INNER MATRIX SYSTEMS
Consumer Health Data Privacy Notice
Last Updated: October 8, 2026
1. OVERVIEW
This Consumer Health Data Privacy Notice (“Health Data Privacy Notice”) supplements the Privacy Policy (our privacy policy available at innermatrixsystems.com) and explains Joey Klein LLC’s (dba Inner Matrix Systems) (“IMS”, “we”, “us”, or “our”) collection, use, and disclosure of “consumer health data” as defined under and subject to the applicable laws in the states of Washington and Nevada. This Health Data Privacy Notice applies when you interact with us through the Services, and applies solely to Washington and Nevada residents or individuals whose consumer health data was collected in Washington or Nevada who interact with us in an individual or household capacity. We do not implement geofencing technology around any entity that provides in-person health care services for the purpose of collecting or deriving consumer health data. Capitalized terms not defined in this Health Data Privacy Notice have the meanings given to them in the Privacy Policy.
For more information regarding our data processing practices of non-consumer health data, please refer to our Privacy Policy.
2. CONSUMER HEALTH DATA WE COLLECT
We may collect or receive consumer health data through our Services. Such consumer health data may include:
A. Inferences and Assessment Data. Inferences we draw about your psychological trends, predispositions, behavior, attitudes, abilities, or aptitudes, and information relating to emotional or psychological patterns or wellbeing topics, based on your responses to assessments, surveys, or interactive tools that we offer (for example, our assessment available at YourInnerProfile.com).
B. Communications Reflecting Wellbeing Information. Information contained in your communications with us that may include information relating to your emotional or psychological patterns or wellbeing.
3. SOURCES FROM WHICH WE COLLECT CONSUMER HEALTH DATA
The sources from which we may collect your consumer health data are:
A. Directly from you. When you create an account, register for or use our Services, including completing or interacting with an assessment, survey, or interactive tool that we offer, or sharing information relating to your emotional or psychological patterns or wellbeing in communications with us.
B. Generated by us. When we derive information from your responses to assessments or other interactions with our Services, such as inferences reflecting your psychological trends, predispositions, behavior, attitudes, or wellbeing. We retain ownership of any proprietary analytical methods, algorithms, or aggregated and de-identified insights derived from such data, provided that such insights have been de-identified in accordance with applicable law and cannot reasonably be used to identify you.
4. PURPOSE FOR COLLECTING CONSUMER HEALTH DATA
The purposes for which we collect and use consumer health data include, and we retain consumer health data only for as long as reasonably necessary to fulfill, the following:
A. To provide our Services, including administering assessments, surveys, or interactive tools and providing you with your results.
B. To respond to your inquiries or other communications with us, including support regarding your account, assessments, or use of the Services.
C. To comply with legal obligations, including responses to valid legal process such as subpoenas, court orders, or regulatory demands.
D. To detect or prevent fraud, security incidents, or activity that is illegal under applicable law.
E. In connection with a merger, acquisition, or sale of all or substantially all of our assets, where consumer health data is among the assets evaluated or transferred.
F. For other purposes with your prior consent.
5. WHAT CONSUMER HEALTH DATA WE DISCLOSE; WHOM WE DISCLOSE IT TO
We may disclose consumer health data to third parties, including:
A. Service Providers. We disclose consumer health data to companies and individuals that perform services on our behalf, including cloud hosting and infrastructure providers, customer relationship management and community platforms (e.g., HubSpot and Mighty Networks), payment processing (e.g., Stripe), and other information technology and customer-support tools.
B. Law Enforcement and Legal Proceedings. We may disclose consumer health data to law enforcement agencies, government authorities, or parties involved in legal proceedings when required by valid legal process, such as a subpoena, court order, or enforceable regulatory demand, or where reasonably necessary to establish, exercise, or defend legal claims related to our products or services.
C. Professional Advisors. We may disclose consumer health data to legal counsel, auditors, or other professional advisors where necessary in connection with legal claims, compliance obligations, or the professional services they provide to us.
D. Corporate Transactions. We may disclose consumer health data in connection with corporate transactions (including a merger, acquisition, reorganization, divestiture, financing, or sale of all or substantially all of our assets), including during due diligence or negotiation of any such transaction, where consumer health data is among the assets evaluated or transferred, provided that the recipient is bound by confidentiality obligations and restrictions on the use of such data that are at least as protective as those set forth in this Health Data Privacy Notice or in the recipient’s own privacy policy that provides equivalent or greater protections.
E. With Your Consent. We may disclose consumer health data to other recipients when we have your prior consent to do so.
We may disclose any of the categories of consumer health data identified in this Health Data Privacy Notice to the recipients listed above, limited to what is reasonably related to the applicable purpose. We contractually prohibit such third parties from collecting, using, or disclosing your health data for their own independent purposes unrelated to the services they provide on our behalf.
We do not sell your consumer health data in a form that identifies you. We may aggregate, de-identify, or anonymize consumer health data in compliance with applicable de-identification standards, and use, license, or disclose such aggregated or de-identified data, in each case in a manner that cannot reasonably be used to infer information about, or be linked to, you, and that meets the de-identification standards required by applicable law. We maintain administrative and technical safeguards to prevent re-identification and will not attempt to re-identify any such de-identified data. If we ever intend to sell or share your consumer health data in an identifiable form for purposes other than those described in this Health Data Privacy Notice, we will first obtain your affirmative authorization as required by applicable law.
6. YOUR RIGHTS; HOW TO EXERCISE YOUR RIGHTS
A. Your Rights
If you are a resident of Washington or Nevada, you have the right to:
- confirm whether we are collecting, sharing, or selling your consumer health data, and access such data;
- receive a list of all third parties with whom we have shared or sold your consumer health data, including an active email address or other online mechanism you may use to contact them;
- delete your consumer health data, subject to certain exceptions as permitted by applicable law (such as where retention is required for legal compliance, to complete an ongoing transaction, to detect or prevent fraud, to exercise or defend legal claims, or for other purposes permitted by law);
- withdraw your consent to our collection and sharing of your consumer health data, which we will process promptly and in no event later than fifteen (15) days after receipt of your request. Please note that withdrawing consent may affect our ability to provide you with certain services, and will not affect the lawfulness of any processing conducted prior to your withdrawal.
B. How to Exercise Your Rights
You may submit a request (as provided below) to exercise any of the rights described above. You may also submit a consumer request on behalf of your minor child, or if you are a guardian or hold a similar legal authority, on behalf of the individual subject to such arrangement. The consumer request must:
- Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected consumer health data.
- Describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Once we receive a consumer request, we will take commercially reasonable actions to authenticate the identity of the person exercising the request, including comparing any such identification data provided against the consumer health data requested. We may authenticate a request by asking for the requestor’s name, phone number, and email.
We cannot respond to your request or provide you with consumer health data if we cannot verify your identity to make the request and confirm that the consumer health data relates to you. We also reserve the right to decline any request where we have a reasonable basis to believe the request is fraudulent.
Making a consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable considering the nature of the consumer health data requested.
To exercise the rights described above, please submit a consumer request to us by emailing [email protected].
C. Initial Request Format and Timing
We endeavor to respond to a consumer request within 45 days of its receipt. For Nevada residents submitting access requests, we will respond within 60 days. If we require more time (for a maximum total of 90 days from receipt for Washington residents, or as otherwise permitted by Nevada law), we will notify you within the initial response period that we require more time and will provide a reason for the delay.
We do not charge a fee to process or respond to your consumer request unless the request is manifestly unfounded, excessive, or repetitive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.
If we determine that we will not act on a request, we will provide a response to you that includes the basis of our reasoning. If the reasoning is our inability to authenticate the request, we will explain the efforts we took to authenticate the request and why we were unable to do so.
D. Appeal Response Format and Timing
If we decide that we cannot comply with your initial consumer request, you have the right to appeal our decision. Any appeal should be sent to the place where the initial consumer request was sent. The appeal should clearly indicate that it is an appeal of an initial consumer request and should include the initial consumer request along with our response explaining why we cannot comply with the initial consumer request.
We will review all appeals and provide a response within 45 days of receipt of the appeal, or within such longer period as permitted by applicable law. In our response to your appeal, we will inform you of any action taken or not taken, along with an explanation of the reason in support of the response. If your appeal is unsuccessful, you can contact the appropriate regulatory enforcement authorities to submit a concern or lodge a complaint.
7. NON-DISCRIMINATION
We will not discriminate against you for exercising any of your rights under applicable consumer health data privacy laws. This means we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services solely because you exercised your rights under this Health Data Privacy Notice, except where (a) your consumer health data is necessary or reasonably required for us to provide a particular good or service at a particular level of quality, or (b) a difference in price, rate, level, or quality is reasonably related to the value provided by your consumer health data.
8. MODIFICATION OF THIS HEALTH DATA PRIVACY NOTICE
This Health Data Privacy Notice may be modified from time to time. The date this Health Data Privacy Notice was “last updated” is at the top of this page. If we make a material change to this Health Data Privacy Notice, we will publish the updated notice to the Site and, where required by applicable law, obtain your consent before collecting or using your consumer health data for any new purposes. Any modifications will be effective as of the "last updated" date posted at the top of the revised notice, except that changes that expand our collection, use, or disclosure of your consumer health data, or that otherwise require your consent under applicable law, will not take effect until such consent is obtained. We advise you to frequently check this Health Data Privacy Notice for any changes. We may also provide notice of such changes to you in other ways, at our discretion, such as by displaying a notification banner on the homepage of the Site, through an in-app notification in the App, or by emailing you at the email we have on file for you.