Washington Consumer Health Data Privacy Policy

Effective date: August 23, 2026

This Washington Consumer Health Data Privacy Policy ("WA Health Policy") applies only to Washington consumers, and only to the categories of information defined as "consumer health data" under Washington's My Health My Data Act (RCW 19.373). It supplements, and does not replace, our general Privacy Policy. Capitalized terms not defined here have the meaning given in our general Privacy Policy.

1. Consumer Health Data We Collect

In connection with providing Athora's body-analysis, workout-planning, and AI coaching features, we may collect the following categories of consumer health data:

• Physique photos you capture or upload for body analysis
• Body-composition estimates and notes generated from those photos (for example, estimated body fat percentage, lean mass, posture and symmetry notes)
• Profile and fitness information, including sex, age, height, weight, fitness goal, and experience level
• Progress data, including weight logs, progress photos, completed workouts, and related workout history
• Messages you send to the AI coach, and any health-related information disclosed within those messages

2. How We Collect It

We collect this information directly from you when you create an account, complete onboarding, upload photos, log progress, or message the AI coach.

3. Purpose of Collection and Use

We use this consumer health data only for the purposes listed below, and for no other purpose without your separate consent:

• Generate body-composition estimates and notes
• Create and update your personalized workout plan
• Power the AI coach and apply the plan changes you request
• Save your progress and history so the app can display it back to you
• Maintain, secure, and troubleshoot the service

4. Sharing of Consumer Health Data

We do not sell consumer health data.

We share consumer health data only with the following categories of third parties, and only as necessary to provide the app's features:

• Supabase (our database, authentication, and storage provider), to store your account, profile, progress, and photo data securely
• AI model providers, including OpenAI, to analyze physique photos and power the AI coach's responses and plan adjustments

These providers process consumer health data on our behalf, under their own security and confidentiality obligations, solely to deliver the app's features back to you. We do not permit these providers to use your consumer health data to train their own models where an opt-out is available, and our configuration reflects this.

5. Your Consent

Before we collect consumer health data for the features described above, we will ask for your affirmative, opt-in consent through a dedicated consent screen in the app, separate from acceptance of our general Terms of Use. You may withdraw this consent at any time by contacting us using the details below. We are also working to add an in-app option to withdraw consent directly. Withdrawing consent will limit or disable the features that depend on this data (such as photo-based body analysis); at this time, fully removing this data from your account requires deleting your account entirely.

6. Your Rights

If you are a Washington consumer, you have the right to:

• Confirm whether we are collecting or sharing your consumer health data, and to access that data (as noted in Section 4, we do not sell consumer health data)
• Withdraw your consent to our collection or sharing of your consumer health data
• Request deletion of your consumer health data

To exercise any of these rights, contact us at the email below. We will respond within the timeframe required by law, and will not require a more burdensome process than the one you used to provide consent.

7. Retention and Deletion

We retain consumer health data only as long as needed to provide the features described above, or until you request deletion or withdraw consent, whichever comes first. When you request deletion, we will also remove your consumer health data from backup and archived copies of our systems within a reasonable period, consistent with our standard backup cycles.

8. Security

Physique and progress photos are stored in a private storage bucket protected by row-level security, so that only your account can access your files. We use encryption in transit and access controls to protect consumer health data, though no method of storage or transmission is completely secure.

9. Geofencing

We do not use geofencing around any healthcare facility, mental health facility, or reproductive or sexual health facility to identify or track Washington consumers, or to send them notifications, advertisements, or messages related to their consumer health data.

10. How to Appeal a Decision

If we deny or partially deny your request to exercise a right described in Section 6, you may appeal that decision by replying to our decision or contacting us at the email below, referencing your original request. We will review your appeal and respond within the timeframe required by law. If we uphold our original decision, we will explain why, and where required by law, provide information on any further steps available to you.

11. Changes to This Policy

If we make material changes to this WA Health Policy, we will update the effective date above and, where required, seek renewed consent before continuing to collect consumer health data under the new terms.

12. Contact Us

Email: support@pulsedevelopment.co

Pulse Development LLC
30 N Gould St Ste N
Sheridan, WY 82801