Consumer Health Data Privacy Notice

Effective Date: June 14, 2026 | Last Updated: June 14, 2026

🩺 In Short

This Notice supplements our Privacy Policy and explains how Flexwell handles "consumer health data" under laws such as Washington's My Health My Data Act (MHMDA), Nevada's SB 370, Connecticut's health-data amendments, and similar laws. We collect this data only with your opt-in consent, never sell it, and never share it with advertisers. This Notice governs to the extent it conflicts with our general Privacy Policy regarding consumer health data.

1. What Is Consumer Health Data

"Consumer health data" is personal information that identifies your past, present, or future physical or mental health status. For Flexwell, this includes:

The supplements, vitamins, and other products you track, including dosages and timing;
Your daily adherence logs (which products you take or skip);
Health goals and wellness notes you enter;
Health and fitness metrics you connect via Apple HealthKit (e.g., heart rate, sleep, steps, HRV, blood oxygen);
Inferences we generate from the above to provide insights and Flex guidance.

2. Sources of Consumer Health Data

You: Information you enter directly into the app.
Your device / Apple HealthKit: Metrics you explicitly authorize Flexwell to read.

We do not collect precise geolocation for health purposes, and we do not use geofencing around healthcare facilities.

3. How We Use Consumer Health Data

To provide tracking, reminders, streaks, and insights you request;
To power Flex's personalized, health-contextualized guidance;
To check your stack for potential interactions;
To secure, maintain, and debug the Service;
To comply with law.

We do not use consumer health data for advertising, marketing, profiling for ads, or audience building.

4. How We Share Consumer Health Data

We share consumer health data only with service providers/processors who act on our instructions under contract and do not use it for their own purposes. Currently these include:

Processor	Purpose
OpenAI, Anthropic	Generating Flex's responses you request
Railway	Encrypted cloud hosting/storage

We do not sell consumer health data, and we do not disclose it to advertising networks, data brokers, or for targeted advertising — ever. Our Health Data Firewall blocks consumer health data from reaching any advertising, analytics, attribution, or crash-logging tool.

5. Your Consent

By enabling health-related features or connecting Apple HealthKit, you provide separate, opt-in consent to:

(a) Collection: our collection of consumer health data to provide the features you request; and
(b) Sharing with processors: our sharing of that data with the processors listed above solely to deliver those features.

You may withdraw consent at any time by disconnecting HealthKit, turning off the relevant features, or deleting your account. Withdrawal does not affect processing already performed.

6. Your Rights

Right to access the consumer health data we have collected about you;
Right to withdraw consent to our collection and sharing;
Right to delete your consumer health data;
Right to appeal a denied request.

To exercise any right, email hello@flexwell.com. We will respond within the timeframe required by applicable law. You may also export and delete HealthKit data directly via iOS Settings > Privacy & Security > Health.

7. Security & Access Controls

We protect consumer health data with encryption in transit and at rest, role-based access controls, restricted administrative access, and logging. We retain consumer health data for the life of your account and delete it within 30 days of account deletion; encrypted backups purge within 90 days.

8. Contact

Micawber Media LLC
1885 FM 2673, Suite H31
Canyon Lake, TX 78132
Email: hello@flexwell.com