Consumer Health Data Privacy Policy

1. About this Policy

This Consumer Health Data Privacy Policy explains how 820 Fitness Group LLC, doing business as ITL Fitness App (“we”, “us”, “our”), collects, uses, shares and deletes consumer health data through the ITL Fitness App: the web app at app.itlfitness.app, the Android and iPhone apps, and the coaching features (the “Services”).

It is written to meet Washington’s My Health My Data Act (chapter 19.373 RCW) and Nevada’s consumer health data law (Senate Bill 370, 2023). It sits beside our Privacy Policy at itlfitness.app/privacy, which covers everything else; where the two overlap, they say the same thing.

We give the rights in this Policy to every user of the Services, wherever you live.

2. The consumer health data we collect, and why

Training: the exercises you do, sets, repetitions and weight, session dates, your difficulty ratings, and which sessions you completed or skipped. We use it to build your training program, adjust it week to week, and show your progress.

Body measurements: body weight and body-fat percentage. We use them to track your progress against your goal and to measure your real maintenance calories.

Sleep: when you went to bed and woke, and how you rated the night. We use it to show your sleep and to take it into account in your insights.

Nutrition: the meals and foods you log or tick off, portion sizes, and water intake. We use it to build your meal plan, track your intake against your targets, and show your progress.

Setup details and goals: age, sex, height, body weight, activity level and your fitness goal. We use them to set your calorie and macro targets.

What the app works out from the above: your calorie and macro targets, estimated and measured maintenance calories, training adjustments, deload recommendations, and the insights the app shows you. These exist only to show them to you and, if you have one, to your coach.

We do not collect heart rate or other vital signs, precise location, contacts, or information about any health condition, diagnosis, medication or health care you seek. We do not use geofencing.

3. Where it comes from

From you: what you type or tap in the app.

From your phone, only if you allow it: in the Android app, Health Connect; in the iPhone app, Apple Health. The app reads body weight, body-fat percentage and sleep, nothing else, and never writes anything back.

From a Withings smart scale, only on the website and only if you connect one: the body-weight and body-composition readings you sync.

From your coach, only if you have accepted one: changes they prescribe to your training or meal plan.

From the app itself: the targets, adjustments and insights it works out from the data above.

4. Who we share it with

We do not sell consumer health data. We do not share it with advertisers, and we do not share it with any affiliate.

Your coach, only if you accept their invitation: they can see your program, training history, most recent weigh-in, meal plans and the sessions you logged. Accepting the invitation is a separate consent from your consent to use the app, and you can withdraw it at any time with Revoke coach access in the app.

Service providers that process it on our behalf, under contract, only to run the Services: Supabase, which stores your account and your data; and Cloudflare, whose servers calculate your program, targets and insights and hold your reminder settings.

Providers that receive no consumer health data: Sentry receives error reports with health data removed on your device before they are sent; Resend delivers account emails; RevenueCat, Google Play and Apple’s App Store handle subscriptions and receive purchase records only; Google Firebase Cloud Messaging, Apple’s push notification service and your browser’s push service deliver the reminders you turned on.

We may disclose information when the law requires it. If we ever wanted to share consumer health data for any other purpose, we would ask for your consent first, separately from any other consent.

5. Your consent

Before the app records any health data, it shows you a notice explaining what it records and asks you to agree. That is your consent to collect consumer health data in order to provide the Services you asked for. Sharing with a coach needs a second, separate consent: accepting the coach’s invitation.

Health Connect, Apple Health and Withings each ask for their own permission, which you can turn off at any time in your phone’s settings or by disconnecting the scale.

6. Your rights

Confirm and access: you can ask whether we collect, share or sell your consumer health data, and for a copy of it, together with a list of every third party and affiliate we have shared it with and how to contact them. You can also export your data yourself, in the app, under More → Data & backup.

Withdraw consent: you can withdraw your consent at any time. In the app, Revoke coach access ends a coach’s access immediately; Delete my cloud data removes the copy on our servers while keeping your account; and Delete account… closes the account. You can also ask us by email.

Delete: you can delete your account yourself, in the app or on the website: More → Privacy & Health Data → Delete account…, enter your password and type DELETE. This deletes your consumer health data from our systems, ends any coach’s access, and deletes your records held by our service providers. Backup copies are purged within 90 days. You can also ask us by email.

We will not treat you differently for using any of these rights.

7. Making a request, and appeals

Email support@itlfitness.app from the email address on your account, saying which right you want to use. If you write from another address, we will ask you to confirm the request from your account’s address, so that we only act for the person the data belongs to.

We will answer within 45 days. If we need longer, we will tell you within those 45 days, and we will answer within 45 more. Requests are free, up to twice in any 12 months.

If we turn down your request, in whole or in part, you can appeal by replying to our answer with the word Appeal and why you disagree. We will answer the appeal in writing within 45 days and explain our decision. If we deny the appeal, you can complain to the Washington State Attorney General at atg.wa.gov/file-complaint.

8. Keeping it safe

Your data is encrypted in transit and at rest where supported, separated from every other account at the database level, and visible only to you and, if you accept one, your coach. Our own access is limited to what is needed to run the Services.

9. Changes to this Policy

This page shows a version number and the date it was last updated. If we change what we collect, why we collect it, or who we share it with, we will publish the new version here and ask you to agree to it in the app before the change applies to you.

10. Contact

820 Fitness Group LLC, doing business as ITL Fitness App, 5900 Balcones Dr Ste 100, Austin, TX 78731, United States. Email support@itlfitness.app.