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Consumer Health Data Privacy Policy

Effective date: August 22, 2026

This policy covers consumer health data only. It exists because Washington’s My Health My Data Act and Nevada’s SB 370 require a separate document for this one category of information, written plainly and kept apart from our general Privacy Policy.

Planning for the end of life means answering questions about health — yours or someone else’s. We ask as few of them as we can, we ask them for one reason at a time, and we tell you here exactly what each answer does.

Passings is not a healthcare provider. Nothing here is a medical record, and nothing you enter is reviewed by a clinician.

1. What we collect, and why

We collect health data only when you type it in. Each category below is tied to the one job it does.

To decide which planning tasks apply to you — whether the person being planned for is receiving hospice or home care; whether they live in a care facility; whether they live with a disability; whether they have stored reproductive material such as embryos, eggs, sperm, or banked tissue; whether they are a registered organ donor; whether an advance directive exists; and whether they receive government assistance such as Medicaid, SSI, or SNAP. These answers add, remove, and reorder items on your checklist. Nothing else reads them.

To route you to the right kind of help — the situation you select when you start a plan: that you are planning ahead, that a serious illness or health situation may be leading to a loss, or that a loss has already occurred. This selects which version of the product you see. It also has one further effect, described in section 4.

To print an emergency card, if you make one — allergies, medications, medical conditions, implanted devices, whether a POLST or DNR exists and where it is kept, and any short note you add. This is optional, off until you turn it on, and deleted entirely when you withdraw consent. It is encrypted before it is stored, so it is not readable in our database, and our support staff cannot read it.

To respond safely if you write to our assistant about self-harm — messages you send to Pax, our in-app assistant, are screened before they reach the model, and a message identified as describing a crisis is flagged so the assistant responds with crisis resources instead of ordinary planning help. That flag is stored with the conversation. We are telling you this because an automated inference about your mental health is health data even though you never filled in a form.

2. Where it comes from

Directly from you, and only from you. We do not sync with health apps, wearables, patient portals, pharmacies, or insurers. We do not import records. We do not read the contents of documents you upload to your vault. We do not buy health data, and we do not infer health status from your browsing or your purchases.

Where a plan is for someone else, the answers are the ones you provide about that person.

3. How we process it

Health data is stored in our database in the United States and processed by our hosting and database provider on our behalf. Emergency card entries are additionally encrypted with per-entry keys before storage.

We do not use health data to train artificial intelligence models, to build advertising profiles, to set prices, or to rank or order the Providers you see. We do not make automated decisions about you that produce legal or similarly significant effects.

Access inside Passings is limited by the same permissions that protect the rest of your plan, with one addition: emergency card medical entries are hidden from everyone on your plan except you, until you turn on access for a specific person who is involved in that person’s care.

4. What we share, and with whom

We do not publish your health data, and we do not disclose it to Providers as part of your plan. Two disclosures are worth stating plainly rather than leaving you to discover them.

Quote requests carry an urgency signal. If you ask us to send a quote request to Providers, that request includes an urgency indicator — planning ahead, a loss may be coming, or a loss has occurred — which is derived from the situation you selected. Providers pay Passings a fee to receive quote requests. The underlying checklist health answers in section 1 are not included, but the urgency indicator does reflect that you told us a serious illness or a death is involved. You choose whether to send a quote request; nothing is sent unless you do.

Emergency card details go where you send them. The card is generated for you to print and carry. If you turn on access for a collaborator involved in the person’s care, that person can see those details in the app. Nobody else can.

Our service providers process health data only on our instructions and only to run the Service: our database, authentication, and file-storage provider; our web hosting and content-delivery provider; and our error-monitoring provider, which is configured to exclude request contents, form input, and user identity. The current list, with each company’s own privacy policy, is in our Privacy Policy and Subprocessor List.

We may disclose health data if we are legally compelled to, or to protect someone from imminent harm. Where we may lawfully tell you first, we will.

5. Advertising and cross-site tracking

Passings shows advertising on some pages of the free experience. No advertising runs on the page where you enter health information about the person you are planning for, on the emergency card, or on the pages that carry your plan’s most sensitive content.

No third party collects health data through our Service, and no third party is permitted to collect consumer health data over time and across different websites or applications through Passings. Our product-analytics tool does not record your screen, does not capture page text or form contents, is off until you consent, and honors Global Privacy Control. You can change these choices at any time on our Your Privacy Choices page.

6. Your rights

You have the right to:

  • Confirm and access the health data we hold about you, including a list of every third party and affiliate with whom we have shared or sold it, together with a way to contact each one.
  • Review and correct it. Most of it you can change yourself, at any time, on the plan it belongs to.
  • Withdraw consent to our collection and sharing of it. Withdrawing consent for the emergency card deletes those entries.
  • Delete it, including from archives and backups. Backup copies are removed on our regular backup cycle, which does not exceed six months. We notify every service provider and third party that received it, and they are required to honor the deletion.
  • Appeal if we deny a request. If we deny your appeal, we will give you a way to complain to your state Attorney General. Washington residents may contact the Washington State Attorney General at www.atg.wa.gov/file-complaint.

7. How to make a request

Email [email protected] with the word “health data” in the subject line, or use our Your Privacy Choices page. We will ask you to verify that you control the account, and we may ask for more detail if a request is unclear.

We respond within 30 days for Nevada residents and within 45 days for Washington residents. A Washington response may be extended once by a further 45 days where a request is complex; we will tell you within the first 45 days if that happens. Requests are free up to twice a year.

An authorized agent may act for you if you give them written permission and we can verify it.

8. Changes to this policy

If we change the categories of health data we collect, or the purposes we collect them for, we will update this policy and obtain your consent before the new collection or use begins. For other material changes we will notify you by email or in the product before they take effect, and the effective date at the top of this page will change.

9. Contact

Passings LLC, 2501 Chatham Rd, Suite R, Springfield, IL 62704, USA.
Privacy inquiries: [email protected]

Effective date: August 22, 2026.