Consumer Health Data Privacy Policy

1. Categories of consumer health data we collect

Through the wellness-coaching workspace, we may process the following categories of consumer health data about a client (“you”):

• Health status & symptoms - check-ins, symptom and complaint information, and wellness “system status” grades.
• Measurements, activity & biometrics - weight, body-composition measurements, blood glucose, body temperature, and similar self-reported metrics.
• Connected device data - if you choose to connect Apple Health, Whoop, Oura, Fitbit, or Ultrahuman, privacy-minimized daily totals and scores such as steps, sleep duration, resting heart rate, heart-rate variability, recovery, and readiness. We do not collect raw continuous sensor streams.
• Lab & diagnostic information - lab files you or your coach upload (for example serum, gut, hormone, or mycotoxin panels) and the marker values extracted from them.
• Pre-participation health screening - where your gym or coach switches it on, your answers to the standard PAR-Q+ readiness questions (for example heart conditions, chest pain, dizziness, chronic conditions, prescribed medication, and joint problems), the date you answered them, and your coach’s recorded decision about any answer you flagged. These answers are used to decide whether you should speak to a doctor first and whether you can book a class yourself; they are not scored, and no automated judgement is made about your fitness to exercise.
• Supplements, peptides & related inputs - wellness supplement and similar information entered for coaching (prescriptions, diagnoses, and lab orders are referred out to a licensed physician and are not provided through the platform).
• Reproductive or menstrual information - cycle status, where you choose to provide it as coaching intake.
• Bodily or health-related imagery - progress photos, and movement or lift video submitted for form review, together with the pose landmarks derived from that video to draw feedback.
• Health-related conversations - messages between you and your coach about your health, and - where your coach records a call and you have consented - recordings and transcripts of coaching or consult calls. Your coach may also speak to the platform’s assistant about your coaching rather than typing; their microphone audio is transcribed so it can become the text of their request, and we do not retain that audio afterwards - what is kept is the resulting text, in your coaching records.
• Status as someone seeking wellness services - the fact that you use a wellness-coaching service, and related account and contact information.
• Inferences - wellness grades, suggested programs, and AI-assisted summaries derived from the above to deliver coaching.
• Saved coaching memories - short notes your coach or the assistant records so your coaching stays consistent between sessions (for example a food you will not eat, or an injury to work around). Your coach can see, edit and delete these. When newer information replaces one, the earlier version stops being used and is kept alongside its replacement for 12 months - with a record of why it was replaced - so your coach can see the change and undo it, after which it is permanently deleted.

2. Sources of the data

• Directly from you - through the client portal, check-ins, uploads, and messages.
• From your coach - the wellness coach you work with, who may enter or upload information on your behalf as part of coaching you.
• From a device you connect, at your direction - the LaunchSite OS iOS app reads only the Apple Health categories shown on its connection screen after you approve Apple’s permission prompt, and a wearable account (Whoop, Oura, Fitbit, Ultrahuman) shares data only after you authorise the connection at that provider. We never receive a device password or credential, and we do not collect raw heart-rate samples.
• Generated by the platform - grades, analyses, transcripts, and inferences the software produces from the information above.

3. Why we collect and how we use it

We collect and use consumer health data only to provide the wellness-coaching service that you or your coach requested, specifically to:

• Operate the coaching workspace and your client portal.
• Generate coaching outputs - wellness grades, suggested programs, lab summaries, reminders, and progress tracking.
• Enable communication between you and your coach.
• Show source-labeled device trends to you and your coach when you enable a connection.
• Secure, maintain, troubleshoot, and improve the service.

We do not use consumer health data for targeted advertising, we do not sell it, and we do not use it to train AI models.

4. Categories of data we share

We share the categories of consumer health data listed in Section 1 only as needed to provide the service, and only with the categories of recipients in Section 5. We do not share consumer health data with third parties for their own marketing or advertising.

5. Who we share it with

• Your coach - the wellness coach who owns your coaching relationship and controls your workspace, and any team members that coach has authorised.
• Service providers (processors / subprocessors) under written data-processing terms. 12 of our providers can access consumer health data - cloud database, authentication and file storage; application hosting; AI providers used for assistive features and transcription; and the device makers you connect. Each is named, with its purpose and processing region, at /privacy/subprocessors. None may use the data for its own purposes or to train AI models. Our billing processor and messaging carriers do not receive consumer health data.
• Legal & safety - to comply with law or valid legal process, or to protect the rights, safety, and security of users and the platform.
• Affiliates / successors - an affiliate, or an acquirer in a merger or asset sale, subject to this policy.

We do not sell consumer health data, and we do not share it with data brokers.

6. Consent

We collect and process consumer health data to provide the coaching service you or your coach requested. Where the law requires consent for collecting or sharing consumer health data beyond what is necessary to provide that service, we will obtain it, and you may withdraw consent at any time as described below.

Optional connections are separately consented. Connecting a device requires both an in-app explanation and the device maker’s own permission step. Disconnecting in LaunchSite OS stops future sync and deletes the imported device data from your workspace; you can separately revoke access at Apple Health, iOS Settings, or the wearable provider.

Call recording. Your coach - not us - decides whether to record a coaching or consult call, and is responsible for obtaining the consent your jurisdiction requires from every participant before doing so. If you do not want a call recorded, tell your coach; if you believe a call was recorded without your consent, contact us at privacy@launchsite-os.com.

We do not sell consumer health data and therefore do not seek the separate authorization a sale would require.

7. Your rights

Subject to applicable law, you have the right to:

• Confirm & access - confirm whether we process your consumer health data and access it.
• Delete - request deletion of your consumer health data, including from our subprocessors.
• Withdraw consent - withdraw consent to our collection and sharing of your consumer health data.
• Appeal - appeal a refusal to act on a request.

To exercise these rights, contact your coach first - they control your workspace and can export or delete your records directly in the app - or email privacy@launchsite-os.com. We will respond within the timeframe required by applicable law and will not discriminate against you for exercising a right. Because much of your information sits inside a coach’s workspace, fulfilling some requests may require us to coordinate with your coach.

8. Data retention & security

We retain consumer health data while your (or your coach’s) account is active or as needed to provide the service, then delete or de-identify it within a commercially reasonable period, subject to legal obligations. We protect it with encryption in transit and at rest, row-level access controls, private file storage served only through authenticated short-lived access, and least-privilege access for automated tooling. See our security practices and Section 6 of the Privacy Policy.

9. Breach notification

If a breach affecting consumer health data occurs, we will notify affected individuals and any authorities as required by applicable law, including the FTC Health Breach Notification Rule and applicable state breach-notification laws, within the timeframes those laws require.

10. Changes & contact

We may update this policy and will post material changes here with a revised date. Questions or requests: privacy@launchsite-os.com · LaunchSite OS, LLC.

This document is provided as a starting template and is not legal advice. Have a qualified privacy attorney review and adapt it for your business and the states in which your clients reside before publishing.