This State Consumer Health Data Addendum ("Health Data Addendum") supplements the ModernGut Privacy Policy and explains how Pico Health Inc. d/b/a ModernGut ("ModernGut," "Company," "we," "us," or "our") collects, uses, and discloses consumer health data or similar health-related information when state-specific consumer health data laws apply.
ModernGut is based in California, but its website and courses are expected to be available throughout the United States, with users from all 50 states. Because ModernGut provides health-related educational content, this Health Data Addendum is intended to address state-specific consumer health data issues that may arise outside California, including in Washington, Nevada, Connecticut, or other applicable jurisdictions.
This Health Data Addendum is incorporated by reference into our Terms of Use and general Privacy Policy.
ModernGut provides content concerning gastroenterology, digestive health, and related healthcare topics, including diagnosed conditions such as irritable bowel syndrome, for general informational and educational purposes only. ModernGut does not currently intend to ask users to provide personal health information through intake forms, questionnaires, quizzes, surveys, assessments, or personalization features. ModernGut also does not provide individualized recommendations based on user responses.
However, because ModernGut offers health-related courses and content, certain information may reveal or suggest a user's interest in health-related topics. This may include course purchase history, course engagement, course pages viewed, webinar participation, newsletter interactions, and similar data.
For purposes of this Health Data Addendum, "Consumer Health Data" means personal information that is linked or reasonably linkable to a consumer and that identifies or may be used to identify the consumer's past, present, or future physical or mental health status, to the extent that definition or a similar definition applies under applicable state law.
This Health Data Addendum applies only to Consumer Health Data subject to applicable state consumer health data laws. It does not apply to information that is exempt from those laws or outside their scope.
ModernGut is not a healthcare provider and does not provide medical diagnosis, treatment, or individualized medical advice through the Services.
Depending on how you interact with the Services and how applicable law defines Consumer Health Data, we may collect the following categories of Consumer Health Data:
ModernGut does not currently intend to collect diagnostic information, symptoms, lab results, medications, supplements, treatment history, or similar personal health information through intake forms, quizzes, surveys, assessments, or personalization features.
We may collect Consumer Health Data from you directly; from your use of the Services; and from service providers that support the Services, including Kajabi (website, course, checkout, contact-management, email, and video-hosting services), Kajabi Payments and Stripe (payment processing), Mailchimp (marketing contact database and email services), ManyChat (social-direct-message lead capture), Plausible (analytics), Google Workspace, customer-support tools, and email platforms. Kajabi's platform may also use service providers or infrastructure providers, including Wistia, RudderStack, Datadog (including session-replay services), Sentry, Cloudflare, and AWS, to support hosting, security, diagnostics, analytics, and platform operations.
We may collect and use Consumer Health Data to provide, operate, maintain, secure, and improve the Services; provide access to courses, videos, articles, webinars, replays, newsletters, and other educational materials; create and manage accounts; process course purchases, transactions, refunds, or other requested services; track course access, progress, completion, and webinar eligibility; respond to communications; screen webinar questions and avoid providing individualized medical advice; understand user interest in health-related educational content; develop and evaluate courses and resources; conduct analytics, quality control, troubleshooting, debugging, and internal research; maintain security; enforce policies; comply with law; and for other purposes disclosed to you with your consent or as otherwise permitted by law.
We will not collect, use, or share additional categories of Consumer Health Data or use Consumer Health Data for additional purposes without providing any disclosure and consent required by applicable law.
We may share the following categories of Consumer Health Data, depending on your interactions with the Services and applicable law:
We may disclose Consumer Health Data, as necessary to provide and support the Services, to the following categories of service providers: website, course-platform, contact-management, email, and video-hosting providers, including Kajabi and Wistia; payment processors, including Kajabi Payments and Stripe; marketing contact-database and email-service providers, including Mailchimp; social-direct-message lead-capture providers, including ManyChat; analytics providers, including Plausible; business email and productivity providers, including Google Workspace; and hosting, infrastructure, security, diagnostics, and platform-support providers, including RudderStack, Datadog, Sentry, Cloudflare, and AWS. We may also disclose Consumer Health Data to professional advisors; government authorities, law enforcement, courts, or other parties when required or permitted by law; parties involved in a business transaction; and other third parties with your consent or as otherwise disclosed at the time of collection.
We do not currently have affiliates with whom we share Consumer Health Data.
ModernGut does not currently operate public forums, user messaging, or public course-comment features on the ModernGut platform. ModernGut may maintain public social media channels where members of the public can comment on posts or interact with ModernGut. Do not submit Consumer Health Data or personal health information in public comments, direct messages, or social media interactions.
Subject to applicable law, you may have the right to confirm whether we collect, share, or sell your Consumer Health Data; access your Consumer Health Data, including information about third parties or affiliates with whom we have shared or sold it; request deletion; withdraw consent for future collection or sharing; and appeal certain decisions.
To exercise these rights, email [email protected] with the subject line "Consumer Health Data Request" and identify the state or jurisdiction from which you are making the request. We may take reasonable steps to verify your identity. We will respond without undue delay and, where Washington law applies, within 45 days of receiving a verifiable request; we may extend that period once by up to 45 additional days where reasonably necessary and will notify you of the reason for the extension. If we deny a request, you may appeal by emailing [email protected] with the subject line "Consumer Health Data Appeal" within a reasonable period after receiving our decision. We will respond to an appeal in writing within 45 days. If we deny your appeal, we will provide information about how to contact the applicable state attorney general. Deleting Consumer Health Data or withdrawing consent may limit our ability to provide certain Services.
ModernGut does not sell Consumer Health Data.
ModernGut does not use Consumer Health Data for targeted advertising, cross-context behavioral advertising, retargeting, affiliate or referral tracking, sponsorship or paid-partnership tracking, or conversion tracking. ModernGut does not deploy advertising, marketing, retargeting, or conversion-tracking pixels or tags on its Services.
If ModernGut later intends to collect, use, or share additional categories of Consumer Health Data, or to use Consumer Health Data for additional purposes, it will provide any disclosure and obtain any consent required by applicable law before doing so.
ModernGut hereby instructs users not to provide personal health information in webinar questions or support requests. Questions containing personal health information should be screened, declined, deleted, or not answered where appropriate.
We use reasonable administrative, technical, and physical safeguards designed to protect Consumer Health Data. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
We retain Consumer Health Data for as long as reasonably necessary to fulfill the purposes described in this Health Data Addendum, provide the Services, comply with legal obligations, resolve disputes, enforce agreements, maintain security, and pursue legitimate business purposes. When Consumer Health Data is no longer needed, we will delete, de-identify, or aggregate it in accordance with applicable law and our retention practices.
We may update this Health Data Addendum from time to time. If we make material changes, we will provide notice as required by applicable law. We will not collect, use, or share additional categories of Consumer Health Data, or use Consumer Health Data for additional purposes, without first providing any disclosure and consent required by applicable law.
If you have questions about this Health Data Addendum or wish to exercise rights regarding Consumer Health Data, please contact us at:
Pico Health Inc. d/b/a ModernGut
1301 N Broadway STE 32039
Los Angeles, CA 90012
Please include "Consumer Health Data Request" in the subject line of your request.
This Health Data Addendum is available through a prominent link on our website homepage and on webpages where we collect personal information. It is also linked from our Privacy Policy.