Consumer Health Data Privacy Policy

Effective date: November 4, 2026

Developer: Primealpha Research

Privacy contact: [email protected]

This policy supplements Sovasta Health's general Privacy Policy. It is intended to describe Sovasta Health's current practices for information that may qualify as consumer health data under applicable U.S. state law, including laws that can define collection broadly enough to include local access, processing, derivation, or inference. This policy does not limit rights provided by applicable law.

1. Age policy

The current U.S. web launch is intended for adults age 18 and older.

2. Categories of consumer health data Sovasta Health may collect or process

Depending on the features available and the features you choose, categories may include:

3. Sources

Sources may include information you enter, device sensors you activate, Apple Health or Health Connect records you authorize, files or documents you choose, and information Sovasta Health derives locally from those sources.

4. Purposes

Sovasta Health processes consumer health data to provide features you request, display local wellness trends and non-diagnostic estimates, perform quality and safety checks, maintain local integrity evidence, support deletion and consent controls, and perform user-directed export or sharing when you choose it. Sovasta Health does not use consumer health data for behavioral advertising or data brokerage.

5. Local-first architecture and remote systems

The current health-intelligence runtime is designed so that the health dataset remains on the user's device. Sovasta Health Commerce Edge is designed not to accept health measurements, camera or audio telemetry, Apple Health or Health Connect records, wellness logs, N-of-1 observations, or Personal Response Graph data.

Local-first architecture does not by itself determine whether applicable law considers local access, processing, derivation, or inference to be collection. Sovasta Health therefore describes these practices in this policy.

6. Sharing, sale, and third parties

7. Consent and withdrawal

Where applicable law requires affirmative consent, Sovasta Health should obtain that consent before the relevant collection, use, or sharing. You may withdraw device and health-platform permissions in system settings and may stop using a feature. A future feature that introduces a new category, purpose, recipient, or transfer must be disclosed and consented to where required before the new practice occurs.

8. Your rights

Depending on applicable law, you may have rights to request confirmation about consumer health data Sovasta Health possesses, obtain information about third parties with whom Sovasta Health has shared or sold such data, request cessation of certain collection or sharing, withdraw consent, request deletion, or appeal a refusal.

For the current local-only health dataset, Sovasta Health generally cannot inspect or remotely delete data it does not possess. Use Sovasta Health's local deletion and permission controls for that dataset. For information Sovasta Health actually possesses because you transferred it to Sovasta Health or because another permitted remote process created it, initiate a request at [email protected]. Do not include raw health data in the initial request. Sovasta Health may use a separate verification process before acting.

9. Appeals

If applicable law gives you a right to appeal a refusal, send an email with the subject "Consumer Health Data Appeal" to [email protected] and identify the prior request without attaching raw health information. Sovasta Health will respond within the time required by applicable law.

10. Deletion

Local records can be deleted using Sovasta Health's Delete Account & Data control, app-storage controls, or uninstall. Apple Health or Health Connect records must be managed separately. For consumer health data Sovasta Health actually possesses remotely, Sovasta Health will process authenticated deletion requests as required by applicable law, subject to lawful exceptions and third-party retention rules.

11. Security

Sovasta Health applies administrative, technical, and product controls appropriate to the nature of the data and the local-first architecture. No security measure can guarantee absolute protection.

12. Geofencing and health targeting

Sovasta Health does not use geofencing around health-care facilities to identify, track, collect consumer health data from, or send health-related messages or advertising to consumers.

13. Changes

If Sovasta Health materially changes the categories, purposes, sharing practices, or other practices described here, it will update this policy and obtain consent where applicable law requires consent before the new practice begins.

14. Contact

Primealpha Research
Email: [email protected]