Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy ('Policy') applies to personal information that may be considered consumer health data under US laws enacted by certain states, including Washington’s My Health My Data Act and the Nevada Consumer Health Privacy Law (SB 370) ('Consumer Health Laws').

This Policy supplements BetterMe’s Privacy Policy and applies only to customers covered by Consumer Health Laws. For general questions, please review BetterMe’s Privacy Policy.

Categories and sources of consumer health data
Purposes and intended uses of consumer health data
Disclosing consumer health data
Your privacy rights
Exercising your rights
Appeal
Changes to this Policy

1. Categories and sources of consumer health data

When you use our mobile applications ('App'), websites and the services provided through them (together 'Services'), we collect information that may be considered consumer health data under Consumer Health Laws.

For the purpose of this Policy, consumer health data means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status.

We may receive consumer health data from the following sources:

(i) Directly from you: for instance, when you register in the App.

(ii) From third parties: for example, when you allow us to access Apple Health App data.

(iii) Automatically when you use our Services or devices: for instance, data collected from your BetterMe Fitness Tracker or Smart Scale.

(i) Data you directly provide to us

When you register for and use our Services, including during the onboarding process and filling out questionnaires or quizzes, you may provide us with data that may be considered consumer health data. For example, we calculate your Body Mass Index (BMI) based on the height and weight you provide to personalize your plan.

Consumer health data may also be collected when you decide to opt-in for our specialized fitness programs or meal plans, specifically:

Diabetes meal plans: we may ask whether you need a meal plan for diabetes and the type of diabetes to tailor our Services and provide an appropriate meal plan.
Specialized programs: we may ask if you wish to include specialized programs such as those for limited mobility, limb loss, prenatal, or postnatal needs, allowing us to provide Services that address your specific requirements.
Cycle insights: to provide you with our cycle tracking feature and corresponding insights, we may ask for information about your cycle to generate predictions, such as the estimated start date of your next period and other cycle-related insights.

(ii) Data received from third parties

We may receive data from third parties, in particular, Apple Health App (and Apple Motion & Fitness API) or Health Connect (together the 'Health App').

Provided you give express permission on your device, we may receive (read) or/and write (share) data about your activity with/from Health App. In some of our Apps, you may decide to allow us to read (receive) the following information from the Health App: the number of steps, distance covered, weight, and dietary energy intake, and any other data you select on the consent screen.

If you grant us access to write data to (share with) Health App, we will transfer to Health App information on your workouts, weight, and dietary energy (calories intake). The pieces of data covered by Health App’s scope will be indicated to you by Apple or Google on their native pop-up screens, over which we have no control.

Before you decide to share your data with the Health App, we encourage you to review their privacy policy, as your data will be subject to those policies. For more information on the Apple Health App, please see http://www.apple.com/ios/health/, and and for more information on Health Connect, please see https://health.google/health-connect-android/. You can withdraw our access to read or write data from the Health App at any time directly in the Health App.

(iii) Data we collect automatically

We may automatically collect certain data when you use our Services or devices. This includes, for example:

Fitness Tracker data. When you connect your BetterMe Fitness Tracker to the App, we may process the data collected by the device, such as step count, heart rate measurements, heart rate variability (HRV), and sleep statistics.
Smart Scale data. We also enable you to sync your data from your BetterMe Smart Scale with the App to access enhanced tracking features. This weight-related data may include BMI (body mass index), body fat and visceral fat percentage, muscle mass, and water percentage.

For data collected from these devices, we will strive to ask you for your consent to process such data before collecting it (usually, on a pop-up screen that emerges when you connect the device to the App).

2. Purposes and intended uses of consumer health data

We may collect and use your consumer health data for the following primary purposes:

(i) To provide our Services.

Our primary purpose for collecting your consumer health data is to enable your seamless access to and use of our Services. This includes customizing your experience by adjusting content and providing offerings tailored to your personal preferences or needs. As a result, you gain access to, for example, a diabetes nutrition plan or a customized meal plan offer (in the in-App chat) that fits your specific requirements.

(ii) For communications related to your Services use.

We may also use your consumer health data to communicate with you regarding your engagement with our Services. For instance, we may send push notifications that include reminders and motivational messages to support your training and nutrition plan, or provide other relevant information about the Services. An example is receiving a daily push notification at a specific time to remind you to work out. You can opt out of push notifications by adjusting your device settings.

With your consent, we may also use your consumer health data to research and analyze your use of the Services. This enables us to better understand what features and training plans of the Services are most popular, and how users interact with our Services. We may develop and introduce new features into the Services based on this data. We may also process your data for these purposes if you consent to participate in a specific study, research initiative, or similar program.

3. Disclosing consumer health data

We may disclose each category of consumer health data described above to achieve the listed purposes and uses. For example, we might disclose your consumer health data to provide the Services you've requested.

We may disclose your consumer health data to:

Our affiliates: our companies that work together to provide you with Services;
Our service providers (processors): we engage them to help us provide, improve, and support our Services. They act solely on our instructions. For example, we use Amazon Web Services to host personal data and enable our Services to operate and be distributed. For more details about our service providers, refer to BetterMe’s Privacy Policy;

In certain circumstances, it may be necessary to share your consumer health data with third parties, for example, to comply with applicable law or to protect your rights.

4. Your privacy rights

You have the following rights regarding your consumer health data:

Right to be informed: you have the right to confirm whether we are processing your consumer health data. We strive to follow the transparency requirements and provide most of the information in this Policy and BetterMe’s Privacy Policy. However, if you have any questions about our data processing practices or if you would like more details about how we use your personal data, please contact us.
Right of access: you have the right to access your consumer health data. If you would like to receive a copy of your data that we process, please send us a data access request. Alternatively, depending on the Service you use, look for a data access privacy feature that is usually available in the profile section.
Right to request correction: you have the right to request that we correct inaccurate information about you. You can log into your profile to update your information or contact us at privacy@betterme.world.
Right to delete: You can request erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time (for example, information about your requests to us); in such event, we will fulfill your request in relation to a portion of the data within the timeframes required for exercising data deletion requests and to another portion of the data after we have complied with our retention obligations (for example, after the end of data retention period obligation for request data).
Right to withdraw: you have the right to withdraw your consent to our collection and sharing of your consumer health data. You may withdraw or update your preferences regarding the processing of your consumer health data at any time by contacting us at privacy@betterme.world or by adjusting your preferences directly in the App settings. If your consent is necessary to provide the Services in full (rather than for a specific feature), withdrawing your consent may result in the inability to continue using certain Services. In this case, you may also request the erasure of your data at any time by contacting us at privacy@betterme.world or using the App settings.

5. Exercising your rights

To exercise any of the available privacy rights, please send a request to privacy@betterme.world or use the privacy features available in our Services.

Verification. To ensure that we properly handle the requests you make regarding your rights, we are required to verify those requests. Depending on the type of request and the Service used by you, this may include your name, age, email, date of subscription purchase, date of last activity, date of account creation or other Service use data that will reasonably identify you as an owner of the account and other relevant data. We may also ask you for additional proof of identity, if necessary, but we strive to require as little as possible (for example, for some requests we will send you a verification code or link).

An authorized agent. You may also designate an authorized agent to exercise your rights on your behalf. If you have provided an authorized agent with a power of attorney, we will work directly with your authorized agent to complete your request. Where you have not provided an authorized agent with a valid power of attorney or similar authorization, we will reach out to you directly to confirm the authorized agent’s authority and collect the verification information. The authorized agent shall verify the identity of both themselves and the consumer.

6. Appeal

Under the Consumer Health Law, if your privacy request is denied, you have the right to appeal that decision within a reasonable timeframe.

To appeal our decision regarding your request, you can contact us, clearly indicating 'USA PRIVACY APPEAL REQUEST' in your message.

While submitting your appeal, please include a copy of or otherwise specifically reference our decision on your privacy request, so we can adequately review and address it.

7. Changes to this Policy

We may modify this Policy from time to time. If we decide to make material changes to this Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Policy.

Last updated: 24 June 2025