Legal

Consumer Health Data Privacy Policy

For residents of Washington and Nevada, USA

Effective date 1 November 2026 · Last updated 1 November 2026

This policy is provided by NudgiFi Technologies Limited under the Washington My Health My Data Act and Nevada Senate Bill 370. It describes how the NudgiFi app handles consumer health data — personal information linked to you that identifies your past, present or future physical or mental health status. It is separate from, and supplements, our general Privacy Policy.

1. Consumer health data we collect

Only when you enable the relevant feature, the NudgiFi app may process on your device:

  • Onboarding and reflection answers about stress, anxiety, mood, sleep, motivation and routines

  • Mood and wellbeing estimates and confidence values generated by the app

  • Steps, workouts and sleep information from Apple Health (Apple devices, with your authorisation)

  • Movement, activity and inactivity information from device motion sensors

  • Biometric templates used for voice-ID and social memory (face and voice embeddings)

  • Precise location, where it could reveal a visit to a health facility

2. Sources

All consumer health data comes from you — your answers, your device’s sensors and permissions you grant, and Apple Health where you authorise it.

3. Purposes

We process consumer health data solely to provide the features you enable: personalised coaching, reminders timed to your context, wellbeing insights, and recognition of saved people or speakers. We do not use it for advertising, profiling for marketing, or research for other users.

4. Where it is stored and who receives it

All consumer health data is stored and processed on your device. NudgiFi Technologies Limited does not collect it on its servers and does not have access to it.

  • Categories shared: none.

  • Affiliates with whom it is shared: none.

  • Third parties with whom it is shared: none. We do not sell consumer health data and have never sold it.

  • Processors: none process your consumer health data. Our general sub-processors (https://nudgifi.com/subprocessors) handle only account and connection information.

  • Information you yourself export, back up to a cloud service, add to a calendar or share with another person goes to the destination you choose, under its terms.

5. Your rights

You have the right to: confirm whether we are collecting, sharing or selling your consumer health data and to access it; withdraw consent; have it deleted, including from any third party; and appeal a decision we make about your request. We will not discriminate against you for exercising these rights.

Because your consumer health data exists only on your device, the fastest way to access, export or delete it is through the app’s own controls (Profile → Privacy and account). To make a request to us, email [email protected] or write to NudgiFi Technologies Limited, 199 St. Saviours Road, Birmingham, B8 1HW, United Kingdom. We respond within 45 days (extendable once by 45 days where reasonably necessary). To appeal a decision, reply to our response with “Appeal” in the subject line; we respond to appeals within 45 days and, if the appeal is denied, you may contact the Washington Attorney General (https://www.atg.wa.gov) or the Nevada Attorney General.

Before the app begins collecting any category above we ask for your separate consent in a clear, specific request. You can withdraw it at any time in the app or in device settings.

7. Changes

We update this policy when our practices change and post the new version at this address with a new effective date.

Contact: [email protected]