Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy explains how FBMK Companies, LLC, doing business as Thrive90 (“Thrive90,” “we,” “us”), collects and uses consumer health data, and the choices you have. It supplements our Privacy Policy. Thrive90 is a personal-development product, not a healthcare provider. We are not a HIPAA covered entity, and what you store here is not a medical record.

1. What consumer health data we collect

We collect consumer health data only that you choose to provide or connect:

• Nutrition and food logs you enter, including meals and water.
• Body data you enter, such as body weight.
• Fasting windows and timers you start.
• Workouts and exercise you log.
• Apple Health daily summaries, only after you select measurements and connect the iPhone app. Available Apple Watch recordings can include sleep, steps, active energy, workout time, resting heart rate, heart rate variability (SDNN), weight and body fat. We do not import raw sample identifiers, location, device names or full HealthKit records.
• Oura biometric data, only if you connect an Oura ring, such as sleep, heart rate, and readiness.
• Reflections in your journals that may touch on your physical or mental wellbeing.

2. How we use it

We use your consumer health data only to operate the Service and personalize your coaching. To generate coaching, briefings, and insights, we send portions of your data to our artificial-intelligence providers (Anthropic and Google) under business terms that do not permit them to use your content to train their models and that limit how long they retain it.

3. We do not sell or share it for advertising

We do not sell your consumer health data, and we do not share it for advertising. We would not share your consumer health data with any third party for that third party’s own purposes without first obtaining your separate, specific authorization.

4. Your consent and how to withdraw it

We collect consumer health data only after you give a separate, specific consent at the point of collection, such as when you connect Oura or first log nutrition, weight, fasting, or water. Connecting a wearable is optional. Apple Health imports are read-only and run when you connect or request a sync in the iPhone app. You choose individual measurements and separately choose whether selected summaries may be shared with Anthropic and Google for coaching. Turning off a measurement removes it from your saved Apple Health summaries. Disconnecting stops future imports and sharing. Saved coaching replies may still contain earlier observations. Imported Apple Health source records are not automatically added to background embeddings or coaching-memory datasets. We never use them for advertising.

You may withdraw your consent at any time from Profile → Account. When you withdraw, we stop collecting consumer health data going forward. You may also delete your consumer health data (Apple Health summaries, Oura-synced data, nutrition, weight, and fasting records) from the same place.

5. Your rights

If you live in Washington, Nevada, Connecticut, or another state with a consumer-health-data law, you have the right to access, delete, and withdraw consent for your consumer health data, and to confirm whether we are processing it and with whom we share it. To exercise these rights, use the controls on your Account or email coach@thrive90.ai. We verify requests against your account and respond within the time required by law.

6. Retention and security

We keep your consumer health data while your account is active and until you delete it or withdraw consent. We protect it in transit and at rest using industry-standard practices, including encryption and row-level security. See our Privacy Policy for more on storage, providers, and security.

7. Contact

Questions about your consumer health data may be sent to coach@thrive90.ai or 716-235-3566. Mail: FBMK Companies, LLC, Buffalo, New York.