Consumer Health Data Privacy Policy

Draft — not in force. This document is still being prepared and has not been reviewed. It does not govern anything. The version and date above are provisional.

This policy applies to consumer health data as defined by Washington's My Health My Data Act, Nevada's SB370, and Connecticut law. It describes what health data RepForge collects, where it comes from, why we collect it, who we share it with, and how you exercise your rights over it. It supplements our general Privacy Policy, and where the two differ for health data, this one governs. [COMPANY NAME], a [STATE] limited liability company at [ADDRESS], is the regulated entity responsible for this data. Contact [PRIVACY EMAIL].

1 · The categories of consumer health data we collect

Bodily functions, vital signs and measurements. Body weight; body-fat percentage; lean body mass; height; resting heart rate; heart rate during exercise; heart-rate variability; sleep duration and sleep analysis; active energy expenditure; exercise minutes; step count; and distance travelled.

Physical and bodily condition you report to us. Pain you flag during a workout — the body areas affected, the severity you selected, any note you wrote, and when you flagged it. Physical limitations or injuries you describe in your profile, and the body areas you mark as affected. Exercises you have chosen to avoid.

Health-related self-assessments. Your own 1–5 ratings, recorded in a check-in, of sleep quality, energy, hunger, stress, training quality, and motivation. And, in the daily recovery pulse, your 1–5 ratings of sleep quality, energy and muscle soreness, together with hours slept, for each day.

Health-related interventions and goals. Your training plans, cardio prescriptions, daily macronutrient targets, target body weight, and physique-preparation phase, event type and event date.

Bodily characteristics. Biological sex and date of birth.

Precise location associated with a health activity. Your GPS route during an outdoor cardio workout you started, used to calculate distance and pace. The full-precision route is written to Apple Health on your device. A simplified outline of it — smoothed to roughly 10 metres and capped at 500 points — is also stored in your RepForge account so the app can draw your route map, alongside the session summary. Tracking runs only while a session you started is active, including when your phone is locked, and stops when you finish it.

Inferences. Figures RepForge calculates from the above — readiness and recovery trends, adherence percentages, estimated calories burned, personal records, and progression suggestions.

2 · Where this data comes from

Directly from you, when you enter it during onboarding, log a workout, complete a check-in, flag pain, or describe a limitation.

From your device, with your permission — Apple Health, when you connect it and approve individual data types, and your device's GPS when you start an outdoor cardio workout.

Generated by us, when RepForge calculates an inference from the data above.

We do not buy consumer health data, and we do not obtain it from data brokers, advertising networks, social networks, or any other third-party source.

3 · Why we collect it, and how we use it

We collect and use consumer health data only to provide RepForge to you, specifically to:

• Generate and adapt your training plans, cardio prescriptions and macronutrient targets.
• Record what you actually did and show you your progress, personal records and adherence.
• Avoid programming exercises you have flagged as painful or asked to avoid, and suggest substitutes.
• Pre-fill screens with figures you or your devices already have, so you retype as little as possible.
• Calculate recovery, readiness and check-in review views.
• Send you only the reminders you have switched on.

We do not use consumer health data for advertising, marketing, profiling for third parties, research, training AI models, or any purpose unrelated to providing you the app.

4 · Who we share it with, and who we do not

We share consumer health data only with the service providers that operate the app on our behalf, under contracts that limit them to that purpose:

• Google LLC — Firebase Authentication, Cloud Firestore, Cloud Functions, App Check and Cloud Messaging, which store and synchronise your data and deliver notifications.
• Google LLC (Gemini via Firebase AI Logic) — only if you use AI Import, and only the programme image or document you choose to submit.
• Apple Inc. — HealthKit data remains on your device under Apple's control and your authorisation; Apple also handles push delivery and subscriptions.

We do not share consumer health data with any other category of third party. We do not share it with advertisers, advertising networks, data brokers, social networks, analytics providers, insurers, employers, or researchers. RepForge contains no analytics, tracking, or advertising software of any kind.

Other RepForge users never see your consumer health data. Social features share only your handle, display name and the workout summaries you switched on. Your body data, pain reports, check-ins, macronutrient targets and limitations are never visible to anyone else.

5 · We do not sell consumer health data

We do not sell consumer health data, and we will not. We have never sold it.

Washington law requires your separate, signed, revocable authorisation before any sale of consumer health data, distinct from your consent to collection. We do not seek such an authorisation because we do not sell this data. If that ever changed, we would have to obtain a valid authorisation from you first, and you could refuse or revoke it without losing access to RepForge.

6 · Consent, and how to withdraw it

We collect consumer health data only with your consent, and only the categories needed to provide the features you use. Consent is given at account creation and again, specifically, at the point each source is enabled — iOS asks you to approve each Apple Health data type individually, and asks separately for location.

You can withdraw consent at any time, and doing so does not require contacting us:

• Apple Health — revoke any or all data types in the Health app under Sharing ▸ Apps ▸ RepForge.
• Location — turn off location access for RepForge in iOS Settings, or simply do not start a GPS workout.
• Check-ins, pain reports and limitations — these are optional; leave them blank, or delete what you have entered.
• Everything — delete your account in the app.

Withdrawing consent stops future collection. To remove data already collected, use the deletion right below.

7 · Your rights over this data

You have the right to:

Know and access. Confirm whether we collect, share or sell your consumer health data — we collect and share as described above, and never sell — and get a list of all third parties we have shared it with, together with contact details for each.

Delete. Have your consumer health data deleted from our records. Deletion is immediate in our live systems, and affected backups roll off within [N] days.

Withdraw consent to collection and to sharing, as described in Section 6.

Not be discriminated against for exercising any of these rights. Nothing you do here affects your price, your access, or the features available to you.

How to exercise them. Deletion is built into the app — Settings ▸ Delete account — and is immediate. The in-app export covers your training history; for a copy of your check-ins, body composition data, recovery ratings, pain reports and limitations, or for anything else, email [PRIVACY EMAIL] with the subject "Consumer Health Data Request".

We will verify the request comes from you, normally by confirming control of the account email address. We respond within 45 days, and may extend once by a further 45 days where the law permits, telling you why. An authorised agent may act on your behalf with written proof of authority. There is no charge.

Appeals. If we decline, we will explain why in writing and tell you how to appeal. Reply with "Appeal" in the subject line and we will respond within 45 days. If you are still unsatisfied you may complain to the Washington State Attorney General at https://www.atg.wa.gov/file-complaint, or to the Attorney General of your own state.

8 · Deletion — what actually happens

When you delete your account, we permanently erase the consumer health data this account owns: your profile body data and limitations, workouts and cardio sessions, measurements, personal records, preps and their check-ins, macronutrient and peak-week records, daily recovery ratings, and pain reports. Deletion is immediate in our live database, and affected backups roll off within [N] days.

Apple Health data that stayed on your device is under your control in the Health app, and deleting your RepForge account does not remove it from there — nor does it remove workouts RepForge previously wrote into Apple Health, which are yours to keep or delete in the Health app.

The only record we keep is that an account accepted a version of our legal documents on a date. It contains no health data.

9 · How long we keep it

We keep consumer health data only while your account exists and you continue to use the features that produce it, and we delete it when you delete your account or the specific data. We do not retain it for any secondary purpose.

10 · Security

Consumer health data is stored by Google Cloud, encrypted in transit and at rest, and protected by per-user access rules that permit only your authenticated account to read or write it. Requests are attested by Firebase App Check. Access by us is limited to what is necessary to operate and support the service.

11 · Changes to this policy

We will not collect, use or share consumer health data for a materially new purpose without first obtaining your consent. If we change this policy we will bump the version, publish the change here, and notify you in the app. The version and effective date are at the top.

12 · Contact

[COMPANY NAME] [ADDRESS] [PRIVACY EMAIL]

For consumer health data requests, put "Consumer Health Data Request" in the subject line.