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CurioCoreFlowbase and SportsFlow legal

Consumer Health Data Privacy Notice

Flowbase and SportsFlow · Effective {EFFECTIVE_DATE}

This Notice explains how CurioCore ("we") collects, uses and shares consumer health data through Flowbase, SportsFlow and FlowCoach. It is provided under the Washington My Health My Data Act, Nevada Senate Bill 370, the Connecticut Data Privacy Act and similar state laws, and applies to residents of those states. It supplements our Privacy Policy. Where the two differ for consumer health data, this Notice controls.

1. Consumer Health Data We Collect

Category Examples
Wellbeing and mental health responses Daily check-ins; answers to wellbeing, emotional regulation, gratitude, self-compassion and resilience questionnaires; WHO-5 and GAD-7 screening answers
Physiological and biometric readings Heart rate, heart rate variability, resting heart rate, sleep, activity and recovery data from connected devices
Health-derived information Wellbeing scores, readiness indicators, load tolerance, trends, threshold events
Body measurements Weight class and age category used for rankings and handicaps
Health-related conversations Health or wellbeing topics you raise with FlowCoach or a coach

2. Why We Collect and Use It

We collect and use consumer health data only to:

  1. Provide the features you request, including scores, readiness, trends and FlowCoach answers;
  2. Share it with coaches as you choose in your settings;
  3. Notify your club's Wellbeing Lead that a screening result met its threshold, without the score, if your club uses screening questionnaires, which are available only through clubs at this time;
  4. Check the reliability of our questionnaires using de-identified data;
  5. Keep the Services secure and comply with law.

We do not use consumer health data for advertising or marketing.

3. Sources

You; devices and services you connect (Apple Health, Garmin, Polar, WHOOP, Oura, Concept2); and information we derive from those sources.

We ask for your consent before collecting consumer health data, and separately before sharing it, except as needed to provide a service you requested. For users under 18, a parent or guardian gives this consent. You may withdraw consent at any time in settings.

5. Who We Share It With

Recipient What Why
Your coaches Readiness by default; scores and other data only if you share them To support your training, at your direction
Your club's Wellbeing Lead That a screening result met its threshold. Never the score or answers Safeguarding
AI provider (Anthropic, PBC, which provides the Claude model) De-identified context needed to answer a FlowCoach question To generate the answer. Not used for training
Hosting provider ({HOSTING}) Stored data To operate the Services

We have no affiliates that receive consumer health data. Contact details for each recipient are available on request.

6. We Do Not Sell Consumer Health Data

We do not sell consumer health data and do not use geofences around health care facilities.

7. Your Rights

You have the right to:

  1. Confirm whether we collect, share or sell your consumer health data;
  2. Access it, including a list of all third parties and affiliates we have shared it with and their contact information;
  3. Withdraw consent to its collection and sharing;
  4. Delete it, including from archives and backups. We will tell our processors and any third parties to delete it too;
  5. Appeal our decision on a request.

To make a request, use settings or email {PRIVACY_EMAIL}. We respond within 45 days, and may extend once by 45 days when reasonably necessary, with notice. Deleted data is removed from backups on their next rotation, within 35 days.

Appeals. If we decline a request, reply to our decision within a reasonable time to appeal. We answer within 45 days and explain our reasons. If your appeal is denied, you may contact the Washington State Attorney General at atg.wa.gov, the Nevada Attorney General at ag.nv.gov, or the Connecticut Attorney General at portal.ct.gov/ag, as applicable.

8. Security

Access to consumer health data is limited to employees and processors who need it to provide the Services, under confidentiality obligations. We use encryption in transit and at rest and log access.

9. Contact

CurioCore, {ADDRESS} · {PRIVACY_EMAIL}