Effective October 29, 2026 · Last updated October 29, 2026
This Consumer Health Data Privacy Policy explains how Framework Wellness LLC ("CellThrive," "we," "us," or "our") collects, uses, and shares consumer health data — personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health — and how you can exercise your rights. It is written to meet Washington's My Health My Data Act (RCW 19.373) and similar laws in Nevada, Connecticut, and other states, and it applies to everyone who uses CellThrive. Our Privacy Policy also applies. CellThrive provides education, not medical care, and we do not sell consumer health data.
We collect: (a) health assessment answers — symptoms, goals, health history, conditions you report, medications, supplements, and allergies; (b) lab and biomarker results from tests you order through us or upload; (c) genetic data from a test kit you order through us or a raw DNA file you upload; (d) data from devices and apps you choose to connect, such as sleep, heart rate, and activity; (e) health-related purchases, such as lab panels, genetic tests, and supplements; (f) health information in messages you send us; and (g) health insights we derive from this information, such as your health map. We use it only to build your health map, personalized insights, and plan; to arrange tests and orders you request; to send you results and account messages; to keep the service secure and working; and to meet legal obligations. With your separate opt-in, we may use de-identified answers, lab results and plan adherence to study which recommendations work and share de-identified findings with research partners or publications. We do not use it for advertising, and we do not collect precise location data.
Directly from you (forms, uploads, and messages); from laboratories that run tests you order through us, including our genetic testing lab; from devices and apps you connect and authorize; and from our supplement dispensary for orders you place.
We share only what is needed for the service you asked for: your name, date of birth, sex, contact details, and test order with our lab-ordering partner and the laboratory that runs your test; your kit and sample information with our genetic testing lab and kit partner; the items you choose to order with our supplement dispensary; and the categories listed in section 1 with service providers that process data for us under contract, only as needed to run CellThrive. We also share consumer health data when the law requires it. We never sell consumer health data — to data brokers or anyone else — and we never share it with advertising or analytics networks.
Categories of third parties: (a) service providers (processors) acting only on our instructions — hosting and database, sign-in, email and text delivery, payment processing, scheduling, customer-relationship management, phone and video calls with call recording and transcription, report generation, and AI tools that help us run the service (for example, to produce your insights, summarize calls, and read lab files); (b) our lab-ordering partner, which places the lab orders you request, and the clinical laboratories that run your blood tests; (c) our genetic testing lab, Gene by Gene (Houston, Texas; a CLIA-certified, CAP-accredited lab), which receives kits through our kit partner, PromicsEdge; (d) our supplement dispensary, for orders you place; and (e) government authorities, when the law requires it. If you message us on Facebook or Instagram, Meta processes those messages under its own policy. Devices and apps you connect send data to us; we do not send your health data to them. Specific affiliates: CellThrive has no affiliates that receive consumer health data.
We collect consumer health data only with your consent or as necessary to provide a service you requested, and we ask for your separate consent before sharing it for any other purpose. Genetic testing and DNA file uploads require their own separate consent first. You can withdraw consent at any time in your account or at cellthrive.health/privacy-request (see section 6); withdrawing may limit what we can provide. We will not collect, use, or share additional categories of consumer health data, or use it for additional purposes, unless we first update this policy and get your consent.
You may: (a) confirm whether we collect, share, or sell your consumer health data; (b) access it, including a list of all third parties and affiliates with whom we have shared or sold it and an email address or other way to contact each; (c) withdraw your consent to our collection and sharing of it; and (d) have it deleted. We delete it from our live systems within 30 days of receiving your request, and never later than 45 days (backup copies within six months), and tell our service providers and the third parties we shared it with to delete it. To make a request, use your account (Account → Your data) or our request form at cellthrive.health/privacy-request. We may ask for information to confirm your identity. You do not need to create an account. We respond within 45 days of receiving your request; if we need more time, we will tell you why within those 45 days and may extend once by another 45 days. Requests are at no charge up to twice a year. We will not treat you differently for using these rights.
If we decline your request, we will tell you why. To appeal, use the same form and choose "Appeal a decision". We will answer your appeal in writing within 45 days and explain our decision. If we deny your appeal, you can file a complaint with the Washington State Attorney General at https://www.atg.wa.gov/file-complaint, or with the attorney general of your state.
If we change this policy, we will update the date above. We will not collect, use, or share consumer health data in a new way, or for a new purpose, without first telling you and getting your consent. Material changes to your other rights follow the notice terms in our Terms of Use.
Framework Wellness LLC (CellThrive), 5830 34th St. N, Birmingham, AL 35207. Email: support@cellthrive.health.
