Consumer Health Data Privacy Policy

Why this policy exists

This Consumer Health Data Privacy Policy is a supplement to the main PinPal Privacy Policy. It is provided to comply with the Washington My Health My Data Act (chapter 19.373 RCW), and is written to give the same protections to consumers in other states with comparable consumer-health-data laws.

It describes, specifically and only, how PinPal Technologies LLC (“PinPal,” “we,” “us,” or “our”) handles consumer health data. For everything else — account information, device information, security, retention, and your rights under other laws — see the main Privacy Policy. If anything here conflicts with the main Privacy Policy as to consumer health data, this supplement controls.

1. What “consumer health data” means

Consumer health data is personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. For PinPal, it is the health-related information you choose to enter into the app.

2. The consumer health data we collect

We collect consumer health data only when you enter it into the app:

• Protocols you create — peptide or compound name, dose, frequency, route, and schedule.
• Dose and injection logs — scheduled and actual timestamps, and completion status.
• Reconstitution calculator inputs — vial size, solvent volume, and the dose you are converting to syringe units.
• Symptom check-ins — the symptoms you select and the severity ratings you assign.
• Body weight values you log.
• Journal entries and any protocol history you paste in through the bulk-import feature.
• If you use the optional Daily Insights feature: a summary of how your biomarkers changed over an analysis window, and the resulting analysis, stored in your Daily Insights history.

What we do not collect as consumer health data. The actual readings from Apple HealthKit — your specific heart rate, HRV, weight, sleep, glucose, and blood pressure numbers — are read into memory on your device, used there for on-device charts and correlations, and are not transmitted to or stored by PinPal. The single narrow exception is the Daily Insights feature above: it sends a summary of how a biomarker changed, never the underlying readings.

3. Where the data comes from

We collect consumer health data from one source: directly from you, when you enter it into the app. We do not buy consumer health data, and we do not collect it from data brokers, advertising networks, social networks, or other third parties.

4. Why we collect it, and how we use it

We collect and use your consumer health data for one purpose: to provide the tracking and informational features you have asked us to provide — logging and displaying your protocols and doses, the reconstitution math helper, your symptom and weight check-ins, the reminders you turn on, your decay curves, and, if you use them, the AI-assisted chat and Daily Insights features.

We do not use your consumer health data for advertising, we do not use it to train AI models, we do not profile you or make automated decisions with legal effects, and we do not use it for any purpose you have not asked for.

5. How we share it, and with whom

We share consumer health data only with the service providers strictly necessary to operate the app, and only so they can perform services for us under contract. We do not share it with affiliates (we have none), advertisers, data brokers, or any third party for that third party's own purposes. The categories of third parties:

• Our backend hosting and database provider — stores the protocol, check-in, weight, journal, and Daily Insights data you enter, so the app can show it back to you.
• Third-party AI inference providers — process only the limited request payloads for the chat and Daily Insights features. Those payloads do not include your name, email address, or account identifier, and do not include the underlying HealthKit readings.

Our subscription-management provider receives purchase and entitlement metadata only; it does not receive consumer health data.

6. We do not sell consumer health data

PinPal has never sold consumer health data and does not sell it. Under the Washington My Health My Data Act, “sell” means exchanging consumer health data for money or other valuable consideration. Because we do not sell, we do not seek — and have never sought — the separate “valid authorization” the Act requires before any sale. We also do not share consumer health data for cross-context behavioral advertising.

7. Consent

PinPal collects your consumer health data only after you have created an account and provided opt-in consent in the app, and only to the extent necessary to provide the features you have requested. The in-app onboarding flow asks for this consent with a dedicated, separate confirmation — it is not bundled into your acceptance of the Terms of Service.

You can withdraw your consent at any time by deleting your account (Settings → Delete Account in the app) or by contacting [email protected]. Withdrawing consent stops further collection; to also remove data already collected, use the deletion right below.

8. Your rights

You have the right to:

• Confirm and access — confirm whether we are processing your consumer health data, and access that data.
• Withdraw consent — to our collection and any sharing of your consumer health data.
• Delete — have your consumer health data deleted.
• Receive a list of recipients — request the categories of third parties and affiliates with whom we have shared your consumer health data.
• Appeal — appeal any denial of the requests above.

How to exercise these rights. Use Settings → Delete Account in the app (fastest and most complete for deletion and withdrawal of consent), or email [email protected]. We may ask you to verify your identity. We respond within 45 days; where reasonably necessary we may extend once by a further 45 days and will tell you why.

Appeals. If we deny a request, we will tell you the reason and how to appeal. To appeal, reply to our denial email. If your appeal is denied, you may submit a complaint to the Washington State Attorney General at atg.wa.gov/file-complaint.

9. Changes to this policy

We may update this policy. Material changes are announced by in-app banner and email at least 30 days before they take effect, except where a shorter period is required by law. Non-material changes are reflected in the date at the top of this page.

10. Contact

Questions or requests about your consumer health data: [email protected]

PinPal Technologies LLC · California, USA