Consumer Health Data Privacy Policy

Effective date: 7 October 2026 · Policy version: 2026-10-02

This policy covers "consumer health data" as defined by Washington's My Health My Data Act and similar laws in Nevada and Connecticut. It adds to our Privacy Policy (recomphealth.org/privacy).

Recomp Health does not sell consumer health data.

Who we are: Recomp Health Limited, 21 Waimauku Station Road, Waimauku, Auckland 0812, New Zealand · privacy@recomphealth.org

1. Consumer health data we collect

• →Body measurements: weight, and waist, hip, chest, neck and thigh measurements.
• →Body composition: body-fat percentage, lean mass, fat mass, and smart-scale readings.
• →DEXA results: regional and total body composition, bone density, visceral fat.
• →Laboratory results you choose to enter, such as HbA1c, glucose, lipids and hormones.
• →Medications and injections: medication name, recorded dose, injection site and date, and any side effects you choose to record.
• →Nutrition: calories, macronutrients, fibre, water and meals.
• →Exercise and training: workouts, sets, cardio sessions and steps.
• →Sleep and heart data from Apple Health, if you allow each type: time asleep, time in bed and, when the source provides them, minutes in each sleep stage; heart rate variability; and resting heart rate. We store these per day, as the source reports them, with the name of the app or device that recorded them (for example, Apple Watch).
• →Readiness entries, such as energy, sleep quality, soreness and stress.
• →Progress photos, if you upload them.
• →Trends and changes we calculate from the above and show back to you. We don't infer medical conditions.
• →Questions about your own data you send to Recomp AI, if you turn it on.

2. Where it comes from

• →You, when you log or upload information.
• →Apple Health or Google Health Connect, only if you connect them and only for the types you allow. Recomp reads; it never writes. Sleep and heart data come from Apple Health only, on iPhone.
  • To tell you when a connected app or device has stopped sending data, the app checks step counts from each source on your phone. Those per-source step counts stay on your phone; we don't store them on our servers.
• →Your device, for your time zone. We use it for day boundaries and to show the right crisis-line numbers.

3. Why we collect and use it

• →To provide the features you ask for: recording, tracking, charts and trends, reports and exports, and images you choose to share.
• →To provide optional AI summaries and answers about your own data, only if you turn AI on.
• →For sleep and heart data from Apple Health: to show you your own values and where they came from. We don't currently send them to Recomp AI.
• →To keep the Service secure and working.

We collect and process consumer health data only with your consent, which you give in the app before using it. We do not use it for advertising, and we do not use it to make decisions about you that have legal or similarly significant effects.

4. Who we share it with, and why

We share consumer health data with these providers only with your consent, and only so they can provide services to us. Our contracts don't let them use it for anything else, including advertising or sale.

Sharing you choose. When you share an image, send a report to a clinician, dietitian or coach, or export your data, you choose who receives it.

5. Your rights

You can:

• →confirm whether we collect, share or sell your consumer health data;
• →access it, including a list of the third parties and affiliates we have shared it with, and how to contact them;
• →delete it, including from the providers we have shared it with (section 7);
• →withdraw your consent to its collection and sharing (section 6).

How to ask:

• →In the app:
  • Settings → Privacy & Consent lets you withdraw consent to Health Data Collection or Health Data Sharing, turn AI off, and Delete my account and data;
  • the Export Centre lets you download your data.
• →By email: privacy@recomphealth.org, from your account email.

What happens next:

• →Response time: we respond within 45 days. If we reasonably need longer, we can extend once by 45 days and will tell you.
• →Appeals: if we decline your request, reply with "Appeal" in the subject line. We will answer within 45 days. If you're not satisfied:
  • Washington residents can contact the Washington State Attorney General (atg.wa.gov/file-complaint);
  • residents of other states can contact their own state Attorney General.

6. Withdrawing consent

Withdrawing consent to collection or sharing stops us collecting and processing your consumer health data. The app can't work without that processing, so it pauses until you consent again. Withdrawing does not delete information already collected. To delete it, use Delete my account and data.

7. Deletion

What we delete. When you delete your account or ask us to delete your consumer health data, we delete it from our active systems. That includes your health records, measurements, DEXA and laboratory records, medication and injection records, nutrition, exercise and readiness records, sleep and heart-rate records, progress photos, stored AI-generated summaries, reports and share links, and your account and profile. We also ask our service providers to delete it, or it is removed under their retention schedules, as required by applicable law:

• →RevenueCat and PostHog: we ask them to delete your record when you delete your account;
• →Anthropic: keeps AI request data for up to 30 days, then deletes it under its commercial terms;
• →Resend: keeps email data for 30 days, then deletes it;
• →Sentry: receives no consumer health data.

Backups. Our database backups are encrypted, and each one is permanently deleted automatically about 60 days after it is made. They can't be edited to remove one person's records, so your data leaves our backups when the backup that holds it expires. Backups aren't restored for ordinary use. If one is ever restored for disaster recovery, we delete every account that had already been deleted before the restored data is used.

State-specific deletion rules. Some states set specific rules for deleting consumer health data. We apply the rules that cover your request.

• →Washington residents. We delete your consumer health data from our active systems, and notify the processors and third parties we shared it with so they delete it, as the My Health My Data Act requires. Where consumer health data is held in archived or backup systems, Washington law allows deletion from those systems to be delayed for up to six months from when we authenticate your request. Our backups expire well within that period (see "Backups" above).
• →Nevada residents. We delete your consumer health data from our active systems and notify the processors and third parties we shared it with so they delete it, as Nevada law requires. Any data in backup systems is deleted as Nevada law permits; in practice that happens when our backups expire (see "Backups" above).
• →Connecticut residents. We apply the deletion requirements for consumer health data and sensitive data under Connecticut law, including deletion from processor systems as the law requires, subject only to the exceptions that law allows. Data in backups leaves them when our backups expire (see "Backups" above).

We keep a record that a deletion took place: the date, the outcome of each deletion step, and your account ID in one-way hashed form only. It holds none of your health information and no email address.

8. Sale, advertising and geofencing

We do not sell consumer health data. We do not use it for targeted advertising. We do not use geofencing around health-care facilities.

9. Contact

Recomp Health Limited · 21 Waimauku Station Road, Waimauku, Auckland 0812, New Zealand · privacy@recomphealth.org