Consumer Health Data Privacy Policy
This Consumer Health Data Privacy Policy supplements the PTG Fitness Privacy Policy. It describes PTG's practices for "consumer health data" under applicable U.S. laws, including Washington's My Health My Data Act and Nevada's consumer health privacy law.
Consumer health data means personal information that identifies or can reasonably be linked to a consumer and relates to or is used to identify or infer the consumer's physical or mental health status. The term can be broader than medical records and can include fitness, nutrition, sleep, and derived wellness information.
1. Categories of Consumer Health Data We Collect
- Body and profile information: age, sex or gender, height, current and target weight, activity level, physical limitations or preferences you choose to provide.
- Fitness and activity information: goals, experience, equipment, schedules, workout plans, exercises, sets, repetitions, duration, completed workouts, steps, active and resting energy, and exercise minutes.
- Nutrition and hydration information: diet preferences and restrictions, meal plans, food and meal logs, meal photos, barcode and food searches, calorie and nutrient information, and water intake.
- Sleep and recovery information: sleep duration, time in bed, bedtime and wake time, sleep efficiency, and related activity summaries.
- Derived and inferred information: calorie targets, nutrition estimates, workout muscle-focus estimates, progress summaries, plan adjustments, and AI-generated recommendations based on the information above.
- Health-related communications: health, fitness, or nutrition details you include in Assistant messages, notes, feedback, or support requests.
PTG does not request medical diagnoses, medication records, genetic data, biometric identifiers, reproductive or sexual-health records, or precise location for health-related purposes. If you voluntarily include such information in a free-text message or image, it will be processed as part of the content you submitted.
2. Sources of Consumer Health Data
- You, when you complete your profile, log activity, or submit content.
- Apple Health, only for the data types you authorize through iOS.
- Device features, when you choose a photo or use the camera for a meal.
- PTG's own calculations and AI-assisted features, which derive estimates or recommendations from your inputs.
- Food and recipe sources, such as Open Food Facts and Edamam, when we retrieve product, nutrient, or recipe information for a feature you request.
3. Why We Collect and Use Consumer Health Data
- Provide the logging, dashboard, and progress features you request.
- Create and adjust workout plans, meal plans, calorie targets, and wellness summaries.
- Sync authorized Apple Health metrics across PTG features.
- Process a meal photo, plan request, or Assistant message after you permit the applicable AI processing.
- Save and retrieve your records, maintain your account, and provide support.
- Protect the security and integrity of the Services, prevent fraud, and comply with law.
We collect and use consumer health data with your consent or to the extent necessary to provide a product or service you requested, as permitted by applicable law. We will not collect additional categories or use consumer health data for a materially different purpose without first updating this notice and obtaining consent when required.
4. Categories of Consumer Health Data We Share
"Share" in this section has the broad meaning used by consumer health privacy laws and includes providing access to a processor that helps deliver the Services.
- Account-linked body, profile, fitness, activity, nutrition, hydration, sleep, plan, log, photo, and derived data is processed by our hosting, database, storage, and server-function provider.
- The subset required for an optional AI feature may be shared with our AI processor after the app presents the recipient, categories, and purpose and obtains your permission.
- Meal search terms, dietary filters, calorie targets, and a pseudonymous service identifier may be shared with a recipe provider where needed to return a requested meal result.
- Consumer health data may be disclosed when legally required, or in a business transaction subject to confidentiality, notice, and other legal safeguards.
PTG does not share consumer health data with Google AdMob or advertising partners. We do not use consumer health data for advertising.
5. Processors and Other Recipients
- Supabase: authentication, database, storage, and server functions. Supabase may process the consumer health categories you save in PTG.
- OpenAI: optional meal-photo analysis, meal and workout planning, goal and muscle-focus analysis, and Assistant responses. The exact subset depends on the feature and is sent only after applicable permission.
- Edamam: recipe search and nutrition results. PTG may send a meal query, dietary filter, calorie target, and pseudonymous service identifier.
- Apple: Apple Health is a user-controlled source of authorized health data. Apple also operates the device, notification, and App Store services used by PTG.
- Open Food Facts: product and nutrient lookups based on a barcode or food-search query. PTG does not attach account or Apple Health records to those requests.
To request the specific third parties or affiliates to which your consumer health data has been disclosed, including an available contact mechanism, submit a request as described below.
6. Consumer Health Data Is Not Sold
PTG does not sell consumer health data and will not sell it without the separate, signed authorization required by applicable law. Permission for Apple Health, AI processing, or advertising is not an authorization to sell consumer health data.
7. Cross-Site or Cross-App Collection
PTG does not permit a third party to collect consumer health data over time across unaffiliated websites, apps, or online services through the Services. Google AdMob may collect non-health advertising and device data as described in the general Privacy Policy, but PTG does not provide it with consumer health data.
8. Your Consumer Health Data Rights
Subject to applicable law, you may request to:
- Confirm whether PTG is collecting, sharing, or selling your consumer health data.
- Access the consumer health data PTG maintains about you.
- Receive a list of third parties and affiliates with whom PTG shared or sold your consumer health data.
- Review and correct inaccurate consumer health data.
- Withdraw consent and direct PTG to stop future collection or sharing.
- Delete your consumer health data.
- Appeal PTG's refusal to act on a request.
- Exercise these rights without unlawful discrimination or a reduction in service unrelated to the data needed for the requested feature.
Withdrawing a permission may disable only the feature that needs the relevant data. For example, revoking Apple Health access stops future Apple Health collection, and revoking AI permission stops future disclosures to OpenAI.
9. How to Exercise Your Rights
Delete your account using the in-app deletion tool, adjust available settings under Profile > Privacy & Data, or email support@ptgfitness.comwith "Consumer Health Data Request" in the subject. Describe the right you want to exercise and the email associated with your account.
We use reasonable steps to authenticate requests. We generally respond within 45 days and may extend once where law allows, with notice and an explanation. If we deny a request, we will explain the decision and how to appeal. To appeal, reply within the stated period with "Consumer Health Data Appeal" and explain why you disagree.
10. Deletion
After authenticating a deletion request, PTG deletes covered consumer health data from active records and notifies applicable processors, contractors, affiliates, and other recipients so they can honor the request. Information stored in archived or backup systems will be deleted when the systems are restored or overwritten and, where Washington law applies, within no more than six months. Lawful security, fraud-prevention, legal-hold, and other statutory exceptions may apply.
11. Security
PTG restricts consumer health data access to personnel and processors that need it for the purposes described above and uses reasonable administrative, technical, and organizational safeguards. Processors must handle consumer health data consistently with this policy and their contractual instructions.
12. Geofencing
PTG does not use precise location to identify or track a person seeking health services, collect consumer health data, or send health-related ads. PTG does not implement geofences around healthcare facilities for those purposes.
13. Changes to This Policy
We will notify affected users of material changes by email, in-app notice, or another legally permitted method. Before collecting, using, or sharing an additional category of consumer health data—or using it for a materially different purpose—we will update this policy and obtain affirmative consent when required.
14. Contact
PTG Fitness
Consumer Health Data Requests: support@ptgfitness.com