Consumer health data policy
Draft, pending legal review. This policy takes effect at Hyprcoach's first public release and may change before then.
Effective date: Hyprcoach's first public release.
This policy is for clients in Washington and Nevada. It is our consumer health data privacy policy under Washington's law on consumer health data (chapter 19.373 RCW) and Nevada's (NRS 603A.400 to 603A.550). Our privacy policy, at hyprcoach.io/privacy, covers the rest of your data.
Who we are
Hyprcoach is a nutrition and training coaching app. It is sold by [to be completed: the company's name], a company registered in [to be completed: the company's country]. In this policy, "we" means that company.
- Contact: [to be completed: the privacy contact's email address].
The consumer health data we collect, and how we use it
What we collect: the five kinds of health data the consent screen names:
- body stats: facts, measurements and photos, such as your height, birth date, sex, weight and body measurements; photos only once the app offers photo upload;
- check-in answers: sleep, energy, hunger and stress;
- lifestyle habits, including alcohol and performance enhancers;
- training and nutrition records: workouts, meals and plans;
- your coach's conclusions: what your coach concludes from this data.
We also keep change records: each change your coach makes to your data or your plans, with the value before and after, and the reason. A change record can hold any of the data above.
Why we collect it: to coach you. We collect it only with your consent, which you give on the consent screen right after you sign in, before any health data is saved.
How we use it, in these specific ways:
- your coach plans your training and nutrition from it, reviews your check-ins, follows your progress, and changes your plans as you go;
- your coach writes their conclusions from it;
- the app shows it back to you: your plans, your workouts and your progress;
- the change records show who changed what, from what to what, and why;
- our backups keep copies for a while, to restore our database after a failure (see "How long we keep it").
Where it comes from
- You, in the app: what you enter, and the workouts you log.
- Your coach, in the coaching dashboard: your plans, the changes to your data, and their conclusions.
Who receives it
We share your consumer health data with no third party and no affiliate, and we never sell it. The providers below process data for us, under contract. Of them, Convex stores your consumer health data, and Cloudflare holds an encrypted copy it cannot read. The others hold none of it. The support mailbox's provider holds what you choose to write to support, which may include health facts (see under the table); it is one of the providers that process data for us under contract once it is chosen: [to be completed: the support mailbox's provider and its contract].
The categories of entities that receive it: our database and file storage provider, our backup storage provider, and our support mailbox's provider.
| Provider | What it does | What it holds about you | Where | Contract and transfer basis |
|---|---|---|---|---|
| Convex | Our database and file storage, behind the app and the coaching dashboard | Everything the app and the coaching dashboard store about you | United States: US East, Northern Virginia | Convex's data processing addendum, part of its agreement. Transfers from the EU: the standard contractual clauses, Module Two (§6.2). [to be completed: whether the addendum covers our Convex plan] |
| Clerk | Sign-in | Your email address, password hash, first and last name, whether your email is verified, your sessions, and sign-in records (attempts, IP address, browser or device). No health data: Clerk's agreement forbids it | United States, in Google Cloud and Cloudflare data centres | Clerk's data processing addendum ("Last updated: November 26, 2024"), part of its agreement. Transfers from the EU: the EU-U.S. Data Privacy Framework (§11.2), with the standard contractual clauses as a fallback |
| Vercel | Hosts the coaching dashboard your coach uses | Records of each request: its address, which can hold your client and plan ids, and the requester's IP address, browser, time and status; and your email address if you sign in to the coaching dashboard with your client account. None of your health data: its addendum forbids it | United States: Vercel's iad1 region, Washington, D.C.; Vercel's main processing is in the United States |
Vercel's data processing addendum for Pro plans (§1). Transfers from the EU: the standard contractual clauses (Schedule 3) |
| Expo (EAS Observe) | Receives the phone's error reports and startup times | Each error report: the error with its stack and component stack, the time and the session, the app's version, build and environment, the device's model, OS and OS version, a country code, and the installation's id, easClientId; and how long the app took to start and to draw its first screen (see the privacy policy's "Diagnostics") |
United States. [to be completed: EAS Observe's storage region] | Expo's terms (§3.2, "Last updated May 29, 2025"): Expo processes the reports for us under the standard contractual clauses, Module Two. Expo is self-certified under the EU-U.S. Data Privacy Framework (its privacy policy, "Last updated October 21st 2025"). [to be completed: whether Expo's terms meet every duty of GDPR Art. 28(3)] |
| Resend | Sends the emails about your account: the deletion emails and the inactivity reminder | Your email address and first name, and each email's content and metadata | United States | Resend's data processing addendum ("Last update: December 31st, 2025"), which binds when we accept its terms. Transfers from the EU: the standard contractual clauses, Module Two (§6.2.2) |
| Sentry | Receives the errors of our backend and of the coaching dashboard | Ids and error codes; never health data | United States: Sentry's US data region | Sentry's data processing addendum, accepted before the first error is sent. Transfers from the EU: the EU-U.S. Data Privacy Framework, with the standard contractual clauses as a fallback (Schedule 3) |
| Axiom | Stores our backend's logs | Ids and error codes; never health data | [to be completed: Axiom's data region] | Axiom's data processing addendum, accepted before the first log. Transfers from the EU: [to be completed: the transfer basis, read with the region] |
| Cloudflare (R2) | Stores a weekly encrypted copy of our database, outside Convex | Encrypted data only: the copy is encrypted before it leaves our backup job, with a key whose private half only Hyprcoach's owner holds, offline | Eastern North America | Cloudflare's data processing addendum, part of its agreement. Transfers from the EU: the standard contractual clauses, Module Two, which apply where we are the controller |
The support mailbox holds what you write to support, which may include health facts: [to be completed: the support mailbox's provider, its country and its transfer basis].
Collection by others across websites
No third party collects your consumer health data over time, or across other websites or online services, when you use the Hyprcoach app. [to be completed: the same answer for the hyprcoach.io website]
How it is processed
Your consumer health data is stored in our database at Convex, in the United States. It travels between your phone, the coaching dashboard and Convex over encrypted connections. Your coach reads it in the coaching dashboard, whose pages load it in the coach's browser, straight from Convex.
Your rights, and how to use them
Washington's law (RCW 19.373.040) and Nevada's (NRS 603A.505) give you the rights below. Each says how to use it in Hyprcoach.
- To confirm whether we collect, share or sell your consumer health data, and to access it, with a list of every third party and affiliate it was shared with and an email address or online way to contact each. Write to support. Within one month we send you a private link to a machine-readable copy. The link works for 7 days, and the copy is never an email attachment. It keeps what you supplied apart from what your coach concluded, and lists who receives your data.
- To withdraw your consent, which stops all collecting, sharing and selling of your consumer health data (we share it with no third party and never sell it): in Profile, Account settings, "Health data consent". Coaching stops, and we start erasing your health data at once: from our database, change records included, and from your phone, with any unfinished workout or workout waiting to be sent. Our backups at Convex and at Cloudflare keep it until they expire, within 5 weeks (see "How long we keep it"). Your account, name, email and settings stay. The consent screen then offers to agree again or to delete your account.
- To have it deleted, from our backups too. Tap Delete account in Account settings or on the consent screen, or use the signed-in page on our website, [to be completed: the website's deletion page address]. You first sign in again in full: your password, and your code if you turned on a second factor. Your account is erased on the date shown: the day before the same date the following month or, when that month has no such date, the day before its last day (a request on 31 January is erased on 27 February, or on 28 February in a leap year), at most 30 days after your request. An email gives the same date. Signing in before then cancels the deletion. A second email confirms the erasure. You can also write to support: we start the same deletion for you. Washington's law lets a backup delay a deletion by at most six months from the day the request is confirmed; ours, at Convex and at Cloudflare, expire within 5 weeks (see "How long we keep it").
- To review and change it: in Profile, Account settings, or write to support.
- To appeal if we refuse to act on a request: [to be completed: how to appeal]. We answer an appeal in writing within 45 days of receiving it, with our reasons. If we refuse it, we tell you how to complain to your state's attorney general.
How to make a request: use the app as above, or write to support: use Contact support in the app's Profile, or [to be completed: the support email address].
How long each request takes: a copy of your data comes within one month of your request; a withdrawal takes effect at once; a deletion takes effect on the date shown, at most 30 days after your request; every other request is answered within 45 days of receiving it, which we can extend once by 45 days, telling you why within the first 45 days. An appeal is answered within 45 days of receiving it, with no extension. This is a summary of what both laws ask (RCW 19.373.040(1)(g) and (h); NRS 603A.510 and 603A.520); the full rules apply, and their details are checked with our lawyer.
How long we keep it
- Your record (profile, plans, workouts, check-ins, and photos once the app offers photo upload): while your account is open. Withdrawing your consent erases its health data and keeps your settings.
- Change records, with their before and after values and reasons: while your account is open, then erased with it. Withdrawing your consent erases them too.
- Consent records: while your account exists.
- After you ask to delete your account: frozen until the erasure date. On that date your account and all its data are erased from our database and file storage, and your account at our sign-in provider is deleted. What the rows below keep for a set time (the deletion log, backups, sign-in records at Clerk, error reports, email records, the dashboard host's logs) expires at the end of that time.
- The deletion log: 12 months after the erasure. It holds only ids that do not name you, dates, and each provider's confirmation.
- An inactive account, when you have not used the app while signed in for 12 months and, once memberships exist, hold no active membership: one reminder email at 11 months, then erased at 12 months unless you use the app before then.
- Database backups at Convex: daily backups 7 days, weekly backups 14 days. After a restore, every erased account is erased again. [to be completed: whether a restore also erases again the health data of clients who withdrew their consent]
- The weekly encrypted copy at Cloudflare: each copy is kept 5 weeks from the day it is made, so a deleted client's data, or the health data of a client who withdrew consent, is gone from this Cloudflare copy within 5 weeks of its erasure. [to be completed: how long Convex keeps its own internal backup copies]
- An unfinished workout on your phone: 7 days. The app checks when it loads and when it comes back on screen. Withdrawing your consent erases it.
- A finished workout not yet sent when your session ends without your choosing (its 30-day lifetime runs out, or it is revoked): kept on the phone in the app's private storage, protected by the phone's own encryption, and tied to your account. It is sent when that account signs back in, and erased when another account signs in on the phone, when you withdraw your consent, or when your account is deleted.
- Sign-in records at Clerk (attempts, IP address, browser or device): [to be completed: how long Clerk keeps them, also after your account is deleted].
- Error reports: 90 days at Expo; 30 days at Sentry and at Axiom.
- The coaching dashboard host's logs: Vercel's period, 1 day, or 30 days with Vercel's Observability Plus. [to be completed: which of the two applies]
- Emails at Resend: content and metadata 30 days. Our backend's copy of each email: 4 weeks.
- A copy of your data sent to you: the link expires after 7 days, and no copy is kept.
- Support emails: deleted with your account, or 12 months after the last reply.
- Files our build system keeps (test data only, never a client's): 7 days.
- Invoices, once payments exist: as long as tax law requires in [to be completed: the company's country].
Changes to this policy
[to be completed: how we tell you of a material change to this policy]