Consumer Health Data Privacy Policy

Last updated: June 5, 2026

Draft — pending legal review. Have counsel review this policy (and confirm the processor list and retention periods) before launch, then remove this notice.

This Consumer Health Data Privacy Policy explains how Comfrey LLC (“Comfrey,” “we,” “us”) collects, uses, shares, and protects consumer health data, and the rights you have over it. It supplements our Privacy Policy and is provided to comply with Washington’s My Health My Data Act and Nevada’s SB 370. It applies to residents of Washington and Nevada, and we extend these protections to all Comfrey users.

What we mean by consumer health data

“Consumer health data” is personal information that identifies your past, present, or future physical or mental health. For Comfrey this includes the fitness and wellness data you choose to log or sync: workouts and strength training, cardio sessions and GPS routes, nutrition and meals, body measurements, weight, progress photos, sleep, steps, water intake, heart rate, and any health-related context you share with the AI Coach.

Where it comes from

We collect this data directly from you when you log it in the app, from your device sensors and camera when you use features like live cardio or the meal scanner (with your permission), and — only if you connect them — from Apple Health and Android Health Connect. We do not buy consumer health data from third parties.

How and why we use it

We use consumer health data only to provide and improve the features you ask for: displaying your progress and trends, powering AI coaching, programs, recipes, and meal plans, syncing and restoring your data across devices, and maintaining the security and reliability of the service. We do not use it for advertising, and we do not use advertising or third-party tracking SDKs.

Who we share it with

We share consumer health data only with service providers that process it on our behalf, under contract, to run Comfrey — for example: Supabase (authentication, database, and storage), the Anthropic API (which powers AI features through our secure backend), Sentry (limited diagnostics — your user id and non-personal error data, never your health data), and RevenueCat with the App Store / Google Play for subscriptions. We do not share consumer health data with affiliate or marketing partners. We may disclose data if required by law or to protect rights and safety. [Confirm the full list of processors with counsel.]

We do not sell your health data

We do not sell your consumer health data, and we will not sell or share it for targeted advertising. We will not collect, use, or share consumer health data beyond what is described here without your consent, or — where a sale would ever be involved — your valid written authorization.

Your rights

You have the right to (1) confirm whether we collect, share, or sell your consumer health data and access that data; (2) withdraw your consent to its collection and sharing; (3) request that we delete your consumer health data; and (4) appeal a denial of any request. We will respond within the timeframe required by law (generally 45 days, with one permitted extension) and will not discriminate against you for exercising these rights. Deleting your account from Profile → Settings → Data & Privacy removes your local data and your cloud-synced records.

How to make a request

Email privacy@trycomfrey.com with the request type. We may need to verify your identity before acting. If we deny a request, you may appeal by replying to our decision; if your appeal is denied, you may contact the Washington Attorney General at atg.wa.gov/file-complaint.

Security and retention

Your data is stored locally on your device and, when you are signed in, mirrored to your private, access-controlled space in Supabase; progress photos live in a private bucket only you can access. We retain consumer health data for as long as your account is active or as needed to provide the service, then delete it on request. [Confirm retention periods with counsel.]

Changes and contact

We will update this policy as our practices or the law change and revise the effective date above. Questions or requests: Comfrey LLC, or privacy@trycomfrey.com.