Consumer Health Data Privacy

A separate notice for consumer health data.

This policy describes consumer health data collection, use, sharing, and Washington privacy rights.

Effective date: September 1, 2026
Last updated: October 6, 2026

This policy describes how Wellness Frontier, operated by Advanced Health and Wellness Group, collects, uses, and shares consumer health data as those terms are defined by the Washington My Health My Data Act.

1. Categories of consumer health data we collect and why

CategoryExamplesPurpose
Bodily functions, vital signs, and measurementssteps, sleep duration, resting heart rate, water you logshow your measurements and progress, support goals, and operate the wellness features you request
Past measurements sent onceyour step totals and time asleep for the 14 finished days before you first connect a health sourcestart your own Wellness Score, so it works from the day you connect. They never earn points
A score worked out from the data aboveyour own Wellness Score, out of 100, from your steps, sleep, water, lessons finished, and thanks sentshow you your own score, and give your employer one company-wide average each month
Device and app check tied to step uploadsthe result of a Google or Apple check that the app is genuine and the phone is real, and a scrambled identifier for the app's installationconfirm that steps came from the real app on a real phone before they earn points, and keep one phone earning for one employee at a time
Health and wellness responsesanswers you choose to provide in a health or wellness surveyprovide your wellness experience and create employer reports that contain participation counts, not your answers
Wellness interests and choicesthe wellness area you voluntarily select as most important for the monthpersonalize the program and create company-wide monthly totals
Wellness-program activitycompleted actions, connected-source status, goals, points, achievements, and days-in-a-row progressoperate the program, recognize participation, and create the limited employer reports described in our general Privacy Policy
Food and weight records you keepwhat you ate or drank, how much, the date and time, and calories if you add them; a weight you type and its dateshow your own records to you. Only you can see them
Action plans you writethe goal and actions you write after a library video, and the yes or no marks for the seven days after you finishshow your own plan to you. Only you can see what you wrote
Facts about your records and videosthe days you added a food or weight entry, not which of the two. The video and month of an action plan you finished. The days you finished a plan. The library videos you finished each monthcount toward your Education goal, points, and badges. Your employer does not see these facts
Benefits and care-seeking questionsa question you submit to an enabled benefits coachanswer the question from employer plan documents and improve the coach using a de-identified question
Information that identifies health-service useuse of health-related app featuresprovide the feature, protect the service, and meet legal obligations

We also process identifiers, such as your name, work email, and account reference, when needed to associate consumer health data with your account.

2. Sources of consumer health data

We collect consumer health data from:

  • you, when you answer a question, set a goal, choose a wellness area, or use a

program feature;

  • Apple Health or Health Connect, after you approve specific read access,

including the 14 finished days sent once when you first connect;

  • your phone, when it confirms to us that the app is genuine and the phone is

real before your steps earn points;

  • program records created when you complete an action, earn points, or use a

feature; and

  • your employer, for account and workplace information used to make the

program available to you.

3. Categories of consumer health data we share

We share the following categories only as needed to provide the service you request or as otherwise permitted by law:

  • consumer health data processed by our contracted service providers for

hosting, databases, storage, email delivery, security, support, document processing, search, and the AI coach;

  • named program-participation information provided to your employer, including

your name, points, and place on the points board if you have points, unless you take your name off that board in the app;

  • participation counts and group-level wellness-program totals provided to

your employer;

  • one company-wide average Wellness Score each month, and how many people it

covers, provided to your employer. This average has no minimum group size, and your employer never receives your own score;

  • what Google or Vimeo receives when a video player loads. Library videos play

in YouTube's player. A challenge video plays in YouTube's or Vimeo's player. They receive the video, the time, your IP address, details about your device, and the web address of the app. The app does not give Google or Vimeo your name, your email address, or your account;

  • information about the app and the phone, and a scrambled fingerprint of a

step upload, sent to Google on Android or Apple on iPhone to confirm the app and the phone. Neither receives your steps; and

  • consumer health data required by valid legal process.

We do not share your individual connected-health measurements, survey answers, coach or benefits questions, medical history, or sensitive-support-resource use with your employer. We do not sell consumer health data.

Your employer also never receives your food, weight, or action plan records. It never receives which library videos you watched.

Your employer's admin can change the email you sign in with. Whoever can read mail at the new address can then sign in and see your health data. Section 4 of our Privacy Policy explains this.

4. Third parties and affiliates

The categories of third parties with which we share consumer health data are:

  • Microsoft Corporation and its Azure services, as contracted processors

for cloud hosting, databases, storage, email delivery, security, document processing, search, and Azure OpenAI when the coach is enabled. Where the coach is enabled, Microsoft keeps a copy of the question submitted to it and the answer returned, and authorized Microsoft personnel may review that copy to detect abuse and misuse of their service. Microsoft keeps it for a limited period and then deletes it. We have not been granted an exemption from this monitoring. That copy is held by Microsoft, not by us: we cannot read it and we cannot delete it in response to a request made to us;

  • Google LLC (on Android) and Apple Inc. (on iPhone), which confirm that

the app is genuine and the phone is real before steps earn points. They receive information about the app and the phone and a scrambled fingerprint of the upload, never your steps, and they process it under their own terms;

  • Google LLC, through its YouTube player, and Vimeo, through its

player, when a video player loads. Library videos play in YouTube's player. A challenge video plays in YouTube's or Vimeo's player, which loads when the challenge is on your screen. Each receives which video it is and when, your IP address, details about your device, and the web address of the app, which can include your employer's name. If you are signed in to Google or Vimeo on that device, it may know who you are by name. Each handles this under its own terms and keeps it for as long as its own rules say. YouTube may show ads that we do not choose;

  • your employer, only for the employer-visible program information and

group-level reports described above; and

  • government authorities or other recipients required by law, when a valid

legal requirement applies.

Specific affiliates: none.

5. How to exercise your rights

Subject to applicable law, you may:

  • confirm whether we collect, share, or sell consumer health data about you;
  • access your consumer health data and receive a list of third parties and

affiliates with which it was shared or sold, including a way to contact them;

  • withdraw consent to future collection or sharing; and
  • request deletion of consumer health data, including notice of the request to

processors and other recipients as required by law.

You may use the app’s Account area to disconnect a health source or request account deletion where that control is available. You may exercise any right, or appeal a refusal to act, by emailing privacy@wellnessfrontier.ai. You do not need to create a new account to make a request. We may ask for information reasonably needed to authenticate you and the request.

We will respond without undue delay and within 45 days. When reasonably necessary, we may extend the response period once by up to 45 additional days and will tell you why during the first 45 days. Responses are free up to twice per year unless a request is manifestly unfounded, excessive, or repetitive.

If we deny an appeal, we will explain the decision in writing and provide a way to contact the Washington State Attorney General.

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