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Washington Consumer Health Data Privacy Policy

Version 1.2

Effective Date: September 17, 2026

1. Introduction

Daye is a group of companies offering Daye products and services globally (“Daye”, “we” or “us”) through the Daye Health Platform (DHP). Daye is made up of different legal entities registered throughout the United Kingdom, the European Union and the United States of America. So when we mention Daye in this document, we are referring to the relevant company in the Daye Company Group which provides products and services to you and is therefore responsible for the processing of your personal information.

For residents of the United States, the service provider and regulated entity will be Anne’s Day Inc., incorporated and registered in the United States of America with registration number 32-0655300, registered at 2140 S. Dupont Highway, Camden, Delaware 19934, United States of America.

Anne’s Day Inc. is supported in its operations by affiliated companies within the Daye Company Group, including Anne’s Day Ltd (United Kingdom) and Tampon Innovations Ltd (Bulgaria), which provide hosting, technical operations, platform administration and support services on its behalf. Consumer Health Data may be stored and processed within secure United Kingdom and European Union cloud infrastructure operated on behalf of Anne’s Day Inc.

This Washington Consumer Health Data Privacy Policy (“Policy”) explains how Daye collects, uses, discloses and protects Consumer Health Data as defined under the Washington My Health My Data Act (“MHMDA”).

This Policy applies to Consumer Health Data collected from Washington consumers in connection with our products, services, websites, mobile applications and diagnostic platforms offered as part of DHP.

This Policy supplements our general DHP Privacy Notice and applies only where required by the Washington My Health My Data Act. In the event of any conflict, inconsistency, or ambiguity between the DHP Privacy Notice and this document, the terms of this document shall prevail.

2. Categories of Consumer Health Data We Collect

Depending on the services you use, we may collect the following categories of Consumer Health Data:

  • Health questionnaires and self-reported symptoms
  • Menstrual and reproductive health information
  • Sexual health information
  • Vaginal microbiome information
  • STI and HPV screening information
  • Hormonal testing information
  • Laboratory test results
  • Biological sample information
  • Healthcare provider or telemedicine interactions
  • Prescription-related information where applicable
  • Diagnostic recommendations
  • Identity verification information collected when you register for our diagnostic platform, including a selfie photograph and a copy of your identity document, which may constitute biometric data under applicable law
  • Purchases of health-related products (such as period care or vaginal health products) that could reasonably indicate your health status
  • Information reasonably capable of identifying your past, present, or future physical or mental health status

We may also collect identifiers and account information that are linked to Consumer Health Data, including:

  • Name
  • Email address
  • Date of birth
  • Shipping address
  • Customer account information
  • Device and usage information where associated with Consumer Health Data

We do not collect precise geolocation information that could indicate a consumer’s attempt to acquire or receive health services or supplies, and we do not use geofencing around any facility that provides in-person health care services.

3. Sources of Consumer Health Data

We collect Consumer Health Data directly from you and from authorized third parties involved in providing our services.

Sources include:

  • Information you provide during account registration.
  • Information submitted when activating a diagnostic test.
  • Questionnaires completed before, during or after testing.
  • Information generated through use of our services.
  • Diagnostic results generated by partner laboratories, including Avrok Bio and IHD Laboratory.
  • Information received from telemedicine providers, including MDI (Medical Diagnostic Integrations), where applicable.
  • Information received from partner pharmacies supporting treatment fulfilment, where applicable.
  • Information received from healthcare professionals involved in your care.
  • Information generated through customer support interactions.
  • Information collected automatically through our website and applications where permitted by law.

4. Why We Collect Consumer Health Data

We collect Consumer Health Data for the following purposes:

  • Providing diagnostic testing services.
  • Registering and activating diagnostic kits.
  • Processing biological samples.
  • Generating laboratory reports.
  • Displaying diagnostic results through your secure account.
  • Providing customer support.
  • Managing your account.
  • Providing treatment pathways where applicable.
  • Improving our products and services.
  • Performing quality assurance.
  • Meeting legal and regulatory obligations.
  • Protecting our systems against fraud, abuse and security threats.
  • Conducting scientific, statistical and product research where permitted by law and subject to appropriate safeguards.

Where required by applicable law, we obtain your consent before collecting or processing Consumer Health Data. In particular, we collect and use Consumer Health Data with your consent, or only to the extent necessary to provide a product or service that you have requested from us. Where we wish to collect or use Consumer Health Data for a purpose that is not necessary to provide a product or service you have requested (such as research or service improvement using identifiable data), we will ask for your prior consent, and you may decline or later withdraw it without losing access to the products and services you have purchased.

5. Categories of Third Parties With Whom We Share Consumer Health Data

We may disclose Consumer Health Data only as necessary to provide our services, comply with legal obligations, or where otherwise permitted by law.

A. Daye Company Group Affiliates

Our affiliates Anne’s Day Ltd (United Kingdom) and Tampon Innovations Ltd (Bulgaria) support the operation of the Daye platform, customer support, business administration, information security, analytics, hosting and other internal business operations on behalf of Anne’s Day Inc. These affiliates may collect or receive Consumer Health Data in the course of providing that support.

B. Laboratory Partners

We may share information with our laboratory partners, including Avrok Bio and IHD Laboratory, for:

  • Receiving biological samples
  • Processing samples
  • Performing laboratory testing
  • Quality assurance
  • Generating laboratory reports
  • Returning diagnostic results
  • Supporting laboratory operations necessary to provide our diagnostic services

C. Healthcare and Telemedicine Providers

Where applicable, we may share information with healthcare providers, telemedicine providers, clinicians or clinical partners, including MDI (Medical Diagnostic Integrations), for:

  • Laboratory order authorisation
  • Clinical review
  • Consultation
  • Treatment pathways
  • Healthcare services associated with your diagnostic testing

D. Pharmacies and Treatment Partners

Where applicable, we may share information with partner pharmacies and treatment providers to support:

  • Prescription fulfilment
  • Medication dispensing
  • Treatment delivery
  • Related healthcare services

E. Service Providers

We may share Consumer Health Data with trusted service providers that assist us with:

  • Cloud hosting
  • Platform operations
  • Information security
  • Customer support
  • Identity verification
  • Communications
  • Payment processing
  • Data storage
  • Analytics
  • Fraud prevention
  • Regulatory compliance

These providers are contractually required to protect Consumer Health Data and may only process it on our behalf for authorized purposes.

Upon request (see “Right to Access” below), we will provide you with a list of all third parties and affiliates with whom we have shared your Consumer Health Data, together with contact information for those third parties.

6. Consumer Health Data We Sell or Share

We do not sell Consumer Health Data for monetary consideration.

Where required by applicable law, we will obtain your separate, affirmative authorization before selling Consumer Health Data. Any such authorization would meet the requirements of the MHMDA, including being signed by you, specific to the data and purchaser concerned, and valid for no more than one year.

We may share Consumer Health Data with third parties only where necessary to:

  • Provide our diagnostic products and services.
  • Process laboratory samples.
  • Deliver diagnostic results.
  • Support treatment pathways.
  • Comply with legal obligations.
  • Protect our rights, users, or the security of our services.

Where sharing constitutes a “sale” under applicable law, we will obtain any consent or authorization required by the Washington My Health My Data Act before such sharing occurs.

We do not share Consumer Health Data with third-party advertising platforms, and we do not use Consumer Health Data for targeted advertising.

7. Consumer Health Data Rights

Subject to applicable law, Washington consumers have the following rights regarding their Consumer Health Data.

Right to Confirm

You may request confirmation of whether we collect, share, or sell your Consumer Health Data.

Right to Access

You may request access to the Consumer Health Data we maintain about you.

Where applicable, we will also provide:

  • The categories of Consumer Health Data collected.
  • The categories of sources from which the data was collected.
  • The purposes for which the data is used.
  • A list of all third parties and affiliates with whom we have shared or sold your Consumer Health Data, together with an active email address or other online mechanism you can use to contact those third parties.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time.

Withdrawal of consent does not affect processing that occurred before withdrawal and may affect our ability to continue providing certain diagnostic services.

Right to Delete

You may request deletion of your Consumer Health Data, subject to applicable legal, regulatory, contractual, medical, laboratory, and record-retention obligations.

Where deletion is required by law, we will also instruct processors, contractors, and service providers acting on our behalf to delete applicable Consumer Health Data where required.

Right to Appeal

If we decline your request, you may appeal our decision by contacting us using the details provided in this Policy.

If your appeal is unsuccessful, you may submit a complaint to the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Non-Discrimination

We will not unlawfully discriminate against you for exercising any of your rights under the MHMDA or this Policy.

8. Security of Consumer Health Data

We implement administrative, technical, and organizational safeguards designed to protect Consumer Health Data against unauthorized access, disclosure, alteration, or destruction.

These safeguards include, where appropriate:

  • Encryption of data in transit.
  • Encryption of data at rest.
  • Secure authentication controls.
  • Access controls based on business need.
  • Multi-factor authentication for administrative access.
  • Security monitoring and logging.
  • Vulnerability management.
  • Secure software development practices.
  • Employee confidentiality obligations.
  • Vendor security assessments.

We restrict access to Consumer Health Data to those employees, processors and contractors for whom access is necessary to further the purposes for which you provided consent or for which the data is necessary to provide a product or service you have requested.

Although we use reasonable safeguards, no method of electronic transmission or storage is completely secure.

9. Retention of Consumer Health Data

We retain Consumer Health Data only for as long as necessary to:

  • Provide our products and services.
  • Comply with applicable legal and regulatory obligations.
  • Resolve disputes.
  • Enforce our agreements.
  • Protect our legal rights.
  • Conduct legitimate business operations.

Retention periods may vary depending on the type of Consumer Health Data, laboratory requirements, legal obligations, and applicable regulatory requirements.

Where Consumer Health Data is no longer required, it will be securely deleted, anonymized, or otherwise disposed of in accordance with our retention policies and applicable law.

10. How to Exercise Your Rights

You may exercise your rights under this Policy by contacting us using the details below.

Email: privacy@yourdaye.com

You may also contact our Data Protection Officer at privacy@yourdaye.com.

To help protect your privacy, we may request additional information necessary to verify your identity before processing your request.

We will respond to requests within the timeframes required by applicable law – generally within 45 days of receipt, extendable once by a further 45 days where reasonably necessary, in which case we will inform you of the extension and the reasons for it within the initial 45-day period. We will respond to an appeal within 45 days of receiving it, informing you in writing of any action taken or not taken and the reasons for our decision.

11. Changes to this Policy

We may update this Policy from time to time. Any changes will be posted on this page with an updated version number and effective date. Where changes are material, we will take additional steps to notify you as required by applicable law. This Policy is linked from the homepage of our website as required by the MHMDA.

12. Children

Our products and services are intended for individuals who are legally permitted to purchase and use our products under applicable law.

We do not knowingly collect Consumer Health Data from children where prohibited by applicable law.

If you believe that a child has provided us with Consumer Health Data in violation of applicable law, please contact us at privacy@yourdaye.com so that we can investigate and, where appropriate, delete the information.

13. International Processing

Consumer Health Data may be stored or processed outside Washington and outside the United States by the affiliates and third parties described in Section 5 of this Policy that support the Daye Health Platform, including within the United Kingdom and the European Union.

Where this occurs, we implement appropriate contractual, technical and organisational safeguards designed to protect Consumer Health Data in accordance with applicable law.