Consumer Health Data Privacy Policy
Effective date: September 3, 2026
1. About this policy
This Consumer Health Data Privacy Policy ("Policy") explains how CINIS ("we," "us," "our") collects, uses, shares, and protects consumer health data, and the rights you have regarding that data. It applies to consumers who are residents of, or whose data is processed in, Washington, Nevada, and any other jurisdiction with consumer-health-data protections, and it supplements our general Privacy Policy. Where this Policy and our general Privacy Policy differ with respect to consumer health data, this Policy controls.
We provide CINIS, an herbal tea system with blends associated with phases of the menstrual cycle. Because our products and website relate to menstrual and reproductive wellness, certain information we collect, including what you purchase and how you interact with our site, may be treated as "consumer health data" under applicable law, even though we do not operate a period-tracking app or knowingly collect clinical health records.
2. What we mean by "consumer health data"
"Consumer health data" means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. For CINIS, this may include:
- Information indicating an interest in or purchase of products associated with menstrual, reproductive, or hormonal health (for example, which blends or subscription you buy).
- Any information you voluntarily share with us about your cycle, symptoms, or wellness goals, for example, in a support message, review, survey, or form.
- Inferences we or our providers could draw from the above about your health status.
We do not ask you to log menstrual-cycle dates, symptoms, or diagnoses as a condition of using our site, and we ask that you not send us sensitive clinical details you don't want us to have.
3. Categories of consumer health data we collect, and our sources
Categories we may collect:
- Purchase and subscription information related to reproductive/hormonal wellness products.
- Contact information (name, email, shipping address) when tied to the above.
- Website interaction data (pages viewed, items added to cart) relating to health-associated products.
- Any health-related details you voluntarily provide in communications with us.
Sources:
- Directly from you, at checkout, when creating an account, subscribing, contacting support, or submitting a form, review, or survey.
- Automatically, through your interactions with our website and standard, consented analytics.
- From our service providers, such as our e-commerce platform, subscription manager, payment processor, and fulfillment partner, acting on our behalf.
4. How and why we use consumer health data
We use consumer health data only for the following purposes:
- To process and fulfill your orders and manage your subscriptions.
- To provide customer support and respond to your inquiries.
- To send communications you have opted into (such as order updates or, if you consented, marketing emails).
- To operate, secure, and improve our website and products.
- To comply with legal obligations and enforce our terms.
We do not use consumer health data for targeted or cross-context behavioral advertising without your consent, and we do not use it to make decisions that would unlawfully discriminate against you.
5. How we share consumer health data, and with whom
We share consumer health data only as needed to run our business, and only with the categories of recipients below, each of whom is contractually bound to protect it and use it only for the services they provide to us:
- Service providers / processors, including our e-commerce platform (Shopify), payment processor, subscription-management provider (Appstle), fulfillment/3PL partner, and our email/communications provider.
- Legal and safety recipients, where required to comply with law, respond to lawful requests, or protect rights and safety.
- Business transfers, in connection with a merger, acquisition, or sale of assets, subject to the protections in this Policy.
We do not share consumer health data with data brokers or for third-party advertising without your consent.
6. We do not sell your consumer health data
We do not sell consumer health data. Under applicable law, a "sale" includes exchanging health data for money or other valuable consideration. We will not sell your consumer health data, and if that ever changed, we would first obtain your valid, separate written authorization as required by law, separate from the consent described below.
7. Consent and how to withdraw it
Where the law requires it, we collect and share your consumer health data only with your consent, and only for the purposes disclosed in this Policy. You may withdraw your consent at any time by emailing us at hello@takecinis.com. Withdrawing consent will not affect the lawfulness of processing that occurred before withdrawal, and we will honor your request as required by law.
8. Your rights
Subject to applicable law, you have the right to:
- Confirm and access whether we are collecting, sharing, or selling your consumer health data, and to review that data.
- Withdraw consent to our collection and sharing of your consumer health data.
- Delete your consumer health data.
- Appeal a refusal to act on your request.
To exercise any of these rights, email hello@takecinis.com with the details of your request. We will verify your request and respond within the timeframes required by law. We will not discriminate against you for exercising your rights. If we deny a request, you may appeal by replying to our response; if your appeal is denied, you may contact the Washington State Attorney General (www.atg.wa.gov) or the attorney general in your state.
9. No geofencing
We do not use geofencing to identify, track, collect data from, or send notifications to consumers based on their proximity to any health-care facility.
10. Data retention
We retain consumer health data only for as long as necessary to provide our products and services, comply with our legal obligations, resolve disputes, and enforce our agreements, after which we delete or de-identify it.
11. How we protect consumer health data
We maintain reasonable administrative, technical, and physical safeguards designed to protect consumer health data, and we limit access to those who need it to provide our services. No system is perfectly secure, but we work to protect your information consistent with applicable law.
12. Nevada residents
If you are a Nevada resident, Nevada's consumer health data law (SB 370) provides protections similar to those described above, including consent requirements and rights to access and delete your consumer health data. You may exercise these rights using the contact information below.
13. Changes to this Policy
We may update this Policy from time to time. Material changes will be reflected by updating the "Effective date" above and, where required, by additional notice. Your continued use of our website after changes take effect constitutes acceptance of the updated Policy.
14. Contact us
For any question or request regarding this Policy or your consumer health data:
CINIS
307 W 38th St, 16th Floor PMB 418, New York, NY 10018
Email: hello@takecinis.com
You may designate an authorized agent to make a request on your behalf, subject to our verification of the agent's authority.
