up to twenty-four (24) months from your most recent inquiry or the conclusion of coordination services, unless a longer period is required by law. We will delete your consumer health data within thirty (30) days of a valid deletion request.

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11. Data Security

We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the information we maintain, and we restrict access to authorized CCG personnel.

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12. No Geofencing

CCG does not use geofencing technology to establish a virtual boundary around any in-person healthcare facility for the purpose of identifying, tracking, collecting data from, or sending notifications to consumers based on their proximity to such a facility.

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13. Children’s Privacy

Our services are intended for adults aged 18 and older. We do not knowingly collect consumer health data from anyone under the age of 18.

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14. Changes to This Policy

We may update this CHD Policy from time to time. Material changes will be reflected by the “Last Updated” date above. We will not collect or share categories of consumer health data that are not disclosed in this policy without first updating it.

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15. Contact Us

CompassCare Global LLC

Email: info@compasscareglobal.com

Website: compasscareglobal.com

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CompassCare Global LLC does not provide medical advice, practice medicine, guarantee clinical outcomes, employ physicians, or direct medical treatment. All clinical decisions remain solely with the licensed providers and accredited hospitals with whom clients choose to engage.