Consumer Health Data Privacy Policy

1. Scope

This Consumer Health Data Privacy Policy applies to consumer health data processed through Trace by AppEcho Labs LLC (“AppEcho,” “Trace,” “we,” “us,” or “our”). “Consumer health data” means personal information that identifies or can reasonably be linked to a consumer and that identifies the consumer’s past, present, or future physical or mental health status, as defined by applicable law.

This notice supplements our general Privacy Policy. If this notice and the general policy conflict regarding consumer health data, this notice controls.

2. Categories of consumer health data we collect

Depending on what you choose to use or enter, Trace may collect:

• symptoms, conditions, severity, duration, bodily location, daily impact, mood, energy, and notes;
• medications, supplements, interventions, treatments, routines, and perceived helpfulness;
• food, hydration, sleep, activity, stress, weather, menstrual or reproductive context, suspected triggers, and custom factors;
• daily Apple Health summaries for sleep duration, steps, workouts, and resting heart rate, plus menstrual-flow information only if you separately enable cycle context in Trace;
• health goals, tracking templates, report preferences, reminder preferences, and appointment-preparation choices;
• summaries, correlations, charts, insights, and reports derived from your entries;
• identifiers needed to associate health records with your account, such as your Firebase user ID; and
• limited health-related product interactions, such as whether a check-in or report was completed, but never the health contents of that check-in or report in analytics or attribution payloads.

Providing health information is voluntary, although Trace cannot provide a feature that depends on information you choose not to provide. Apple Health and automatic weather are optional.

3. Categories of sources

We collect consumer health data from:

• you, when you enter, edit, import, or communicate information;
• Apple Health, only for data types you authorize through Apple’s system permissions;
• Apple Weather, when you enable automatic weather context; and
• Trace itself, when it organizes your entries into summaries, patterns, charts, or reports.

4. Why we collect and use consumer health data

We collect and use consumer health data only to:

• provide the tracking, synchronization, insight, summary, reminder, report, export, and sharing features you request;
• personalize your templates, factors, and experience;
• maintain, secure, troubleshoot, and support Trace and your account;
• prevent fraud, abuse, or security incidents and preserve system integrity; and
• comply with law and establish or defend legal claims.

We do not use consumer health data for targeted advertising, marketing profiles, cross-app tracking, data-broker products, insurance eligibility, employment decisions, credit decisions, or automated decisions that produce legal or similarly significant effects.

5. Categories of consumer health data we share

We disclose account-linked health entries, settings, summaries, and generated reports to Google LLC through Firebase solely as our cloud processor for authentication, storage, synchronization, messaging, and server functions needed to provide Trace. Google processes this data on our behalf under contractual and security obligations.

Trace also discloses narrowly limited product-interaction data to the following processors. PostHog events may be account-linked after sign-in; AppsFlyer attribution remains install-scoped. Because use of a health app may itself be considered consumer health data in some jurisdictions, we list these disclosures even though they do not contain the substance of your health records:

• PostHog: allow-listed events such as whether onboarding, a check-in, or a report was completed; Firebase user ID after sign-in; platform; app version; and plan type.
• AppsFlyer: install and campaign attribution, an install-scoped AppsFlyer identifier, and non-content funnel events such as onboarding, paywall, trial, or subscription milestones. Trace does not send AppsFlyer the Firebase user ID, and advertising identifiers are disabled.
• RevenueCat and the applicable app store: account identifier, subscription product, entitlement, trial, renewal, and expiration status.
• Apple Weather: when you enable automatic weather, your device sends precise location to Apple solely to return current local conditions. AppEcho does not receive or store the coordinates.

We may disclose the minimum necessary consumer health data to security, legal, or technical advisers when needed to investigate an incident, comply with valid law, or protect legal rights. We may also disclose data as part of a business transaction, subject to applicable law and protections consistent with this notice.

We do not disclose your symptom labels, medications, notes, severity values, report contents, Apple Health values, or Apple Health permission choices to PostHog, AppsFlyer, RevenueCat, advertising networks, or data brokers.

When you choose to export or share a report through your device, you direct that disclosure. Trace does not choose the recipient. The recipient’s privacy practices apply after the information leaves Trace.

We have no affiliates with whom we share consumer health data as of the effective date of this notice.

6. We do not sell consumer health data

AppEcho does not sell consumer health data. We also do not exchange consumer health data for money or other valuable consideration, use it for targeted advertising, or permit our processors to use it for their own advertising.

7. Your consumer health data rights

Subject to applicable law and exceptions, you may request to:

• confirm whether we collect, share, or sell your consumer health data;
• access the consumer health data we maintain about you;
• receive a list of third parties and affiliates with whom your consumer health data has been shared or sold, with contact information where required;
• withdraw consent for future collection or sharing of consumer health data; and
• delete your consumer health data.

You can edit or delete entries, export your data, disconnect optional sources, or delete your account in Trace settings. You can also email support@trackwithtrace.com with “Health Data Request” in the subject. We may take reasonable steps to authenticate your request. An authorized agent may submit a request where permitted, subject to verification of authority and identity.

When a verified deletion request applies, we will delete covered health data from active systems and direct applicable processors or contractors to do the same. Deletion from archived or backup systems may be delayed for up to six months where permitted by law; affected data will not be restored to active use except as needed for security or integrity.

If we deny your request, we will explain why and provide instructions to appeal. To appeal, reply to our decision or email us with “Health Data Appeal” in the subject. We will not unlawfully discriminate against you for exercising these rights.

8. Changes to this notice

We will update this notice before collecting, using, or sharing new categories of consumer health data or using existing categories for materially new purposes. Where law requires, we will obtain your affirmative consent before the new collection, use, or sharing begins.

9. Contact us