Consumer Health Data Privacy Policy

Effective date: May 14, 2026

This Consumer Health Data Privacy Policy describes how Able Years LLC (“Able Years,” “we,” “our,” or “us”) collects, uses, and shares consumer health data in accordance with the Washington My Health My Data Act (RCW 19.373, “MHMDA”). This policy is a standalone document and applies only to consumer health data as defined by Washington state law.

This policy applies to:

• Washington state residents
• Any individual whose consumer health data is collected by us in Washington state

For information about how we handle other personal information that is not consumer health data, please contact us at privacy@ableyears.com.

What is consumer health data?

Under MHMDA, “consumer health data” means personal information that is linked to a specific individual and that identifies that person’s past, present, or future physical or mental health status. This is a broad legal definition. For Able Years, it includes the information you provide when you complete our Independence Assessment.

Categories of consumer health data we collect

We collect the following categories of consumer health data:

• Functional and physical capacity information — including your self-reported ability to climb stairs, get up from a chair, reach overhead, carry groceries, and similar daily activities
• Pain and injury information — including locations of ongoing pain or limitations (knees, hips, lower back, shoulders, neck), recent surgeries, and recovery status
• Falls and balance information — including history of falls or near-falls in the past 12 months
• Confidence and self-perception information — including your confidence in your ability to perform physical activities
• Demographic information that may be linked to your health profile — including age range and gender identity
• Motivations and goals— including the reasons you are interested in our program (such as a recent fall, a doctor’s recommendation, or a desire to stay independent)
• Computed assessments — including the Independence Score generated from your responses

We collect these categories through the Independence Assessment available at ableyears.com.

Categories of sources

We collect consumer health data directly from you when you voluntarily complete the Independence Assessment on our website. We do not purchase, license, or otherwise obtain consumer health data from third parties.

How we use consumer health data

We use consumer health data only for the following specific purposes:

1. To generate your Independence Score and display it to you
2. To provide you with a summary of your results and recommended areas of focus
3. To follow up with you about Able Years’ fitness program by phone, email, or text — using the contact information you provide
4. To prepare for an initial Strategy Session conversation if you choose to schedule one with us

We do not use consumer health data for any purpose other than those listed above.

Who we share consumer health data with

We share consumer health data only with the following category of recipient:

• Our service provider, GoHighLevel — GoHighLevel is the customer relationship management (CRM) platform we use to store contact information and follow up with prospective members. GoHighLevel processes consumer health data on our behalf under a Data Processing Agreement that requires them to handle this data in accordance with MHMDA.

We do not share consumer health data with any other third party, including marketing partners, advertising networks, data brokers, or affiliates.

What we do NOT do with consumer health data

To be explicit:

• We do not sell consumer health data. We will never sell your consumer health data to any third party.
• We do not use consumer health data for targeted advertising. We do not allow third parties to use your consumer health data to target advertising to you on our behalf or theirs.
• We do not use geofencing around any healthcare facility or location to identify or track consumers seeking health services, to collect consumer health data, or to send health-related advertising.
• We do not collect precise location information that could indicate your attempt to acquire or receive health services or supplies.
• We do not share consumer health data with law enforcement unless required by valid legal process (subpoena, warrant, or court order).

How long we keep your consumer health data

We retain consumer health data for three years from your most recent interaction with Able Years. After three years of inactivity, we delete your consumer health data from our systems and direct GoHighLevel to do the same.

You may request earlier deletion at any time using the rights described below.

Your rights

Under MHMDA, you have the following rights regarding your consumer health data:

Right to know

You may ask us to confirm whether we are collecting, sharing, or storing your consumer health data, and to provide you with a copy of the data we hold about you.

Right to delete

You may ask us to delete your consumer health data. When we receive a deletion request, we will delete the data from our systems and direct GoHighLevel to delete the data from theirs. We will complete this within 45 days of receiving your request.

Right to withdraw consent

You may withdraw your consent for our collection, use, or sharing of your consumer health data at any time. After you withdraw consent, we will stop collecting new data from you and we will stop sharing your existing data, except where retention is required to comply with the law.

Right to appeal

If we deny any request you make under this policy, you may appeal that denial by emailing privacy@ableyears.com with the subject line “MHMDA Appeal.” We will respond to your appeal within 45 days. If you are not satisfied with the outcome of your appeal, you may file a complaint with the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.

How to exercise your rights

To make any of the requests described above:

• Email: privacy@ableyears.com
• Subject line:Include “MHMDA Request — [Access / Delete / Withdraw Consent / Appeal]” so we route your request quickly
• Include in the body: Your full name, the email address you used to interact with us, your ZIP code, and a description of your request

We will respond to your request within 45 days. We may need to verify your identity before processing your request to protect your privacy.

There is no cost to exercise these rights. We will not deny you any service or charge you a different price because you exercised these rights.

Changes to this policy

We may update this policy from time to time to reflect changes in our practices or in applicable law. When we make material changes, we will update the “Effective date” at the top of this page. Material changes will not apply retroactively to consumer health data we collected before the change.

We encourage you to review this policy periodically.

Contact us

If you have questions about this policy or our handling of consumer health data:

Able Years LLC
Spokane, Washington
Email: privacy@ableyears.com
Phone: (509) 309-0946

Washington Unified Business Identifier: 606-140-951

This policy is provided in accordance with the Washington My Health My Data Act, RCW 19.373. It is a standalone Consumer Health Data Privacy Policy and supplements (but is not a substitute for) any general website Privacy Policy.