Consumer Health Data Privacy Policy

1.At a glance

2.About this policy

This Consumer Health Data Privacy Policy is provided by Ashlar Enterprises LLC (“Ashlar”, “we”, “us”), an Oklahoma limited liability company that operates LifeAnchor. It is written to meet Washington’s My Health My Data Act (RCW 19.373) and Nevada’s consumer health data law (Senate Bill 370, codified in NRS Chapter 603A), and we apply it to every LifeAnchor user, wherever they live.

“Consumer health data” means personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health status. That includes information we derive or infer from other data.

This policy supplements our Privacy Policy. If the two differ on consumer health data, this policy controls.

LifeAnchor is sold directly to consumers. Ashlar is not a health plan, a health care provider or a business associate of one, so LifeAnchor is not covered by HIPAA. LifeAnchor’s health features help you record and view information; they do not diagnose, interpret readings or give medical advice. See our Health Disclaimer.

3.Consumer health data we collect, why, and who receives it

We collect only what you or your household choose to enter or connect. Most features are optional and many fields can be left blank.

We do not collect biometric data such as fingerprints or face scans. If you lock the mobile app with your device’s biometrics, that happens on your device and we never receive it. We do not collect precise location data from your device.

4.Where we get consumer health data

• From you, when you enter or upload information in LifeAnchor’s Health features, your profile, your Emergency Card or the Vault.
• From your household, when a parent or guardian logs information about a child, or another member enters information about you (for example, recording a medication a family member gives you).
• From health services and devices you connect — Oura, Dexcom and Tidepool — and from pump export files you upload.
• From your use of AI features, when a question you ask contains health information.

5.How we use consumer health data

We use consumer health data to provide the health features you request — to store, display, chart and organise it, to sync with devices you connect, to show your Emergency Card, and to run AI features you choose to use. We also use it as necessary to keep LifeAnchor secure (for example, recording access in our audit log), to respond to your requests and support questions, and to comply with law.

We do not use consumer health data for advertising or marketing, to build profiles for anyone else, or to train AI models.

6.Who we share consumer health data with

We share consumer health data only with the following categories of recipients:

• Members of your household, as you or your household grant. Access is decided per person and per health category by our database, not just by the app’s screens. If you are an adult, other members of your household cannot see your health information unless you share it or grant them access. Sensitive categories — mental health, reproductive health, health documents, device integrations and the health timeline — are visible to another person only if you grant access. Members can use sharing settings to share or withhold particular metrics. A parent or guardian (the head or co-head of household) can see a minor’s non-sensitive health information; sensitive categories still require an explicit grant.
• Our processors (service providers). Supabase, Inc. stores the data (database, authentication and file storage, in the United States). DigitalOcean, LLC hosts the application servers the data passes through (in the United States). They process data only on our instructions. Open Food Facts receives only a barcode or food search text, never your identity.
• The AI provider your family chose. If you use an AI feature, the health information that feature needs goes to the provider your family connected (Anthropic, OpenAI or Google), under your family’s own account and that provider’s terms. Health data is sent only to first-party connections an admin has confirmed, health-related AI is not available to children under 13, and AI features do not diagnose, interpret readings or calculate medication or insulin doses. See our AI Notice.
• Device and health companies you connect. When you connect Oura, Dexcom or Tidepool, we receive your data from them under your account with them, and send them what is needed to maintain that connection.
• People who view your Emergency Card — see Emergency Card.
• Ashlar staff, under controls. Authorised staff may access health information only when needed to support you, secure the service or meet legal obligations, using controlled tools. Emergency access is time-limited (60 minutes), and all access to health information is recorded in an append-only, hash-chained audit log.
• As required by law, such as in response to a valid court order, and only to the extent required.

Affiliates. Ashlar has no affiliates that receive consumer health data. Ashlar’s internal customer-support system does not receive health records; it holds account and plan details and any feedback you send (so please leave health details out of feedback).

You can ask us for a list of the specific third parties with which we have shared your consumer health data (see Your rights).

7.Consent

We collect consumer health data only to the extent necessary to provide a feature you have asked for, or with your consent. We share it only as necessary to provide the feature you asked for — for example, showing it to a family member you granted access, or sending your question to your AI provider when you ask it — or with your separate consent.

If we ever want to collect, use or share it for another purpose, we will ask for a separate consent first, explaining what data, why, who would receive it and how you can withdraw. A parent or legal guardian gives consent for a child.

You can withdraw consent at any time (see below). Withdrawing consent means we will stop the collection or sharing it covered; some features may stop working as a result.

8.We never sell consumer health data

We do not sell consumer health data, and we do not exchange it for anything of value. Washington law would require a separate, signed, valid authorisation from you before any sale; we do not ask for one because we do not sell.

9.No geofencing

We do not use geofences — virtual boundaries around a location — around health care facilities or anywhere else to identify, track, collect data from or send messages or ads to anyone. LifeAnchor does not collect your device’s GPS location; the only location information it has is text you type, such as a city or ZIP code.

10.Emergency Card

The Emergency Card is designed to share critical information quickly. If you set one up, the information on it — allergies, medications, conditions, blood type, DNR and organ-donor flags, physician, hospital and notes you add — is shown to someone who has the card’s link or access, for a limited time. Anyone you give that access can see it, so choose what to include and who to give it to carefully. You can edit or remove the information on your card at any time.

11.Your rights

You have the right to:

• Confirm and access. Confirm whether we collect, share or sell your consumer health data, and get access to it, including a list of all third parties and affiliates with which we have shared it and an active email address or other online contact for each. You can download your data, including that list, yourself from Settings → More → Your Data, or ask us by email.
• Delete. Have your consumer health data deleted. Once we have verified your request, we delete it within 30 days, and we also tell our processors to delete it. Data in encrypted backups leaves them within 30 days as the backups expire; it is not restored except for disaster recovery, and if a backup is ever restored, we re-apply deletions. The audit record of access to health information is kept for at least six years as a security record, and we may keep information the law requires us to keep.
• Withdraw consent. Withdraw your consent to our collection or sharing of your consumer health data.
• Not be discriminated against. We will not treat you differently for exercising these rights.

A parent or legal guardian can exercise these rights for a child.

12.How to exercise your rights

• Make a request by emailing [email protected].
• We verify your identity before acting, usually by confirming the request through the email address on your account. We use information you give us for verification only for that purpose.
• We respond within 45 days of receiving your request. If reasonably necessary, we may extend that once by a further 45 days; if we do, we will tell you within the first 45 days and explain why. Once we have verified a deletion request, we complete the deletion within 30 days.
• Requests are free, up to twice a year. We may charge a reasonable fee or decline a request that is manifestly unfounded, excessive or repetitive, and will tell you why.
• Appeals. If we decline your request, reply to our decision email with “Appeal”. We will respond in writing within 45 days, explaining what we did and why. If your appeal is denied, you may file a complaint with the Washington State Attorney General or, if you live in Nevada, contact the Nevada Attorney General.

13.How we protect consumer health data

We limit access to consumer health data to people who need it to provide the service or meet our obligations, and we protect it with administrative, technical and physical safeguards, including HTTPS (TLS) for every connection, database row-level security that is regularly tested by automated cross-household probes, extra encryption at rest for health-device tokens, AI keys, health-goal notes and attachments, medication label photos and Vault documents, and a tamper-evident audit log of access to health information kept for at least six years.

LifeAnchor is not end-to-end encrypted: our servers process health data in readable form so the features can work. If we discover a breach of unsecured health information, we will notify affected people and the Federal Trade Commission within 60 calendar days, as the FTC Health Breach Notification Rule requires, and will notify the media where it requires. See our Security page.

14.Children and teens

Minors can use LifeAnchor only as household members added by a parent or legal guardian, who consents to the collection of their consumer health data. Health-related AI is blocked for children under 13, and members under 18 get stricter rules in the AI coach. When a member turns 18, their health records become their own. See our Children’s Privacy Notice.

15.How long we keep it

We keep consumer health data while your account is active, or until you delete it or ask us to. See our Data Retention page for details, including the exceptions described above.

16.Changes to this policy

If we change this policy, we will post the new version with a new effective date. If a change would let us collect, use or share consumer health data in a way not described here, we will ask for your consent before doing so.

Effective date: October 13, 2026. Version 1.0.

17.Contact us

Ashlar Enterprises LLC, 9905 S Pennsylvania Ave, Suite A, Oklahoma City, OK 73159 · (405) 957-9360 · [email protected]