Last Updated: September 1, 2024
This resource is about how we handle health data at Zolt. We recommend reading it along with the general Zolt privacy notice (the “general privacy notice”) which includes full details of how we process personal data and respect privacy rights. This notice specifically covers “consumer health data” under Washington State My Health My Data Act and Nevada’s Consumer Health Data Privacy Law. But hey, if you are not from Washington or Nevada, do not worry, we also protect your health data!
Introduction
At Zolt Labs LLC, also known as “Zolt,” we genuinely care about keeping consumer health data private and safe. With this Consumer Health Data Privacy Notice, our goal is to explain what types of consumer health data we collect and process, where we obtain the consumer health data, the types of consumer health data we disclose to other parties and types of parties we disclose consumer health data to, and rights regarding consumer health data.
We also want to clarify that the Zolt application provides information and feedback based on information that could qualify as consumer health data. Without this data, the application cannot give personalized feedback. Users are free to delete or modify their entries containing consumer health data anytime, but doing so may mean losing some personalized information and feedback.
Consumer Health Data We Collect
As described in the What Personal Data We Collect and Process and Why, How Long We Keep It, and With Whom We Share It section of the general privacy notice, the data we collect depends on the context of the user interactions with Zolt and the information users choose to provide us with, as well as the products and features each user uses. Because consumer health data is broadly defined under laws like Washington State My Health My Data Act and Nevada’s Consumer Health Data Privacy Law, many of the categories of personal data we collect could fall under this category.
Examples of consumer health data we collect or process include:
- Information users voluntarily share on social media, in interviews, customer support queries, emails, or for publishing success stories. This could include, for example, photos, bodily measurements, physical condition, surgeries, medical history, dietary preferences, allergies, and success stories.
- Data inputted by users into the Zolt app, such as body metrics, nutrient intake, protein, carb, and fat percentages, lifestyle details like cardio experience, exercise frequency, activity level, strength sports experience, period information, and progress photos.
- Data received from Health Connect with user authorization.
- Customized calorie targets and macro programs generated by the Zolt app based on user input and data from Health Connect.
Sources of Health Data
As described further in the What Personal Data We Collect and Process and Why, How Long We Keep It, and With Whom We Share It section of the general privacy notice, the source of the data depends on the situation in which we obtain it. We collect it directly from Zolt app users when they use the app, from Health Connect with their permission, or through direct interactions with Zolt via email, social media, customer support, or interviews.
Why We Collect and Use Consumer Health Data
We collect and use consumer health data for the purposes described in the What Personal Data We Collect and Process and Why, How Long We Keep It, and With Whom We Share It of the general privacy notice.
Primarily, we collect and use consumer health data as reasonably necessary to provide Zolt app users with the features or assistance they have requested or authorized, particularly to provide them with personalized meal planning, tracking, and recommendations, enhancing their app experience and functionality, and allowing them to upload progress photos. We also collect and use the consumer health data that users want to appear in their published success stories.
Incidentally, we collect unsolicited consumer health data in the context of user interactions with us, and we do not intend to use such data for any other purpose than responding to users.
If we ever plan to use consumer health data for anything other than its stated purpose, we’ll ask for consent, as required by law, such as for advertising or marketing.
Our Disclosures of Health Data
We may share the categories of consumer health data described above with the third parties listed in the What Personal Data We Collect and Process and Why, How Long We Keep It, and With Whom We Share It section of the general privacy notice. We also disclose consumer health data in accordance with the International Transfers of Your Personal Data section of the general privacy notice.
In particular, the only third parties that may process personal data, including consumer health data, are the ones associated with the social media platform individuals use to connect with us, or the service providers that help us provide the services, namely App Global GK (Japan), Athlete Body KK (Japan), Google, LLC (USA) and Gleap GmbH (Austria).
We have not authorized any third party to collect express consumer health data over time and across different websites or online services when a consumer uses our website or uses the Zolt app.
We may also share consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets or with law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process (although we don’t think they’re very interested in our users’ calorie intake!).
How to Exercise Privacy Rights
Data privacy laws, such as the Washington State My Health My Data Act and Nevada’s Consumer Health Data Privacy Law provide certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. Individuals can request to exercise such rights using the various tools and mechanisms described in the What Privacy Rights Do You Have? section of the general privacy notice. For app data, users can download an export of their data, delete and modify entries, and delete their account. To access or control consumer health data processed by Zolt that is not available via the Zolt app options, you can always contact Zolt at the contact information in the How Can You Exercise Your Privacy Rights? section of the general privacy notice.
If a request to exercise a right under the Washington State My Health My Data Act or Nevada’s Consumer Health Data Privacy Law is denied, individuals may appeal that decision by contacting hi@zolthealth.com. If an appeal is unsuccessful, individuals can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint, and with the Nevada State Attorney General at https://ag.nv.gov/.
Changes to Our Consumer Health Privacy Notice
We are always working to improve our services, policies and processes. Therefore, our Consumer Health Data Privacy Notice may undergo changes. When we make important changes to this notice, here is how we will keep users informed:
Website Information: One can always find the most current version of our Consumer Health Privacy Notice on our website. The date of the latest update will be clearly shown at the top of the page.
Email Alerts: All our users will receive an email detailing any substantial updates or changes to the privacy notice. This email will outline the changes and their potential impact on your data privacy.