Consumer Health Data Privacy Policy

"Consumer Health Data" means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. Consumer Health Data does not include information that is publicly available, de-identified, or aggregated. What Consumer Health Data we collect may differ depending on how you interact with us.

For Lighter, Consumer Health Data reflects the fact that you use a GLP-1 / peptide tracking app together with the entries you make about your medications, body metrics, side effects, and related goals.

The Consumer Health Data we collect may include:

We also draw limited inferences from your entries about your past, present, or future physical or mental health status in order to provide the tracking and progress features you request. Lighter has no AI chatbot, no iMessage integration, and no community or social features, so we do not collect any data associated with those functions.

As described in the Categories of Sources of Personal Data section of the Lighter Privacy Policy, we may collect Personal Data, including Consumer Health Data, from the following sources:

• Directly from you, when you complete onboarding, log data, upload progress photos, or contact us.
• From Apple Health, only if you grant permission (read-only, to pre-fill certain onboarding fields).
• From the App Store and our subscription providers, for purchase and entitlement status.
• Automatically from your device, for app functionality, security, and the limited, non-identifying analytics described below.

We collect, use, disclose, or otherwise process your Consumer Health Data as reasonably necessary for the purposes described in the Our Commercial and Business Purposes for Collecting Personal Data and Other Permitted Purposes for Processing Personal Data sections of the Lighter Privacy Policy, but primarily to provide you with products and services as you have requested or authorized.

We use Consumer Health Data to (a) provide, personalize, and maintain the tracking features and progress views you request; (b) secure and monitor our Services, prevent fraud and abuse, and fix errors; (c) honor your privacy choices and legal rights; and (d) perform internal analytics to improve service quality. Your full-fidelity health data (exact weights, dose amounts, medication names, side effects, notes, and photos) is never sent to analytics or advertising services; only coarse, non-identifying signals are used for analytics.

We disclose your Consumer Health Data as reasonably necessary to Third Parties and Affiliates, which may include:

• Service Providers. We may disclose your Consumer Health Data to contractors, processors, and vendors to provide and improve our Services to you.
• Other Parties. We may disclose your Consumer Health Data to other parties if you explicitly gave us consent to do so.

The service providers who process Consumer Health Data on our behalf, under contracts that limit them to our instructions, currently include:

We do not sell consumer health data.

Where required, we obtain your opt-in consent before collecting consumer health data that is not strictly necessary to provide a product or service you requested. Separately, we obtain your opt-in consent before sharing consumer health data for any non-necessary purpose. These consents are presented clearly and conspicuously in the interface where collection or sharing occurs and describe the categories of data, purposes, recipients, and how to withdraw consent. You may withdraw consent at any time, and we will stop the collection or sharing covered by the withdrawn consent.

If you are a resident of, or we have collected your Consumer Health Data from, certain U.S. states, you may have rights afforded to you, including those set forth in this section (subject to certain exceptions).

• Access: You have the right to request confirmation of or access to the Consumer Health Data that we process about you, including a list of all third parties to whom we have disclosed your Consumer Health Data and their contact information.
• Deletion: You have the right to request that we delete the Consumer Health Data that we have collected about you. You can delete your entire account and its data from inside the app (Settings, then Delete Account), or by emailing us.
• Withdraw Consent: You have the right to withdraw consent from us collecting and disclosing your Consumer Health Data.
• Appeal: If we refuse to take action on your request within a reasonable period of time after receiving it, you may appeal our decision. If we deny your appeal, you have the right to contact the Washington Attorney General at www.atg.wa.gov/file-complaint.

To exercise your rights, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria.

You may submit a Valid Request by contacting us at [email protected].

If you have any questions about this section or whether any of these rights apply to you, please contact us at [email protected]. We will not discriminate against you for exercising your rights under applicable law.

Lighter is a self-tracking tool. It provides general tracking and progress features and does not provide medical advice, diagnose conditions, recommend treatments or dose changes, or establish a provider-patient relationship. Always consult a licensed clinician for questions about your health or medications. Do not use the app for emergencies.

You can reach us with questions or requests at [email protected] — Flame Industries Inc., 7901 4th St N, STE 300, St. Petersburg, FL 33702.