Privacy Policy

This Privacy Policy explains how Zolt Labs LLC (“Zolt,” “we,” “us,” or “our”) collects, uses, shares, and protects personal data when you use the Zolt mobile application, our websites, Zolt Coach and other artificial-intelligence features, connected-device integrations, support channels, and related services (collectively, the “Services”).

Health and fitness information can be sensitive. We use it to provide the features you request, not to sell advertisements or make decisions about employment, insurance, credit, or eligibility for services.

Our separate Consumer Health Data Privacy Notice provides additional disclosures and rights relating to consumer health data.

1. Scope and our role

This Policy applies to personal data Zolt controls in connection with the Services. Zolt is generally the controller or business responsible for deciding why and how that data is processed. Other companies may process data for us as service providers or independently under their own terms when you choose to use their services.

2. Personal data we collect

Account and profile information

• Email address, name or display name, authentication identifiers, account settings, units, time zone, and preferences.
• Subscription status, purchase identifiers, entitlement information, and limited transaction records. App stores and payment processors handle payment-card details.
• Information you provide to support, feedback, surveys, interviews, promotions, or social-media channels.

Health, fitness, nutrition, and wellness information

Depending on the features you use and the permissions you grant, this may include:

• Body weight, body-fat percentage, height, body measurements, weight trends, progress photos, goals, calorie and macro targets, estimated energy expenditure, and related calculations.
• Food logs, meals, recipes, serving information, calories, macronutrients, micronutrients, water, caffeine, alcohol, dietary preferences, and allergy information you choose to provide.
• Steps, distance, floors, stand time, daylight exposure, active and resting energy, workouts, exercise details, training load, pace, heart-rate information, and fitness estimates.
• Sleep sessions, sleep stages, sleep duration, sleep efficiency, sleep consistency, respiratory rate, resting heart rate, heart-rate variability, oxygen saturation, temperature, recovery information, and scores or trends derived from these data.
• Journal entries, habits, readiness check-ins, lifestyle responses, symptoms or health-related details you voluntarily enter, and personalized insights or inferences generated from your data.

Data from connected health platforms

With your permission, Zolt may receive data from Apple HealthKit, Android Health Connect, Google Health API, Fitbit or Pixel devices, and other services you connect. Google Health data may include activity and fitness data, sleep data, and health metrics and measurements such as steps, distance, floors, calories, active-zone minutes, workouts, sleep, weight, body fat, resting heart rate, heart-rate variability, respiratory rate, oxygen saturation, and temperature.

For server-based connected services, we also process connection status, granted permission categories, encrypted OAuth credentials, sync timestamps, source and device information, and limited diagnostics needed to operate and secure the integration. Zolt does not request GPS routes or free-text notes through the Google Health integration.

AI and Coach information

• Prompts, messages, responses, feedback, and information you attach or submit to AI features.
• Relevant app context, such as the health screen, date, workout, meal, journal item, score, goal, or other record about which you ask Zolt Coach.
• Relevant profile, goal, nutrition, weight, activity, sleep, recovery, workout, hydration, habit, and journal information that the Coach retrieves to answer your request.
• User-visible Coach memories derived from statements you make, including the supporting excerpt, category, importance, dates, and an embedding used to retrieve relevant memories.
• AI usage information such as model used, token counts, feature, operational status, and safety or error events.

Device, usage, and technical information

• Device and app identifiers, operating system, app version, language, IP address, approximate region, time zone, and network information.
• Feature interactions, navigation events, attribution information, subscription events, performance data, crash reports, diagnostics, and security logs.
• Website activity, browser information, cookies, pixels, and similar technologies, subject to applicable consent requirements.

3. Sources of personal data

We collect personal data:

• directly from you when you use or contact the Services;
• from your device and local Zolt databases when you enable a feature;
• from health platforms, wearables, and apps you authorize Zolt to access;
• from app stores, authentication providers, payment and subscription providers, analytics providers, and communications platforms; and
• through calculations and inferences Zolt creates from the data described above.

4. How we use personal data

We use personal data to:

• provide, personalize, maintain, and troubleshoot the Services;
• display health, activity, nutrition, sleep, recovery, and body trends;
• calculate scores, estimates, targets, summaries, and personalized coaching;
• synchronize authorized connected services and resolve duplicate or conflicting data sources;
• authenticate users, manage subscriptions, provide support, and send service communications;
• operate AI features, retrieve relevant user-authorized context, and prepare user-confirmed actions such as food logs or goals;
• protect users and the Services, prevent fraud and abuse, enforce our Terms, and comply with law; and
• analyze aggregate or de-identified usage to improve reliability and user-facing functionality.

5. AI processing and automated features

Zolt uses third-party AI service providers, including Google and OpenAI, to generate responses, structure food information, create summaries, and support other user-facing features. We send the information reasonably needed to answer your request. Depending on your request and settings, that information may include sensitive health or wellness information.

Google Health information is subject to an additional boundary: AI coaching may use derived sleep and recovery summaries only after you affirmatively enable the separate Google Health AI-processing control. Raw Google Health time series, OAuth credentials, and operational sync records are not sent to the coaching model.

Zolt does not use your personal data to train a general-purpose or foundational AI model. Our AI providers process data under their applicable business or API terms. AI output is probabilistic and may be inaccurate. It is not used by Zolt to make legal or similarly significant decisions about you.

6. Google Health API Limited Use

Zolt’s use and transfer of information received from Google Health API adheres to the Google Health API Developer and User Data Policy, including the Limited Use requirements.

We use Google Health data and data derived from it only to provide or improve prominent, user-facing Zolt health and fitness features that you request or authorize. We do not sell it, use it for advertising, use it to determine employment, insurance, credit, or lending eligibility, or use it for health research or regulated medical-device functions without the approvals and consent required by applicable law and Google policy.

7. How we disclose personal data

We do not sell personal data. We disclose personal data only as described below and require service providers to protect it consistently with their contractual obligations and applicable law.

We may also disclose personal data to professional advisers; to authorities when reasonably necessary to comply with law, protect safety, or enforce our rights; or in connection with a merger, financing, acquisition, reorganization, or sale of assets, subject to applicable notice and consent requirements for consumer health data.

8. Advertising and analytics

We do not use health information from Apple HealthKit, Health Connect, Google Health API, or Zolt health records for third-party advertising, cross-context behavioral advertising, or sale to data brokers. Website analytics and marketing technologies may process website and campaign interactions as permitted by law and your cookie or platform choices, but they do not receive your private Zolt health records for advertising.

9. Legal bases

Where applicable law requires a legal basis, we process personal data to perform our contract with you, based on your consent, to comply with legal obligations, and for legitimate interests such as security, support, and improving the Services where those interests are not overridden by your rights. You may withdraw consent at any time, but withdrawal does not affect processing already completed lawfully.

10. Data retention and deletion

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, to comply with law, resolve disputes, protect users, and enforce agreements. Retention depends on the data type, the feature used, your settings, and legal requirements.

• Account and profile data is generally kept while your account is active and deleted when your account is deleted, subject to limited legal or security exceptions.
• Disconnecting Google Health clears Zolt’s Google credentials and attempts to revoke the Google token. You may choose to delete imported history or retain it as read-only data.
• If Zolt Pro ends, Google Health synchronization pauses. Imported Google Health data is scheduled for deletion after 30 days unless you resubscribe before that deadline.
• Purchase, fraud-prevention, security, and legal records may be kept as required by law or for legitimate business needs.

You can delete your Zolt account in the app. Account deletion removes data associated with your account from active systems, including connected Google Health credentials, imported and derived Google Health data, and associated sync records, subject to legal requirements and limited backup processing.

11. Security

We use reasonable technical, administrative, and organizational safeguards designed to protect personal data. These include access controls, encryption in transit, encryption of Google OAuth credentials, monitoring, and data minimization. No method of storage or transmission is completely secure, so we cannot guarantee absolute security.

12. International data transfers

Zolt is based in the United States and our service providers operate in multiple countries. Where required, we use recognized transfer mechanisms such as adequacy decisions, the EU Standard Contractual Clauses, the UK Addendum, or other lawful safeguards.

13. Your choices and privacy rights

Depending on where you live, you may have rights to access, correct, delete, or receive a copy of personal data; restrict or object to processing; withdraw consent; appeal a denied request; and lodge a complaint with a regulator.

You can exercise many controls directly in Zolt, including:

• editing profile, goals, logs, and other entries;
• managing connected-app permissions and data sharing;
• disconnecting Google Health and choosing what happens to imported data;
• managing Coach memories;
• exporting supported account data; and
• deleting your account.

You may also submit a request through in-app support or by emailing hi@zolthealth.com. We may need to verify your identity before completing a request.

14. Children

The Services are not directed to children under 18, and you must be at least 18 or the age of legal majority in your jurisdiction to create an account. We do not knowingly collect personal data from children in violation of applicable law. Contact us if you believe a child has provided personal data to Zolt.

15. Changes to this Policy

We may update this Policy as the Services or law changes. We will post the updated version here, change the effective date, and provide additional notice when required. If a change requires consent, we will obtain it before applying the new processing to you.

16. Contact us

Zolt Labs LLC
Email: hi@zolthealth.com