Consumer Health Data Privacy Notice

1.

Introduction

This Consumer Health Data Privacy Notice explains how Wellva handles consumer health data when laws that specifically protect consumer health data apply.

It supplements our Privacy Policy and describes the categories of consumer health data we may process, the reasons we process it, and the rights available to eligible consumers.

2.

Scope of This Notice

This notice applies only to consumer health data covered by applicable law, and only to the extent those laws apply to your use of Wellva.

If this notice conflicts with another privacy disclosure, this notice controls for consumer health data covered by those laws.

3.

Consumer Health Data We Collect

Depending on how you use the app, we may process consumer health data such as:

Cycle dates, fertility-related inputs, and symptom logs
Health-related observations or notes you choose to record
Inferences generated from your inputs, such as predicted cycle phases or fertile windows
Account-linked information when needed to provide access, syncing, or support

4.

Sources of Consumer Health Data

We collect consumer health data from the following sources:

Directly from you when you enter information into the app
From your interactions with product features that generate predictions or summaries
From limited technical records needed to operate the service securely and reliably

We do not buy consumer health data from data brokers.

5.

How We Use Consumer Health Data

We use consumer health data to:

Provide core app functionality, predictions, and insights
Maintain, secure, and improve the service
Support account access, syncing, and troubleshooting
Comply with legal obligations and respond to valid requests where required by law

We do not use consumer health data for advertising profiling or ad targeting.

6.

Disclosure and Sharing

We may disclose consumer health data only in limited circumstances, such as:

To service providers processing data on our behalf under contractual restrictions
To comply with applicable law, lawful process, or regulatory requirements
To protect rights, safety, or the security of the service when permitted by law
As part of a corporate transaction, subject to applicable safeguards and notice requirements

We do not sell consumer health data.

7.

Your Rights and Choices

Where applicable law provides these rights, you may have the right to:

Confirm whether we collect, use, or disclose consumer health data about you
Access or receive a copy of covered consumer health data
Request deletion of covered consumer health data
Withdraw consent when processing depends on your consent
Appeal a decision on your request where the law provides that right

8.

How to Submit Requests

You may submit privacy requests using the contact methods we make available through Wellva once they are published.

We may need to verify your identity before fulfilling a request, and we may decline or limit a request where permitted by applicable law.

9.

Retention and Security

We retain consumer health data only for as long as needed to provide the service, comply with legal obligations, resolve disputes, and enforce agreements.

We use technical and organizational safeguards designed to protect consumer health data, but no system can guarantee absolute security.

10.

Changes and Contact

We may update this notice from time to time to reflect legal, product, or operational changes.

Official contact details for privacy requests and inquiries will be published before launch.