Consumer Health Data Privacy Notice

Consumer Health Data Privacy Notice

Last Updated: September 17, 2026

Gen Digital Inc., together with its subsidiaries and affiliates (collectively, “Company,” “us,” “we,” or “our”), is committed to protecting the privacy of personal data (i.e., information reasonably related to a specific individual). This Consumer Health Data Privacy Notice (“Notice”) supplements our Privacy Notices and applies to Personal Data defined as “consumer health data” (“consumer health data”) subject to the Washington State My Health My Data Act or other applicable state consumer health privacy laws.  

Consumer Health Data We Collect and Sources of Collection 

The information we collect about you, including consumer health data, depends on how you interact with the relevant products and services, the information you provide, the services you connect, and the features and settings you enable. We may collect the following categories of consumer health data: 

  • Information about your or your family members' health conditions, diagnoses, symptoms, treatments, interventions, medications, allergies, dietary restrictions, medical providers, or other health-related needs that you choose to provide through our products and services.  

  • Information relating to health care services, appointments, testing, prescriptions, or other health-related information contained in connected emails, messages, calendar entries, school or childcare communications, or other connected services that you choose to connect.  

  • Information indicating that you or another individual is seeking, receiving, or has received health care services or treatment.  

  • Health-related information about children, dependents, family members, caregivers, or other individuals that you or another user makes available through a connected account or communication.  

  • Inferences regarding your or another individual's past, present, or future physical or mental health status or health care needs that are derived from the data that you provide and information from connected services.  

  • Other consumer health data that you choose to provide or authorize our products and services to access. 

We may collect these categories of consumer health data from the following sources:  

  • Directly from you (or other people such as other users in your family or household). 

  • From third-party services that you choose to connect to our products and services, including email, calendar, messaging, school, childcare, family-management, and similar services, as well as websites that are accessed at your direction. 

Why We Collect and Use Consumer Health Data 

We collect and use consumer health data as reasonably necessary to provide features and services you request or authorize, including to: 

  • Maintain connected accounts and retrieve information necessary to provide the services you request.  

  • Personalize features and services by combining information from connected services and drawing inferences to generate summaries, reminders, recommendations, and other requested features.  

  • Use automated technologies to respond to your requests and provide relevant features including taking action you requested.  

  • Protect, secure, maintain, troubleshoot, and improve features and services; detect and prevent fraud, abuse, and security incidents; and comply with applicable law. 

We may aggregate or de-identify consumer health data so that it no longer identifies you and use that aggregate or de-identified information as permitted by applicable law. 

With Whom We Share Consumer Health Data 

We may share each category of consumer health data that we collect: 

  • With service providers and vendors that perform services on our behalf, including cloud-hosting, security, customer support, analytics, and automated technology providers, for the purposes described above. 

  • With our subsidiaries and affiliates that support or provide our products and services. 

  • With connected third-party services, websites, merchants, reservation providers, payment or transaction providers, and other recipients when you direct or authorize us to interact or transact with them on your behalf. Those third parties process information under their own privacy policies. 

  • With other parties to a corporate transaction or proceeding, such as a reorganization, merger, acquisition, consolidation, initial public offering, financing, bankruptcy, dissolution, or transfer, divestiture, or sale of all or part of our business or assets or in contemplation of such an event. These transfers of consumer health data would be subject to strict contractual confidentiality requirements, and, in the event that we ultimately transfer such data, we will inform the transferee that it must use your consumer health data only for the purposes disclosed in this Notice. 

  • With government agencies, law enforcement, and other recipients as necessary to comply with legal obligations; protect our rights, systems, users, or the public; or respond to valid legal requests. 

  • With other parties with your affirmative consent or at your direction. 

If we ever engage in a disclosure or other activity that constitutes a sale of consumer health data under applicable law, we will first obtain any authorization required by law.   

How to Exercise Your Rights 

You may have rights with respect to your consumer health data, subject to applicable exceptions, under Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, or another state with an applicable consumer health privacy law. These rights may include:  

  • Accessing your consumer health data;  

  • Confirming whether we collect, share, or sell your consumer health data;  

  • Requesting deletion of your consumer health data; and  

  • Withdrawing your consent to the collection or sharing of your consumer health data, where applicable. 

You can request to exercise these rights by contacting us at dpo@gendigital.com. If we deny your request, you may appeal that decision by contacting us at dpo@gendigital.com. If we deny your appeal, we will provide you with information about how to contact the appropriate Attorney General or other applicable regulatory authority, where required by applicable law.  

Updates to this Notice 

We may change this Notice to reflect changes in law, our data collection and use practices, product features, or advances in technology. We will make the revised Notice available through our services and identify the date it was last revised at the top of the Notice. If we make a material change, we will provide appropriate notice in accordance with applicable legal requirements. Your continued use of our services after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this Notice.