Consumer Health Data Privacy Policy

This policy is for residents of Washington and Nevada, and for anyone whose consumer health data we collect in those states. It supplements our Privacy Notice. "Consumer health data" means personal information that identifies your past, present or future physical or mental health status. FIT TRAINR LLC ("FitTrainr", "we") publishes it under the Washington My Health My Data Act and Nevada law (NRS 603A.400 to 603A.550).

1. Consumer health data we collect

We collect the following categories when you or your coach use the matching feature:

• Body metrics: weight, body fat percentage, muscle mass, body mass index, resting heart rate, blood pressure, fasting glucose, and notes you add.
• Tape measurements of the body, and your age and height if a form asks for them.
• Progress photos.
• Daily logs: steps, sleep hours, water, cardio minutes and calories, morning weight, and your own ratings of appetite, digestion and training performance.
• Nutrition records: food logs, comments you add to meals, custom foods, meal plans, calorie and macronutrient targets, food allergies you report, supplement plans with their amounts and timing, and your record of supplements taken or skipped.
• Training records: workout plans, logged sets, reps, weights and effort ratings, and goals.
• Health-marker values you type into a form, such as numbers from bloodwork you obtained yourself (for example cholesterol, glucose, HbA1c, hormone, thyroid, vitamin D, ferritin or CRP values).
• Answers to check-in, intake, daily-log and other forms your coach sends you. Depending on the questions your coach chooses, these can include digestion and bowel habits, sleep, stress, injuries, and reproductive or sexual health information such as changes to your menstrual cycle or your libido. Coaches can also write their own questions.
• Injury and exercise-restriction notes, and other notes your coach writes or dictates about you.
• Health-related content you choose to put in messages to your coach or in AI features, including nutrition-label photos you scan.
• If you contact a coach through a public enquiry or booking form without an account: your goal, your main challenge, and anything you write in the notes field.

2. Why we collect it and how we use it

We collect and use this data only to provide the service you asked for:

• to store your records and show you your history and trends;
• to make your records available to the coach you work with, or have contacted, so they can coach you;
• to produce the AI output you ask for;
• to send you and your coach notifications about your activity;
• to keep the Service secure, prevent abuse, and answer your support requests;
• to meet legal obligations.

We do not sell consumer health data. We do not use it for advertising or share it with advertisers. We do not use it to train AI models.

3. Where the data comes from

• You, when you log data, upload photos, complete forms, write messages, or submit a coach's enquiry or booking form.
• Your coach and your coach's organisation, when they record information about you, such as notes, injury notes, goals, plans and supplement plans.

We do not obtain consumer health data from data brokers, from other websites or apps, or from other outside sources.

4. Consumer health data we share, and with whom

We share all of the categories in section 1 with one category of third party: the fitness, nutrition or wellness coach you have joined or contacted on FitTrainr, and that coach's organisation. Administrators of the organisation can see each client's records. We share the data because seeing your records is the coaching service you requested. Your coach is an independent professional, not a FitTrainr employee.

If you change coaches, your new coach can see the records you logged yourself before the change, such as body metrics, food logs, workouts and photos. A coach who no longer works with you loses access.

We do not share consumer health data with any affiliate.

We also disclose information when the law requires it, as described in section 3.4 of the Privacy Notice.

5. How the data is processed

The data is stored on Google Cloud in the United States. Service providers process it on our behalf and only on our instructions:

• Google Cloud, for hosting, databases and file storage.
• Google Vertex AI, for AI features. An AI feature receives what you or your coach type or upload into it, and the plan details needed to answer. We do not send your form answers, health-marker values, body metrics or progress photos to AI features.
• Google Speech-to-Text, to transcribe voice notes a coach dictates.
• Our email, text-message and push-notification providers, which deliver notifications. A notification can include a message preview, or your name and the title of a form you submitted.

Our Subprocessors page gives more detail. Authorised FitTrainr staff access the data only when needed to run the Service, keep it secure, or help you. To prevent abuse we keep the first part of each AI prompt for 90 days, and authorised staff can review it.

No third party may collect consumer health data about you over time and across different websites or online services when you use FitTrainr.

6. Your rights and how to use them

You have the right to:

• confirm whether we are collecting, sharing or selling consumer health data about you;
• access that data, including a list of every third party we have shared it with and a way to contact each of them;
• withdraw consent, and ask us to stop collecting or sharing your consumer health data;
• have your consumer health data deleted.

To use these rights:

• Delete your account: in the app, open Profile and choose Delete account. Your account, and the records held in our database, are deleted immediately. Progress-photo files, your messages with your coach and your AI chat history are not yet removed automatically; we delete them within 30 days. Signed contracts are kept by the coach you signed with as legal records. Backup copies are overwritten within 30 days.
• Review or change your data: you can see your records in the app, and delete food, water, photo and supplement entries yourself. To correct or delete any other record, email us.
• Any other request, including a copy of your data, the list of third parties, stopping sharing with a coach, or deleting specific records: email support@fittrainr.com from the email address on your account. If you have no account, email us from the address you used on the coach's form. You do not need to create an account. We may ask for more information to confirm your identity.

Stopping sharing with a coach ends that coach's access to your records and ends their coaching through FitTrainr.

When we delete your data, we notify your coach and our service providers of the deletion.

We respond within 45 days. If a request is complex we may take up to 45 more days, and we will tell you why within the first 45. Requests are free at least twice a year. We will not treat you differently for using these rights.

7. Appeals

If we refuse a request, you may appeal by replying to our decision or emailing support@fittrainr.com with the subject "Privacy appeal". We will answer in writing within 45 days and explain our reasons. If we deny your appeal, you may complain to the Washington Attorney General at atg.wa.gov/file-complaint or contact the Nevada Attorney General at ag.nv.gov.

8. Changes to this policy

If we make a material change, we update this page and its effective date, record the change in our legal changelog, and email account holders. We will not collect, use or share a new category of consumer health data, or use it for a new purpose, without telling you first and getting your consent where the law requires it.

9. Contact

Email support@fittrainr.com.