WASHINGTON CONSUMER HEALTH DATA PRIVACY NOTICE

Last updated November 2026

Brello, LLC (d/b/a “Brello Rise”) ("we," "us," or "our") prepared this Washington Consumer Health Data Privacy Notice (“Notice”) to supplement the information already explained in Brello Rise’s Privacy Notice. It applies solely to Washington consumers who interact with us in an individual or household capacity, and covers only Personal Information defined as “consumer health data,” subject to Washington’s My Health My Data Act.


1. Scope of this Notice


Brello Rise is a wellness and streaming service offered to active Brello members as a benefit, and is not sold separately. This Notice describes what consumer health data we collect, how we collect and use it, who we disclose it to and why, and the choices you may have regarding our use or disclosure of your consumer health data. This Notice only applies to consumer health data, which is a subset of personal information that identifies your past, present, or future physical or mental health status.


2. What This Notice Does Not Cover


This Notice does not apply to any Personal Information other than consumer health data that is subject to the Washington My Health My Data Act. Consumer health data does not include information generated by your interactions with us, such as browsing or purchasing, that does not identify your health status. Consumer health data also does not include publicly available information, protected health information subject to HIPAA, or Personal Information that has been deidentified in accordance with applicable law does not qualify as consumer health data. To the extent we process deidentified information, we will maintain and use the information in deidentified form, and will not attempt to reidentify the information, unless otherwise permitted by applicable law.


3. What Categories of Consumer Health Data Do We Collect?


Brello Rise provides general fitness and wellness video content. We do not require you to provide any health intake or screening questionnaire, and we do not collect biometric data, genetic data, reproductive or sexual health information, gender-affirming care information diagnosis or treatment information, medication or prescription information, or precise location data through Brello Rise. To the extent any of the following is linked to you and identifies your health status, it may be treated as consumer health data. Not all categories will be collected or received for every individual.


  • The fitness or wellness classes and video content you choose to view through Brello Rise;

  • Wellness interests, goals, or preferences you voluntarily provide; and

  • Any health-related information you choose to include in a comment you post.

  • Information that we derive or extrapolate from data that is not consumer health data, and then use to associate an individual to the information listed above

4. Categories of Sources From Which We Collect Your Consumer Health Data


To the extent we collect consumer health data, we may obtain it directly from you, through the classes you select, the preferences you provide, or the comments you post; automatically from your use of Brello Rise and your device, through the limited service- provider analytics used to deliver video; and from Brello as your membership provider. We may obtain consumer health data from different sources, including information:


  • Provided directly by you or a member of your household via questionnaire responses or other communications with us

  • Collected from a device associated with you or your household

  • Collected from another company within our family of companies

  • Collected from another solution or asset

5. What Are the Purposes for Collecting Your Consumer Health Data?


We use any consumer health data only to provide the Brello Rise content and features you request, such as streaming the classes you select and remembering your preferences; to maintain the security and integrity of the Service and to detect and prevent fraud; to comply with our legal obligations; and for any other purpose with your consent. We do not use consumer health data for advertising or to create profiles for targeted advertising. We may collect and use consumer health data as set out below:


  • To fulfill our legal functions or obligations, such as maintaining and auditing compliance.

  • Helping to ensure security and integrity of our systems, including detection and prevention of security incidents.

  • To detect or prevent harmful behavior such as identity theft, fraud, harassment, or deceptive activities, or activities that are illegal under applicable law.

  • For other purposes with your consent.

6. What Categories of Consumer Health Data Do We Share?


We may share each of the categories of consumer health data described above with your consent to complete transactions or provide products or services you have requested, and for the purposes described in this Notice.


7. Who Do We Share Your Consumer Health Data With and Why?


We may share consumer health data with business partners, including as those providing advertising and technology services, governmental agencies and legal bodies, and purchasers of or successors to our business or assets. We may also share consumer health data within our family of companies, including among these affiliates:


  • AP MAX, Inc., d/b/a Southend Pharmacy

  • HelloWellness

  • Allia Health Group

  • Brello, LLC

8. How Can You Exercise Your Washington Consumer Health Data Rights?


If you are a resident of Washington, you may have the right to (1) request access to your consumer health data; (2) confirm whether we have disclosed or sold your consumer health data; (3) delete your consumer health data; or (4) withdraw your consent or authorization relating to such data. You can make these requests by writing to us at info@brellohealh.com


9. How To Submit an Appeal


You may appeal our decision concerning your request for consumer health data by going to contacting us directly at:


Brello, LLC

Attn.: Compliance

415 Westheimer RD. #103

Houston, TX 77006

info@brellohealth.com