> Consumer Health Data Privacy Policy - POWR Health Tracking App
>
> How POWR collects, uses, and shares consumer health data under Washington's My Health My Data Act, Nevada's consumer health data law, Connecticut's Data Privacy Act, and similar state laws, and how to exercise your rights.

Source: https://powrhealth.com/consumer-health-data (HTML) · https://powrhealth.com/llms.txt (site overview for agents)

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Last updated: October 7, 2026

# Consumer Health Data Privacy Policy

What health data POWR collects, why, who receives it, and how to exercise your rights.

On this page

-   [Who This Policy Covers](#scope)
-   [Health Data We Collect](#categories)
-   [Where It Comes From](#sources)
-   [Why We Collect and Use It](#purposes)
-   [Who We Share It With](#sharing)
-   [Your Rights](#your-rights)
-   [How to Exercise Your Rights](#how-to-exercise)
-   [Changes to This Policy](#changes)
-   [Contact Us](#contact)

Vitality Wellness LLC ("Company," "we," "us," or "our") operates the POWR mobile application, website (powrhealth.com), and related services (the "Service"). This policy is effective October 7, 2026.

It supplements our [Privacy Policy](https://powrhealth.com/privacy), which has the full detail. Where this policy is more specific about consumer health data, this policy applies.

**We do not sell consumer health data.**

## 1\. Who This Policy Covers

This policy covers "consumer health data" as defined by Washington's My Health My Data Act, Nevada's consumer health data law (SB 370), Connecticut's Data Privacy Act, and similar state laws. In short, that is personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health.

## 2\. Health Data We Collect

Depending on the features you use and the permissions you grant, we collect:

-   **Activity:** workouts and their details, workout routes, steps, distance, active energy, and exercise minutes;
-   **Heart and breathing:** heart rate, resting heart rate, heart rate variability, blood oxygen saturation, respiratory rate, and VO₂ max;
-   **Sleep and recovery:** sleep records and stages, recovery and readiness readings, and body or skin temperature;
-   **Body:** height, weight, body fat, lean mass, date of birth, and biological sex;
-   **Nutrition:** food and water you log, calories, nutrients, dietary preferences, and food allergens;
-   **Supplements:** supplements you log, with dose and timing;
-   **Cycle:** menstrual cycle entries and related symptoms;
-   **Lab results and clinical records:** lab reports you upload or enter, and records you import from Apple Health Records, such as lab results, medications, conditions, allergies, and immunizations;
-   **Mental wellbeing:** Apple State of Mind entries and mindful minutes;
-   **Progress photos** you upload;
-   **Coach chats:** messages you exchange with the in-app AI coach;
-   **Goals and plans:** your health goals, training plans, and meal plans;
-   **Information we derive** from the above, such as wellness scores, calorie targets, and trends.

## 3\. Where It Comes From

-   **You**, when you log, record, upload, or type something in the Service;
-   **Apple Health** on your iPhone, for the categories you allow, including Apple Health Records you have linked there;
-   **Wearables and fitness services you connect**, such as WHOOP, Polar, and Wahoo;
-   **Lab documents you upload**, which we transcribe into results you review;
-   **Our own calculations**, which derive scores and trends from the data above.

## 4\. Why We Collect and Use It

-   To provide the features you use, such as tracking, history, trends, scores, and plans;
-   To personalize the Service to your goals;
-   To power AI features, such as photo logging, lab transcription, and the in-app coach, only after you turn AI features on;
-   To answer an AI assistant you connect, only for the categories you approved;
-   To keep the Service secure, prevent abuse, and meet legal obligations.

We do not use consumer health data for advertising, and we do not sell it.

**How we process it.** We store consumer health data encrypted on Google Cloud servers in the United States. Our servers use it to build your scores, trends, and plans. Only staff and contractors who need it to run or support the Service can access it.

**No cross-site tracking.** No third party collects consumer health data about you over time and across other websites or apps through POWR. We do not use advertising trackers.

## 5\. Who We Share It With

### 5.1 Processors

These companies process data for us, under contract and only on our instructions:

-   **Google Cloud and Firebase (Google):** store all the categories in Section 2 to run hosting, database, file storage, and sign-in;
-   **Anthropic (Claude):** only after you turn AI features on, receives what each request needs: food photos and descriptions, lab documents you upload for transcription, progress photos you send for a physique reading, your messages to the in-app coach, and related readings such as recent meals, workouts, sleep, recovery, heart rate variability, resting heart rate, and body measurements;
-   **Google AI services (Gemini, through Vertex AI):** only after you turn AI features on, receive what each request needs: voice recordings of meals you log by speaking, the readings a health category page summarizes in one line (such as heart rate variability and resting heart rate, or your cycle phase with related sleep and recovery readings on the cycle page), and, when the coach's memory is on, short excerpts of what you have told the coach.

Our app analytics and crash reporting providers receive usage and diagnostic information only if you turn those settings on. They do not receive the contents of your health records.

### 5.2 AI Assistants You Connect, With Your Separate Consent

You can let a third-party AI assistant read parts of your POWR data. Today that means ChatGPT, run by OpenAI, and Grok, run by xAI. These are independent companies, not our processors.

-   We share nothing with an assistant until you approve it on POWR's consent screen. That consent is separate from your consent to POWR collecting your data.
-   You choose the categories it may read: recovery and sleep (sleep, readiness, heart rate variability, resting heart rate, breathing rate, blood oxygen, stress); training (workouts, lifts, steps, distance, pace zones, strain, VO₂ max, fitness age); food log and nutrition (meals, calories, nutrients, water, meal plan); body metrics (weight, weight goal, body fat, lean mass); and your plan (scheduled sessions and progress). It can also see which devices you have connected and whether you have Powr Pro.
-   Data POWR receives from WHOOP or Wahoo is never shared with an AI assistant.
-   We send data only to answer the assistant's requests. It can read but never change anything in POWR.
-   It never receives cycle data, lab results, clinical records, progress photos, or coach chats.
-   Once it receives your data, its provider handles it under the [OpenAI privacy policy](https://openai.com/policies/privacy-policy/) or the [xAI privacy policy](https://x.ai/legal/privacy-policy). We cannot control how long it keeps that data or whether it uses it to train its models.
-   To ask OpenAI about your data, use [privacy.openai.com](https://privacy.openai.com/) or email [dsar@openai.com](mailto:dsar@openai.com). To ask xAI, see the [xAI privacy policy](https://x.ai/legal/privacy-policy).
-   You can withdraw this consent at any time in the POWR app under *Settings > Health connections > Connected agents*, or by emailing [legal@powrhealth.com](mailto:legal@powrhealth.com) with the subject line "Privacy Request." Access ends immediately. Data the assistant already received stays with its provider.

Section 4.3 of our [Privacy Policy](https://powrhealth.com/privacy#ai-assistants) has the full detail.

### 5.3 Other Disclosures

We may also disclose consumer health data when the law requires it, or to a successor in a merger or sale of our business. In that case the successor must honor our commitment never to sell your health data, or get your separate consent, as described in Section 9.4 of our [Privacy Policy](https://powrhealth.com/privacy).

## 6\. Your Rights

Depending on where you live, you have the right to:

-   **Confirm and access:** learn whether we collect or share your consumer health data, and get a copy of it;
-   **See who received it:** get a list of the third parties and affiliates we shared it with, and how to contact them;
-   **Correct it:** fix inaccurate data, most of which you can edit directly in the app;
-   **Delete it:** have us delete it;
-   **Withdraw consent:** stop collection or sharing that relies on your consent;
-   **Take it with you:** get a copy in a format you can move to another service;
-   **Opt out:** of targeted advertising, sale, or profiling. We do none of these with your health data;
-   **Appeal:** ask us to reconsider if we decline your request;
-   **Equal treatment:** exercise these rights without being treated differently.

## 7\. How to Exercise Your Rights

### 7.1 In the App

-   Delete your account under *Settings > Account > Delete Account*;
-   Disconnect an AI assistant under *Settings > Health connections > Connected agents*;
-   Disconnect a wearable or fitness service in the app, or change Apple Health permissions in iOS Settings;
-   Turn AI features off in Settings;
-   Edit or delete individual records.

### 7.2 By Email

Email [legal@powrhealth.com](mailto:legal@powrhealth.com) with the subject line "Privacy Request" and tell us which right you want to use. We will verify your identity, then respond within 45 days of receiving your request. If we need more time, we may extend this once by up to 45 more days, and we will tell you why within the first 45 days. Requests are free, at least twice a year.

We delete your data within 30 days of verifying your request. We also tell our processors and every AI assistant provider you shared data with (OpenAI, xAI) about your request so they can delete it too. Backup copies are deleted on the schedule in Section 6.5 of our [Privacy Policy](https://powrhealth.com/privacy), and never later than six months after your request.

### 7.3 Appeals

If we decline your request, you can appeal by replying to our decision or emailing [legal@powrhealth.com](mailto:legal@powrhealth.com) with the subject line "Privacy Appeal." We will send you our decision and reasons in writing within 45 days. If we deny your appeal, you can file a complaint with your state attorney general: [Washington](https://www.atg.wa.gov/file-complaint), [Nevada](https://ag.nv.gov/), or [Connecticut](https://portal.ct.gov/ag).

## 8\. Changes to This Policy

When we change this policy, we update the "Last updated" date above. For a material change, we will notify you through the Service or by email. We will ask for your consent before we collect or share consumer health data for a new purpose that needs it.

## 9\. Contact Us

**Vitality Wellness LLC**

A Wyoming Limited Liability Company

[legal@powrhealth.com](mailto:legal@powrhealth.com)

For consumer health data requests, please email with the subject line "Privacy Request."
