Washington State Consumer Health Data Privacy Policy
Effective Date: March 24, 2024
This Washington State Consumer Health Data Privacy Policy supplements the Life Time (“Company”, “we”, “us”) Privacy Policy (“Privacy Policy”) and applies to the extent you are a resident of the state of Washington from whom we collect “consumer health data” (“CHD”), as defined by the Washington State My Health My Data Act (“MHMDA”), or to personal data we collect in Washington, to the extent such data is CHD.
Consumer Health Data We May Collect
As described in the Information We Collect section of our Privacy Policy, the data we collect varies and depends, among other things, on the context of your interactions with us, the products and features you use, and applicable law. Because MHMDA defines CHD very broadly, some of the categories of data we collect could also be considered CHD under that law even though we do not use it to identify health conditions or status and only collect such information if you choose to provide it to us. We only collect and use the below information to provide the goods and services you request and provide you with information and access to our clubs, membership programs, events, and activities.
Below are examples of the categories of data we collect that could be deemed CHD:
- Information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments. For example, we may collect such information when it might be associated with a product or service you purchase, when you sign up for a membership or participate in classes, programs, and activities or when you share such information with your Life Time personal trainer or nutritionist. We may also collect information about health-related surgeries or procedures, or fitness and exercise activity data when you provide it to us, such as prior to your participation in a class, training session, or part of a fitness assessment.
- Bodily functions, vital signs, symptoms or measurements related to your physical or mental health status (for example, your height and weight, fitness and exercise activity data, lab results and metabolic conditions).
- Location information that could reasonably indicate your attempt to acquire or receive health services or supplies. For example, if you are at one of our health clubs or on this website (“Website”) and our mobile applications (“App”), and search for a club location where you can purchase or obtain health products, or services, we may collect location data that could be deemed to reveal health-related information.
- Information that could be related to reproductive or sexual health information such as information about products you purchase, or your participation in certain classes, programs, and activities. For example, we may collect information about vitamins and supplements that you purchase or classes that you sign up for that may indicate pregnancy status or other information related to your reproductive or sexual health information.
- Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. For example, we collect your search queries on this website (“Website”) and our mobile applications (“App”), which may include queries concerning nutrition, wellness, fitness, or other health-related products or services.
We collect other non-health information as described in our Privacy Policy in order to provide our Website and the App (collectively, the “Services”) or operate our business such as information about products or services you have purchased, images, or voice recordings which we do not process to associate or identify you with information that could be deemed CHD.
Sources of Consumer Health Data
To the extent any of the information we collect constitutes CHD, we collect personal data (which may include CHD as described above) directly from you, from your interactions with our site and applications, products and services, and from third parties. For example, if you choose to connect and integrate our products and services with third-party applications so that we can provide you with products and services that you request, those third-party applications may disclose personal data (which may include CHD as described above) to us.
Why We Collect and Use Consumer Health Data
To the extent we collect and use CHD, we do so for the purposes described in the Purposes for Collection and Use of Information section of our Privacy Policy. More specifically, we collect and use information that could be considered CHD:
- As reasonably necessary to provide you with the products or services you have requested or authorized. This may include delivering and operating the products and services and their features, responding to your communications, personalization of certain product or service features, ensuring the secure and reliable operation of the products and the systems that support them, troubleshooting and improving the products, and other essential business operations that support the provision of the products or services (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).
- For any purpose for which you consent or direct us to collect or use it.
We may use CHD for other purposes for which we will give you choices and/or obtain your consent as required by law. See the Your access to and choices regarding your personal information section of the Privacy Policy and the How to Exercise Your MHMDA Rights section below for more details on the rights and choices you may have.
Our Disclosure of Consumer Health Data
We may disclose each of the categories of data that could be considered CHD described above for the purposes described below:
- To the extent necessary to provide a product or service that you have requested or as reasonably necessary to complete any transaction or provide any product or service you have requested or authorized, as described above.
- If we are involved in a merger, asset sale, financing, corporate divesture, reorganization, or acquisition of all or some portion of our business to another company or if we undergo liquidation or bankruptcy proceedings, we may disclose your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed.
- For any purpose for which you consent or direct us to disclose it.
If you make a purchase or payment for a membership, product, or service, we will disclose information about the transaction as necessary to process the payment, including protection against fraud. And we may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.
Third Parties To Whom We Disclose Consumer Health Data
As necessary for the purposes described above to provide the products and services that you request from us, we disclose information that could be considered CHD with the following categories of third parties:
- Service providers. Vendors, service providers, or contractors (“processors”) that provide services on our behalf may access information that might be considered CHD for the purposes described above. For example, companies that provide customer service support, technical services, or assist in protecting and securing our systems and services may need access to data to provide those functions on our behalf.
- Financial institutions & payment processors. When you make a purchase, sign up for a membership, or enter into a financial transaction, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
- Parties to a corporate transaction. We may disclose information that might be considered CHD as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
- Affiliates. To the extent that we disclose data across our subsidiaries, affiliates, and related companies, we do so to facilitate the provision of goods or services you may have requested from Life Time. If you would like to request a full list of our specific affiliates, please email us at privacy@lt.life.
- With third parties for legal or security reasons. As described in our Privacy Policy, we disclose data to third parties (including law enforcement or other government agencies) when we believe doing so is necessary to comply with applicable law or respond to valid legal process.
- Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.
- Other users and individuals. If you use our services to interact with other users of the service or other recipients of communications, we may disclose data, including information that might be considered CHD, as directed by you and your interactions in order to provide the services or product you request.
- The public. You may select options available through our services to publicly display and disclose certain information, such as your MyLT profile, demographic data, content, or geolocation data, which may include information that might be considered CHD.
How to Exercise Your MHMDA Rights
MHMDA provides certain rights with respect to CHD, including rights to confirm collection of, access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the methods described in the Your access to and choices regarding your personal information section of the Privacy Policy. And if you want to access or control CHD that we process that is not available via those methods, you can contact us using the contact information in the Contact Us section of the Privacy Policy or by using our Request Portal.
If your request to exercise a right under the MHMDA is denied, you may appeal that decision by contacting our privacy support team at ATTN: Privacy Team, Life Time, Inc. 2902 Corporate Place, Chanhassen, MN 55317. If your appeal is unsuccessful, you can raise a concern or file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.