1. Scope
This policy explains how CLAD Ventures LLC ("we," "our," or "us") collects, uses and shares consumer health data through LODE, our iPhone and Apple Watch app (the "App"). It applies to consumers protected by Washington's My Health My Data Act, Nevada's consumer health data law (SB 370) and Connecticut's consumer health data provisions, and to anyone else who wants to know how we handle this data. It supplements our Privacy Policy.
2. Consumer Health Data We Collect
| Category | Examples | Where it comes from |
|---|---|---|
| Heart rate | Readings during workouts, average heart rate, heart-rate zones | Apple Health, from your Apple Watch, compatible earbuds or a Bluetooth heart-rate monitor |
| Body weight | Body weight in your profile and recorded with workouts | You, or Apple Health if you allow it |
| Injury and joint information | Joints or movements you ask Spotter to avoid | You |
| Health-related notes | Free-text notes you give Spotter, which may mention health conditions | You |
Your other workout records (exercises, sets, reps, weights lifted, effort scores and ratings) are general fitness data. They sync as described in our Privacy Policy, with or without this consent.
The App can also read workouts, active energy and body weight from Apple Health for display. Those Apple Health records stay on your device and are not uploaded to us.
We do not collect precise location, and we do not use geofencing.
3. How We Use It
We use consumer health data only to provide the App's features to you:
- Logging and displaying your workouts, heart-rate charts and zones, effort scores and body-weight trends.
- Building Spotter plans that leave out or de-prioritize exercises for joints or movements you want to avoid.
- Syncing your data between your devices, if you're signed in and have consented.
We do not use consumer health data for advertising or marketing, to make decisions about you outside the App, or to train AI models.
4. Your Consent
In guest mode, consumer health data stays on your device and is never sent to us.
When you sign in, the App asks for your consent before any consumer health data syncs to our cloud store. If you agree, it syncs with the rest of your App data. If you choose "Not Now," the App keeps working, but your consumer health data stays on your phone and is left out of your cloud copy.
You can withdraw consent at any time in Settings > Data & Privacy. When you do, the App removes your consumer health data from our cloud store and keeps it on your phone only. We keep a record of each consent decision, with its date and version, as proof of your choice.
5. Sharing
We share consumer health data only with service providers (processors) that store it on our behalf, under contracts that limit them to providing their services to us:
| Third party | Role | Consumer health data it receives |
|---|---|---|
| Supabase, Inc. | Cloud storage and sync | All synced consumer health data, if you consent |
| Amazon Web Services, Inc. | Infrastructure hosting used by Supabase | The same data, as Supabase's host |
We have no affiliates that receive consumer health data. Clerk, our sign-in provider, does not receive it.
We may also disclose consumer health data if the law requires it. We may share it with people you choose through the iOS share sheet, such as a workout card showing your average heart rate, because you direct us to.
6. No Sale
We do not sell consumer health data, and we will not sell it.
7. How Long We Keep It
We keep synced consumer health data while your account exists and you have consented. When you withdraw consent, delete your app data or delete your account, it's removed from our cloud store right away. It is removed from our provider's backups within 7 days.
8. Your Rights
You have the right to:
- Confirm whether we collect, share or sell your consumer health data.
- Access your consumer health data.
- Get a list of the third parties and affiliates we have shared it with, with their contact information.
- Withdraw your consent.
- Have your consumer health data deleted, including from backups.
- Appeal if we deny your request.
You can withdraw consent, export your data, and delete your data or account yourself in the App. For anything else, email info@clad-ventures.com with the subject "Consumer Health Data Request" from the email address on your LODE account. We will verify your request using information associated with your account.
We will respond within 45 days of receiving your request. If we need more time, we may extend that once by another 45 days and will tell you why. We will not charge you for a request, unless requests are clearly unfounded or excessive, and we will not discriminate against you for exercising your rights.
9. Appeals
If we deny your request, you may appeal by replying to our decision within 30 days. We will respond to your appeal within 45 days and explain our decision in writing.
If we deny your appeal, you may contact your state attorney general. Washington residents can file a complaint with the Washington State Attorney General.
10. Changes
We may update this policy. When we do, we will change the date above. If we want to collect, use or share consumer health data in a materially different way, we will ask for your consent first.
11. Contact
CLAD Ventures LLC
Email: info@clad-ventures.com