CONSUMER HEALTH DATA PRIVACY POLICY
Last Updated: July 28, 2026
Thank you for visiting Winona, Inc. (“Winona”) website https://bywinona.com/ (the “Site”), contacting Winona, and/or using any Winona mobile and online applications or services (the “Services”). This Consumer Health Data Privacy Policy is intended to describe how Winona handles “Consumer Health Data” (as defined by Washington and Nevada law) that you provide, or that we learn about the individuals who: visit our website, use our Services, contact us by mail, email or telephone or in person, or through any other means. We recommend that you carefully review this notice before providing us with any information.
This Policy supplements our general privacy policy, available at https://bywinona.com/privacy-policy (the "General Privacy Policy"), and addresses only consumer health data as defined by applicable law. This Policy does not replace the General Privacy Policy, which continues to apply to personal information that is not consumer health data. To the extent there is any conflict between this Policy and the General Privacy Policy with respect to consumer health data, this Policy controls.
This Consumer Health Data Privacy Policy does not apply to health information used for diagnosis and provision of treatment that we collect on behalf of the medical providers and pharmacies who provide services to you through the Services. We handle this information in accordance with our agreements with those medical providers and pharmacies and applicable law.
Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Consumer Health Data with us.
We may update this Consumer Health Data Privacy Policy from time to time. Any updated Consumer Health Privacy Notice will be effective when posted. Please check this Consumer Health Privacy Notice periodically for updates.
Sources of Consumer Health Data
We collect Consumer Health Data about you from the following sources:
Directly from you. We may collect Consumer Health Data you provide to us directly, such as when you contact us through our Services, interact with us in person, sign up for offers or newsletters, communicate with us, place or customize orders, or sign up for an account or other services.
Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Services. This may include information about how you use and interact with our Services, information about your device, and internet usage information.
From third parties. We may collect Consumer Health Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us.
From publicly available sources. We may collect Consumer Health Data about you from publicly available sources, such as public profiles and websites.
We may combine information that we receive from the various sources described in this Consumer Health Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.
Types of Consumer Health Data We Collect
We may collect the following types of Consumer Health Data:
Health conditions, treatments, diseases, or diagnosis
Inferences about health derived from other health or non-health data, such as information that indicates an attempt to acquire health services or supplies.
How We Use Consumer Health Data
We may use Consumer Health Data for the following purposes:
To provide you products and services, such as making our Services, products and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
In connection with a corporate transaction, such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
For marketing, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Consumer Health Data we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Services; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email or by contacting us using the information in the Contact Us section below.
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
How We Disclose Consumer Health Data
We disclose the Consumer Health Data described above to third parties, including the categories of recipients described below:
Medical professionals and pharmacies that provide services to you via the Services
Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Use and other agreements or policies, and to protect our, our customers’, or third parties' safety, property, or rights.
Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Consumer Health Data in comments, reviews, or other content that you share in public areas of our Services may be read, collected, or used by other users or the public.
Entities to which you have consented to the disclosure.
Data Subject Rights
Washington consumers may have certain rights regarding your Consumer Health Data:
Right to Access. You may have the right to confirm whether we process your Consumer Health Data and to obtain information about how we process such data.
Right to Delete. You may have the right to request that we delete Consumer Health Data concerning you.
Right to Withdraw Consent. If you provided consent to process Consumer Health Data, you may have the right to withdraw such consent.
Right to Correct. You may have the right to correct your Consumer Health Data.
You may exercise the rights available to you by emailing us at hello@bywinona.com.
Contact Information
If you have questions regarding this Consumer Health Data Privacy Policy, please contact us at hello@bywinona.com