Legal
Consumer Health Data Privacy Policy
Effective [date of publication] · Last updated November 8, 2026
This policy explains how [legal entity name] ("GURU Vitals", "we", "us") handles consumer health data. It meets the Washington My Health My Data Act (RCW 19.373), Nevada's consumer health data law (NRS 603A.400 to 603A.550) and Connecticut's consumer health data rules (Conn. Gen. Stat. § 42-515 and following). It applies to you if you live in one of those states, or if your data is collected there. In practice we apply it to every user. It works alongside our Privacy Policy, which covers all personal data.
"Consumer health data" means personal data that is linked, or reasonably linkable, to you and identifies your past, present or future physical or mental health. That includes data we infer or calculate. Almost everything GURU Vitals measures counts.
1. The consumer health data we collect, and why
| Category | Examples | Why we collect it |
|---|---|---|
| Vital signs and bodily functions | Heart rate, heart rate variability, blood oxygen (SpO₂), estimated overnight blood pressure | To show your vitals and trends, and to calculate your scores |
| Sleep | Sleep timing, duration and stages | To show your sleep and calculate sleep and readiness scores |
| Activity and fitness | Steps, detected activities, workouts, heart-rate zones, VO₂ max estimates, strain | To log training, calculate strain and build workouts |
| Body measurements | Height, weight, body fat, muscle mass, body water | To track body composition and personalize targets |
| Nutrition | Food logs, meal photos, calories, macros and micronutrients | To log meals, score them and suggest swaps |
| Health information you give us | Goals, injuries, conditions, medications or symptoms you enter or mention to the coach | To personalize your plan and the coach's answers |
| Scores and inferences | Readiness, sleep, strain and energy scores, meal health scores, trends | To give you one daily read of your body and guide your plan |
| Data from connected health apps | Data types you allow from Apple Health or Google Health Connect | To combine your data in one place |
We also use this data, where needed, to keep the Services secure, provide support, meet legal obligations and check that our features are accurate. We don't use it for advertising or marketing.
2. Where it comes from
- You, when you enter it or talk to the coach;
- Your GURU Vitals band or ring, and your GURU Scan scale;
- Apple Health or Google Health Connect, if you connect them;
- Our own calculations from the data above.
3. Consent to collect, and consent to share
We collect consumer health data only to provide the features you ask for, or with your consent for a specific purpose. Sharing it needs a separate consent from collecting it. Both are asked for in the app with a clear yes or no that you have to choose actively. We never take consent from you just accepting our Terms. Each request tells you the categories of data, the purpose, who receives it and how to withdraw. You can withdraw either consent at any time in Settings › Privacy or by emailing us.
4. The categories we share, and with whom
| Who receives it | What | When |
|---|---|---|
| The AI model provider behind the coach (a service provider) | Your message, goals, recent scores and logs, and the coach's memories | Only after you agree in the app, when you use the coach |
| Other service providers (cloud hosting, customer support, crash reporting) | Whatever they need to run their part of the Services | Under contract, only to provide the Services |
| Your trainer | Readiness, sleep, heart data, strain, nutrition summaries and workouts | Only if you invite them, and until you stop sharing |
| Anyone else you invite | Only the metrics you pick, including a weekly summary if you turn it on | Only if you invite them, and until you stop sharing |
| Your employer's wellness program | Team-level totals; individual data only with a further opt-in, under a pseudonymous ID | Only if you join, and until you leave or withdraw |
| Other members of a challenge | Your display name, the metric compared and your rank | Only for challenges you join |
| Apple Health or Google Health Connect | Data types you choose to write to them | Only if you connect them |
Affiliates: we [have no affiliates / list affiliates] that receive consumer health data. Partner gyms receive your device's access key identifier, never your consumer health data.
5. We don't sell consumer health data
We don't sell consumer health data and never have. If that ever changed, we would first need your separate, signed authorization, as Washington and Nevada law requires. We also don't allow third parties to collect your consumer health data across websites or apps over time.
We don't use geofences, virtual boundaries that react when you enter a place, around hospitals, clinics or any other in-person health care facility.
6. Your rights
- Confirm and access: ask whether we collect, share or sell your consumer health data, and get a copy. That includes a list of every third party and affiliate we've shared it with, and how to contact each one.
- Correct: fix data that is wrong.
- Withdraw consent to collecting or sharing.
- Delete: we delete your consumer health data from our live systems within 30 days and from backups within 6 months. We tell every service provider and third party we shared it with to delete it too.
- Appeal if we refuse a request.
How to ask: use Settings › Privacy in the app, or email privacy@guruvitals.com. We'll confirm the request comes from you. We reply within 45 days, and if we need up to 45 more days, we'll tell you why. Requests are free, up to twice a year.
Appeals: reply to our decision with "Appeal" within 60 days. We'll answer within 45 days and explain our reasons. If you're still not satisfied, you can contact your state Attorney General. In Washington, that's at atg.wa.gov.
We won't treat you differently for using any of these rights.
7. Changes
If we start collecting a new category of consumer health data, or using or sharing it for a new purpose, we'll update this policy and ask for your consent in the app before we do. We'll also tell you about other material changes in the app or by email. The effective date at the top shows the current version.
8. Contact us
[Legal entity name]
[Street address, city, state ZIP]
privacy@guruvitals.com
Phone: [phone number]