Consumer Health Data Privacy Notice

1. Our Collection and Use of Consumer Health Data

The term “Consumer Health Data” as used in this Consumer Health Notice means any personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status as defined in the Washington My Health My Data Act or the Nevada Consumer Health Data Privacy Law (collectively, the “Consumer Health Privacy Laws”). The Consumer Health Data we collect depends on the context of your interactions with us and, in most cases, is information you decide to share with us. Consumer Health Data does not include information that is considered deidentified under the Consumer Health Privacy Laws.

Examples of Consumer Health Data that we may collect include:

• Information about your health-related conditions, symptoms, experiences, diagnoses, testing, or treatments shared with us through our coaching application, intake forms, in-app messaging with your coach, or our customer support channels.
• Information about your bodily functions, vital signs, symptoms, or measurements, including heart rate, body weight, body composition, and active energy expenditure shared with us through Apple HealthKit when you opt in to share that data.
• Information about your fitness goals, exercise history, current training routine, equipment access, and physical readiness shared with us through our training application form.
• Workout activity logged or completed in the App or Portal, including sets, reps, weights lifted, time spent, exercises performed, perceived exertion, and workout completion records.
• Form check videos, photographs, or other media you upload to the Service in connection with personal training.
• Any health-related information you share with us through customer support, coaching check-in calls, or in-app messaging.
• Other information that may be used to infer or derive data related to the above or other health-related information.

We may process and use your Consumer Health Data (including with your consent where required by the Consumer Health Privacy Laws) for the following purposes:

• To provide and manage the Service, including delivering workouts, programs, coaching, and other features you request.
• To personalize your training experience, including tailoring workouts, programming recommendations, progressions, and coaching feedback to your stated goals, history, and logged activity.
• To enable communication between you and your coach for the purpose of providing coaching, accountability, and form check feedback.
• To improve, maintain, and develop the Service.
• To respond to your questions, concerns, and other requests for assistance.
• To verify your identity and entitlement to the Service.
• To create anonymous, aggregated, or deidentified data that can no longer reasonably be linked to you.

We do not use Consumer Health Data for advertising. We do not sell Consumer Health Data. We do not share Consumer Health Data with third parties for the purpose of targeted advertising or for any purpose unrelated to providing the Service to you. We do not engage in geofencing around any health facility.

We may combine your Consumer Health Data with other personal information we collect directly from you or receive from other sources to provide the Service.

2. Sources of Consumer Health Data

We collect Consumer Health Data primarily from you, through your direct interactions with the Service. Specific collection points include:

• The training application form at strongherco.com/train/apply, where you provide fitness goals, exercise history, current routine, equipment, readiness, and other intake information.
• The free workout claim flow at strongherco.com/train/free-workout, where you provide your email address in exchange for access to a free workout.
• The App, the Portal, and other places where you log workouts, sets, reps, weights, or completion records.
• Apple HealthKit, when you opt in to share heart rate, active energy, body mass, body fat percentage, and workout session data from your Apple device.
• In-app messaging between you and your coach, where you may share health-related context, questions, or feedback.
• Customer support communications with us via email at support@strongherco.com or through any in-Service feedback channels.
• Coaching check-in calls, video form-check uploads, and any other coaching communications, where applicable to the level of service you have purchased.

We may also receive Consumer Health Data indirectly through service providers acting on our behalf in the course of operating the Service. For more information, please see the “What kind of Personal Information do we collect?” section of our Privacy Policy.

3. Our Disclosure of Consumer Health Data

We may share the categories of Consumer Health Data set forth above as follows:

• With Your Coach: When you purchase a coaching tier that includes a human coach, we share your relevant Consumer Health Data (workout history, application responses, in-app messages, form check uploads, and progress data) with your coach for the purpose of providing coaching services.
• Service Providers: We work with a limited set of service providers who help us operate the Service. These include providers of database hosting (Supabase), application hosting (Railway, Vercel), video delivery (Bunny Stream), error tracking (Sentry), email delivery (Resend, Kit), and payment processing (Stripe). These service providers are bound by contractual obligations to use Consumer Health Data only as needed to perform services on our behalf and to maintain appropriate safeguards.
• App Integrations: When you opt in to share information with third-party products or services via integrated features, including Apple HealthKit, we may share Consumer Health Data with these services, or we may allow these services to collect Consumer Health Data directly from you in connection with the Service. Apple HealthKit data accessed by the Service is governed by Apple’s privacy policy and is never used for advertising or shared with third parties without your explicit permission.
• Business Transactions: We may take part in or be involved with a business transaction such as a merger, acquisition, or sale of business assets. We may disclose Consumer Health Data to a third party during the negotiation of or in connection with such a transaction. In the event of such a transaction, we will provide notice and obtain consent where required by applicable law.
• Legal Obligations and Rights: We may disclose Consumer Health Data to third parties in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal process; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us, our customers, or any person; or as otherwise required by applicable law.
• With Your Consent: We may disclose Consumer Health Data about you to other service providers or publicly with your consent or at your direction. For example, with your consent we may publish a testimonial that references your progress or experience.

We do not sell your Consumer Health Data. We do not share your Consumer Health Data for the purpose of targeted advertising or cross-context behavioral advertising.

4. Your Privacy Rights

The Consumer Health Privacy Laws provide the following rights with respect to Consumer Health Data we collect about you:

• Right to Access / Confirm: You may have the right to confirm whether we are collecting, sharing, or selling Consumer Health Data about you and with whom we may be disclosing such Consumer Health Data, and to access such data.
• Right to Withdraw Consent: If you have provided your consent for our processing or sharing of your Consumer Health Data, you may have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing that occurred prior to the withdrawal.
• Right to Delete: You may have the right to request that we delete your Consumer Health Data and that all service providers and third parties to whom we have disclosed your Consumer Health Data also delete such data. Where required by law, we will honor verified deletion requests within thirty (30) days of receipt.

5. How to Exercise Your Privacy Rights

To exercise any of the privacy rights set forth above, please submit a request to support@strongherco.com.

Before processing your request, we will need to authenticate your identity. To authenticate your identity, we will generally require matching a minimum amount of information you provide us with the information we maintain about you in our systems. This process may require us to request additional information from you, including but not limited to your email address, phone number, or the approximate date of your most recent transaction or interaction with us.

We will respond to your verified request within forty-five (45) days, and within thirty (30) days for deletion requests covering Consumer Health Data where required by the Consumer Health Privacy Laws. If we need additional time to process your request, we will notify you of the extension and the reason for it.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to authenticate your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for our decision.

You may use an authorized agent to submit a request on your behalf. To do so, the authorized agent must provide either (a) a valid power of attorney or (b) a signed letter from you containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the specific request. We may separately contact you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

6. Appealing Privacy Rights Decisions

If your request to exercise a right under the Consumer Health Privacy Laws is denied, you may appeal that decision by contacting us at support@strongherco.com and including “Privacy Rights Appeal” in the subject line. We will respond to your appeal within forty-five (45) days of receipt.

If your appeal is unsuccessful, you may raise a concern or lodge a complaint with the applicable State Attorney General:

• Washington Residents: Washington State Attorney General’s Office, atg.wa.gov
• Nevada Residents: Nevada Attorney General’s Office, ag.nv.gov

7. Changes to this Consumer Health Notice

We may update this Consumer Health Notice from time to time. When we make changes to this Consumer Health Notice, we will change the Effective Date at the top of this Consumer Health Notice. If we make material changes to this Consumer Health Notice, we will notify individuals by email to their registered email address, by prominent posting on the Site, App, or Portal, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise specified.

8. Contact Us

If you have any questions about this Consumer Health Notice, you may contact us at:

StrongHer Collective LLC
Email: support@strongherco.com
Website: strongherco.com