Health Data Privacy Notice

Effective date: July 30, 2026
Last updated: July 30, 2026

This Health Data Privacy Notice explains how dipara ("dipara," "we," "us," or "our") collects, uses, processes, discloses, and protects consumer health data when you use our TCM Body Constitution Quiz and related services.

This policy supplements our general Privacy Policy. If there is a conflict between this Health Data Privacy Notice and our general Privacy Policy regarding consumer health data, this Health Data Privacy Notice will control.

1. Scope of This Policy

This policy applies to consumer health data that we collect or generate through:

  • the dipara TCM Body Constitution Quiz;
  • personalized TCM-inspired wellness reports;
  • constitution-based email communications;
  • related customer service and privacy requests;
  • and systems used to calculate, deliver, secure, and analyze the Quiz.

"Consumer health data" generally means personal information that identifies, relates to, describes, or may reasonably be linked to a consumer’s past, present, or future physical or mental health status.

Our Quiz is provided for educational, cultural, wellness, and self-awareness purposes only. It is not a medical diagnosis and is not intended to diagnose, treat, cure, or prevent any disease or medical condition.

2. Categories of Consumer Health Data We Collect or Process

Depending on how you use the Quiz, we may collect or process the following categories of consumer health data.

A. Quiz questionnaire responses

This includes answers you provide about experiences or tendencies relating to matters such as:

  • energy and fatigue;
  • sensitivity to warmth or cold;
  • sleep and rest;
  • digestion and appetite;
  • thirst and bodily fluids;
  • sweating; bowel movements;
  • mood, tension, and relaxation;
  • circulation-related experiences;
  • skin or environmental sensitivities;
  • and other everyday bodily or wellness experiences included in the Quiz.

Your individual question responses are transmitted for the purpose of calculating your results.

We do not intentionally retain your individual question responses as user-level records in our Klaviyo customer profiles or anonymous Quiz analytics database after the calculation is completed.

B. Calculated and inferred Quiz results

We generate or infer information from your questionnaire responses, including:

  • Primary TCM Constitution Tendency;
  • Secondary TCM Constitution Tendencies;
  • scores for the TCM constitution categories included in the Quiz;
  • Five-Dimension profile scores;
  • Five-Zang functional pattern scores;
  • support areas and wellness directions;
  • Blood Support or related report pathways, where applicable; personalized wellness interpretations; food, movement, rest, routine, and self-care suggestions;
  • and personalized report text and report modules.

These results are TCM-inspired wellness interpretations and are not medical findings.

C. Email-linked Quiz and report information

If you submit your email address to receive a report, we may associate your email address with:

  • your calculated Quiz results and scores; your personalized report and recommendations;
  • the date and time the Quiz was completed;
  • the Quiz version and report version used; report delivery status;
  • communication preferences;
  •  marketing subscription status, where applicable;
  • the consent language presented to you;
  • the date and method of consent; and consent or disclosure version information.

If you complete the Quiz without submitting an email address, we do not intentionally create an email-linked customer profile from your Quiz results.

D. Technical and security information

When you use the Quiz, our website and service providers may automatically process technical information, such as:

  • IP address;
  • browser and device information;
  • request date and time; security and error logs;
  • general website interaction information;
  • and randomly generated Quiz-attempt identifiers.

We use this information to operate the Quiz, protect system security, diagnose errors, and prevent duplicate statistical counting.

We may temporarily retain a randomly generated Quiz-attempt identifier for up to 14 days. This identifier is not intentionally stored together with your email address, individual answers, IP address, exact scores, or complete result combination in our anonymous Quiz analytics database.

E. Anonymous and aggregated Quiz statistics

We may create and retain anonymous or aggregated statistics, such as:

  • the total number of completed quizzes;
  • the general distribution of Primary and Secondary Tendencies;
  • the distribution of Five-Dimension support areas;
  • and general Quiz performance or completion statistics.

These statistics are intended to help us understand and improve the Quiz and are not intended to identify an individual user.

3. Sources of Consumer Health Data

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

Directly from you

We collect information directly from you when you:

  • answer Quiz questions;
  • submit an email address;
  • select communication preferences;
  • provide consent; 
  • request a personalized report; contact us about your Quiz results;
  • or submit a privacy request.
  • Generated by our systems

Our systems generate scores, tendencies, support areas, interpretations, and personalized recommendations based on the answers you provide.

Automatically through the Quiz and website

Our website and service providers may automatically process technical, security, and interaction information when you access or use the Quiz.

We do not purchase Quiz-related consumer health data from data brokers or obtain it from public records.

4. Why We Collect and Use Consumer Health Data

We may collect and use consumer health data for the following purposes:

Providing the requested Quiz service

We use your questionnaire responses to:

  • calculate and display your Quiz results;
  • identify your Primary and Secondary Tendencies;
  • generate Five-Dimension and Five-Zang profiles;
  • produce personalized wellness interpretations;
  • and provide the Quiz and report you requested.

Delivering personalized reports

If you submit your email address, we use your email-linked Quiz information to:

  • generate and deliver your personalized report;
  • resend or troubleshoot your report;
  • maintain a record of your report request;
  • prevent duplicate or incorrect delivery;
  • and respond to questions about your report.

Constitution-based communications

Where you have provided affirmative consent to receive such communications, we may use your calculated Quiz profile to personalize occasional emails concerning:

  • TCM-inspired wellness education; seasonal wellness information;
  • routines relevant to your constitution profile;
  • dipara products and services; new product announcements;
  • and promotions or offers.

You may withdraw your consent to promotional communications at any time by using the unsubscribe link in an email or by contacting us.

Unsubscribing from promotional emails does not automatically delete your stored Quiz profile. You may separately request deletion as described below.

Improving and maintaining the Quiz

We may use anonymous, aggregated, or limited technical information to:

  • understand how frequently the Quiz is completed;
  • evaluate the general distribution of results;
  • improve Quiz questions, calculations, and reports;
  • diagnose technical problems;
  • prevent duplicate counting;
  • protect the Quiz against misuse; and maintain system security.

Legal and compliance purposes

We may process consumer health data where reasonably necessary to:

  • comply with applicable laws;
  • respond to valid legal requests;
  • investigate fraud, misuse, or security incidents;
  • protect our users, business, systems, or legal rights; and establish, exercise, or defend legal claims.

We will not use consumer health data for additional materially different purposes without providing any notice or obtaining any consent required by applicable law.

5. How Consumer Health Data Is Processed

Quiz responses are sent to server-side systems operated through Cloudflare for calculation and validation.

The calculation systems use the answers to generate scores, tendencies, support areas, and personalized report content. Results are then returned to your browser so they can be displayed to you.

If you submit an email address, relevant calculated results, report content, consent information, and communication information may be sent through Cloudflare to Klaviyo for report delivery and customer communication management.

Individual questionnaire responses are not intentionally added to your Klaviyo customer profile. Klaviyo receives calculated results and report-related information rather than a question-by-question record of your answers.

6. Categories of Consumer Health Data We Disclose

We may disclose the following categories of consumer health data where necessary to provide the requested service:

  • questionnaire responses transmitted for server-side calculation;
  • calculated Quiz scores and tendencies;
  • Five-Dimension and Five-Zang results;
  • personalized report and support-direction content; email address and report-delivery information;
  • consent and communication-preference records;
  • Quiz version and completion information; 
  • and technical and security information associated with the operation of the Quiz.

We do not sell consumer health data.

We do not intentionally disclose individual Quiz responses or calculated profiles to advertising platforms for their independent advertising purposes.

We do not use individual consumer health data to build advertising audiences or target advertisements across unrelated websites.

7. Service Providers and Other Recipients

We may disclose or make consumer health data available to the following categories of recipients.

Cloudflare

Cloudflare provides:

  • server and Worker infrastructure;
  • server-side Quiz calculation; security and network services;
  • technical logging and troubleshooting;
  • duplicate-count prevention;
  • and anonymous or aggregated Quiz analytics infrastructure.

Cloudflare may process questionnaire responses, calculated results, email submission data, request information, and technical identifiers on our behalf.

Klaviyo

Klaviyo provides:

  • email delivery; personalized report delivery;
  • customer profile storage;
  • consent and subscription management; suppression and unsubscribe management;
  • and constitution-based email communications.

Klaviyo may process your email address, calculated Quiz results, personalized report content, completion and version information, consent records, and communication history on our behalf.

Professional advisers and authorities

We may disclose information to attorneys, accountants, security professionals, insurers, regulators, courts, law enforcement, or government authorities where reasonably necessary to comply with law, protect legal rights, investigate security incidents, or respond to valid legal process.

Business transactions

Consumer health data may be transferred as part of a merger, acquisition, financing, bankruptcy, reorganization, or sale of all or part of our business. Any recipient will be required to handle the information consistently with applicable law and the commitments described in this policy.

We do not currently share consumer health data with corporate affiliates for their own independent use.

8. Cross-Site Collection and Advertising

We do not knowingly permit third parties to collect individual Quiz responses or calculated constitution profiles over time and across unrelated websites or online services for targeted advertising.

Our website may use general website analytics, advertising, or cookie technologies as described in our general Privacy Policy. We do not intentionally include your individual Quiz answers, exact scores, constitution profile, or personalized report content in advertising-platform event parameters, website URLs, or advertising audience information.

9. Sale of Consumer Health Data

We do not sell consumer health data.

We will not sell consumer health data without obtaining any written authorization separately required by applicable law.

We will not condition access to the Quiz, a report, a product, or another service on your authorizing the sale of consumer health data.

10. Retention of Consumer Health Data

We retain consumer health data only for as long as reasonably necessary for the purposes described in this policy, including to:

  • calculate and deliver requested results;
  • maintain your personalized report;
  • provide requested communications;
  • maintain consent, unsubscribe, and suppression records;
  • provide customer support; protect system security;
  • comply with applicable legal obligations;
  • and resolve disputes or enforce our agreements.

Individual question responses are processed for calculation and are not intentionally retained as user-level records in our customer profile or anonymous Quiz analytics databases after calculation.

A randomly generated Quiz-attempt identifier used for duplicate-count prevention may be retained for up to 14 days.

Email-linked calculated Quiz results and personalized report information may be retained while your profile remains active or while reasonably necessary to provide reports and communications, unless you request deletion or a longer period is required or permitted by law.

Consent and suppression records may be retained after you unsubscribe where reasonably necessary to document your preferences, demonstrate compliance, and prevent additional unwanted communications.

Anonymous or aggregated statistics that cannot reasonably be linked to you may be retained for a longer period.

Archived or backup copies may remain temporarily after a deletion request and will be deleted or rendered inaccessible in accordance with our normal backup cycles and applicable law.

11. Your Consumer Health Data Rights

Depending on where you live, you may have the right to:

  • confirm whether we collect, use, share, or sell consumer health data concerning you;
  • access consumer health data associated with you; obtain a list of third parties or affiliates with whom your consumer health data has been shared or sold;
  • review consumer health data associated with you; request correction of inaccurate consumer health data;
  • withdraw consent to future collection or sharing;
  • request that we stop collecting or sharing consumer health data;
  • request deletion of consumer health data; 
  • appeal our refusal to act on a request; and exercise your rights without unlawful discrimination.

These rights may be subject to identity verification and limitations permitted by applicable law.

12. How to Exercise Your Rights

To submit a consumer health data request, email:

support@thedipara.com

Please use the subject line:

Consumer Health Data Request

In your request, please state which right you wish to exercise and provide the email address you used when submitting the Quiz.

We may ask you to verify ownership of that email address or provide additional information reasonably necessary to authenticate your identity and locate your data.

You are not required to create a new account to submit a request.

Where required by applicable law:

  • we will respond without undue delay and generally within 45 days;
  • we may extend the response period where reasonably necessary and will notify you of the extension;
  • qualifying requests will be processed free of charge, subject to applicable limits for excessive, repetitive, or manifestly unfounded requests; and when we honor a deletion request, we will notify applicable processors and service providers so that they can delete the relevant consumer health data from their systems, subject to legal and backup-system limitations.

Withdrawing consent applies to future collection or sharing and may not require deletion of information already collected. To request deletion, you must specifically request deletion.

13. Appeals

If we refuse to act on your request, you may appeal our decision by emailing:

support@thedipara.com

Please use the subject line:

Health Data Privacy Notice Appeal

Please describe the original request and why you believe our decision should be reconsidered.

We will review the appeal and provide a written response within the period required by applicable law. If we deny your appeal, we will provide information about how you may contact the appropriate state attorney general or regulatory authority where required.

14. Security

We maintain administrative, technical, and organizational safeguards designed to protect consumer health data based on the nature and volume of the data we process.

We restrict access to consumer health data to service providers, contractors, and personnel who reasonably need access to provide the requested services, maintain system security, comply with law, or fulfill the purposes described in this policy.

However, no data transmission or storage system can be guaranteed to be completely secure.

15. Children's Consumer Health Data

The Quiz is intended for adults and is not directed to children under 18.

We do not knowingly collect consumer health data from children under 18 through the Quiz. If you believe a child has submitted consumer health data, please contact us at support@thedipara.com so that we can review and delete the information where appropriate.

16. International Processing

Our service providers may process information in the United States or other countries. Privacy and data protection laws in those countries may differ from the laws where you live.

Where required, we use appropriate contractual, organizational, or legal measures for international processing and transfers.

17. Changes to This Policy

We may update this Health Data Privacy to reflect changes to:

  • the Quiz;
  • the information we collect;
  • our service providers;
  • our processing practices;
  • our legal obligations;
  • or our business operations.

When we make changes, we will post the revised policy on our website and update the “Last updated” date.

If a change materially affects how we collect, use, or disclose consumer health data, we will provide additional notice where required, such as through the Quiz page, website notice, or email.

We will obtain affirmative consent before collecting or using additional categories of consumer health data or using consumer health data for materially different purposes where required by applicable law.

18. Contact Us

For questions about this policy or our consumer health data practices, or to exercise your rights, contact:

Email: support@thedipara.com