Consumer Health Data Privacy Policy

1. Categories of Consumer Health Data Collected

TraciaAI collects the following categories of consumer health data, as defined under the Washington My Health My Data Act (RCW 19.373):

• Meal descriptions and nutritional information you log
• Workout and exercise data you record
• Body composition analysis results (text summaries only — photos are never stored)
• Weight history and body measurements
• Health goals (weight loss, muscle gain, maintenance)
• Health platform data synced from Apple HealthKit or Google Health Connect (steps, active calories, resting heart rate)
• AI coaching conversations related to nutrition, fitness, or wellness
• Inferences derived from the above (e.g., BMI calculated from height and weight, caloric targets)

2. Categories of Sources

We collect consumer health data from the following categories of sources:

• Directly from you: Information you provide when creating your profile (height, weight, age, gender, activity level, goals), meals and workouts you log, messages you send to the AI coach, and photos you submit for meal logging or body composition analysis (body photos are immediately discarded after AI processing)
• Health platform integrations: Data you choose to sync from Apple HealthKit or Google Health Connect, accessed only with your explicit permission
• Derived by TraciaAI: Inferences generated from data you provide, such as BMI, caloric targets, and macro breakdowns

We do not purchase consumer health data from third-party data brokers. We do not collect consumer health data through tracking technologies on third-party websites.

3. Purpose of Collection and How Data Will Be Used

We collect and use consumer health data for the following purposes:

• Providing the App's core services: meal tracking, workout tracking, AI coaching, and goal management
• Generating AI-powered nutritional estimates, workout suggestions, and coaching guidance
• Calculating personalized caloric and macronutrient targets
• Producing weekly progress summaries and insights
• Improving our AI models using anonymized, aggregated data only

We do not use consumer health data for advertising or marketing purposes. We do not use consumer health data to discriminate against any consumer.

4. Categories of Consumer Health Data Shared

The following categories of consumer health data may be shared with third parties solely for the purpose of providing the App's services:

• Chat messages and user context (shared with AI service providers for coaching responses)
• Meal photos (shared temporarily with AI service providers for food image analysis)
• Account and health data (stored by hosting and cloud storage providers)

We do not sell consumer health data. We do not share consumer health data for advertising purposes. We do not share consumer health data with data brokers.

5. Categories of Third Parties and Specific Affiliates

We share consumer health data with the following third parties:

• Anthropic (Claude API): Receives chat messages and user context to generate AI coaching responses. Data is not retained beyond the API call.
• Google (Gemini API): Receives meal photos temporarily for food image analysis. Photos are not retained beyond the API call.
• Railway: Hosts our backend infrastructure where your account and health data are stored.
• Cloudflare R2: Stores meal photos in encrypted cloud storage for the retention period specified in our Privacy Policy.

Affiliates: Hubster S.M.N LTD has no affiliates that receive or process consumer health data.

6. How to Exercise Your Rights

Under the Washington My Health My Data Act, you have the following rights:

• Right to Know: Confirm whether we are collecting, sharing, or selling your consumer health data and access the specific data we hold, including a list of all third parties and affiliates who have received your data
• Right to Withdraw Consent: Revoke your consent to the collection and sharing of consumer health data at any time
• Right to Delete: Request deletion of your consumer health data. We will fulfill deletion requests without unreasonable delay and no more than 30 calendar days from receipt of the request.

To exercise any of these rights, contact us at hey@hubst3r.com or use the account deletion feature within the App. We will respond to verified requests within 30 days. We will not discriminate against you for exercising your rights.

7. Appeal Process

If your request to exercise a right under this policy is denied, you may appeal the denial by contacting us at hey@hubst3r.com with the subject line "MHMDA Appeal". We will respond to your appeal within 45 days with a written explanation of our decision.

If your appeal is denied, you may file a complaint with the Washington State Attorney General:

Washington State Attorney General's Office
Website: www.atg.wa.gov/file-complaint