Consumer Health Data Privacy Policy

1. Scope

This policy supplements our Privacy Policy and describes how A3J Technology LLC handles “consumer health data” as defined by Washington’s My Health My Data Act and similar state laws. It applies to all A3J apps and our website.

2. Consumer health data we collect and why

We collect only what the features you use require. [Remove any row an app does not collect.]

3. Sources

You (what you enter in the app), your device and the apps you connect such as Apple Health or wearables (only with your permission), and inferences our apps generate from that information.

4. Consent

We ask for your consent before collecting consumer health data, except where it is necessary to provide a feature you request. We ask for separate consent before sharing it, except with processors that handle it on our behalf. You can withdraw consent at any time in the app or by emailing us.

5. How we share consumer health data

• Processors: [e.g., hosting/database provider], which store and process data only on our instructions and under contract.
• Third parties: only with your separate consent or at your direction, such as when you export or share a workout.
• Affiliates: we do not share consumer health data with affiliates. [Confirm; if data will ever be shared with another AXA Ventures company, list it here and obtain separate consent.]

We do not sell consumer health data. We do not use it for advertising, and we do not geofence around health care facilities.

6. Your rights

• Confirm whether we collect, share, or sell your consumer health data.
• Access your data, including a list of all third parties and affiliates we have shared it with and how to contact them.
• Withdraw your consent.
• Delete your data. We will notify processors and third parties, and remove it from archives and backups within 6 months.

To make a request, use [in-app path] or email privacy@a3jtech.com. We will verify your identity and respond within 45 days (extendable once by 45 days when reasonably necessary, with notice). Requests are free up to twice a year.

7. Appeals

If we decline your request, email privacy@a3jtech.com with “Appeal” in the subject line. We will respond in writing within 45 days, explaining our decision. If your appeal is denied, you may contact the Washington State Attorney General.

8. Security

We restrict access to consumer health data to employees, processors, and contractors who need it to provide the Services, and protect it with reasonable administrative, technical, and physical safeguards.

9. Changes

We will post updates here. We will obtain new consent before collecting or sharing consumer health data for a new purpose.

10. Contact us