Consumer Health Data Privacy Policy
DUSQ is a product of Ezymind Nexus, Inc. (operating as DUSQ), a Delaware corporation, registered address 131 Continental Dr, Suite 305, Newark, DE 19713, a wholly-owned subsidiary of Ezymind Healthcare Private Limited (India).
This Consumer Health Data Privacy Policy describes how DUSQ collects, uses, shares, and lets you control your consumer health data, as required by the Washington My Health My Data Act. In this policy, “DUSQ,” “we,” and “us” means Ezymind Nexus, Inc. For the purposes of this policy, “consumer health data” means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status.
1. Categories of consumer health data we collect, and the sources
We collect the following categories of consumer health data, from the sources shown:
| Category of consumer health data | Sources |
|---|---|
| Sleep and physiological measures from your DUSQ device, such as sleep and readiness measures, autonomic signals, and heart-rate-derived measures | From you, through your use of the DUSQ device and app |
| Device usage, adherence, and environment measures related to your sleep | From your DUSQ device and app |
| Information you provide about your sleep, habits, goals, and wellbeing, including in sleep coaching and intake | Directly from you |
| Information that identifies you as having sought or received the sleep coaching or other health-related features of the service | From your use of the service |
| Any health-related inferences we draw from the above to provide the service | Derived by us from the data above |
2. Purpose for collecting and using consumer health data
We collect and use consumer health data for these purposes:
(a) to provide the DUSQ device features and app, including sleep and wellness insights you have enabled;
(b) to provide the sleep coaching feature, where you have requested it, including letting your coach and coaching team see your data to help you;
(c) to operate, secure, maintain, and improve the service;
(d) to communicate with you about the service and respond to your requests;
(e) to comply with law and to protect the rights, safety, and property of you, DUSQ, and others.
We collect and use consumer health data only with your consent, or as necessary to provide a product or service you have requested from us. We do not use it for any purpose not described in this policy without your consent.
3. Categories of consumer health data we share
We share the following categories of consumer health data only as needed to provide the service and as described in this policy: sleep and physiological measures, device usage and environment measures, information you provide in coaching and intake, and health-related inferences used to provide the service. Disclosing consumer health data to a service provider or to our affiliate to provide a product or service you have requested, consistent with the purpose for which it was collected, is not a “sale” and is not a “share” requiring separate consent under the Act.
We do not sell your consumer health data. We do not sell consumer health data and will not do so without first obtaining the valid authorization the Act requires.
4. Categories of third parties and specific affiliates we share with
Categories of third parties:
(a) service providers that process consumer health data on our behalf and on our instructions, in the categories of cloud hosting and infrastructure, security, and communications tooling;
(b) government authorities or others where necessary to comply with law or protect rights or safety;
(c) a successor entity in connection with a merger, acquisition, financing, or sale of assets.
Specific affiliate: Ezymind Healthcare Private Limited (India), which operates DUSQ sleep coaching and processes consumer health data on behalf of Ezymind Nexus, Inc. solely to provide the service.
5. How to exercise your rights
If you are a Washington consumer, you have the right to:
(a) confirm whether we are collecting, sharing, or selling your consumer health data, and access that data;
(b) withdraw your consent to our collection and sharing of your consumer health data;
(c) have your consumer health data deleted;
(d) appeal a refusal to act on your request.
5.1 To exercise any of these rights, contact us at [consumer health data request email] or [in-app request path]. You may use an authorized agent where the law allows. We will verify and respond to your request within 45 days. We may extend this once when reasonably necessary, and we will tell you if we do. We will not discriminate against you for exercising your rights.
5.2 If we deny your request, you may appeal by contacting [appeal email]. If your appeal is denied, you may contact the Washington State Attorney General.
