Consumer Health Data Privacy Policy
(United States)
This Consumer Health Data Privacy Policy supplements our Privacy Notice and applies to "consumer health data" of residents of Washington, Nevada, and other U.S. states with consumer- health-data laws (including data collected while you are physically present in such a state). It is provided pursuant to the Washington My Health My Data Act (Wash. Rev. Code ch. 19.373), Nevada SB 370 (NRS ch. 603A), and similar laws. This Policy is published at https://neura.health/legal/chd-policy and is linked from the neura.health homepage and from within the app, as required by Washington law. Where this Policy and the Privacy Notice overlap, the more protective statement applies.
1. Consumer Health Data We Collect
Through the Neura Health app we collect the following categories of consumer health data, only with your consent or as necessary to provide services you request:
• health measurements and biometric-type readings from wearables and health sources you connect (for example activity, heart rate, sleep, and body metrics), received through our integration provider (Terra);
• health information you choose to enter or say in the app, including in AI chat conversations and voice input (transcribed to text); • health-related insights, plans, and summaries the Service generates for you from the above ("derived" or "inferred" health data);
• account and technical data that, combined with the above, could identify your health status.
We do not collect precise geolocation, and we do not use geofencing around health-care facilities or any other location. Although the app requests a location permission in connection with potential workout-data features via our integration provider (Terra), we do not currently store or use your location or route data.
Sources
We collect consumer health data directly from you (what you enter or say in the app) and from
the wearables and health apps you choose to connect, delivered via Terra
3. Why We Collect and Use It
We collect and use consumer health data only to provide the services you request: syncing your connected data, generating personalised insights, plans, coaching, and AI chat responses, storing your history and memory, securing the Service, and providing support. We do not use consumer health data for advertising or marketing, and we do not sell it.
4. Sharing and Recipients
We do not sell consumer health data, and we will not sell it without the separate, signed authorization required by law. We do not share it with third parties for their own purposes. Consumer health data is disclosed only to:
• our processors, who act under contracts that bind them to our instructions and confidentiality (Microsoft Azure — hosting, storage, and AI processing within our environment; Terra — wearable data integration; see the Privacy Notice, Section 6, for the full list);
• public authorities, only where legally required and only in response to a valid, legally binding request.
5. Your Rights
If you are a resident of a state with a consumer-health-data law (or your data was collected there), you have the right to:
• know and access the consumer health data we collect about you, including the categories of third parties and processors it is shared with (and, where required, a means of contacting them);
• withdraw consent to our collection and sharing of your consumer health data;
• delete your consumer health data, including from backups (backup deletion may take additional time as backups cycle) and from our processors;
• appeal a decision we make on your request.
To exercise these rights, email support@neura.health or use the in-app Privacy & Data controls (including "Delete my account"). We will verify your identity and respond within the timeframe required by the applicable law (in Washington, within 45 days, extendable by 45 days where reasonably necessary). You may use an authorised agent where the applicable law provides for it; we may verify the agent's authority.
Appeals. If we deny your request, you may appeal by replying to our decision or emailing support@neura.health with the subject line "Health Data Appeal." We will respond within the legally required period (in Washington, 45 days). If your appeal is unsuccessful, you may contact your state attorney general — in Washington, at www.atg.wa.gov/file-complaint
6. Changes
We will post any changes to this Policy here with an updated effective date and, where the change materially affects how we process consumer health data, we will notify you and, where required, ask for your consent.
7. Contact
Neura Labs Oy
Pitkäkalliontie 9, 01800 Klaukkala, Finland
support@neura.health