Hasu Somatics LLC — Consumer Health Data Privacy Policy

Last updated: August 2026

This separate policy explains how Hasu Somatics LLC (“Hasu Somatics,” “we,” “us,” or “our”) handles personal information that may qualify as consumer health data. It is intended to provide additional transparency in light of Washington’s My Health My Data Act, chapter 19.373 RCW. Whether a particular provision applies depends on the facts, the consumer’s location, the place of collection, and the law’s definitions and exemptions.

1. Scope and purpose

This policy applies to consumer health data that we collect in connection with our website and Squarespace forms, Calendly scheduling and intake, direct business email, Thinkific course and account services, and related support or service communications. It supplements our general Privacy Policy and focuses only on consumer health data and related rights.

For this policy, consumer health data means personal information that is linked or reasonably linkable to a consumer and identifies the consumer’s past, present, or future physical or mental health status. Depending on context, this may include information about symptoms, bodily functions, movement, day-to-day limitations, or seeking a health-related service.

2. Categories of consumer health data we may collect

Depending on what you choose to share and how you interact with us, we may collect:

  • Identity and contact information linked to health-related information, such as your name, email address, appointment details, and optional phone number.

  • General information about pain, tension, bracing, fear of movement, symptoms, bodily functions, movement limitations, or other bodily experiences.

  • Information about how a movement or bodily concern affects daily activities, confidence, relationships, work, recreation, or other parts of life.

  • General information about approaches you have tried and whether they seemed helpful.

  • Personal goals, desired changes, and the kind of support or course experience you are seeking.

  • Information showing that you sought, scheduled, or received information about a somatic movement course, discovery call, or related service.

  • Consumer health data you voluntarily include in a website contact message, direct email, Thinkific communication, scheduling response, or conversation.

  • Technical or interaction information, such as an IP address, cookie or device identifier, course-page visit, or appointment interaction, only when it is linked or reasonably linkable to you and is processed to identify or associate you with a physical or mental health status or with seeking a health-related service.

The current Calendly form does not intentionally request detailed health information. It instructs people not to include medical records, diagnoses, medications, or detailed health history in the optional logistical or decision-related field. A person could still voluntarily include health-related information despite that instruction, but doing so is not required to schedule a call. Please provide only the minimum information you are comfortable sharing.

3. Categories of sources

We may collect consumer health data from:

  • You directly, including through Calendly intake answers, Squarespace contact forms, direct email, course or support communications, and conversations you request.

  • Calendly, Squarespace, Thinkific, and other processors that operate the service or communication channel you choose to use.

  • Your interactions with our website or Thinkific course pages through Google Analytics 4 and similar technical records, but only to the extent the information is linked or reasonably linkable to you and qualifies as consumer health data.

  • Records created in administering an appointment, requested service, course account, enrollment, support request, privacy request, or consent choice.

We do not purchase consumer health data from data brokers.

4. Exact purposes for collection and use

We collect and use consumer health data only for the following purposes:

  • To schedule, confirm, administer, and communicate about a discovery call or other service you request.

  • To prepare for and conduct a requested conversation, understand the general concern or goal you choose to share, and assess whether a Hasu Somatics service or course may be a suitable fit.

  • To respond to website-contact messages, direct emails, support requests, and questions.

  • To create and administer a requested Thinkific account, course enrollment, course access, learning support, or related service.

  • To maintain records of your request, consent choice, withdrawal, privacy request, appeal, or our response.

  • To secure our systems, prevent misuse or fraud, troubleshoot, and protect the confidentiality and integrity of information.

  • To comply with applicable law, respond to valid legal process, establish or defend legal claims, and maintain records reasonably necessary for those purposes.

We do not use the content of Calendly free-text intake answers to build advertising profiles or for unrelated email marketing. Optional marketing-email choices are separate from consumer health data collection and use.

5. When collection is necessary to provide a requested service

Where permitted by applicable law, we may collect consumer health data without a separate consent only to the extent necessary to provide a product or service you requested. Basic contact and appointment information may be necessary to schedule and administer a discovery call. Course-account and enrollment information may be necessary to provide requested course access.

Health-related information is not requested or required to schedule a call. If you voluntarily include health-related information despite the instruction not to do so, we use it only for the requested interaction, support, course administration, or other purposes disclosed in this policy. Please provide only the minimum information you are comfortable sharing.

6. When affirmative consent may be required

When collection is not necessary to provide a product or service you requested, we may ask for affirmative consent before collecting consumer health data for a specified purpose. A consent request should be clear, specific, informed, voluntary, opt-in, and separate from unrelated terms.

We may also ask for affirmative consent before:

  • Collecting, using, or disclosing an additional category of consumer health data not disclosed in this policy.

  • Using consumer health data for an additional purpose not disclosed in this policy.

  • Sharing consumer health data when separate and distinct sharing consent is required and the disclosure is not necessary to provide a product or service you requested.

We do not condition a requested service on consent that is not necessary to provide that service, except where the law permits otherwise.

7. Withdrawing consent

You may withdraw consent from future collection or sharing of consumer health data by emailing taro@taroiwamoto.com with the subject “Consumer Health Data Request.” Tell us which consent you want to withdraw and the service or interaction involved. Withdrawal applies prospectively and may limit our ability to provide a feature that depends on the information. Withdrawing consent does not, by itself, delete information already collected; you may also submit a deletion request.

8. Processors, disclosures, and statutory sharing

We use service providers that may act as processors by handling information on our behalf and under instructions connected to a requested service. Washington law defines sharing to exclude certain processor disclosures when they are consistent with the purpose for which the data was collected and disclosed to the consumer. A service’s label does not determine its legal role: the actual contract, instructions, configuration, and processing matter. We therefore identify processors transparently and do not assume that every disclosure falls outside statutory sharing.

Categories disclosed to processors may include identity and contact information linked to health-related information; appointment details and intake answers; website-contact or direct-email content; course-account, enrollment, and support information; consent and request records; and technical or interaction data that qualifies as consumer health data.

The processors and service destinations we use for the categories and purposes described above are:

  • Calendly — appointment selections, name, email address, time zone, intake answers, optional phone number, and event-communication choices for scheduling and administering a requested call.

  • Squarespace — website and form operation, including newsletter fields and contact-form messages. Squarespace receives health-related information only if a person chooses to enter it in the contact form.

  • Google Workspace/Gmail — direct email, support communications, and service notifications sent to the business mailbox at taro@taroiwamoto.com.

  • Thinkific — course pages, accounts, enrollments, learning activity, checkout-related records, and course or support communications. We do not direct Calendly free-text intake-answer content to Thinkific.

  • Mailchimp — email contact, subscription, audience, and Thinkific user or lead information used for email administration. We do not direct Calendly free-text intake-answer content to Mailchimp.

  • Google Analytics 4 — website and Thinkific course-page analytics and related technical or interaction information. We do not direct Calendly free-text intake-answer content to Google Analytics 4.

We will update this list before using any additional processor or service destination to receive consumer health data.

We do not currently identify an affiliate or other third party that receives consumer health data for its own independent marketing purposes. We may disclose only the information reasonably necessary to a government authority, court, legal adviser, insurer, or other recipient when required by law, valid legal process, or the establishment, exercise, or defense of legal claims.

9. No sale of consumer health data

Hasu Somatics LLC does not sell consumer health data. We do not exchange consumer health data for money or other valuable consideration. If that practice changes, we will update this policy and obtain the separate, valid authorization required by applicable law before any sale.

10. Your consumer health data rights

Subject to applicable law, exceptions, and our ability to authenticate your request, you may have the right to:

  • Confirm whether we are collecting, sharing, or selling consumer health data about you.

  • Access consumer health data about you.

  • Receive a list of third parties and affiliates with which we have shared or sold your consumer health data, including an active email address or other online contact mechanism when required.

  • Withdraw consent from future collection or sharing.

  • Request deletion of consumer health data about you.

  • Appeal a refusal to act on your request.

You may also ask us to correct inaccurate consumer health data. RCW 19.373.040 does not state a separate correction right, but we will review correction requests and correct information where reasonably appropriate or required by another applicable law.

When deletion is required, we will delete the consumer health data from our records and notify applicable affiliates, processors, contractors, and other third parties as required. Deletion from archived or backup systems may be delayed for restoration purposes for up to six months after the request is authenticated, where the statute permits.

11. How to submit a request

Email taro@taroiwamoto.com with the subject “Consumer Health Data Request.” Describe the right you want to exercise and the service or interaction involved. You do not need to create a new account. If you already have a relevant account, we may ask you to use it as part of verification.

Submit an appeal to the same address with the subject “Consumer Health Data Appeal” and identify the request and decision you want us to reconsider.

12. Identity verification

We use commercially reasonable methods to determine that a request is made by, or on behalf of, the person entitled to exercise the right. Depending on the request and the sensitivity of the information, we may:

  • Confirm control of the email address associated with the interaction or account.

  • Ask for limited information about the appointment, form, course, or communication sufficient to match the request to our records.

  • Use an existing account or another secure and reliable method when appropriate.

  • Request additional information reasonably necessary to authenticate the request if the initial information is insufficient.

We will not ask for medical records or detailed medical history merely to verify a request. If we cannot authenticate a request using commercially reasonable efforts, we may decline to act and will explain that decision as required. An authorized agent may submit a request where applicable; we may verify the agent’s authority and the consumer’s identity.

13. Response periods, fees, and appeals

For requests to confirm, access, withdraw consent, or delete under RCW 19.373.040, we will respond without undue delay and within 45 days after receiving the request. Prompt authentication efforts do not extend that initial period. When reasonably necessary because of the complexity or number of requests, we may extend the period once by up to 45 additional days if we notify you within the initial 45 days and explain the reason.

We will provide information free of charge up to twice per year. If a request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable administrative fee or decline to act, as permitted by law, and we bear the burden of supporting that decision.

If we refuse to act, you may appeal within a reasonable period after receiving the decision. We will inform you in writing of the action taken or not taken on the appeal within 45 days after receiving it and explain the reasons. If an appeal is denied, we will provide an available online mechanism or other method to contact the Washington Attorney General, where required.

14. Security

We restrict access to consumer health data to people, processors, and contractors whose access is necessary to carry out a disclosed, consented purpose or provide a product or service the consumer requested. We use reasonable administrative, technical, and physical safeguards appropriate to the volume and nature of the information and rely on contractual and security measures of processors. No transmission or storage system can be guaranteed completely secure.

15. Retention

We retain consumer health data only as long as reasonably necessary for the disclosed purpose, including scheduling and preparing for a requested call, providing a requested service or course, responding to communications, maintaining consent and privacy-request records, protecting security, resolving disputes, and meeting legal or recordkeeping obligations. Retention varies by record type and service. When information is no longer reasonably necessary, we delete or de-identify it, subject to backup, security, legal, and technical requirements.

16. Changes to this policy

We may update this policy when our practices, services, processors, or legal obligations change. The revised policy will show a new last-updated date. Before collecting, using, or sharing an additional category of consumer health data or using it for an additional purpose not disclosed here, we will update the disclosure and obtain affirmative consent when required.

17. Contact information

Hasu Somatics LLC

Portage, Michigan 49024

Email: taro@taroiwamoto.com