1. Scope
This policy describes consumer health data. It supplements the ENDIA FLOW Privacy Policy and is a separate notice. It applies where U.S. state consumer-health laws apply, including the Washington My Health My Data Act and the Nevada consumer-health-data law.
2. Consumer health data we collect or process
- a Body/Mind check-in you enter, which stays on your device and is not uploaded as a health record;
- heart rate from an optional camera reading;
- heart rate and, when available, heart rate variability from a wearable through Health Connect or HealthKit / Apple Health, read-only;
- a summarized rhythm reference linked to your account: median heart rate when real readings exist, median HRV when a real wearable reading exists, sample counts, and an HRV-metric identifier such as RMSSD or SDNN;
- wellness state labels or session outputs derived by the App from your check-in and, when authorized, optional rhythm signals. These outputs are used for the ENDIA experience and remain on the device as part of the local session experience and history.
Camera frames are processed briefly in memory on your device to calculate a numerical pulse rate, then overwritten. We do not create, store, or transmit photos, videos, biometric templates, faceprints, or facial geometry. Raw readings and session history stay on the device. Website forms do not collect consumer health data.
3. Sources
We collect this data from you and, if you authorize it, from your device or a connected health platform. Derived state labels are produced on the device from information you provide or authorize.
4. Purposes
We use this data only to inform the wellness session shown to you, to keep and restore the summarized reference on your account, and to handle a privacy or deletion request. This processing does not make decisions that produce legal or similarly significant effects. We do not use it for diagnosis, treatment, credit, insurance, employment, housing, or advertising.
5. Disclosures, sale, and advertising
We disclose the summarized rhythm reference to Google Firebase / Firestore acting as our processor to host it with your account. We do not sell consumer health data or share it with third parties or affiliates for advertising or other independent purposes.
We do not disclose heart rate, HRV, check-in, derived state labels, or other consumer health data to RevenueCat, Meta, Google Ads, Tinybird (including through the Flock.js script), Supabase, or affiliates.
If we ever shared consumer health data with a third party other than a processor needed to host the summarized reference, we would ask for separate consent first.
6. Retention and deletion
You may request deletion of your consumer health data without deleting your ENDIA account by contacting privacy@endiaflow.com. Where applicable, we will delete the summarized rhythm reference we maintain and instruct relevant processors to honor the request.
Deleting your account also deletes that reference, the Firebase Authentication account, and the Firestore document. In-App deletion removes local rhythm-reference data and local session history on that device. The website cannot erase data that exists only on your device.
Deletion from active systems may not immediately remove limited residual copies or technical logs maintained temporarily by a processor for security, integrity, backup, fraud prevention, legal, or similar purposes. Any such retention is limited to what is necessary under the processor’s processes or applicable law.
7. Geofencing and cross-site collection
We do not use geofencing around health-care facilities, mental-health facilities, or similar locations, for advertising or for any other purpose. We do not collect precise location.
We do not permit third parties to collect consumer health data through ENDIA over time across unrelated websites or online services. Site advertising and measurement technologies do not receive ENDIA App health data.
8. Your rights, including review and correction
If these laws apply to you, you may confirm whether we collect, share, or sell consumer health data; access it; obtain a list of third parties and affiliates with whom we have shared or sold it; withdraw consent; and request deletion.
You may ask us to review or correct consumer health data we maintain about you by contacting privacy@endiaflow.com. The baseline is a computed summary. You can correct it by asking us to delete it and, if you choose, building a new one.
We may need to verify the request. If we deny a request, you may appeal by writing to privacy@endiaflow.com with the word Appeal. If we deny the appeal, you may contact your state attorney general. Washington: atg.wa.gov/file-complaint. Nevada: ag.nv.gov.
9. Washington and Nevada timing
Washington: applicable requests are handled within 45 days of receipt, subject to one permitted 45-day extension. Authentication does not extend that period. If consumer health data requested for deletion is stored in archived or backup systems, deletion may be delayed as permitted by law, but not beyond six months after authentication of the deletion request. We do not currently maintain such systems.
Nevada: deletion requests are completed within 30 days after authentication. Relevant processors, contractors, affiliates, or other recipients notified of the request must also complete deletion within the period required by law. If the data is stored in archived or backup systems, deletion may be delayed, where permitted, for no more than two years after authentication as necessary to restore those systems. We do not currently maintain such systems. Other requests are handled within 45 days after authentication, subject to one permitted 45-day extension.
10. Consent and withdrawal
Camera and wearable features are optional. ENDIA shows its own screen before any system permission, for camera and for a wearable. That screen identifies the data used (heart rate and, from a wearable, heart-rate variability when available), the purpose (to help inform the state the session begins from and to maintain your personal rhythm reference), who receives it (individual readings stay on the device; only the summarized rhythm reference may be saved to your account, hosted by Google Firebase), and how to stop (decline on that screen, or remove the camera permission or ENDIA FLOW’s health access in your phone’s settings). Accepting the Terms and confirming that you are 18 or older is not consent to collect consumer health data.
You can withdraw permission at any time in your device settings, in Health Connect, or in Apple Health. After you withdraw, we stop reading new rhythm data. Your summarized baseline stays with your account until you delete your account or ask us to delete it at privacy@endiaflow.com. We keep camera and wearable consent records separately, including the notice version and time of acceptance, so we can document that the applicable consent was given before collection.
11. Security
We limit access to consumer health data to people and processors who need it for the purposes in this policy. We use reasonable administrative, technical, and physical safeguards, including access controls and encryption in transit for the summarized reference sent to our processor. No method of storage or transmission is completely secure.
12. Changes
We will update the effective date when this policy changes. For a material change, we will notify you in the App before it takes effect and ask for new consent where required.
13. Contact
Nascimento e Memolo Desenvolvimento de Programas de Computador Ltda
CNPJ 68.454.409/0001-11
Alameda Professor Lucas Nogueira Garcez, 865, Sala 01, Vila Thais, Atibaia – SP, 12942-020, Brazil
privacy@endiaflow.com · support@endiaflow.com · +55 11 97380-1961