Consumer Health Data Privacy Policy

Last Updated: September 13, 2026

This Consumer Health Data Privacy Policy is a separate policy that applies specifically to "consumer health data" as that term is defined under the Washington My Health My Data Act (MHMDA), Nevada SB 370, and similar state laws. It supplements our general Privacy Policy. Where this policy conflicts with the general Privacy Policy in relation to consumer health data, this policy controls.

1. What We Mean by Consumer Health Data

These laws define consumer health data broadly — far more broadly than most people expect. It includes any information that identifies your past, present or future physical or mental health status. In Nana's Care Team, the following is treated as consumer health data:

• Medications — names, doses, prescribing clinician, and the record of when each dose was given and by whom
• Diagnoses and health conditions you record
• Allergies
• Vital signs — blood pressure, blood sugar, weight, temperature and similar measurements
• Appointments with healthcare providers, including the provider's identity and specialty
• Care notes describing symptoms, behaviour, mood or condition
• Photographs you attach to care records, where they depict a person's physical condition, a medication, or a medical document
• Healthcare provider contacts, because the identity of a person's specialist can itself reveal a health condition

2. Whose Data This Concerns

Nana's Care Team is unusual in an important way: most of the health data in it is about someone other than the person entering it. A family member records information about a care recipient.

This means two distinct people have interests in the same records:

• The account holder — the caregiver who created or joined the care team
• The care recipient — the person the records are about, who may or may not use the App themselves, and who may not be able to

By entering information about another person, you confirm that you have the legal authority to do so — as their agent, guardian, healthcare proxy, power of attorney holder, or with their permission. We cannot verify this and rely on your representation.

If you are a care recipient whose information is held in the App and you wish to exercise rights over that information, contact us at support@aspenapps.us. We will work with you and the account holder in good faith, and will honour a verified request over the account holder's objection where the law requires it.

3. How We Collect Consumer Health Data

Only from you, directly. Every piece of health data in Nana's Care Team was typed or uploaded into the App by you or by another member of your care circle.

We do not:

• Collect health data automatically from your device, sensors or health apps
• Purchase or obtain health data from third parties, brokers or public sources
• Infer health conditions from your behaviour or usage
• Use cookies, pixels, SDKs or any other tracking technology to collect health data
• Connect to Apple Health, Google Fit, pharmacies, insurers or medical record systems

4. Why We Collect It

For one purpose: to provide the coordination and record-keeping service you asked for. Specifically, to display your records back to you, share them with the care circle members you invite, and assemble the Care Summary you can export or share.

We do not use consumer health data for advertising, marketing, profiling, product analytics, research, or training machine learning models.

4.1 A Note on the Daily Message Feature

The App can display a short daily supportive message generated by an external AI service (Anthropic). No health data, no care recipient information, and no account information is sent to that service. The request contains a fixed instruction only. The feature can be switched off entirely in Settings.

5. Who We Share It With

Who	What they receive	Why
Members of your care circle	The care team records you share with them	This is the purpose of the App. You control who is invited and you can remove them.
Supabase (database and authentication hosting)	Stored data, encrypted in transit and at rest	Processor acting on our instructions. They do not use your data for their own purposes.
Netlify (application hosting)	Serves the application; processes requests	Processor acting on our instructions.
Apple / Google	Subscription and payment status only — no health data	They process subscription payments. We never receive your card details.
Law enforcement or courts	Only what a valid, binding legal order compels	We will object to overbroad requests and, where legally permitted, notify you first.

6. We Do Not Sell Consumer Health Data

We do not sell consumer health data, and we do not intend to. "Sell" here has the broad statutory meaning — the exchange of consumer health data for monetary or other valuable consideration — not just cash sales.

Should this ever change, the law requires us to obtain your separate, written authorization beforehand, on a specific form, distinct from this policy and from any consent you give to use the App. We would have to ask you explicitly, and you could decline and keep using the App.

7. Your Rights

Regardless of the state you live in, we extend these rights to every user:

• Right to know — to confirm whether we hold consumer health data about you, and to obtain a list of all third parties it has been shared with
• Right to access — to receive a copy of your consumer health data
• Right to withdraw consent — to withdraw consent to our collection and sharing of your consumer health data
• Right to delete — to have your consumer health data deleted, including from our backups and from our service providers
• Right to non-discrimination — we will not deny service, charge a different price, or provide a lesser experience because you exercised a right

7.1 How to Exercise Them

Deletion is built into the App and does not require you to contact anyone: Settings → Delete My Account permanently deletes your account, the care teams you own, and all associated health records.

For any other request, email support@aspenapps.us. We will verify that the request comes from you or your authorised agent, and respond within 45 days, extendable once by a further 45 days where reasonably necessary, in which case we will tell you before the first period expires.

7.2 If We Refuse

If we decline a request we will tell you why, and explain how to appeal. Appeals go to the same address, marked "Appeal". If we deny an appeal, Washington residents may complain to the Washington State Attorney General at atg.wa.gov/file-complaint.

8. How Long We Keep It

We keep consumer health data for as long as your account is active, because the value of a care record is its history. When you delete your account it is removed from our active systems immediately and from encrypted backups within 30 days.

Closing a care team (for example after a bereavement) deliberately archives rather than deletes — families frequently want the care summary, notes and photographs afterwards. Archived records remain subject to this policy, and permanent deletion remains available at any time through Settings → Delete My Account.

9. How We Protect It

• Encryption in transit (HTTPS/TLS) and at rest
• Row-level database isolation — enforced by the database itself, so records are only reachable by members of the care team they belong to
• Passwords stored only as salted hashes; we never see them
• Automatic sign-out after 30 minutes of inactivity
• No advertising, analytics or tracking SDKs anywhere in the App

No system is perfectly secure. If a breach affects your consumer health data we will notify you as described in our Privacy Policy.

10. Contact

Email: support@aspenapps.us

Entity: Aspen Apps, LLC

Location: Colorado, United States