Consumer Health Data Privacy Notice

This notice applies to consumer health data, and is written for residents of Washington (under the My Health My Data Act) and Nevada (under SB 370). Anyone may rely on it — we apply the same practices everywhere — but only those residents have the specific statutory rights in §6.

• Body measurements — weight, body-fat estimates, circumference measurements, and similar.
• Progress photos.
• Injuries, physical limitations, and rehabilitation notes.
• Nutrition plans, food logs, calorie and macronutrient targets.
• Workout history and performance data that reflects physical condition.
• Anything a coach records in session notes about a client’s health.

• A coach enters it about their client.
• A client enters it themselves through the client portal.
• It is calculated from data already entered — for example a body-composition estimate from measurements you provided.

We do not buy health data, obtain it from data brokers, or collect it from third-party sources.

We do not sell consumer health data. Washington law requires valid authorisation, on a specific form, before any sale. We have never sold health data and have no plans to, so we have never sought such an authorisation.

Health data reaches these processors, and no one else:

Each is bound by contract to process it only on our instruction. We would also disclose health data if legally compelled by valid process, and we would tell you unless prohibited from doing so.

• Right to know. Get a list of every third party we have shared your consumer health data with, and how to contact them.
• Right to withdraw consent. Withdraw consent to collection and to sharing, at any time.
• Right to delete. Ask us to delete your consumer health data. We honour this across our live systems and instruct our processors to do the same. Encrypted backups roll over within 30 days.
• Right against discrimination. Exercising these rights does not change the service or price you receive.

Health data lives as long as the coach keeps the client record. Deleting a client, or the account, removes it from live systems and it clears encrypted backups within 30 days. The full schedule is in §8 of the Privacy Policy.

• Encrypted in transit (TLS 1.3) and at rest (AES-256).
• Progress photos held in access-controlled storage, never on a public URL.
• Row-level security policies so one coach cannot read another coach’s client records.
• Access limited to the coach, the client, and the small number of staff who need it for support.

You are the controller of your clients’ health data. That carries obligations we cannot discharge for you:

• Get consent before recording health data, and separate consent before sharing it with anyone.
• Tell clients what you record and why.
• For clients under 18, get verifiable consent from a parent or guardian first.
• Handle access and deletion requests from your own clients — you can action them directly in the app.
• If you serve Washington residents, you may need your own consumer health data privacy notice.

Our Data Processing Agreement sets out what we do and do not do on your behalf.

Changes to this notice are posted here with an updated date. Material changes are notified by email or in-app notice before they take effect, and we do not apply a change retroactively to health data already collected without asking you first.