Consumer Health Data Privacy Policy

1. Categories of consumer health data we collect

Through the wellness-coaching workspace, we may process the following categories of consumer health data about a client (“you”):

• Health status & symptoms — check-ins, symptom and complaint information, and wellness “system status” grades.
• Measurements & biometrics — weight, body-composition measurements, blood glucose, body temperature, and similar self-reported metrics.
• Lab & diagnostic information — lab files you or your coach upload (for example serum, gut, hormone, or mycotoxin panels) and the marker values extracted from them.
• Supplements, peptides & related inputs — wellness supplement and similar information entered for coaching (prescriptions, diagnoses, and lab orders are referred out to a licensed physician and are not provided through the platform).
• Reproductive or menstrual information — cycle status, where you choose to provide it as coaching intake.
• Bodily or health-related imagery — progress photos you or your coach upload.
• Status as someone seeking wellness services — the fact that you use a wellness-coaching service, and related account and contact information.
• Inferences — wellness grades, suggested programs, and AI-assisted summaries derived from the above to deliver coaching.

2. Sources of the data

• Directly from you — through the client portal, check-ins, uploads, and messages.
• From your coach — the wellness coach you work with, who may enter or upload information on your behalf as part of coaching you.
• Generated by the platform — grades, analyses, and inferences the software produces from the information above.

3. Why we collect and how we use it

We collect and use consumer health data only to provide the wellness-coaching service that you or your coach requested, specifically to:

• Operate the coaching workspace and your client portal.
• Generate coaching outputs — wellness grades, suggested programs, lab summaries, reminders, and progress tracking.
• Enable communication between you and your coach.
• Secure, maintain, troubleshoot, and improve the service.

We do not use consumer health data for targeted advertising, and we do not sell it.

4. Categories of data we share

We share the categories of consumer health data listed in Section 1 only as needed to provide the service, and only with the categories of recipients in Section 5. We do not share consumer health data with third parties for their own marketing or advertising.

5. Who we share it with

• Your coach — the wellness coach who owns your coaching relationship and controls your workspace.
• Service providers (processors / subprocessors) under written data-processing terms (DPAs), including: cloud database, authentication, and file storage and application hosting (Supabase; Microsoft Azure); an AI provider used for assistive features (Microsoft Azure OpenAI), which does not use the data to train its models; and error-monitoring tooling configured to exclude personal data. Our billing processor does not receive consumer health data.
• Legal & safety — to comply with law or valid legal process, or to protect the rights, safety, and security of users and the platform.
• Affiliates / successors — an affiliate, or an acquirer in a merger or asset sale, subject to this policy.

We do not sell consumer health data, and we do not share it with data brokers.

6. Consent

We collect and process consumer health data to provide the coaching service you or your coach requested. Where the law requires consent for collecting or sharing consumer health data beyond what is necessary to provide that service, we will obtain it, and you may withdraw consent at any time as described below. We do not sell consumer health data and therefore do not seek the separate authorization a sale would require.

7. Your rights

Subject to applicable law, you have the right to:

• Confirm & access — confirm whether we process your consumer health data and access it.
• Delete — request deletion of your consumer health data.
• Withdraw consent — withdraw consent to our collection and sharing of your consumer health data.
• Appeal — appeal a refusal to act on a request.

To exercise these rights, email privacy@launchsite-os.com, or contact your coach, who controls your workspace and can export or delete your records. We will respond within the timeframe required by applicable law and will not discriminate against you for exercising a right. Because much of your information sits inside a coach’s workspace, fulfilling some requests may require us to coordinate with your coach.

8. Data retention & security

We retain consumer health data while your (or your coach’s) account is active or as needed to provide the service, then delete or de-identify it within a commercially reasonable period, subject to legal obligations. We protect it with encryption in transit and at rest, row-level access controls, private file storage, and least-privilege access for automated tooling. See our security practices.

9. Breach notification

If a breach affecting consumer health data occurs, we will notify affected individuals and any authorities as required by applicable law, including the FTC Health Breach Notification Rule and applicable state breach-notification laws, within the timeframes those laws require.

10. Changes & contact

We may update this policy and will post material changes here with a revised date. Questions or requests: privacy@launchsite-os.com · LaunchSite OS, LLC.

This document is provided as a starting template and is not legal advice. Have a qualified privacy attorney review and adapt it for your business and the states in which your clients reside before publishing.