Legal
Research Participation
Last updated: May 25, 2026
This page contains the RWE Contributor Privacy Notice, RWE Contributor Authorization & Informed Consent, Curator Privacy Notice, and Curator Authorization & Informed Consent.
1. Purpose and Scope of This Notice
This RWE Contributor Privacy Notice (the “Notice”) explains how Enel Health Inc. (“Enel Health,” “we,” “us,” or “our”) collects, uses, stores, protects, and shares information from individuals who contribute data to Enel Health’s Real-World Evidence (“RWE”) Program.
This Notice applies to information that forms part of an RWE Contributor’s profile, health profile, wellness record, daily check-ins, AI-agent interactions, community contributions, uploaded documents, account activity, or related contribution to Enel Health services.
This Notice is separate from, and should be read together with:
- the Enel Health Terms of Use and Founding Member Program Terms;
- the Enel Health Consumer Health Data Privacy Policy (which is the standalone notice required by the Washington My Health My Data Act and which supplements this Notice with respect to Consumer Health Data as defined in that policy);
- the Enel Health Curator Privacy Notice (which applies to Curators who provide self-identified demographic information and interests in order to receive Matched Insights);
- the Enel Health Algorithmic Matching & Automated Decision-Making Disclosure (which describes how the Matching Algorithm uses de-identified contributor data to generate Matched Insights for Curators);
- the Enel Health Website Privacy & Cookie Notice (which applies to general website browsing, marketing pages, newsletters, contact forms, cookies, and analytics);
- the Enel Health State Privacy Rights Notice (which describes state-specific consumer rights); and
- the RWE Contributor Authorization & Informed Consent applicable to you (which captures the specific authorizations you have given).
If there is a conflict between this Notice and any of the foregoing with respect to a specific topic, the more specific document controls for that topic. In all events, where this Notice provides greater protection to you than another Enel Health document, this Notice controls.
2. Our Data Commitment
Enel Health is designed to help individuals better organize and understand their wellness data, and — at their election — contribute that data to a real-world evidence dataset that may advance scientific understanding and public health.
As a baseline commitment, regardless of any other provision of any Enel Health document:
- Enel Health does not sell Consumer Health Data.
- Enel Health does not use Consumer Health Data for cross-context behavioral advertising or third-party targeted advertising.
- Enel Health does not disclose Consumer Health Data to third-party model providers for use in training those providers’ foundation models.
- Where Enel Health uses third-party model providers to deliver AI Features, Enel Health configures its agreements to disable training on Enel Health customer data where the provider offers that option, and to require contractual deletion of Enel Health prompts and outputs from the provider’s systems.
- Enel Health applies the highest-protection state-law requirements applicable to your residence and to the location where data was collected, rather than treating them as a floor for compliance.
3. Three Sources of RWE Contributor Data
Enel Health processes RWE Contributor data from three general sources:
- data collected directly from you;
- data collected from connected services, third parties, or integrations you authorize; and
- data generated by Enel Health based on your use of the service (“Derived Data”).
4. Data Collected Directly From You
Depending on the protocols and features you use, Enel Health may collect:
- account information: name, email, phone number, login credentials, role, organization, and communication preferences;
- demographic information: age, sex assigned at birth, gender identity (optional), location, language, and household characteristics;
- health, wellness, and lifestyle information: goals, symptoms, medical history you choose to share, medications and supplements, allergies, diet, exercise, sleep, stress, mental wellbeing, family history, and lifestyle factors;
- eligibility and contraindication screening responses;
- daily check-in responses: mood, energy, sleep quality, hunger, cravings, focus, stress, weight, symptoms, notes, and any media you upload;
- protocol selection and adherence data;
- survey and questionnaire responses;
- lab, diagnostic, genomic, imaging, wearable, or biomarker information you upload or authorize us to receive;
- notes, journal entries, files, images, PDFs, reports, documents, or other materials you provide;
- messages, prompts, chat interactions, AI-agent conversations, saved outputs, and account activity;
- community posts you author;
- communications with Enel Health, including support requests, onboarding interactions, feedback, and testimonials;
- payment, subscription, and membership information, where applicable;
- security and compliance information, such as authentication logs and access records; and
- any other information you choose to submit.
You should only submit information that you are comfortable providing and that you have the legal right to provide. You should not submit another person’s health, wellness, genetic, biometric, financial, or other sensitive information unless you have the legal right to do so.
5. Data Collected From Connected Services or Third Parties
With your authorization, Enel Health may collect information from third-party sources, including:
- laboratories and diagnostic providers;
- genomic testing providers (subject to the additional consent requirements of any applicable state genetic-privacy law);
- wearable device platforms;
- fitness, nutrition, sleep, or wellness applications;
- healthcare providers;
- pharmacies;
- electronic health record systems;
- insurance, benefits, or employer-sponsored programs, where applicable;
- product partners, supplement providers, marketplaces, or affiliated service providers;
- public databases, research datasets, and scientific sources; and
- other services that you connect to Enel Health.
Enel Health collects this information only where permitted by law, authorized by you, necessary to provide the service, or otherwise disclosed in this Notice or related consent materials. Third-party services have their own privacy policies and terms. Enel Health does not control those third-party services.
6. Derived Data Generated by Enel Health
Enel Health may generate additional data based on information you provide or authorize, including:
- wellness summaries and trend analysis;
- lifestyle insights;
- risk indicators (clearly labeled as informational, not diagnostic);
- AI-generated summaries;
- research classifications and cohort groupings;
- de-identified or aggregated analytics;
- derived biomarkers or calculated metrics;
- internal quality, safety, and performance metrics;
- recommendation scores or relevance rankings;
- inferences about your preferences (used only for personalizing the Service);
- structured information extracted from uploaded files; and
- system-generated account, usage, and security metadata.
Derived Data is intended for informational, educational, research, wellness, organizational, or decision-support purposes. Enel Health does not replace licensed medical care, and Derived Data is not a diagnosis.
7. How Enel Health Uses RWE Contributor Data
Enel Health uses RWE Contributor data only for the purposes described in this Notice or in the specific RWE Contributor Authorization & Informed Consent applicable to you. Categories of use include:
- providing, personalizing, operating, maintaining, and improving Enel Health services;
- creating and maintaining your account and contributor profile;
- reviewing and approving Founding Member registrations;
- generating wellness insights, summaries, recommendations, dashboards, and reports;
- supporting AI Features (only with your separate authorization for AI processing);
- helping you organize and understand your information;
- enabling secure sharing with providers, coaches, or recipients at your direction;
- responding to support requests;
- conducting internal analytics, quality control, and safety reviews;
- developing, testing, evaluating, and improving features, prompts, workflows, and systems (using de-identified or aggregated data wherever feasible);
- supporting the Enel Health RWE Program, including generation of de-identified datasets for internal research, scientific publication, and (with your separate authorization) sharing with qualified third-party researchers, sponsors, or product partners;
- generating de-identified, aggregated, statistical, or pattern-based Matched Insights that may be displayed to Curators (other users who have provided their own self-identified demographic profile and interests in order to see how RWE Contributors with similar profiles have engaged with wellness protocols). Contributor data is never disclosed to Curators in identifiable form, and Matched Insights are subject to minimum-cohort-size requirements, small-cell suppression, and contractual and technical prohibitions on re-identification, as further described in the Algorithmic Matching & Automated Decision-Making Disclosure;
- creating aggregated, de-identified, or anonymized information;
- detecting fraud, abuse, security threats, unauthorized access, or misuse;
- complying with legal, regulatory, contractual, tax, accounting, and compliance obligations, including the FTC Health Breach Notification Rule;
- enforcing the Terms of Use and contributor agreements;
- communicating with you about services, programs, updates, security, privacy, billing, and account matters; and
- carrying out other purposes with your consent.
8. AI and Automated Processing
Enel Health may use artificial intelligence, machine learning, language models, retrieval systems, recommendation engines, classification systems, and automated analytics to help process RWE Contributor data.
AI Features may be used to:
- summarize records;
- organize documents;
- identify patterns;
- extract structured information;
- generate wellness insights;
- support recommendations;
- compare information against public research or product data;
- assist internal review workflows;
- improve system performance and user experience;
- support research and product development; and
- detect misuse, fraud, or security risk.
AI outputs may be incomplete, inaccurate, outdated, biased, or inappropriate for your circumstances. AI outputs are not medical advice, diagnosis, or treatment, and are not a substitute for professional judgment.
Enel Health does not use AI Features as the sole basis for any decision producing legal or similarly significant effects on you. Where applicable state law (including the California Consumer Privacy Act ADMT regulations effective January 1, 2026, and the Colorado AI Act) requires pre-use notice, opt-out, or risk assessment before using AI for significant decisions about you, Enel Health complies with those requirements and describes them in the State Privacy Rights Notice.
Enel Health safeguards for AI Features include access controls, logging, human review where appropriate, restricted data environments, model evaluation, data minimization, vendor review, and contractual controls (including contractual prohibitions on training on Enel Health customer data where the provider offers that option).
9. De-Identification, Aggregation, and the RWE Program
Before Enel Health uses RWE Contributor data for any purpose other than providing the service you requested, Enel Health applies one of the following standards:
- the HIPAA Safe Harbor de-identification method (45 C.F.R. § 164.514(b)(2)) — removing the eighteen specified identifiers and ensuring no actual knowledge of remaining re-identification risk;
- the HIPAA Expert Determination method (45 C.F.R. § 164.514(b)(1)) — based on a written determination by a qualified statistician or privacy expert that the risk of re-identification is very small; or
- a documented de-identification standard at least as protective as the foregoing.
Enel Health imposes contractual prohibitions on re-identification on every recipient of de-identified data, and reviews aggregated outputs for small-cell risk before release.
De-identified or aggregated data may be used for:
- internal research, analytics, quality, safety, and product improvement;
- scientific publication and presentation;
- public-good health insights;
- research and discovery partnerships with academic institutions;
- commercial partnerships with qualified product or research partners (subject to your authorization);
- statistical reports;
- regulatory, safety, or scientific analysis;
- improving recommendations and data quality; and
- market, product, scientific, or research insights that do not identify you.
When Enel Health releases aggregate datasets, Enel Health applies privacy-preserving controls such as removal of direct identifiers, pseudonymization, aggregation, minimum cohort sizes, k-anonymity thresholds, suppression of small cells, re-identification risk assessment, contractual restrictions against re-identification, access controls, audit logging, and review of intended use.
10. Who Enel Health Shares Data With
Enel Health may share data with the limited categories of recipients described below. The Consumer Health Data Privacy Policy lists specific affiliates and categories of third parties for Consumer Health Data.
10.1 Service Providers
Enel Health shares data with vendors and service providers that help operate Enel Health, including cloud-hosting providers, database providers, security providers, analytics providers, payment processors, customer-support tools, communication systems, AI model providers, software-infrastructure providers, laboratories, and integration providers. Service providers are bound by written data-processing agreements that restrict use to authorized purposes.
10.2 Healthcare, Wellness, or Coaching Providers
At your direction or as part of services you select, Enel Health may share information with clinicians, coaches, nutritionists, pharmacists, care teams, or other health and wellness professionals you designate.
10.3 Research Collaborators
Where permitted by your authorization and applicable law, Enel Health may share de-identified, pseudonymized, aggregated, or limited contributor data with approved researchers, institutions, commercial partners, or public-good health initiatives. Recipients must agree not to attempt to identify contributors, contact contributors without authorization, sell contributor-level data, or use data outside approved purposes.
10.4 Product and Business Partners
Enel Health may work with supplement companies, diagnostic companies, labs, wellness providers, marketplaces, digital health companies, research organizations, universities, and technology partners. Partner access is limited to de-identified, aggregated, or specifically authorized data.
10.5 Legal, Compliance, and Safety Recipients
Enel Health may disclose data when necessary to comply with law, enforce agreements, respond to lawful requests, protect rights and safety, investigate fraud or abuse, or complete a merger, acquisition, financing, restructuring, or sale of assets. Enel Health will provide notice to affected RWE Contributors in advance of any business transaction involving their personal information where required by applicable law.
11. No Sale, No Targeted Advertising, No Foundation-Model Training
Enel Health does not sell Consumer Health Data, does not use Consumer Health Data for cross-context behavioral advertising or third-party targeted advertising, and does not provide identifiable Consumer Health Data to third-party model providers for use in training those providers’ foundation models.
Enel Health will not change these commitments without (a) updating this Notice and the Consumer Health Data Privacy Policy in advance, (b) providing clear and conspicuous notice to affected RWE Contributors, (c) obtaining a new affirmative opt-in for any sale or sharing of Consumer Health Data, and (d) complying with all applicable state-law authorization, notice, and waiting-period requirements.
12. Protecting Your Data
Enel Health uses administrative, technical, and organizational safeguards designed to protect RWE Contributor data. Safeguards include:
- encryption in transit using TLS 1.2 or higher;
- encryption at rest for databases containing Consumer Health Data;
- role-based access controls and least-privilege provisioning;
- two-factor authentication for administrative access;
- audit logging, monitoring, and alerting;
- secure cloud infrastructure with documented configuration baselines;
- vendor security review and written data-processing agreements;
- confidentiality obligations for all personnel and contractors;
- data minimization and de-identification controls;
- re-identification risk review;
- incident-response procedures with documented timelines;
- backup and recovery controls; and
- periodic third-party security assessment.
Enel Health’s safeguards are designed to meet or exceed the standards described in HIPAA’s Security Rule (45 C.F.R. Part 164, Subpart C) on an as-applicable basis, the FTC Safeguards Rule, the NIST Cybersecurity Framework, and applicable state safeguards laws. Enel Health is not a HIPAA-covered entity, but where Enel Health acts as a business associate or contractor of a covered entity, Enel Health complies with the HIPAA Rules as applicable.
No system is completely secure. Enel Health cannot guarantee that unauthorized access, loss, misuse, or breach will never occur.
13. Security Incident and Breach Notice
If a security incident affects unsecured PHR Identifiable Health Information, Enel Health complies with the FTC Health Breach Notification Rule, 16 C.F.R. Part 318, including notification to affected individuals, the FTC, and (where 500 or more individuals in a state or jurisdiction are affected) the media, in each case within sixty (60) days of discovery and, for incidents affecting 500 or more individuals, contemporaneously with individual notice.
Enel Health also complies with applicable state breach-notification laws, including the California Customer Records Act (Cal. Civ. Code § 1798.82), the Washington Data Breach Notification Law, and analogous laws in other states. State notification timelines may be shorter than the federal HBNR timeline; Enel Health applies the shortest applicable timeline.
14. Data Retention
Default retention periods are:
- Account information: for the life of the account and twenty-four (24) months after account closure, then deleted or de-identified;
- Daily check-in data (identifiable): for the life of the account and thirty-six (36) months after account closure, then deleted or de-identified;
- AI agent chat history: for the life of the account and twelve (12) months after account closure;
- Community posts: for the life of the account; archived or anonymized on account closure;
- De-identified data: retained as part of the RWE Program without time limit (re-identification prohibited);
- Security, audit, and compliance logs: minimum of twenty-four (24) months;
- Billing and tax records: minimum of seven (7) years where required by law.
Some data may be retained longer where required or permitted by law, necessary for security or compliance, already de-identified or aggregated, already used in completed research or reports, or contained in backups subject to a routine backup retention schedule.
15. International Data Transfers
Enel Health is based in the United States, with primary operations in California. Enel Health may use service providers, infrastructure providers, researchers, vendors, or partners located in other jurisdictions. This means your data may be processed outside your state or country.
Where required, Enel Health uses appropriate safeguards for international transfers, which may include contractual protections, standard contractual clauses, data-processing agreements, transfer impact assessments, and vendor review.
16. Contributor Rights
Depending on your location and applicable law, you may have rights to:
- access your personal data;
- correct inaccurate data;
- request deletion;
- request export or portability;
- restrict certain processing;
- object to certain processing;
- withdraw consent where processing is based on consent;
- opt out of certain communications;
- appeal certain privacy decisions;
- limit certain uses of sensitive personal information;
- opt out of sale or sharing where applicable;
- opt out of profiling or automated decision-making where applicable; and
- file a complaint with a privacy regulator.
Detailed, state-by-state rights are described in the State Privacy Rights Notice. To submit a privacy request, contact info@enelhealth.com or use the dedicated request form available at https://enelhealth.com/privacy-requests.
Enel Health will verify your identity before fulfilling a request. Some requests may be limited by legal, security, research, compliance, contractual, or technical requirements. Enel Health will respond within forty-five (45) calendar days of receipt of a verifiable request, with one additional forty-five (45) day extension where reasonably necessary and with notice to you, unless a shorter timeline applies under state law.
Where required by law, you may use an authorized agent to submit privacy requests, subject to verification of the agent’s authority and your identity. If Enel Health denies your request, you may appeal by contacting info@enelhealth.com and stating that you are appealing. Enel Health will respond to your appeal within sixty (60) days.
17. Withdrawal From the RWE Program
You may withdraw from the RWE Program at any time through your account settings or by contacting info@enelhealth.com. Withdrawal stops future collection and future use of identifiable data, but does not require Enel Health to retrieve or recall de-identified or aggregated data that has already been included in completed analyses, publications, regulatory filings, or external datasets, and does not apply to data Enel Health is required by law, contract with a regulator, or court order to retain.
18. Children and Minors
Enel Health is not intended for, and does not knowingly collect personal information from, anyone under eighteen (18). Do not submit information about a minor through Enel Health. If you believe a minor has provided personal information to Enel Health, contact info@enelhealth.com and Enel Health will delete that information.
19. Changes to This Notice
Enel Health may update this Notice from time to time. Updates may reflect changes in law, regulation, technology, research practices, AI features, security standards, services, vendor relationships, or business operations.
For material changes, Enel Health will use reasonable efforts to provide notice through the Service, email, account notification, website posting, or another reasonable method. Where applicable law requires affirmative consent before applying a material change to the processing of Consumer Health Data, Enel Health will obtain that consent before applying the change to your information. Unless otherwise stated, updates become effective when posted or when notice is provided.
20. Contact Us
Enel Health Inc.
Privacy Office
5639 La Jolla Blvd
La Jolla, CA 92037
info@enelhealth.com
https://enelhealth.com
RWE Contributor Authorization & Informed Consent
Last updated: May 25, 2026
1. Why You Are Reading This Document
Enel Health is asking your permission to collect data about your wellness experience and to use that data — under specific controls — to generate real-world evidence (“RWE”) that may help advance scientific understanding of self-directed wellness protocols. This document explains what Enel Health is asking for, what you get to decide, what happens to your data, and what your rights are.
This document is not a contract. It is your authorization. You can give some authorizations and decline others. You can change your mind later for any authorization that is not strictly necessary to provide the service you are using.
If you do not want to authorize anything beyond what is strictly necessary to use Enel Health, you may simply complete Authorization 1 (Required Account) and skip the rest. You will still be able to use Enel Health, but you will not be a contributor to the RWE Program.
2. Definitions
“Consumer Health Data” means data that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status, including self-reported observations, symptoms, weight, mood, energy, sleep, hunger, cravings, focus, stress, and inferences derived from these.
“De-Identified Data” means data that has been processed using the HIPAA Safe Harbor method (45 C.F.R. § 164.514(b)(2)), the HIPAA Expert Determination method (45 C.F.R. § 164.514(b)(1)), or a documented standard at least as protective as the foregoing, such that the data cannot reasonably be used to identify you.
“Real-World Evidence” or “RWE” means clinical or observational evidence about the use, benefits, or risks of wellness or medical products and protocols, derived from analysis of data collected outside the controlled setting of a randomized clinical trial. “Real-World Data” or “RWD” means the underlying data from which RWE is derived.
3. What Enel Health Wants to Collect and Use
Depending on the protocols you select and the integrations you connect, Enel Health may collect:
- your self-reported daily check-ins (mood, energy, sleep quality, hunger, cravings, focus, stress, weight, symptoms, free-text notes);
- your selected protocol and adherence information;
- your responses to eligibility and contraindication screening questions;
- your interactions with Enel Health AI agents (chat history, prompts, outputs);
- uploads you choose to provide (documents, images, lab reports);
- community content you author;
- data from wearables, fitness, nutrition, or sleep applications you connect;
- with separate authorization, data from laboratories, diagnostic providers, pharmacies, or electronic health records;
- inferences and derived metrics generated from the foregoing.
4. The Risks of Contributing Data
Enel Health uses strong safeguards to protect your data, but no security system is perfect. Risks of contributing data include:
- risk of an unauthorized data breach despite Enel Health’s safeguards;
- risk of inadvertent re-identification of de-identified data, particularly if you contribute unusual or unique combinations of data;
- risk that information you share through AI agents or community spaces could be exposed in unforeseen ways;
- risk that data used for RWE analyses or scientific publications may produce findings that affect public understanding of wellness protocols in ways you did not anticipate; and
- risk that you may experience emotional, psychological, or social discomfort from completing certain check-in questions or reading certain AI outputs.
Enel Health is not your healthcare provider, and the information available to you through Enel Health, including AI outputs and the daily check-in tool, is not medical advice, diagnosis, or treatment. You must consult a licensed clinician for any medical decision. If you are considering an extended fast (24 hours or longer) or any restricted-intake protocol, discuss it with your physician first.
5. The Benefits of Contributing Data
There are no guaranteed benefits to you from contributing data to the RWE Program. Possible benefits include:
- personalized insights and trend visualizations of your own data;
- supportive AI-generated education and motivation;
- a sense of contribution to public-good wellness research;
- opportunities (in the future) to participate in further studies or product features.
6. Authorizations — Read Each Carefully
Authorization 1 — Required for Any Use of Enel Health
I am at least 18 years old. I have read the Enel Health Terms of Use and Founding Member Program Terms, the RWE Contributor Privacy Notice, the Consumer Health Data Privacy Policy, the Website Privacy & Cookie Notice, and the State Privacy Rights Notice. I agree to those documents, and I authorize Enel Health to collect and process my account, demographic, and usage information as strictly necessary to provide me the service I have requested.
Status: REQUIRED. Without this authorization, you cannot use Enel Health.
Authorization 2 — Health-Safety Screening (Required if You Select a Restricted-Intake Protocol)
I have read the Health-Safety Eligibility and Contraindications section of the Terms of Use. I represent and warrant that, to the best of my knowledge, I do not have a contraindication that would make caloric restriction, extended fasting, or restricted-intake protocols dangerous for me; or, if I do have a contraindication, I have obtained written clearance from a licensed physician familiar with my medical history before beginning the protocol. I understand that providing false information to bypass eligibility gates is a material breach of the Terms and an assumption of risk by me.
Status: REQUIRED if you select any extended fasting protocol (24 hours or longer) or any other protocol that Enel Health designates as restricted. You may use Enel Health without selecting such a protocol.
Authorization 3 — RWE Program Participation (De-Identified Data)
I authorize Enel Health to use my data, in de-identified form (using the HIPAA Safe Harbor method, the HIPAA Expert Determination method, or a documented standard at least as protective), as part of the Enel Health Real-World Evidence Program. De-identified data may be used by Enel Health and by qualified third parties under written agreements that prohibit re-identification, for the following purposes: internal research, analytics, quality and safety improvement, scientific publication, public-good health insights, generation of de-identified Matched Insights that may be displayed to Curators (other users who provide self-identified demographic information and interests to see how contributors with similar profiles have engaged with wellness protocols), and (where I separately authorize) regulatory submissions.
Matched Insights are presented in de-identified, aggregated, or statistical form, subject to minimum-cohort-size requirements, small-cell suppression, and contractual and technical prohibitions on re-identification. I will not be identified to Curators. Further detail about how Matched Insights are generated is in the Algorithmic Matching & Automated Decision-Making Disclosure.
Status: OPTIONAL. Default: UNCHECKED. You can use Enel Health without this authorization. Withdrawal: you may withdraw at any time; withdrawal stops future contributions but does not retrieve de-identified data already included in completed analyses, publications, external datasets, or Matched Insights previously generated.
Authorization 4 — Processing of Identifiable Consumer Health Data Beyond Strictly Necessary Use
I authorize Enel Health to process my identifiable Consumer Health Data within Enel Health for purposes beyond what is strictly necessary to provide the service I have requested — including for personalization, generation of identified wellness insights, internal product development, and operation of identified-data AI Features I have separately authorized. I understand that absent this authorization, Enel Health will limit its processing of my Consumer Health Data to what is strictly necessary to provide the service I have requested.
Status: OPTIONAL. Default: UNCHECKED. Withdrawal: you may withdraw at any time through account settings or by contacting info@enelhealth.com.
Authorization 5 — Sharing Identifiable Consumer Health Data With Qualified Researchers or Sponsors
I authorize Enel Health to share my identifiable Consumer Health Data with qualified third-party researchers, academic institutions, sponsors, or product partners, under written agreements that (a) prohibit re-identification (where Enel Health provides de-identified data only), (b) restrict use to disclosed purposes, (c) flow down equivalent privacy obligations, and (d) require return or destruction at the end of the engagement.
Status: OPTIONAL. Default: UNCHECKED. Withdrawal: you may withdraw at any time; withdrawal stops future sharing but does not retrieve data already shared, although Enel Health will notify recipients of your withdrawal and, where contractually possible, require recipients to delete identifiable data.
Authorization 6 — AI Features Using Identifiable Consumer Health Data
I authorize Enel Health to use my identifiable Consumer Health Data in connection with AI Features (including chat with Enel Health AI agents, AI-generated summaries, AI-generated recommendations, retrieval, and evaluation of AI outputs). I understand that some processing by AI Features uses third-party model providers; Enel Health requires those providers to delete prompts and outputs after processing and prohibits training on Enel Health customer data where the provider offers that option.
Status: OPTIONAL. Default: UNCHECKED. If you do not give this authorization, you can still use Enel Health, but AI Features that involve identifiable Consumer Health Data will be unavailable to you, and AI Features may be limited to general (non-personalized) responses.
Authorization 7 — Future Sale of Identifiable Consumer Health Data
I authorize Enel Health, if and only if it elects in the future to sell identifiable Consumer Health Data, to sell my identifiable Consumer Health Data, subject to (a) Enel Health providing me clear advance notice of any proposed sale, (b) Enel Health obtaining any further consent required by applicable state law (including any signature requirements under the Washington My Health My Data Act), and (c) my right to withdraw this authorization at any time before any sale.
Status: OPTIONAL. Default: UNCHECKED. Even if you give this authorization, Enel Health is not currently selling Consumer Health Data, and you will receive a separate notice before any sale begins. Selecting this box is not required to use Enel Health.
Authorization 8 — Marketing Communications
I would like to receive marketing communications from Enel Health, including newsletters, product announcements, and invitations to future programs.
Status: OPTIONAL. Default: UNCHECKED. You may unsubscribe at any time using the unsubscribe link in any marketing email or by contacting info@enelhealth.com. Even if you do not authorize marketing, Enel Health will still send transactional and account-related communications.
Authorization 9 — Contact for Future Research Opportunities
I would like to be contacted about future Enel Health research programs, longer-form studies, or opportunities to participate in IRB-supervised protocols that may apply to me based on my contributor profile and preferences. Being contacted is not a commitment to participate; any future protocol will be presented with its own consent.
Status: OPTIONAL. Default: UNCHECKED.
7. Enel Health’s Commitments to You
Enel Health makes the following commitments to every RWE Contributor:
- No identification of contributors to Curators. Matched Insights presented to Curators are de-identified, aggregated, or statistical only. Contributor identifying information is never disclosed to a Curator.
- Minimum cohort sizes. Enel Health does not generate or display a Matched Insight unless the underlying contributor cohort meets a minimum-size threshold designed to reduce re-identification risk.
- Small-cell suppression. Statistical outputs that would otherwise convey individually identifying information are suppressed before display.
- No discrimination. Enel Health does not use race, ethnicity, gender, age, religion, sexual orientation, disability, or any other protected characteristic to deny, limit, or differentiate access to any Enel Health feature, protocol, product, service, or content. Demographic attributes are used only as similarity dimensions in the Matching Algorithm and only as authorized by the relevant user.
- No sale or targeted advertising of Consumer Health Data. Enel Health does not sell Consumer Health Data and does not use Consumer Health Data for cross-context behavioral advertising or third-party targeted advertising.
- No foundation-model training on identifiable Consumer Health Data. Where Enel Health uses third-party model providers, Enel Health configures those agreements to disable training on Enel Health customer data and to require deletion of prompts and outputs from provider systems.
- Contractual prohibition on re-identification. Every recipient of de-identified contributor data is contractually prohibited from re-identification.
8. Your Rights as a Contributor
You always have the right to:
- withdraw any optional authorization at any time, prospectively, through account settings or by contacting info@enelhealth.com;
- access the data Enel Health holds about you;
- correct inaccurate data;
- request deletion of identifiable data (subject to limited exceptions described in the RWE Contributor Privacy Notice and the Consumer Health Data Privacy Policy);
- export a portable copy of your data;
- appeal Enel Health’s response to your request;
- contact your state attorney general or applicable privacy regulator if you believe Enel Health has violated your rights;
- ask questions about the RWE Program at any time.
Withdrawal of an optional authorization does not affect the lawfulness of processing carried out before withdrawal. Withdrawal does not require Enel Health to retrieve de-identified or aggregated data already included in completed analyses, publications, or external datasets, or data Enel Health is required by law or court order to retain.
9. What Happens If You Decline
If you decline any optional authorization, Enel Health will not penalize you with reduced service quality, higher prices, or restricted access beyond what is necessary to honor your decision. Specifically:
- Declining Authorization 3 (RWE Program): you will continue to have full access to the Enel Health service, but your data will not be used for RWE purposes.
- Declining Authorization 4 (Identifiable Processing): Enel Health will limit processing of your Consumer Health Data to what is strictly necessary to provide the service you have requested.
- Declining Authorization 5 (Sharing): your identifiable data will not be shared with third-party researchers or sponsors.
- Declining Authorization 6 (AI Identifiable): AI Features will operate in general / non-personalized mode.
- Declining Authorization 7 (Future Sale): your data will not be sold even if Enel Health later elects to sell other contributors’ data.
- Declining Authorization 8 (Marketing): you will not receive marketing communications.
- Declining Authorization 9 (Future Research Contact): you will not be contacted about future research opportunities.
10. Re-Consent for Material Changes
If Enel Health makes a material change to how it uses or shares your Consumer Health Data — for example, by adding a new category of recipient, a new purpose not described above, or a new sale category — Enel Health will provide clear notice and obtain a new authorization from you before applying the change to data you have already contributed. Continued use of Enel Health without affirmative re-consent will not constitute consent to material changes affecting Consumer Health Data.
11. Questions
You may ask questions about this Authorization, the RWE Program, or your rights at any time. Contact:
Enel Health Inc.
Privacy Office
5639 La Jolla Blvd
La Jolla, CA 92037
info@enelhealth.com
https://enelhealth.com
12. Acknowledgment and Signature Block
Contributor name: ____________________________________________
Date of birth: __________________
Signature: ____________________________________________
Date signed: __________________
Email address: ____________________________________________
Authorizations selected (please check):
- [ ] Authorization 1 — Required Account (must be checked to proceed)
- [ ] Authorization 2 — Health-Safety Screening (required for restricted-intake protocols)
- [ ] Authorization 3 — RWE Program Participation (De-Identified Data)
- [ ] Authorization 4 — Processing of Identifiable Consumer Health Data
- [ ] Authorization 5 — Sharing Identifiable Consumer Health Data With Researchers/Sponsors
- [ ] Authorization 6 — AI Features Using Identifiable Consumer Health Data
- [ ] Authorization 7 — Future Sale of Identifiable Consumer Health Data
- [ ] Authorization 8 — Marketing Communications
- [ ] Authorization 9 — Contact for Future Research Opportunities
Curator Privacy Notice
Last updated: May 25, 2026
1. Purpose and Scope of This Notice
This Curator Privacy Notice (the “Notice”) explains how Enel Health Inc. (“Enel Health,” “we,” “us,” or “our”) collects, uses, stores, protects, and shares information from individuals who use Enel Health in the Curator role — that is, individuals who provide self-identified demographic information and interests in order to receive Matched Insights drawn from the de-identified profiles of RWE Contributors with similar profiles.
This Notice is separate from, and should be read together with:
- the Enel Health Terms of Use and Founding Member Program Terms;
- the Enel Health Consumer Health Data Privacy Policy (which is the standalone notice required by the Washington My Health My Data Act);
- the Enel Health Algorithmic Matching & Automated Decision-Making Disclosure (which describes the Matching Algorithm and is the pre-use notice required by CCPA ADMT regulations);
- the Enel Health RWE Contributor Privacy Notice (which applies if you also choose to be an RWE Contributor);
- the Enel Health Website Privacy & Cookie Notice;
- the Enel Health State Privacy Rights Notice; and
- the Curator Authorization & Informed Consent applicable to you.
Where another Enel Health document is more specific, that document controls for the topic. Where this Notice provides greater protection to you than another Enel Health document, this Notice controls.
2. Our Data Commitment
As a baseline commitment, regardless of any other provision of any Enel Health document:
- Enel Health does not sell Consumer Health Data, including Curator demographic information and interests.
- Enel Health does not use Consumer Health Data for cross-context behavioral advertising or third-party targeted advertising.
- Enel Health does not disclose Consumer Health Data to third-party model providers for use in training those providers’ foundation models.
- Enel Health does not use the Matching Algorithm to deny, limit, or differentiate access to any feature, protocol, product, service, or content on the basis of race, ethnicity, gender, age, religion, sexual orientation, disability, or any other protected characteristic.
- Enel Health does not use the Matching Algorithm in employment, housing, credit, insurance, public-accommodation, or other contexts protected by federal or state civil-rights laws.
3. What Enel Health Collects From Curators
Depending on the authorizations you give and your use of Enel Health, we collect:
- Account information: name, email address, login credentials, communication preferences, and security and authentication information.
- Self-identified gender (required for the Matching Algorithm; you may select “prefer not to say”).
- Self-identified age or year of birth (required for the Matching Algorithm).
- Self-identified race and ethnicity (Sensitive Personal Information; collected only with your separate affirmative opt-in).
- Other self-identified demographic attributes you choose to provide.
- Stated wellness interests, conditions you are exploring, protocols or products you are considering.
- Your interactions with Matched Insights (which insights you view, save, or follow).
- Communications with Enel Health, including support requests and feedback.
- Inferences derived from the foregoing that may identify physical or mental health status or health-related preferences.
- Security, audit, and compliance information.
Sensitive Personal Information. Race and ethnicity are Sensitive Personal Information under the California Consumer Privacy Act, and Sensitive Data under most other state privacy laws. We collect this information only where you have affirmatively opted in, only as similarity dimensions in the Matching Algorithm, and only to support the editorial transparency of Matched Insights. You may decline, you may select “prefer not to say,” and you may withdraw or update this information at any time.
Genetic information. Race and ethnicity, as collected by Enel Health, are self-identification information. We do not collect, test for, or infer genetic information from Curator demographic data. We do not share Curator demographic information with any genetic testing service.
4. How Enel Health Uses Curator Data
Enel Health uses Curator data only for the purposes described in this Notice or the Curator Authorization. Categories of use include:
- operating the Matching Algorithm and presenting Matched Insights;
- authenticating your account and securing your access;
- personalizing the Service (with your authorization);
- supporting AI Features that you have separately authorized;
- conducting internal analytics, quality control, and safety reviews;
- conducting anti-bias testing and fairness review of the Matching Algorithm;
- improving the Matching Algorithm and Enel Health features;
- responding to your support requests;
- detecting fraud, abuse, security threats, unauthorized access, or misuse;
- complying with legal, regulatory, contractual, tax, accounting, and compliance obligations;
- enforcing the Terms of Use;
- communicating with you about your account, security, privacy, billing, legal notices, and material service changes; and
- carrying out other purposes with your consent.
5. The Matching Algorithm
The Enel Health Matching Algorithm is automated decision-making technology that compares your self-identified profile to the de-identified profiles of RWE Contributors and generates Matched Insights for you. The Matching Algorithm is described in the Algorithmic Matching & Automated Decision-Making Disclosure, which is the pre-use notice required by the California Consumer Privacy Act regulations effective January 1, 2026.
You have the right to opt out of automated decision-making, to access information about the Matching Algorithm, and to correct or withdraw the personal information used as inputs. See Section 8 (Your Rights) and the ADMT Disclosure for details.
6. Who Enel Health Shares Curator Data With
Enel Health may share Curator data with the limited categories of recipients described below. The Consumer Health Data Privacy Policy lists specific affiliates and categories of third parties for Consumer Health Data.
6.1 Service Providers
Enel Health shares Curator data with vendors and service providers that help operate Enel Health, including cloud-hosting providers, database providers, security providers, customer-support tools, communication systems, AI model providers, and software-infrastructure providers. Service providers are bound by written data-processing agreements that restrict use to authorized purposes.
6.2 No Disclosure to RWE Contributors or Other Curators
Curator demographic information and interests are not displayed to RWE Contributors or to other Curators in identifiable form.
6.3 No Advertising or Marketing Sharing
Enel Health does not share Curator demographic information, interests, or Consumer Health Data with third-party advertising or marketing systems. Curator data is not used for cross-context behavioral advertising or third-party targeted advertising.
6.4 Legal, Compliance, and Safety Recipients
Enel Health may disclose Curator data when necessary to comply with law, enforce agreements, respond to lawful requests, protect rights and safety, investigate fraud or abuse, or complete a merger, acquisition, financing, restructuring, or sale of assets. Enel Health will provide notice to affected Curators in advance of any business transaction involving their personal information where required by applicable law.
7. Data Retention
Default retention periods for Curator data are:
- Account information: for the life of the account and twenty-four (24) months after account closure, then deleted or de-identified;
- Self-identified demographic information and interests: for the life of the account and twenty-four (24) months after account closure;
- Matched Insight interaction logs (identifiable): for the life of the account and twelve (12) months after account closure;
- Aggregate, de-identified usage statistics: retained without time limit;
- Security, audit, and compliance logs: minimum of twenty-four (24) months;
- Billing and tax records: minimum of seven (7) years where required by law.
8. Your Rights
Depending on your location and applicable law, you have rights to:
- access your personal data;
- correct inaccurate data, including correcting or updating self-identified demographic information and interests;
- request deletion;
- request export or portability;
- withdraw any optional authorization (including your authorization for Enel Health to collect or use race or ethnicity);
- opt out of automated decision-making for any significant decision and request human review where required by law;
- limit the use of your Sensitive Personal Information beyond what is strictly necessary to provide the Matching service;
- opt out of marketing communications;
- appeal Enel Health’s response to your request;
- file a complaint with your state attorney general or applicable privacy regulator.
State-specific rights, response timeframes, and appeal procedures are described in the State Privacy Rights Notice. To submit a request, contact info@enelhealth.com or use the form at https://enelhealth.com/privacy-requests. Enel Health verifies your identity before fulfilling a request and will respond within forty-five (45) calendar days of receipt of a verifiable request, with one additional forty-five (45) day extension where reasonably necessary and with notice to you.
9. Security
Enel Health uses administrative, technical, and organizational safeguards designed to protect Curator data, including encryption in transit and at rest, role-based access controls, two-factor authentication for administrative access, audit logging, secure vendor agreements, incident-response procedures, and re-identification risk review.
10. Security Incident and Breach Notice
If a security incident affects unsecured PHR Identifiable Health Information, Enel Health complies with the FTC Health Breach Notification Rule, 16 C.F.R. Part 318, including notification to affected individuals, the FTC, and (where 500 or more individuals in a state or jurisdiction are affected) the media, within sixty (60) days of discovery and (for incidents affecting 500 or more individuals) contemporaneously with individual notice. Enel Health also complies with applicable state breach-notification laws, including the California Customer Records Act, the Washington Data Breach Notification Law, and analogous laws in other states.
11. Children and Minors
Enel Health is not intended for, and does not knowingly collect personal information from, anyone under eighteen (18). If you believe a minor has provided personal information, contact info@enelhealth.com.
12. Changes to This Notice
Enel Health may update this Notice. For material changes, Enel Health will provide notice through the Service, email, account notification, website posting, or another reasonable method. Where applicable law requires affirmative consent before applying a material change to the processing of Consumer Health Data, Enel Health will obtain that consent before applying the change to your information.
13. Contact
Enel Health Inc.
Privacy Office
5639 La Jolla Blvd
La Jolla, CA 92037
info@enelhealth.com
https://enelhealth.com
Curator Authorization & Informed Consent
Last updated: May 25, 2026
1. Why You Are Reading This Document
Enel Health is asking your permission to collect some self-identified demographic information and your stated interests, and to use that information to operate the Enel Health Matching Algorithm. The Matching Algorithm compares your profile to the de-identified profiles of Real-World Evidence (“RWE”) Contributors with similar profiles, and presents Matched Insights to you that summarize their aggregated, de-identified experience with wellness protocols and products.
This document is not a contract. It is your authorization. You can give some authorizations and decline others. You can change your mind later for any authorization that is not strictly necessary to provide the service you are using.
You may use Enel Health without authorizing the collection of race or ethnicity. If you decline, the Matching Algorithm will use the remaining demographic attributes and interests you provide. You will not be denied any feature for declining to provide race or ethnicity, and you may always select “prefer not to say.”
2. Definitions
“Curator” means a user, like you, who provides self-identified demographic information and stated interests to receive Matched Insights. You are a Curator under this Authorization. (You may also choose, separately, to be an RWE Contributor; if so, a separate RWE Contributor Authorization applies to that role.)
“Matched Insights” means the de-identified, aggregated, or statistical information Enel Health presents to you based on similarity between your self-identified profile and the de-identified profiles of one or more RWE Contributors. Matched Insights are subject to minimum cohort sizes, small-cell suppression, and contractual and technical prohibitions on re-identification.
“Matching Algorithm” means the automated processing that compares your self-identified profile to the de-identified profiles of RWE Contributors for the purpose of generating Matched Insights. The Matching Algorithm is described in the Algorithmic Matching & Automated Decision-Making Disclosure (the “ADMT Disclosure”). The Matching Algorithm is “automated decision-making technology” within the meaning of the California Consumer Privacy Act regulations effective January 1, 2026, and is “profiling” within the meaning of various other state privacy laws.
“Consumer Health Data” means personal information that is linked or reasonably linkable to you and that identifies or reasonably infers your past, present, or future physical or mental health status. Your self-identified demographic information and stated interests, when used together to operate the Matching Algorithm or to generate health-related inferences, are Consumer Health Data.
“Sensitive Personal Information” or “Sensitive Data” means the categories so designated under applicable state privacy law. These categories include race, ethnicity, and information concerning a consumer’s health, sex life, or sexual orientation, among others.
3. What Enel Health Will Collect From You
As a Curator, Enel Health will collect the following information from you, depending on the authorizations you give:
- Account information: name, email address, login credentials, and communication preferences.
- Gender (required for the Matching Algorithm; you may select “prefer not to say,” in which case gender will not be used as a similarity dimension).
- Age or year of birth (required for the Matching Algorithm).
- Race and ethnicity (optional Sensitive Personal Information; collected only with your separate affirmative opt-in).
- Other self-identified demographic attributes you choose to provide (optional).
- Stated wellness interests, conditions you are curious about, protocols you are considering, products you are evaluating, and similar topical preferences.
- Your interactions with Matched Insights (which Matched Insights you view, save, or follow), used to refine future Matched Insights for you and for product improvement.
- Communications with Enel Health, including support requests and feedback.
- Security and audit information (authentication events, IP address at significant events, user agent at consent capture, document versions accepted).
4. What Enel Health Will Not Do
- Enel Health will not identify any RWE Contributor to you. Matched Insights are de-identified, aggregated, or statistical.
- Enel Health will not use your race, ethnicity, gender, or age to deny or limit your access to any feature, protocol, product, service, content, or recommendation.
- Enel Health will not sell your Consumer Health Data, including your demographic information and interests.
- Enel Health will not use your Consumer Health Data for cross-context behavioral advertising or third-party targeted advertising.
- Enel Health will not provide your identifiable Consumer Health Data to a third-party model provider for use in training that provider’s foundation models.
- Enel Health will not use the Matching Algorithm to make employment, housing, credit, insurance, public-accommodation, or other legally-protected decisions about you.
- Enel Health will not make any significant decision about you using ADMT alone, without meaningful human review, where applicable law prohibits that.
5. The Risks of Being a Curator
Enel Health uses strong safeguards, but no system is perfect. Risks include:
- risk of an unauthorized data breach despite Enel Health’s safeguards;
- risk that demographic combinations you provide (for example, a rare combination of age, race, ethnicity, and interest) make your account more identifiable than typical accounts;
- risk that Matched Insights may be incomplete, biased, outdated, or not predictive of your individual experience — the underlying contributor data reflects only what those contributors reported, and is not a clinical study;
- risk that you may rely on Matched Insights for a wellness decision when you should consult a licensed clinician;
- risk that you may experience emotional, psychological, or social discomfort from certain content;
- risk that algorithmic outputs may reflect biases in the underlying contributor population, even with anti-bias controls.
Enel Health is not your healthcare provider, and Matched Insights are not medical advice, diagnosis, or treatment. You must consult a licensed clinician for any medical decision. Matched Insights describe what contributors with similar profiles reported, not what is medically right for you.
6. The Benefits of Being a Curator
There are no guaranteed benefits to you. Possible benefits include:
- seeing how RWE Contributors with profiles similar to yours engaged with specific wellness protocols, products, or interventions;
- understanding aggregated patterns in self-reported outcomes;
- being able to compare alternatives in a way that reflects the experience of similar people, rather than only generic content;
- supporting a more transparent, real-world-evidence-anchored wellness ecosystem.
7. Authorizations — Read Each Carefully
Authorization 1 — Required for Any Use of Enel Health as a Curator
I am at least 18 years old. I have read the Enel Health Terms of Use and Founding Member Program Terms, the Curator Privacy Notice, the Consumer Health Data Privacy Policy, the Website Privacy & Cookie Notice, the State Privacy Rights Notice, and the Algorithmic Matching & Automated Decision-Making Disclosure. I agree to those documents, and I authorize Enel Health to collect and process my account information, my gender, my age, and my stated interests as strictly necessary to provide me the Matching service I have requested.
Status: REQUIRED. Without this authorization, you cannot use Enel Health as a Curator.
Authorization 2 — Sensitive Personal Information for Matching (Race, Ethnicity)
I authorize Enel Health to collect and use my self-identified race and ethnicity as similarity dimensions in the Matching Algorithm. I understand that race and ethnicity are Sensitive Personal Information under California law and Sensitive Data under most other state privacy laws. I understand that Enel Health treats race and ethnicity as self-identification, not as genetic information, and that Enel Health will not use these attributes to deny or limit my access to any feature.
Status: OPTIONAL. Default: UNCHECKED. If you decline, the Matching Algorithm will operate using your remaining demographic attributes and interests. You may withdraw or update this information at any time through your account settings or by contacting info@enelhealth.com.
Authorization 3 — Automated Decision-Making (ADMT) for Matching
I have read the Algorithmic Matching & Automated Decision-Making Disclosure. I authorize Enel Health to use automated decision-making technology to generate Matched Insights for me based on the information I have provided. I understand that I may opt out of automated decision-making at any time. If I opt out, Enel Health will either (a) provide me a manually curated or generally accessible version of the service, or (b) inform me that the Matching feature is unavailable without ADMT and offer me alternative access to general wellness content.
Status: OPTIONAL. Default: UNCHECKED. Withdrawal: you may opt out at any time through your account settings or by contacting info@enelhealth.com.
Authorization 4 — Processing of Identifiable Consumer Health Data Beyond Strictly Necessary Use
I authorize Enel Health to process the identifiable Consumer Health Data inferred from my Curator activity — including my stated interests and the Matched Insights I view, save, or follow — for purposes beyond what is strictly necessary to provide the service I have requested, including personalized education, deeper personalization of Matched Insights, internal product improvement, and operation of AI Features I have separately authorized. I understand that absent this authorization, Enel Health will limit its processing of my Consumer Health Data to what is strictly necessary to provide the Matching service.
Status: OPTIONAL. Default: UNCHECKED. Withdrawal: you may withdraw at any time through account settings or by contacting info@enelhealth.com.
Authorization 5 — AI Features Using Identifiable Consumer Health Data
I authorize Enel Health to use my identifiable Consumer Health Data (including my interests and Matched Insights interactions) in connection with AI Features (including chat with Enel Health AI agents, AI-generated summaries, and AI-generated personalization). I understand that some processing by AI Features uses third-party model providers; Enel Health requires those providers to delete prompts and outputs after processing and prohibits training on Enel Health customer data where the provider offers that option.
Status: OPTIONAL. Default: UNCHECKED. If you do not give this authorization, you can still use Enel Health, but AI Features that involve identifiable Consumer Health Data will be limited to general (non-personalized) responses.
Authorization 6 — Marketing Communications
I would like to receive marketing communications from Enel Health, including newsletters, product announcements, and invitations to future programs.
Status: OPTIONAL. Default: UNCHECKED. You may unsubscribe at any time using the unsubscribe link in any marketing email or by contacting info@enelhealth.com. Even if you do not authorize marketing, Enel Health will still send transactional and account-related communications.
Authorization 7 — Invitation to Become an RWE Contributor or Participate in Future Research
I would like to be invited to convert to an RWE Contributor role in the future, or to participate in future Enel Health research programs. Being invited is not a commitment to participate; any future role will be presented with its own consent.
Status: OPTIONAL. Default: UNCHECKED.
8. Enel Health’s Commitments to You
Enel Health makes the following commitments to every Curator:
- No contributor identification. Matched Insights describe contributors only in aggregate, statistical, or de-identified form; you will not be shown any identifiable contributor.
- Minimum cohort sizes and small-cell suppression. Enel Health will not present a Matched Insight unless the underlying contributor cohort meets the minimum-size threshold described in the ADMT Disclosure, in order to reduce re-identification risk and avoid statistically uninformative results.
- Anti-discrimination. Enel Health does not use race, ethnicity, gender, age, religion, sexual orientation, disability, or any other protected characteristic to deny, limit, or differentiate access to any feature, protocol, product, service, or content. Demographic attributes are used solely as similarity dimensions in the Matching Algorithm.
- No protected-context decisions. Enel Health does not use the Matching Algorithm in employment, housing, credit, insurance, public-accommodation, or other contexts protected by federal or state civil-rights laws.
- No sale or targeted advertising of Consumer Health Data. Enel Health does not sell Consumer Health Data and does not use Consumer Health Data for cross-context behavioral advertising or third-party targeted advertising.
- Right to opt out of ADMT. You may opt out of automated decision-making at any time.
- Right to access information about the Matching Algorithm. You may request information about the categories of personal information used, the logic at a general level, and the significance of the outputs.
- Right to ask Enel Health to reconsider an ADMT outcome with human review where required by law.
- Right to correct any inaccurate self-identified information.
- Right to update or withdraw race, ethnicity, or any other Sensitive Personal Information at any time.
9. Your Rights
You always have the right to:
- withdraw any optional authorization at any time, prospectively, through account settings or by contacting info@enelhealth.com;
- access the data Enel Health holds about you;
- correct inaccurate data;
- update or withdraw race, ethnicity, gender, age, or any other self-identified information;
- request deletion of your data (subject to limited exceptions described in the Curator Privacy Notice and the Consumer Health Data Privacy Policy);
- export a portable copy of your data;
- opt out of automated decision-making for any significant decision and request human review where required by law;
- limit the use of your Sensitive Personal Information beyond what is strictly necessary to provide the service you have requested;
- appeal Enel Health’s response to your request;
- contact your state attorney general or applicable privacy regulator;
- ask questions about the Matching Algorithm at any time.
10. What Happens If You Decline
If you decline any optional authorization, Enel Health will not penalize you with reduced service quality, higher prices, or restricted access beyond what is necessary to honor your decision. Specifically:
- Declining Authorization 2 (Sensitive Personal Information): the Matching Algorithm will operate using your remaining demographic attributes and interests.
- Declining Authorization 3 (ADMT): you may not receive Matched Insights generated by automated decision-making. Enel Health will offer you a generally accessible version of the service or an alternative path.
- Declining Authorization 4 (Identifiable Processing): Enel Health will limit processing of your Consumer Health Data to what is strictly necessary to provide the Matching service.
- Declining Authorization 5 (AI Identifiable): AI Features will operate in general / non-personalized mode.
- Declining Authorization 6 (Marketing): you will not receive marketing communications.
- Declining Authorization 7 (Future Invitation): you will not be invited to convert or participate in future research.
11. Re-Consent for Material Changes
If Enel Health makes a material change to how the Matching Algorithm operates — for example, by adding new input categories, a new significant decision use case, or a new sale category — Enel Health will provide clear notice and obtain a new authorization from you before applying the change to data you have already contributed. Continued use of Enel Health without affirmative re-consent will not constitute consent to material changes affecting Consumer Health Data or ADMT use.
12. Questions
You may ask questions about this Authorization, the Matching Algorithm, or your rights at any time. Contact:
Enel Health Inc.
Privacy Office
5639 La Jolla Blvd
La Jolla, CA 92037
info@enelhealth.com
https://enelhealth.com
13. Acknowledgment and Signature Block
Curator name: ____________________________________________
Date of birth: __________________
Signature: ____________________________________________
Date signed: __________________
Email address: ____________________________________________
Authorizations selected (please check):
- [ ] Authorization 1 — Required Account (must be checked to proceed)
- [ ] Authorization 2 — Sensitive Personal Information for Matching (race, ethnicity)
- [ ] Authorization 3 — Automated Decision-Making (ADMT) for Matching
- [ ] Authorization 4 — Processing of Identifiable Consumer Health Data
- [ ] Authorization 5 — AI Features Using Identifiable Consumer Health Data
- [ ] Authorization 6 — Marketing Communications
- [ ] Authorization 7 — Invitation to Become an RWE Contributor or Participate in Future Research