Consumer Health Data Privacy Policy
For all consumers — required standalone disclosure
DRAFT — for counsel review before publishing. This is a standalone consumer-health-data policy prepared to meet Washington's My Health My Data Act (and to serve residents of other states with similar consumer-health-data laws, such as Nevada). By design it contains only the disclosures these laws require and no marketing content, and it must be linked separately on the homepage. Bracketed text marks facts to confirm. See
READ-ME-FIRST.md.
Last updated: [EFFECTIVE DATE — e.g., June 8, 2026]
This policy applies to consumer health data that [LEGAL ENTITY NAME] ("Cadence," "we") collects through the Cadence application. It supplements, and does not replace, our Client Privacy Policy. Cadence is intended for adults 18 and over.
1. Categories of consumer health data we collect, and why
We collect the following categories of consumer health data only to provide the fitness-coaching service you and your coach use Cadence for — to record your inputs, show your progress, enable your coach to coach you, and operate and secure the app:
| Category | Examples | Purpose |
|---|---|---|
| Body measurements & weight | Body weight; chest, waist, hips, arm, thigh measurements | Track progress; enable coaching |
| Fitness & exercise activity | Workouts logged (exercises, sets, reps, weights, effort), habits, step counts | Deliver and adjust your training program |
| Sleep, energy & mood | Self-reported sleep, energy, mood, hunger, water intake | Inform check-ins and coaching |
| Nutrition & diet | Meals logged, calories/macros/portions, food photos, post-meal reflections, dietary restrictions, allergies | Nutrition coaching |
| Health history you provide | Free-text intake notes that may include injuries or medical conditions you choose to share | Let your coach tailor your program safely |
| Bodily/biometric imagery | Progress photos (front/side/back) you choose to take, each with a visibility control | Visual progress tracking, only as you allow |
| Goals & derived insights | Health/fitness goals; progress and trends calculated from the above | Show progress; motivate; guide coaching |
You choose what to log. We do not require you to provide any specific health information.
2. Sources of consumer health data
We collect this data from:
- You, directly — what you enter, upload, or log in the app.
- Your coach (trainer), who may record baseline measurements, goals, or notes as part of coaching you.
- Automatically from your use of the app, to the limited extent the app derives insights (e.g., progress trends) from the data above.
We do not collect consumer health data from wearables, third-party data brokers, or advertising sources.
3. Categories of consumer health data we share
We share the categories listed in Section 1 only as necessary to provide the service:
- All categories may be shared with your coach, because they are coaching you.
- All categories may be processed by our service providers that host and operate the app on our behalf.
We do not share consumer health data for advertising, and we do not sell it.
4. Categories of third parties and affiliates we share with
- Your coach (trainer) — the person who invited you to Cadence.
- Service providers (processors), by category: secure cloud hosting and database infrastructure; an email/notification provider; and error-monitoring tools. These providers are contractually bound to protect the data and use it only to provide their service to us. (We maintain a current list of the specific companies and provide it on request.)
- Legal and safety recipients — courts, regulators, or law enforcement, only where legally required or to protect rights, safety, and security.
- A successor entity — in a merger, acquisition, or asset sale, bound by protections at least as strong as these.
We do not share consumer health data with advertising networks, data brokers, or affiliates for marketing.
5. We do not sell your consumer health data
Cadence does not sell consumer health data. We will not sell it. If that ever changed, the law requires us to obtain your valid written authorization first, and we would not sell without it.
6. Your rights
You have the right to:
- Confirm whether we collect, share, or sell your consumer health data, and to access that data.
- Withdraw consent to our collection and sharing of your consumer health data.
- Delete your consumer health data.
How to exercise these rights. Email [privacy@traincadence.app] [or use the in-app request tool, if you link one]. We'll verify your request and respond within [RESPONSE WINDOW — e.g., 45 days], with one extension where permitted. After you delete or withdraw consent, we'll also notify our processors to delete the relevant data, subject to limited legal retention.
Appeals. If we decline your request, we'll explain why and tell you how to appeal. If your appeal is denied, you may contact the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.
7. Contact
[LEGAL ENTITY NAME] [MAILING ADDRESS] [privacy@traincadence.app]
- Trainer Terms of Service — The commercial agreement for coaches running their business on Cadence.
- Client Terms of Use — End-user terms for the people trainers coach — including the fitness-vs-medical disclaimers.
- Client Privacy Policy — How Cadence handles the health and coaching data clients log.
- Trainer Privacy Policy — How Cadence handles trainers' business and account data, and processes client data on their behalf.