Consumer Health Data Privacy Policy

1. Scope

Consumer health data is personal information that identifies or can reasonably be linked to a person and relates to physical or mental health status, fitness, nutrition, bodily functions, symptoms, measurements, interventions, or information inferred from those details. The exact legal definition may vary by state.

True Standard Fitness provides fitness, nutrition, wellness, and coaching tools. We do not represent that True Standard Fitness is a HIPAA covered entity. Consumer privacy laws may still protect health-related information even when HIPAA does not apply.

2. Categories of consumer health data

Depending on the features you choose, we may collect:

• Fitness goals, activity level, workout history, exercise selection, sets, repetitions, weight, effort, performance, mobility, limitations, and recovery information.
• Nutrition goals, food preferences, meal information, calories, macronutrients, supplements, dietary restrictions, and related logs.
• Body measurements, weight, body-composition information, progress trends, check-in responses, and progress photos.
• Injuries, symptoms, health conditions, medications, pregnancy status, sleep, stress, or other health context that you voluntarily include in an intake, chat, check-in, support message, or coaching conversation.
• Programs, recommendations, scores, summaries, or other health-related inferences created from information you provide.
• Permissions and consent receipts associated with collecting, using, or disclosing consumer health data.

3. Sources

• Directly from you: information entered in an account, intake, quiz, chat, check-in, log, photo upload, or communication.
• From your use of a feature: workout completion, nutrition activity, coaching interactions, and progress patterns created as you use the Services.
• From a connection you choose: information provided through a fitness, health, calendar, or other integration that you authorize, if such a connection is offered.
• Derived by the Services: plans, progress indicators, personalization, and other inferences based on the information above.

4. Why we collect and process consumer health data

We collect and process consumer health data only as reasonably necessary to:

• Provide requested fitness, nutrition, wellness, tracking, check-in, and coaching features.
• Personalize workouts, nutrition information, progress displays, reminders, and coaching responses.
• Respond to support requests and maintain continuity across the features you use.
• Operate, secure, troubleshoot, and improve health-related features.
• Honor permissions, withdrawals, access requests, exports, corrections, and deletions.
• Comply with applicable law and protect users, the public, and the Services.

Where applicable law requires permission for a particular collection, use, or disclosure, we request that permission separately. We do not use acceptance of general Terms as a substitute for a required health-data permission.

5. AI processing

When you use an AI feature, relevant health-related information may be included in the prompt or context needed to provide the response. Depending on the enabled feature, the AI processor may be Anthropic, OpenAI, or Google Gemini. Personal or health-related information is sent to an AI processor only after feature-specific permission where required.

AI is not a person or healthcare professional, can be inaccurate, and does not provide diagnosis, treatment, medical care, or emergency services. You may choose not to use an AI feature.

6. Processors and other disclosures

We may disclose consumer health data to the following categories of recipients only for a purpose described above:

• Infrastructure and storage processors: Cloudflare hosts and secures the Services and stores application data.
• AI processors: Anthropic, OpenAI, or Google Gemini processes prompts and context for the specific AI feature you choose to use.
• Communications processors: Twilio or Resend may process health-related content if you choose to communicate that information through SMS or email.
• Authorized coaching and support personnel: personnel and contractors may access information needed to provide the coaching or support you request, subject to confidentiality obligations.
• Legal and safety recipients: a court, regulator, law-enforcement body, emergency responder, or other recipient when disclosure is required by law or reasonably necessary to protect safety or legal rights.

Processors are permitted to handle consumer health data only to provide services to us or as otherwise permitted by applicable law. We do not authorize a processor to use consumer health data for its own targeted advertising.

7. No sale and no targeted advertising

We do not sell consumer health data. We do not use or disclose consumer health data for targeted advertising. We do not disclose workout or nutrition details, coaching chats, progress photos, body measurements, symptoms, health conditions, medications, or health-related inferences to advertising networks.

8. Your consumer health data rights

Subject to applicable law and identity verification, you may:

• Access consumer health data associated with you and receive information about how it is used or disclosed.
• Correct inaccurate consumer health data.
• Export available consumer health data in a portable format.
• Withdraw permission for future processing that depends on permission. Withdrawal does not affect processing that was lawful before withdrawal.
• Delete consumer health data, subject to limited legal exceptions.

Use available tools under Account > Legal in the app or email [email protected]. We may request information reasonably necessary to verify your identity and protect the account. An authorized agent may act for you when permitted by law and after providing proof of authority.

If we deny a request, you may appeal by replying to the decision or emailing the same address with the subject "Consumer Health Data Appeal." We will review and respond as required by applicable law. You may also contact the appropriate state attorney general or privacy regulator.

9. Deletion and processors

When a verified deletion request applies, we delete the covered consumer health data from active systems and direct processors to delete it where required, unless retention is permitted or required by law. Limited information may be retained for security, fraud prevention, legal claims, or to document and honor the request. Residual copies in backups are removed through the normal backup lifecycle and are not restored for routine business use.

10. Retention and security

We retain consumer health data only for as long as reasonably necessary to provide the requested feature, maintain the account, honor your choices, protect the Services, and meet legal obligations. The period depends on the type of data and the feature.

We use administrative, technical, and physical safeguards designed to protect consumer health data, including access controls and security monitoring. No storage or transmission method can guarantee absolute security. If an incident affects consumer health data, we investigate, mitigate, and provide notices required by applicable law.

11. Changes to this Policy

We may update this Policy as our health-related features or legal obligations change. We will post the updated version with a new "Last updated" date and provide any additional notice or fresh permission required by law.

12. Contact us

T&L Companies LLC d/b/a True Standard Fitness
6222 NW Gisela St
Port St Lucie, FL 34986
Email: [email protected]