GENZA Consumer Health Data Privacy Policy

Version: 1.0

Effective Date: March 31, 2026

This Consumer Health Data Privacy Policy (“Policy”) supplements the GENZA Privacy Policy and applies only to individuals who are residents of U.S. states with consumer health data laws (currently including Washington and Nevada, and any other state that adopts similar laws) when those laws apply to our processing of their information (“you”).

If there is any conflict between this Policy and our main Privacy Policy regarding Consumer Health Data, this Policy controls for that subject.

GENZA is not a healthcare provider and is generally not subject to HIPAA. These state laws may apply to certain health-related data we process outside of traditional medical contexts.

1. What is “Consumer Health Data”?

For purposes of this Policy, “Consumer Health Data” (CHD) means personal information that is linked or reasonably linkable to you and that identifies or is used to identify your past, present, or future physical or mental health status, as defined by applicable law in your state (for example, Washington’s My Health My Data Act and Nevada’s Consumer Health Data Privacy Law).

Depending on the law, this can include both medical information and non-medical information that indicates your physical or mental health status, including inferences relating to mental state, emotional well-being, sexual life, reproductive health, or similar sensitive topics.

2. Categories of Consumer Health Data We May Collect

Depending on what you choose to share on GENZA, the following may be treated as CHD:

• Information about mental or emotional well-being that you choose to share (for example, references to stress, anxiety, trauma, burnout, loneliness, or similar topics).

• Information about sexual life or sexual health that you choose to share (for example, orientation, preferences, boundaries, relationship expectations, or health-related details).

• Information about physical health, disability, or accessibility needs that you choose to include in your profile, messages, support communications, or other interactions with the Service.

• Inferences drawn from information you choose to provide, or from your use of certain features, where those inferences reflect aspects of your physical or mental health status under applicable law.

If you do not want this information processed, please do not include it in your profile, prompts, messages, support requests, or other user-submitted content.

3. How We Collect Consumer Health Data

We may collect CHD from the following sources:

1. Directly from you

   • when you create or edit your profile, complete prompts, quests, or compatibility-related features, or otherwise choose to share health-related or sensitive personal information;

   • when you send messages, participate in chats, rooms, voice, prompts, or other interactive features;

   • when you contact us, including in support or safety reports that mention issues such as trauma, abuse, harassment, self-harm, sexual violence, or other health-related matters.

2. Automatically from your use of the Service

   • usage data and feature interaction data that may, depending on context and configuration, be used to infer certain health-related preferences, sensitivities, or well-being indicators where permitted by law.

3. From service providers or processors

   • where they process information on our behalf for safety, moderation, analytics, support, fraud prevention, or development, they may generate or process inferences that qualify as CHD under applicable law.

We do not collect CHD from healthcare providers or electronic health records systems.

4. Purposes for Collecting and Using Consumer Health Data

We collect, use, and disclose CHD only as necessary to provide the services you request, to protect users and the Service, or with your consent, as required by applicable consumer health data laws.

Depending on your use of GENZA, we may use CHD for the following purposes:

• Providing and personalizing GENZA, including operating your account, presenting your profile, supporting compatibility and social features, and reflecting information you choose to share.

• Safety, moderation, and enforcement, including detecting and responding to harassment, threats, sexual misconduct, self-harm indications, fraud, abuse, or other violations of our Terms, Community Guidelines, or safety rules.

• Communications and support, including responding to questions, support requests, disputes, and account issues.

• Legal compliance and protection of rights and safety, including responding to legal obligations or protecting you, other users, GENZA, and the public.

We do not sell Consumer Health Data, and we do not use CHD for targeted advertising or marketing in a manner inconsistent with applicable consumer health data laws.

5. How We Disclose Consumer Health Data

We may disclose CHD to the following categories of recipients, only for the purposes listed above and in line with this Policy and applicable law:

1. Service providers and processors

   • companies that host our services, provide infrastructure, security, fraud detection, moderation, analytics, customer support, or development services;

   • they are contractually required to use CHD only on our instructions and not for their own purposes, except as otherwise permitted by law.

2. Affiliates

   • companies within our corporate group that support GENZA operations, subject to appropriate privacy and confidentiality safeguards.

3. Other users

   • CHD that you intentionally include in your profile, messages, chats, rooms, or other user-visible content will be visible to other users according to your settings and the design of the Service.

4. Law enforcement and legal recipients

   • when we believe disclosure is required by law, regulation, subpoena, court order, or legal process;

   • when we believe it is necessary to protect the rights, property, or safety of you, other users, GENZA, or the public.

5. Business transfers

   • in connection with a merger, acquisition, restructuring, financing, or sale of assets, subject to continuity of protections for CHD as required by applicable law.

We do not disclose CHD to data brokers.

6. Sale of Consumer Health Data

GENZA does not sell your Consumer Health Data.

If we ever wished to “sell” CHD in the sense defined by applicable consumer health data laws, we would first obtain any separate authorization required by law, including where required a written and signed authorization identifying the categories of CHD, the purpose of the sale, and the relevant third-party recipients.

7. Consent, Withdrawal of Consent, and Limiting Use

Where the collection or use of CHD is not strictly necessary to provide a product or service you requested, or is otherwise subject to consent under applicable law, we will obtain your affirmative consent before collecting or using such CHD, or we will not collect it.

You may:

• Withdraw your consent to our collection or use of specific CHD at any time, subject to legal requirements and permitted exceptions;

• Limit our use and disclosure of CHD to the purposes allowed by law, such as providing requested services, maintaining security, preventing fraud, or complying with legal obligations.

To do this, you can:

• adjust relevant settings in the GENZA app, where available; and/or

• contact us using the methods described in Section 10 (“How to Exercise Your Rights”).

If you withdraw consent or limit use, some features that depend on that CHD may become limited or unavailable.

8. Your Rights Regarding Consumer Health Data

Subject to certain exceptions and verification requirements, residents of Washington, Nevada, and other states with similar laws may have the following rights in relation to CHD:

1. Right to confirm and access

   • to confirm whether we are collecting or sharing your CHD;

   • to access the CHD we hold about you;

   • to receive, where required by law, a list of third parties and affiliates with whom we have shared your CHD.

2. Right to deletion

   • to request deletion of CHD we have collected about you, subject to legal exceptions such as security, fraud prevention, legal compliance, or dispute preservation.

3. Right to withdraw consent / limit use

   • to withdraw consent or limit our collection, use, or disclosure of CHD to certain permitted purposes.

4. Right to data portability (where required)

   • to receive a copy of certain CHD in a portable, readily usable format, where technically feasible and required by law.

5. Right to appeal

   • if we decline to act on your request, in whole or in part, you can submit an appeal;

   • we will explain our decision and, where required by law, how you can contact the relevant state authority if you are not satisfied with our response.

We will not discriminate against you for exercising any of these rights, although certain features may not function without some data.

9. Security and Retention of Consumer Health Data

We implement reasonable administrative, technical, and physical safeguards designed to protect CHD from unauthorized access, use, or disclosure, as required by applicable law.

We keep CHD only for as long as reasonably necessary to:

• provide the services you request;

• support legitimate business needs such as security, fraud prevention, moderation, support, and recordkeeping;

• comply with legal, regulatory, contractual, or evidentiary obligations;

• resolve disputes and enforce our agreements.

Retention periods may vary depending on the type of CHD, the context in which it was collected, and our legal obligations. When CHD is no longer needed, we will delete it or de-identify it in accordance with applicable law and our internal policies.

10. How to Exercise Your Consumer Health Data Rights

If you live in Washington, Nevada, or another state with consumer health data laws, you can exercise your CHD rights by:

1. In the app

   • Use the Help / Support or Privacy section and select a privacy or consumer health data request, where available.

2. Through our contact channels

   • Use the contact details provided in the GENZA app or in our main Privacy Policy and indicate that your request relates to Consumer Health Data and your state of residence.

   • Please indicate that your request relates to Consumer Health Data and your state of residence.

We may need to verify your identity before processing your request, which may involve requesting certain information from you. You may also authorize an agent to act on your behalf, subject to verification procedures required by law.

If we deny your request in whole or in part, we will provide an explanation and information on how to appeal our decision. If you remain unsatisfied, you may have the right to contact your state attorney general or other regulator.

11. Changes to This Policy

We may update this Consumer Health Data Privacy Policy from time to time, for example when:

• laws or regulatory guidance change;

• we introduce new features or data uses that affect CHD;

• we make changes to our privacy program.

When we make material changes, we will update the Effective Date at the top of this Policy and may provide additional notice as required by law.

If you have questions about this Policy or our handling of Consumer Health Data, please contact us through the Help / Support section in the GENZA app or using the contact details provided in our main Privacy Policy.