Consumer Health Data Privacy Notice

This Consumer Health Data Privacy Notice describes how Zolt Labs LLC (“Zolt,” “we,” “us,” or “our”) collects, uses, and shares consumer health data. It supplements our Privacy Policy. If this notice conflicts with the Privacy Policy regarding consumer health data, this notice controls.

1. Scope

This notice applies to consumer health data that is subject to consumer health privacy laws, including Washington's My Health My Data Act and Nevada's consumer health data law. Depending on where you live, some of the rights described below may not apply to you.

“Consumer health data” means personal information that is linked or reasonably linkable to you and identifies your past, present, or future physical or mental health status. It may include information you provide directly, information from connected services, and health-related information Zolt derives from other data.

2. Consumer health data we collect

Depending on the features you use, Zolt may collect:

• Body and wellness information: age, sex, height, weight, body composition, activity level, goals, symptoms, journal entries, wellness preferences, and other information you choose to provide.
• Nutrition information: foods, meals, photos, nutrient estimates, calorie and macro targets, dietary preferences, and meal history.
• Activity and fitness information: steps, distance, floors, exercise, active time, calories burned, and related activity measurements.
• Sleep and recovery information: sleep sessions, sleep stages, resting heart rate, heart-rate variability, respiratory rate, blood oxygen, temperature, and recovery-related measurements.
• Connected-platform information: information you authorize Zolt to access from Apple HealthKit, Android Health Connect, Google Health APIs, or another supported health or fitness service.
• Derived or inferred health information: estimates, trends, summaries, scores, goals, total daily energy expenditure, coaching context, and other insights generated from the information available to Zolt.
• Health-related AI information: health or wellness details you include in prompts, messages, feedback, or other content submitted to AI-powered features, together with related responses and personalized context.
• Technical information associated with health features: connection status, permissions, synchronization timestamps, data source identifiers, and error or diagnostic information needed to operate and secure a connection.

3. Sources of consumer health data

We collect consumer health data from:

• you, including through the Zolt app and AI-powered features;
• your devices and the health or fitness services you choose to connect;
• service providers that help operate features you request, such as food, nutrition, and AI services; and
• our own analysis of the information above, which may produce health-related estimates, summaries, and insights.

4. Why we collect and use consumer health data

We collect and use consumer health data to:

• provide the nutrition, activity, sleep, recovery, journaling, and coaching features you request;
• personalize goals, recommendations, reminders, summaries, and insights;
• synchronize information from services you authorize and display it in Zolt;
• operate AI-powered features and generate responses to your requests;
• maintain, troubleshoot, secure, and improve Zolt's health features;
• prevent fraud, misuse, security incidents, and violations of our Terms of Service; and
• comply with applicable law and enforce legal rights.

5. AI-powered features and Google Health data

Zolt uses AI model providers, including Google and OpenAI, to provide AI-powered features. When you use those features, relevant prompts, health context, instructions, and generated responses may be processed by the applicable provider to fulfill your request.

Google Health data is not made available to Zolt's AI features unless you separately consent to that use. With consent, Zolt may send limited, derived sleep and recovery summaries to the applicable AI provider to personalize coaching. Zolt does not send raw Google Health time-series records, Google OAuth credentials, or synchronization records to an AI model. You can withdraw this consent without disconnecting Google Health.

Zolt does not use your personal data to train a general-purpose or foundational AI model.

6. How we share consumer health data

We share consumer health data only as necessary to provide features you request, with your authorization, or as permitted or required by law. The categories of recipients may include:

Zolt does not sell consumer health data. Zolt does not share consumer health data for cross-context behavioral advertising or targeted advertising. We do not permit service providers to use consumer health data for their own advertising.

7. Google Health Limited Use

Zolt's use and transfer of information received from Google Health APIs adheres to the Google Health APIs Services User Data Policy, including its Limited Use requirements. We use Google Health data only to provide or improve user-facing health and fitness features that are visible and prominent in Zolt, and we do not use it for advertising, creditworthiness, lending, employment, insurance underwriting, or eligibility decisions.

8. Your choices and consent

• You choose whether to connect a supported health platform and which permissions to grant.
• You can change platform permissions through the applicable device or account settings.
• You can separately enable or disable the use of eligible Google Health summaries in AI-powered features.
• You can disconnect Google Health or another supported integration from Zolt.
• You can delete specific information where the feature provides that control, or request deletion of your account and associated personal data.

Withdrawing consent stops the future collection or sharing covered by that consent, but it does not affect processing that occurred before withdrawal.

9. Your consumer health data rights

Subject to applicable law and verification of your request, you may have the right to:

• confirm whether we collect, share, or sell your consumer health data;
• access the consumer health data we maintain about you;
• obtain a list of third parties or affiliates with whom we shared or sold your consumer health data;
• withdraw consent to certain collection or sharing;
• delete consumer health data; and
• appeal our refusal to act on a request.

You may submit a request through available in-app controls or by emailing hi@zolthealth.com. Please include enough information for us to identify your account and understand your request. We may ask for additional information to verify your identity and protect your data. An authorized agent may submit a request where permitted by law, but we may require proof of the agent's authority and verification of your identity.

To appeal a decision, email us with the subject “Consumer Health Data Appeal” and explain why you believe the decision should be reconsidered. If your appeal is denied, you may contact your state attorney general or other applicable regulator. We will not discriminate against you for exercising your privacy rights.

10. Deletion

When you disconnect Google Health, you may be offered available options to delete or keep previously synchronized information. If access to Google Health features ends with a qualifying subscription, Zolt schedules stored Google Health data for deletion after 30 days unless you restore access or delete it sooner. Deleting your Zolt account deletes associated personal data, subject to limited exceptions where we must retain information for security, fraud prevention, legal compliance, dispute resolution, or enforcement.

11. Security

We use administrative, technical, and physical safeguards designed to protect consumer health data. No method of storage or transmission is completely secure, and we cannot guarantee absolute security.

12. Changes to this notice

We may update this notice as our services or legal obligations change. We will post the updated notice and revise the effective date. Where required, we will provide additional notice or obtain consent before a material change takes effect.

13. Contact us

Zolt Labs LLC
Email: hi@zolthealth.com