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Consumer Health Data Privacy Policy

Effective Date: 05-08-2025

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1. Introduction

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This Consumer Health Data Privacy Policy ("Policy") applies to personal data defined as “Consumer Health Data” by the Washington My Health My Data Act, and any other similar state-level laws such as those in Nevada and Connecticut (collectively, "MHMD"), that is collected from you by SuperGenix dba Somos Inc. ("Somos, " "our, " "us," or "we"). This Policy supplements the Somos Privacy Policy. If there is a conflict between any other Somos policy, statement, or notice and this Policy, this Policy will prevail as to Consumer Health Data collected under MHMD. For the purposes of this Policy, unless otherwise noted, all references to Somos include the Somos https://www.somosxr.com/ website and its subdomains, any Somos games or applications, and any other interactions with Somos through which Consumer Health Data may be collected.

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Consumer Health Data under MHMD means 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 Policy does not apply where an exception or exemption applies such as for Protected Health Information under the Health Insurance Portability and Accountability Act of 1996. 

 

2. Consumer Health Data We Collect

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As described in our Privacy Policy, the personal data we collect depends on the context of your interactions with Somos. 

We may collect the following categories of personal information about you, which may be Consumer Health Data under MHMD:

  • Movement data, body tracking, hand tracking, movement tracking, controller tracking, controller input, and voice data;

  • Health and lifestyle history; 

  • Information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments; and

  • Emg (Electromyography) or other sensor collected data.

 

3. Sources of Consumer Health Data

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Somos does not collect your Consumer Health Data unless you voluntarily provide it to us by using our services. We collect personal information, including Consumer Health Data, from the following categories of sources:

  • Directly from you when you use our services; 

  • When you voluntarily provide it in an open text field, such as in response to surveys; 

  • When you voluntarily provide it in any other forum, such on a social-media platform or online discussion forum.

 

4. Use of Your Consumer Health Data

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We use Consumer Health Data for the following purposes: 

  • To provide you with the services you have requested or authorized;  

  • To deliver our services;  

  • To ensure the secure and reliable operation of our services and the systems that support them including troubleshooting and improving the services;  

  • For essential business operations that support the provision of our services such as analyzing our performance and meeting our legal obligations; and

  • Other purposes for which we give you choices or obtain your consent as required by law.

 

Where we require your consent to collect personal information for a specified purpose, a description of those purposes is provided to you at the time of collection. 

 

5. Sharing Consumer Health Data With Third Parties

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Somos will only share your Consumer Health Data with employees and trusted partners and only for the services you have consented to or to the extent necessary to provide a product or service that you have requested or comply with applicable law.

 

As necessary for the purposes described above, we may share personal information, including Consumer Health Data, with following categories of third parties: 

  • Affiliates. We may enable access to affiliates, for example, where we share common data systems or where access helps us to provide our services and operate our business.

  • Service providers. Vendors working on our behalf may access Consumer Health Data for the purposes described above. 

  • Partners. We may share Consumer Health Data with other companies, such as Meta Platforms, Inc. ("Meta"), to enable your access to our games on Meta devices or platforms.    

  • Financial institutions & payment processors. When you make a purchase 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. 

  • Government agencies. We may disclose data to 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 users. 

  • The public. You may select options available through our services to publicly display and disclose certain information, such as a review, demographic data, content and files, or other data, which may include Consumer Health Data.

 

6. How to Exercise Your Rights

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MHMD provides certain rights with respect to Consumer Health Data, including the right to access, delete, or withdraw consent relating to your Consumer Health Data, subject to certain exceptions. You may exercise any of your rights by contacting us directly using the contact details found in this Policy. The written request should include sufficient information to verify your identity and specify the right you wish to exercise. For any questions or assistance, you may also reach out using the contact information below.

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If your request to exercise a right under the MHMD is denied, you may appeal that decision by contacting us, noting “Appeal of My Health My Data Decision,” and we will escalate it. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with your state’s attorney general. Complaint forms for Washington, Nevada, and Connecticut are available at www.atg.wa.gov/file-complaint;  https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/; and https://portal.ct.gov/ag/common/complaint-form-landing-page.   

 

7. Changes to This Policy

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Somos reserves the right to change this Policy from time to time. For example, when there are changes in our services, changes in our data protection practices, or changes in the law. When changes to this Policy are significant, we will inform you through this policy page.

 

8. Contact Information​

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All notices or requests should be written and given by email to: 

Somos

support@somosxr.com   (please be sure to include “My Health My Data” in the subject line)

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