Consumer Health Data Privacy Policy

Effective date: April 2, 2026

Last updated: April 2, 2026

1. About This Policy

This Consumer Health Data Privacy Policy is published pursuant to the Washington My Health My Data Act (RCW 19.373). It applies to consumer health data collected, shared, or used by Solo Innovations LLC (“Solo Innovations,” “we,” “us,” or “our”) through the Solo Fitness mobile application (“Solo Fitness” or “the app”). Solo Innovations LLC is a regulated entity under MHMDA as a company that conducts business in Washington State and collects consumer health data.

2. Categories of Consumer Health Data Collected

Under MHMDA, “consumer health data” means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status.

We collect the following categories of consumer health data through Solo Fitness:

Biometric data: Heart rate, resting heart rate, heart rate variability (HRV), heart rate recovery, R-R intervals, blood pressure, blood oxygen saturation (SpO2), respiratory rate, wrist/skin temperature, electrodermal activity, body weight, body fat percentage, lean body mass, BMI, waist circumference, and VO2 max.

Sleep data: Sleep stages (awake, light, deep, REM), sleep duration, breathing disturbances during sleep, and sleep efficiency.

Fitness and activity data: Steps, active calories, basal calories, workouts (type, duration, intensity, and perceived exertion), running power, ground contact time, vertical oscillation, stride length, walking steadiness, and GPS routes (latitude, longitude, altitude, and speed).

Reproductive and sexual health data: Menstrual flow tracking, ovulation test results, cycle length, and period length.

Nutrition data: Meal logs, calorie and macronutrient tracking, food photos, menu photos, barcode scans, fasting sessions, water intake, and caffeine intake.

Mental health and wellness data: Journal entries (free-text), mood scores, energy scores, soreness ratings, stress ratings, daily wellness check-ins, and mindfulness session data.

Body measurements: Height, weight, gender, age, and date of birth.

Location data in a health context: GPS coordinates recorded during workouts.

3. Purpose of Collection

We collect consumer health data for the following purposes:

1. AI coaching: Providing personalized health and fitness coaching powered by artificial intelligence.
2. Tracking and display: Presenting your health and fitness metrics within the app for your review.
3. Pattern insights: Identifying trends and patterns across your health data to surface actionable insights.
4. Nutrition scanning: Processing food photos, menu photos, and barcode scans to log nutritional information.
5. GPS route mapping: Recording workout routes to display maps and calculate pace, distance, and elevation.
6. Wearable synchronization: Importing health data from connected wearable devices.
7. HealthKit and Health Connect synchronization: Reading from and writing to Apple HealthKit or Google Health Connect with your permission.
8. Sleep and recovery analysis: Analyzing sleep and biometric data to generate recovery scores and recommendations.
9. Cycle tracking: Recording and analyzing reproductive health data for menstrual cycle insights.
10. Journal and wellness tracking: Storing journal entries, mood scores, and wellness check-ins for self-reflection and trend analysis.

4. Categories of Sources

We collect consumer health data from the following sources:

• Directly from you: Data you enter manually in the app, including journal entries, meal logs, body measurements, mood scores, and workout details.
• Apple HealthKit: Health and fitness data synced from Apple Health with your permission.
• Google Health Connect: Health and fitness data synced from Health Connect with your permission.
• Connected wearables: Health data imported from Oura, Garmin, and WHOOP via OAuth-authenticated connections.
• Device sensors: GPS coordinates captured by your device during workouts.
• AI-generated inferences: Health insights, recovery scores, and coaching recommendations derived from your data by our AI systems.

5. Categories of Consumer Health Data Shared

We share the following categories of consumer health data with third parties:

• Health context summaries are shared with Google Gemini to power AI coaching features.
• Social content is shared with OpenAI for content moderation purposes.
• Health data is synced bidirectionally with Apple HealthKit and Google Health Connect when you enable integration.
• Health data is synced from Oura, Garmin, and WHOOP when you connect those devices.

6. Categories of Third Parties and Affiliates

• AI service providers: Google (Gemini) and OpenAI, for AI coaching and content moderation.
• Cloud infrastructure: Supabase, for data storage and processing.
• Health platforms: Apple HealthKit and Google Health Connect, for bidirectional health data synchronization.
• Wearable device manufacturers: Oura, Garmin, and WHOOP, for importing health data from connected devices.

We do not share consumer health data with data brokers, advertisers, or marketing platforms.

7. Consent

We obtain your separate, affirmative consent before:

• Collecting consumer health data.
• Sharing consumer health data with third parties.
• Using consumer health data for any new purpose not disclosed in this policy.

Consent is obtained through in-app permission dialogs that clearly describe the data being collected or shared and the purpose of the collection or sharing.

You may withdraw your consent at any time through your app settings.

8. Sale of Consumer Health Data

We do NOT sell consumer health data. We do not exchange consumer health data for monetary or other valuable consideration.

9. Geofencing

We do NOT use geofencing technology around any healthcare facility, mental health facility, reproductive health facility, substance abuse treatment facility, or any other facility providing health care services to:

• Identify or track consumers.
• Collect consumer health data.
• Send notifications or advertisements to consumers.

10. Your Rights

Under MHMDA, you have the following rights regarding your consumer health data:

• Right to confirm: You may ask us to confirm whether we are collecting, sharing, or selling your consumer health data.
• Right to access: You may request a copy of the consumer health data we have collected about you.
• Right to withdraw consent: You may withdraw your consent to the collection, sharing, or use of your consumer health data.
• Right to delete: You may request that we delete your consumer health data, including data stored in backups, within six months of your request.
• Right to non-discrimination: We will not discriminate against you for exercising any of these rights.

11. How to Exercise Your Rights

You may exercise your rights in any of the following ways:

• In the app: Navigate to Settings to manage your data, withdraw consent, or request deletion.
• By email: Send your request to privacy@soloinnovationshq.com.

We will respond to your request within 30 calendar days.

12. Contact

Solo Innovations LLC Seattle, WA

Email: privacy@soloinnovationshq.com