Consumer Health Data Privacy Policy
This policy is required by US consumer health data laws, including Washington’s My Health My Data Act, Nevada’s SB 370 and Connecticut’s consumer health data rules. “Consumer health data” means personal information that identifies your past, present or future physical or mental health status. Our full Privacy Policy applies too.
Categories of consumer health data we collect
- Pre-exercise health-check answers, and injuries, pain, surgeries or conditions you tell us about.
- Body measurements: weight, height, body fat.
- Bodily functions and vital signs: heart rate variability, resting heart rate, sleep and sleep stages, recovery data.
- Menstrual cycle days and symptoms (only if you turn cycle tracking on).
- Medical documents you upload (for example blood work, DEXA scans, medical clearance, physio reports).
- Progress photos.
- Nutrition and supplement logs, training and effort data, and coaching notes that relate to your health.
- Wearable data from devices you connect (sleep, recovery, HRV, resting heart rate, and workouts, activity and body measurements where the device sends them).
Why we collect and use it
Only to provide the coaching you asked for:
- Planning your training and nutrition.
- Tracking your progress.
- Keeping training safe.
- Communicating with you.
- Running and securing the app.
We ask for your consent in the app before we collect it, separately for wearable connections and cycle tracking. We never use it for advertising.
Sources
You, your coach, and wearable makers or phone health apps you connect (through our own Open Wearables server).
Categories we share, and with whom
- All of the categories above are shared with your coach and our coaching staff.
- Cycle data is shared with them only if you switch sharing on.
- Our service providers store and process it for us under contract:
- Hosting: [Fill in: Hosting providers and countries].
- Backups: [Fill in: Backups].
- Client-management (CRM) software, if your coach sends it health information such as weight or training load: [Fill in: Client-management (CRM) provider and what it receives].
We don’t share consumer health data with any other third party or affiliate, and we do not sell it. If that ever changed, we would first ask for your separate consent, and for any sale your signed authorisation as the law requires.
Your rights and how to use them
- Confirm and access: whether we collect, share or sell your consumer health data (we don’t sell it), the list of third parties we share it with, and a copy. Use Settings → Your data → Download my data, or email us.
- Withdraw consent: switch off cycle tracking or disconnect a device in Settings, or withdraw your health-data consent in Settings → Privacy & consent. Coaching can’t continue without health data, so withdrawing that consent ends your coaching, and we then delete your account.
- Delete: Settings → Your data → Request account deletion, or email us. We delete it from our systems and from our providers’ within 30 days, and from backups as they roll over ([Fill in: Backups]), with every deletion re-applied if a backup is ever restored.
- Appeal: if we turn down a request, reply to our answer to appeal. We respond within 45 days. If you’re still not satisfied, you can contact your state Attorney General (for Washington: atg.wa.gov).
We answer within 45 days (we may extend once by 45 more if necessary and will tell you). Contact: [Fill in: Privacy and support email], or [Fill in: Mailing address].
We don’t use geofences around health care facilities.
This page is a draft prepared for review by a qualified lawyer and still contains placeholders.