Consumer Health Data Privacy Policy

About This Policy

This Consumer Health Data Privacy Policy is provided by Mercer Island Capital Management, LLC^® (“MICAP,” “we,” “us,” or “our”) in accordance with the Washington My Health My Data Act (“MHMDA”). It is separate and distinct from our general Privacy Policy and applies specifically to “consumer health data” as defined under the MHMDA. To the extent any information we handle is also governed by other privacy laws such as the Gramm-Leach-Bliley Act, those frameworks continue to apply.

Categories of Consumer Health Data We Collect

In the course of providing financial planning and investment advisory services, we may collect limited consumer health data when it is relevant to your plan — for example, in connection with insurance, long-term care, disability, estate, or retirement planning. This may include:

• Information you voluntarily provide about your health status, medical conditions, or health-related life circumstances relevant to your financial plan.
• Information relating to long-term care, disability, life, or health insurance needs and coverage.

We do not collect consumer health data beyond what is reasonably necessary to provide the services you have requested.

Sources of Consumer Health Data

• Directly from you, through our conversations, questionnaires, and planning documents.
• From professionals or third parties you authorize us to communicate with on your behalf.

How and Why We Use Consumer Health Data

We use consumer health data solely to provide the advisory and financial planning services you have requested — such as developing recommendations related to insurance, long-term care, retirement, and estate planning — and to meet our legal, regulatory, and recordkeeping obligations. We do not use consumer health data for advertising, and we do not sell it.

How We Share Consumer Health Data

We do not sell consumer health data. We share it only as necessary to provide our services and only with your consent or as otherwise permitted or required by law, including with:

• Service providers and processors who assist us in delivering our services and who are contractually obligated to protect your data.
• Insurance carriers or other professionals you authorize us to engage on your behalf.
• Regulatory authorities or in response to legal process, as required by law.

Your Rights Under the MHMDA

Washington consumers have the right to:

• Confirm whether we are collecting, sharing, or selling your consumer health data, and to access that data.
• Withdraw consent to our collection and sharing of your consumer health data.
• Request that we delete your consumer health data.
• Appeal a denial of any request. If we deny your request, you may appeal by contacting us using the information below. If your appeal is denied, you may contact the Washington State Attorney General at atg.wa.gov.

We will not discriminate against you for exercising any of these rights. To submit a request, contact us using the details below; we may need to verify your identity before responding.

Data Security and Retention

We maintain physical, electronic, and procedural safeguards designed to protect consumer health data, and we retain it only as long as necessary to provide our services and to comply with our legal and regulatory obligations.

Changes to This Policy

We may update this Consumer Health Data Privacy Policy from time to time. Material changes will be reflected by the effective date above and posted on this page.

Contact Us

To exercise your rights or ask questions about this policy, contact: