WellOff Consumer Health Data Privacy Notice
SwiftTech Health Inc.
Last Updated: June 23, 2026
This Consumer Health Data Privacy Notice (this “Notice”) supplements the WellOff Privacy Policy and applies to consumer health data that SwiftTech Health Inc. (“SwiftTech,” “WellOff,” “we,” “us,” or “our”) collects through the WellOff application, our websites welloff.health and swifttechhealth.com, and related services (collectively, the “Service”). It is provided to address requirements under U.S. state consumer-health-data laws, including the Washington My Health My Data Act, Nevada Senate Bill 370, and the consumer health data provisions of the Connecticut Data Privacy Act.
The Service is offered only to residents of the United States who are 18 years of age or older. WellOff is a wellness self-tracking product. The Company is not a “covered entity” or “business associate” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and consumer health data you provide through the Service is not “protected health information” under HIPAA.
This Notice should be read together with the WellOff Privacy Policy and Terms of Service. Where this Notice and the Privacy Policy both apply to the same data, the more protective provision controls. As used in this Notice, “consumer health data” and “CHD” mean personal information that identifies your past, present, or future physical or mental health status, as defined under applicable state law.
1. Consumer Health Data We Collect
We collect the following categories of consumer health data, in each case only the data you choose to enter or generate through your use of the Service:
• Medication and dose information, including current and historical medications, doses, taper schedules, time on medication, prior taper attempts, other prescriptions, supplements, and the history of changes to your medication.
• Self-reported symptoms, which you rate on a 0–4 scale, across mood, cognitive, sleep, physical, and neurological categories — including suicidal ideation, self-harm, ability to stay safe, and thoughts of harming others.
• Exercise, diet, alcohol, and other lifestyle and health factors you choose to log.
• Reproductive information you choose to log, including whether you log a menstrual period or pregnancy as a daily factor.
• Free-text journal entries, which may contain any health or other information you choose to include.
• Free text you choose to submit in a feedback or error report, which may contain any health or other information you choose to enter.
• Voice recordings, when you use voice check-in or voice features.
• Photos you upload, including food photos and photos of prior paper or app logs, which may incidentally contain prescriber or pharmacy information.
• Buddy-system information you choose to share with a connected peer, which may include gender, age, zip code or major city, medication, taper stage, and an open-text bio.
• The content of messages you send to a connected peer through the buddy system, which you may use to discuss symptoms, medication, or other health information.
2. Sources of Consumer Health Data
We collect consumer health data directly from you, as you enter or generate it through your use of the Service — by text, by tap, by voice, or by uploading a photo. We do not purchase consumer health data, and we do not obtain it from data brokers.
3. How We Use Consumer Health Data
We use consumer health data for the following purposes:
• To provide the core function of the Service, which is to enable you to record, review, visualize, and track your own health information over time.
• To enable features you choose to use, including symptom, mood, dose, and habit tracking; journaling; voice and tap check-in; the buddy system; and AI-assisted logging.
• To transcribe voice input, generate spoken responses during your voice check-in, and assist with logging, where you use those features, through our AI sub-processors described in Section 4.
• To operate, secure, and improve the Service, including to detect, investigate, and prevent fraud, abuse, and security incidents, and to review reports you or another user submit through the buddy system.
• To comply with legal obligations and respond to lawful requests.
We do not use consumer health data to serve advertising, and we do not use it to create advertising audiences. We collect and use consumer health data to provide the tracking and related features you request; your decision to use a feature is your direction to collect and use the data that feature requires.
4. How We Share Consumer Health Data
We share consumer health data only with the following categories of recipients:
• Service providers and processors. Companies that host, secure, support, and operate the Service on our behalf, including hosting and infrastructure, AI sub-processors (described below), and email delivery, each engaged under a contract that limits their use of the data to providing services to us.
• AI sub-processors. Third-party providers that transcribe your voice input, generate spoken replies during your voice check-in, analyze the photos you submit (food photos for nutrition information, and photos of prior paper or app logs to read prior medication and dose data), read data you import from a spreadsheet or CSV file to add it to your logs, and generate audio (text-to-speech), in each case only to deliver the feature you have requested. We do not retain voice recordings; the audio is discarded after transcription, and only the resulting text is kept. Food photos you submit are retained so you can review them; photos of prior logs are not retained. Under the terms on which we use these providers, they do not use your data to train their models. These providers may retain the data they receive, subject to their own terms, which govern how long and for what purposes they retain it. We do not send them this data for any purpose other than delivering the feature you requested.
• Other users, at your direction. Information you choose to share through the buddy system is shared with the buddy you connect with, subject to your privacy controls. This feature is opt-in and is not enabled by default.
• Legal and safety. When required by law, or to protect the rights, safety, and security of users, the public, or WellOff.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to the commitments in the Privacy Policy.
We do not share the consumer health data you log in the application with advertising platforms or data brokers, and we do not use it for targeted or cross-context behavioral advertising. The only activity that may constitute a “sale” or “sharing” of personal information is the consent-based website advertising described below, which involves website identifiers and activity, not the consumer health data you log in the application.
Website advertising technologies. On our websites only, and only where you consent through our cookie banner, advertising technologies receive online identifiers and information about your activity on the website. Under the California Consumer Privacy Act and similar state laws, this disclosure may constitute a “sale” or “sharing” of personal information. This activity is limited to website identifiers and activity. The consumer health data you log in the application is not disclosed to advertising platforms. We honor the Global Privacy Control as a valid opt-out signal, and you can withdraw consent at any time through the cookie banner.
List of third parties on request. You may request a list of the specific third parties and affiliates to which we have disclosed your consumer health data, together with a means of contacting them, by emailing hello@welloff.health.
5. Your Privacy Rights
Subject to applicable state law, you have the following rights with respect to your consumer health data:
• Right to know. To confirm whether we collect, share, or sell your consumer health data and to access that data.
• Right to a list of recipients. To obtain a list of all third parties and affiliates with which we have shared your consumer health data, together with a means of contacting each one.
• Right to delete. To have your consumer health data deleted, including by our processors and contractors.
• Right to withdraw consent. Where we rely on your consent to collect or share consumer health data, to withdraw that consent.
• Right against discrimination. To exercise these rights without being subjected to discrimination.
How to exercise your rights. To exercise any of these rights, email hello@welloff.health. You may also edit or delete most content directly in the application. You may use an authorized agent where permitted; we may ask the agent for proof of authorization and may ask you to verify your identity before we act on a request.
Our response. We will respond to a verifiable request within 45 days. If we need more time, we will notify you within that period and may take up to an additional 45 days, as permitted by law.
Appeals
If we decline to act on your request, you may appeal by emailing hello@welloff.health with “Consumer Health Data Appeal” in the subject line. Appeal mechanics vary by state:
• Connecticut. We will respond to your appeal within 60 days. If we deny the appeal, we will provide a method to contact the Connecticut Attorney General.
• Nevada. You may appeal our decision. If we deny the appeal, you may submit a complaint to the Nevada Attorney General.
• Washington. You may appeal our decision. If we deny the appeal, you may submit a complaint to the Washington Attorney General.
6. Reproductive, Menstrual, and Pregnancy-Related Information
We apply the following protections to the reproductive information you choose to log, including whether you log a menstrual period or pregnancy.
We will never use this information for advertising or marketing, and we will never sell or share it with advertising platforms or data brokers.
We disclose this information only in two situations: (i) as strictly necessary to provide a feature you have asked for, where any provider involved is bound by confidentiality obligations that prohibit using the information for any other purpose; or (ii) where we are legally compelled to do so by a valid court order, subpoena, or other legal process we are required to comply with.
We will not voluntarily disclose this information to law enforcement or government agencies in the absence of a court-ordered requirement, and we will notify you of any compelled disclosure to the extent we are legally permitted to do so. As a U.S. company, we remain subject to U.S. legal process.
7. Changes to This Notice
We may update this Notice from time to time. If we make material changes, we will notify you through the Service or by email and update the “Last Updated” date above. Where required by law, we will obtain your consent before applying a material change to consumer health data we have already collected.
8. Contact Us
Questions about this Notice may be directed to:
SwiftTech Health Inc.
Email: hello@welloff.health
Web: welloff.health