Washington Consumer Health Data Privacy Policy

Categories of consumer health data collected, and how they are used

TrainO collects or processes the following categories of consumer health data: heart-rate and cardiovascular fitness measurements; physical activity and workout information; body measurements; sleep-derived recovery information; fitness and nutrition records; reproductive-cycle information processed locally when the optional Cycle feature is enabled; and fitness-related inferences or derived indicators generated from those data.

This data is used to provide the features the consumer requests: to personalize training load, recovery and nutrition targets, to display the consumer's own history and progress, and to compute descriptive fitness indicators from the consumer's own information. It is not used for advertising, marketing or behavioral profiling, and it is not used to make any medical determination.

Categories of sources

Sources include: information entered directly by the consumer; Apple Health when the consumer grants access; compatible Bluetooth devices; device location and sensors when the consumer starts an outdoor activity; and indicators derived by TrainO from the consumer's own information.

Consumer health data sharing

TrainO does not sell consumer health data. TrainO does not share consumer health data with third parties or affiliates as the term "share" is defined by the Washington My Health My Data Act.

Service providers acting as processors may process consumer health data on TrainO's behalf where necessary to provide the requested service and consistently with the purpose disclosed to the consumer. Those processor disclosures are not treated as "sharing" under the Act when the statutory processor exception applies.

If TrainO introduces a feature that constitutes sharing under Washington law, this policy will first identify the relevant categories and third parties or affiliates, and TrainO will obtain any consent required by law before the sharing occurs.

Consumer rights

A Washington consumer may:

• Confirm and access. Ask whether TrainO is collecting, sharing or selling consumer health data and access the consumer health data TrainO maintains about that consumer.
• Third-party information. Where applicable, obtain the list required by Washington law of third parties or affiliates with whom consumer health data has been shared or sold and the available mechanism for contacting them.
• Withdraw consent. Withdraw consent for future collection or sharing of consumer health data where processing is based on consent.
• Delete. Request deletion of consumer health data. TrainO will process a valid deletion request across the systems covered by Washington law and notify processors, contractors, affiliates or third parties where the Act requires it. Where consumer health data is held in archived or backup systems, deletion may be delayed only for the period permitted by Washington law.
• Appeal. If TrainO refuses a request, the consumer may appeal the decision by replying to the decision or emailing privacy@delportaltechnologies.com with the subject "Washington Privacy Appeal". If the appeal is denied, TrainO will provide the information required by Washington law for contacting the Washington Attorney General.

Requests may be submitted through the in-App privacy controls or to privacy@delportaltechnologies.com. TrainO may take reasonable steps to authenticate the consumer before completing a request.