Consumer Health Data Privacy Notice

At Wellva, privacy is a core part of how we build our products.

1. We do not sell your consumer health data.
2. We do not use your health data for advertising, ad targeting, or marketing profiling. We do not share health data with advertising platforms, ad networks, or data brokers.
3. We do not share health data with advertising platforms, data brokers, or ad networks.
4. We collect only the minimum amount of consumer health data needed to provide the features you choose to use.
5. We process consumer health data to support your use of Wellva, not to exploit it.

“Consumer health data” means personal data that is linked or reasonably linkable to you and that identifies, describes, or may reasonably be used to infer your past, present, or future physical or mental health status.

For Wellva, consumer health data may include information relating to menstrual health, fertility, pregnancy, symptoms, body measurements, medication-related entries, wellness tracking, and similar health-related information that you choose to provide or that we derive from your use of the App.

We may collect consumer health data from the following sources:

1. Directly from you, when you enter information into the App, configure settings, log symptoms, add notes, record medication-related entries, or otherwise use health-related features.
2. From your use of the App, including your use of cycle tracking, fertility insights, pregnancy mode, medication reminders, kick counting, partner-sharing features, and related Services.
3. From account and sign-in activity where necessary to connect health-related app data to your account or synchronized devices.
4. From in-app interactions that relate to health or wellness features, such as logs, check-ins, and notes.
5. From data we derive or infer based on the information you provide, such as cycle predictions, fertile window estimates, ovulation estimates, pregnancy progress information, and cycle trends.

Depending on the features you use, Wellva may collect the following categories of consumer health data:

1. Menstrual and cycle information, such as cycle length, period length, period dates, cycle history, and related calendar information.
2. Fertility and ovulation information, such as fertility-related indicators, ovulation estimates, ovulation test entries, and related reproductive health tracking.
3. Pregnancy-related information, such as pregnancy start date, due date, pregnancy history, pregnancy progress, checklist activity, and fetal kick count sessions.
4. Symptom and wellness information, such as symptom logs, mood entries, body-related observations, wellness tracking, and free-text notes you choose to add.
5. Sexual and intimacy-related information, if you choose to log it.
6. Body measurement and body signal information, such as temperature entries and weight entries.
7. Medication-related information, such as medication reminders, schedules, and intake records.
8. Inferred or derived health insights, such as cycle predictions, fertile window estimates, ovulation estimates, pregnancy progress information, and cycle trend insights.

We may also be able to infer health-related information from non-health data you provide through your use of the App.

We do not collect precise location data or use location data to infer sensitive health conditions.

We use consumer health data to provide, operate, maintain, secure, and improve the health-related features and services you choose to use in Wellva.

We may use consumer health data to:

1. Provide cycle, fertility, pregnancy, symptom, medication, and wellness tracking features.
2. Generate predictions, trends, insights, and personalized health-related app functions.
3. Display your logged data, notes, and history in the App.
4. Synchronize your health-related app data across devices where account sync is available.
5. Support partner-sharing features when you intentionally enable them.
6. Schedule and support reminders that you choose to configure.
7. Deliver educational, pregnancy-related, wellness, and other in-app content that supports the features you use.
8. Respond to your requests and provide support.
9. Maintain security, detect misuse, prevent unauthorized access, and protect the integrity of our Services.
10. Comply with legal obligations and protect our legal rights.

We may also use consumer health data for internal operational purposes such as maintaining, debugging, securing, and improving the performance and reliability of the App and related Services, provided that we do not use your health data for advertising.

We do not use consumer health data for purposes that are unrelated to the features and services you choose to use.

We do not sell consumer health data.

We do not use consumer health data for advertising, targeted advertising, or marketing profiling.

We do not share consumer health data with advertising platforms, ad networks, or data brokers.

We may disclose consumer health data only in the following limited circumstances:

1. To service providers and processors that help us operate Wellva, such as cloud hosting providers, authentication providers, storage providers, infrastructure providers, security services, and customer support tools. These providers process data on our behalf under written agreements and are not authorized to use it for their own independent purposes except as permitted by law.
2. To sign-in providers such as Apple or Google, but only to the extent necessary when you choose those login methods.
3. To a linked partner if you intentionally enable a partner-sharing feature. In that case, the linked partner may receive limited health-related information based on the mode and sharing features you have chosen to use.
4. To legal authorities, courts, regulators, or other parties where required by law, legal process, or enforceable governmental request.
5. To protect the rights, safety, security, or integrity of Wellva, our users, or others, including in connection with fraud prevention, security incidents, and misuse of the Services.
6. In connection with a merger, acquisition, restructuring, sale of assets, financing, insolvency process, or similar corporate transaction, subject to applicable legal protections.

Except as described above, we do not disclose consumer health data to third parties for their own advertising or commercial profiling purposes.

Where required by law, we obtain your consent to collect and process consumer health data.

You provide this consent by choosing to enter and store health-related information in the App or by using features that rely on that information.

You may withdraw your consent at any time by:

1. Deleting the relevant data from the App.
2. Deleting your account through the App settings, if that feature is available.
3. Contacting us at contact@wellva.one

Please note that because Wellva’s core services rely on health-related information, withdrawing consent for the collection or processing of consumer health data may limit or prevent us from providing some or all health-related features of the App.

We retain personal data for as long as reasonably necessary to provide Wellva, maintain account and sync functionality, comply with legal obligations, resolve disputes, enforce our agreements, and protect the security and integrity of our Services.

In general:

1. Consumer health data stored locally on your device may remain there until deleted, overwritten, or removed when you uninstall the App.
2. Consumer health data associated with an account or synchronization feature may be retained while your account is active and for a limited period afterward, typically up to 30 days after account closure or last activity, unless longer retention is required by law, security needs, fraud prevention, or dispute resolution.
3. Some data may remain in backups or disaster recovery systems for a limited additional period.
4. If you request deletion, we will delete or de-identify consumer health data as required by applicable law, subject to lawful exceptions.

Depending on the law that applies to you, you may have the right to:

1. Confirm whether we collect, use, or share your consumer health data.
2. Access consumer health data that we have collected about you.
3. Delete consumer health data that we have collected about you.
4. Withdraw consent relating to the collection or sharing of consumer health data.
5. Receive information about the categories of consumer health data we collect, the purposes for which we collect and use it, and the categories of third parties with whom it is shared.
6. Appeal a denial of your privacy request, where required by applicable law.
7. Be free from unlawful discrimination for exercising your privacy rights.

To exercise your rights, contact us at contact@wellva.one

We may need to verify your identity before responding to your request. If we deny your request, and the law gives you the right to appeal that decision, you may do so by replying to our decision email or contacting us again at contact@wellva.one with the subject line “Privacy Appeal.”

If you have questions or concerns about this Consumer Health Data Privacy Notice or our handling of consumer health data, please contact us at:

Wellva OÜ
Ahtri tn 12
10151 Tallinn, Estonia

Contact: contact@wellva.one

If you live in a jurisdiction that gives you the right to contact a regulator or supervisory authority, you may also contact that authority directly.