US Consumer Health Data Privacy Notice

This notice supplements the Adobe Privacy Policy (the “Privacy Policy”) and applies to personal data defined as “consumer health data” subject to the Washington My Health My Data Act (MHMDA), the Nevada Health Data Privacy Act (NHDPA), and other applicable state US consumer health privacy laws.

Consumer Health Data We Collect

As described in the “What information does Adobe collect about me? ” section of our Privacy Policy, the data we collect depends on how you interact with us, the services you use, and the choices you make. Because consumer health data is defined very broadly, many of the categories of data we collect could be considered consumer health data.

Such data may also be categorized as follows:

Information about your health-related conditions, status, or diagnoses. For example, we may collect such information through surveys or other communication with you for research studies, improving product accessibility, product and service delivery and event planning and management
Characteristics and measurements of your image, video or audio content. For example, if you enable a product or feature with a face or voice analysis feature and you consent to the collection of this data, we will process this information to provide the service to you. This includes photographs, which may also be considered biometric information under the MHMDA.
Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies. For example, if you enable the ability to add precise location metadata to photos and images through your mobile device, we may receive GPS, cell tower, and Wi-Fi hotspot location data that could reveal health-related information. Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. For example, your interactions with us could involve queries concerning nutrition, wellness, fitness, medical conditions, or other health-related topics.
Other information that may be used to infer or derive data related to the above or other health information.

Sources of Consumer Health Data

As described further in the “What information does Adobe collect about me? ” section of the Privacy Policy, the personal data we collect (which may include consumer health data) depends on how you interact with us, the services you use, and the choices you make. We may collect personal data directly from you, from your interactions with our products and services, from third party data sources, and publicly available sources, and data we infer or generate from other data.

Why We Collect and Use Consumer Health Data

We collect and use consumer health data for the purposes described in the section of the Privacy Policy titled “What information does Adobe collect about me? ”. Primarily, we collect and use consumer health data as reasonably necessary to provide you with the products and services you have requested or authorized. This may include delivering and operating the products and their features, personalization of certain product features, ensuring the secure and reliable operation of the products and the systems that support them, troubleshooting and improving the products, and other essential business operations that support the provision of the products (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).

We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law – for example, for research and development, providing you with requested health-related accommodations when visiting our offices or attending an Adobe-sponsored event, or for advertising or marketing purposes. See the “ What rights do I have regarding my personal information and how can I exercise these rights?” section of the Privacy Policy and the “How to Exercise Your Rights” section below for more details on the controls and choices you may have.

Our Disclosure of Consumer Health Data

We may disclose each of the categories of consumer health data described above for the purposes described in the “ Does Adobe disclose my personal information to others?” section of the Privacy Policy. We may disclose personal data, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any product you have requested or authorized, as described in the previous section above.

For example, if you enable products and services that process biometric information, we may store that information with our cloud service providers. And we may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

Categories of Providers with Whom We Disclose Consumer Health Data

As necessary for the purposes described above, we disclose consumer health data with the following categories of providers:

Service providers. Vendors or agents (“processors”) working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to data to provide those functions.
Business partners. We may disclose consumer health data with other companies, for example, where you use a service that is cobranded and jointly operated with another company, or where you use our services to interact with another company.
Financial institutions & payment processors. When you make a purchase or enter into a financial transaction, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
Subsidiaries, Affiliates. We enable access to data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business. A list of specific affiliates is available here.
Government agencies. We will disclose consumer health data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process.
Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.
Other users and individuals. If you use our services to interact with other users of the service or other recipients of communications, we will disclose data, including consumer health data, as directed by you and your interactions.
The public. You may select options available through our services to publicly display and disclose certain information, such as your profile, demographic data, content and files, or geolocation data, which may include consumer health data.

How to Exercise Your Rights

U.S. consumer health privacy laws, including MHMDA and the NHDPA, provide certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the various tools and mechanisms described in the “What rights do I have regarding my personal information and how can I exercise these rights?” section of the Privacy Policy. For example, depending on the product you use, you can access and make choices about your data through product controls. And if you want to access or control consumer health data we process that is not available via those tools, you can always contact us by using our web form.

If your request to exercise a right is denied, you may appeal that decision by contacting our privacy support team via our web form. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington Attorney General at https://www.atg.wa.gov/file-complaint, the Nevada State Attorney General at https://ag.nv.gov/complaints/file_complaint/, or other regulatory authorities as applicable.

How to Contact Us

For details on how to contact us and additional information on how we address material changes to our privacy policy, please see the section of our Privacy Policy titled “ Who can I contact with questions or concerns?”