Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy is published by Foxtide LLC (“Foxtide”, “we”) as required by the Washington My Health My Data Act, RCW 19.373, and addresses consumer health data we process through the Cinder iOS application. It applies in addition to our general Privacy Policy. This policy is also intended to satisfy comparable disclosure obligations under Nevada SB 370 (NRS Chapter 603A as amended) and the Connecticut Data Privacy Act consumer-health-data amendments (CT Gen. Stat. § 42-515 et seq.).

1. Categories of consumer health data we collect

• the substance you’re trying to quit (cigarettes, vape, dip, nicotine pouches, or similar) and your daily amount before quitting
• your quit date and quit-related context (motivation, what you expect to be hardest, prior quit attempts)
• daily check-in data: mood rating (1–5), whether you had a slip on that day, and your optional one-line note
• self-reported health baselines you choose to share
• life-impact answers describing how nicotine has affected specific areas of your life, selected from a menu
• the integer Recovery Score derived from your Apple Health resting heart rate, heart rate variability, and sleep samples (the underlying samples are not collected by us — they are read on your device and discarded)
• screen views, taps, and session recordings that may incidentally capture your in-app behavior related to quitting nicotine

2. Sources of consumer health data

• directly from you, when you enter answers into the app
• from the Apple HealthKit framework on your device, when you grant Cinder permission to read heart rate, HRV, and sleep data
• generated by the Cinder app itself, when you interact with it (screen views, button taps, session recordings via PostHog)

3. Categories of consumer health data we share, and the categories of third parties with whom we share it

We do not sell consumer health data. We share consumer health data only with the following categories of third parties acting as our service providers or processors:

• Database hosting: Supabase, Inc. (United States). Stores your onboarding answers, daily check-ins, money goal, health baselines, life-impact answers, and Recovery Score history, scoped to your anonymous device ID.
• Product analytics and session replay: PostHog, Inc. (United States, US Cloud region). Receives screen views, taps, and session recordings tied to your anonymous device ID.
• Subscription state: RevenueCat, Inc. (United States). Receives subscription and purchase events tied to your anonymous device ID. RevenueCat does not receive consumer health data.
• Crash and performance diagnostics: Apple Inc. via TestFlight and App Store Connect, and PostHog for product-level crash signals.

We do not share consumer health data with any affiliate or other category of recipient beyond those listed above.

4. Purposes for which we collect, use, and share consumer health data

• to provide the Cinder quit-tracking service you requested
• to calculate and display your Recovery Score
• to personalize content (such as which milestone messages and which life-impact insights appear)
• to diagnose bugs, understand confusing screens, and improve the app
• to enforce our terms and comply with legal obligations

We do not use consumer health data for advertising, for cross-context behavioral profiling, or for training large language models or other artificial intelligence systems.

5. How we obtain consent, and how you can withdraw it

Necessary collection. Some consumer health data is necessary to provide the Cinder service. This includes the substance you’re quitting, your daily amount, your quit date, and your daily check-in entries. Collecting these is necessary to perform the service you requested when you installed Cinder.

Opt-in consent. Before we collect consumer health data that is not strictly necessary to provide the service — specifically: your Apple Health data (heart rate, HRV, sleep) used to derive the Recovery Score; your optional money-saved goal and life-impact answers; your optional one-line note on the daily check-in; and product analytics including session recording — we ask you to opt in. We record the date and version of your consent.

Withdrawing consent. You may withdraw consent at any time:

• Session recording and product analytics: Settings → Privacy → Session recording or Product analytics toggle inside the Cinder app.
• Apple Health access: iOS Settings → Privacy & Security → Health → Cinder.
• All other consumer health data: email support@getcinder.app with the subject line “CHD — Withdraw Consent”.

Withdrawing consent stops further collection and use for the purpose you withdrew consent from. To also delete consumer health data we have already collected, exercise your right to delete (Section 6).

6. Your rights and how to exercise them

• Right to confirm and access: confirm whether we are collecting, sharing, or selling your consumer health data, and access the consumer health data we have collected about you.
• Right to delete: request deletion of your consumer health data. We will delete it from our systems within 30 days and notify all affiliates, processors, contractors, and other third parties with whom we have shared the data to do the same.
• Right to withdraw consent: withdraw consent for collection and sharing of consumer health data (see Section 5).
• Right against discrimination: we will not deny you goods or services, charge a different price, or provide a different level of quality for exercising any of these rights.

How to exercise: email support@getcinder.app with the subject line “CHD — [Right You Are Exercising]”. Because Cinder is a no-account app, the anonymous device ID stored in your iPhone’s Keychain is the only way we can locate your data. Include your device ID (Settings → About → Device ID inside the Cinder app) when you write to us, or describe the device and approximate install date so we can locate the record.

Response time. We will respond within 45 days. If we need additional time (because of the complexity or volume of your request) we will notify you within the first 45 days and explain why, taking no longer than 90 days in total.

Right to appeal. If we deny your request, you may appeal by replying to our response email. We will substantively respond to your appeal within 45 days. If we deny the appeal, you may file a complaint with the Washington State Attorney General at atg.wa.gov/file-complaint.

7. Sale of consumer health data

We do not sell your consumer health data. “Sale” here has the meaning given by RCW 19.373.010 (exchange of consumer health data for monetary or other valuable consideration). We have not sold consumer health data in the past 12 months and have no plans to do so. If we ever change this practice, we will obtain your valid authorization in advance using a written authorization that satisfies RCW 19.373.060, and that authorization will be revocable at any time.

8. Changes to this policy

If we make material changes to this policy — including adding new categories of consumer health data we collect, new processing purposes, or new categories of recipients — we will obtain your prior affirmative consent before the changes take effect with respect to your previously-collected consumer health data. We will also update the “Last updated” date at the top of this page.

9. Contact

For any question about this Consumer Health Data Privacy Policy or to exercise any right described above, email support@getcinder.app.

Foxtide LLC · Cinder · iOS