Terms of service
Consumer Health Data Privacy Policy
Effective date: [INSERT DATE OF PUBLICATION] Last updated: [INSERT DATE OF PUBLICATION]
This Consumer Health Data Privacy Policy is provided by Sea Witch Botanicals ("Sea Witch Botanicals," "we," "us," or "our"), operated by Living Glass Houses, LLC, in compliance with Washington's My Health My Data Act ("MHMDA"), RCW 19.373. It is separate and distinct from our general Privacy Policy, as required by RCW 19.373.030.
This policy applies to Consumer Health Data we collect from Washington residents and other consumers protected by MHMDA.
1. What Is "Consumer Health Data"?
Under MHMDA, "Consumer Health Data" is Personal Information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. This can include data that we, or our vendors, derive or extrapolate from other (non-health) data — for example, inferences drawn from product browsing or purchase behavior.
Because some Sea Witch Botanicals product descriptions, blog posts, and marketing materials reference wellness-related benefits (for example, supporting sleep, relaxation, calm, or mood), data showing a consumer's interest in, purchase of, or engagement with those products may qualify as Consumer Health Data under MHMDA's broad definition.
2. Categories of Consumer Health Data We Collect
We may collect, process, or infer the following categories of Consumer Health Data:
| Category | Examples |
|---|---|
| Product interaction data tied to wellness claims | Pages viewed, products clicked or purchased, and search terms when those products are marketed for sleep, relaxation, mood, or other wellness-related benefits |
| Inferred wellness interests | Audience segments or product recommendations we or our vendors derive from your browsing and purchase activity (for example, a "sleep support" or "stress relief" segment) |
| Voluntary disclosures | Information you choose to share in customer service messages, surveys, or product reviews that references your health, wellness goals, sensitivities, or use of our products |
| Email and SMS engagement | Opens, clicks, and conversions associated with marketing campaigns that reference wellness benefits |
We do not intentionally collect:
- Diagnoses, medical conditions, prescriptions, or treatment records
- Biometric data (heart rate, sleep tracking, etc.)
- Reproductive or sexual health data
- Precise geolocation data that would reveal a visit to a health facility
- Genetic data
If you voluntarily share any of the above in correspondence with us, we will treat it as Consumer Health Data and delete it when it is no longer needed.
3. Sources of Consumer Health Data
- You directly — through orders, account creation, customer service contact, product reviews, surveys, and form submissions.
- Automatically — through cookies, pixels, and analytics tools on our Site.
- Service providers — including Klaviyo, Meta, Google, Shopify, Recharge, Stamped.io, and Smile.io, which may collect Site activity that we use to infer wellness interests.
4. How We Use Consumer Health Data
We use Consumer Health Data only for the following purposes:
- To fulfill your orders and provide customer service;
- To personalize product recommendations and Site content;
- To send marketing communications you have opted into (email and SMS);
- To run advertising on third-party platforms, including retargeting and audience modeling, only with your consent as required by MHMDA;
- To improve our products and Site;
- To comply with legal obligations.
We do not sell Consumer Health Data, as "sell" is defined under MHMDA (the exchange of Consumer Health Data for monetary or other valuable consideration).
5. Sharing of Consumer Health Data
We share Consumer Health Data only with the following categories of recipients, and only as needed to provide our services or as required by law:
| Recipient | Purpose |
|---|---|
| Shopify | E-commerce platform, hosting, payments |
| Recharge | Subscription billing |
| Klaviyo | Email and SMS marketing, audience segmentation |
| Stamped.io | Product reviews |
| Smile.io | Loyalty program |
| ShipStation | Order fulfillment |
| TaxJar / Numeral | Sales tax compliance |
| Google / Meta | Advertising (with your consent, as required for Consumer Health Data) |
| Bread Loaf Corporation | Marketing, retention, and development services |
| Amazon | Sales channel fulfillment |
| Professional advisors and successors | As described in our main Privacy Policy |
Additional apps and processors may be added over time. Where any such app processes Consumer Health Data on our behalf, it does so as a processor under written agreement that requires MHMDA-compliant handling. A current and complete list of processors with access to Consumer Health Data is maintained internally and available upon written request.
We do not share Consumer Health Data with third parties for their own independent purposes without your separate, valid authorization as required by RCW 19.373.040.
6. Your Rights Under MHMDA
If you are a Washington resident, or otherwise protected by MHMDA, you have the right to:
- Confirm whether we are collecting, sharing, or selling your Consumer Health Data, and to access that data;
- Withdraw consent to our collection and sharing of your Consumer Health Data;
- Request deletion of your Consumer Health Data. Upon receiving a verified deletion request, we will delete the data from our records and, where required by RCW 19.373.050, direct our processors and affiliates to do the same;
- Appeal any denial of a request, by replying to our response email.
How to exercise your MHMDA rights
Email hifriend@seawitchbotanicals.com with the subject line "MHMDA Request" and a description of your request. We will verify your identity before responding. We will respond within 45 days, with one possible 45-day extension when reasonably necessary; we will notify you if an extension is required.
We will not discriminate against you for exercising your rights under MHMDA.
You may also file a complaint with the Washington State Attorney General's Office: https://www.atg.wa.gov/file-complaint
7. Consent
Where MHMDA requires consent — including for the collection of Consumer Health Data beyond what is necessary to provide a product or service you requested, and for any sharing of Consumer Health Data — we obtain that consent through clear, affirmative action (for example, checking a box that is not pre-checked, or completing a separate opt-in). You may withdraw consent at any time by contacting us at hifriend@seawitchbotanicals.com or by following the unsubscribe instructions in our marketing communications.
We do not sell Consumer Health Data. If that ever changes, we would obtain separate, valid authorization signed by you in compliance with RCW 19.373.040 before doing so.
8. Security
We apply the same administrative, technical, and physical safeguards described in our main Privacy Policy to Consumer Health Data, and we require our processors to do the same.
9. Changes to This Policy
We may update this Consumer Health Data Privacy Policy from time to time. Material changes will be reflected in the "Last updated" date above and, where required, communicated through additional notice.
10. Contact Us
Sea Witch Botanicals Living Glass Houses, LLC 1616 N State St, STE 103, Bellingham, WA 98225 Email: hifriend@seawitchbotanicals.com