Consumer Health Data Privacy Policy
Wholeday · STI Financial LLC, doing business as Wholeday, Temecula, California
Effective October 18, 2026 · Version 1
This policy explains how we handle consumer health data under Washington's My Health My Data Act (RCW 19.373), Nevada's consumer health data law (SB 370) and Connecticut's consumer health data provisions. It applies to the Wholeday iPhone app and to wholedayapp.com, including our waitlist. It adds to our Privacy Policy, which covers everything else.
The short version
- The app: your health records stay on your iPhone. We don't receive them and keep no copy. They leave your iPhone only when you choose to send them somewhere, for example to Apple Health, a backup folder, your prescriber, or the optional AI coach with your own key. (These laws define "collecting" broadly, to include processing data in any way. The app processes your records on your iPhone to provide its features; section 1 lists what that covers.)
- The website: if you join the waitlist, we keep your email address. Because Wholeday is an app for people who take medications such as GLP-1s, joining the waitlist could suggest that you're interested in health-related services. We treat your waitlist entry as consumer health data.
- We use service providers to run the website and the waitlist. We never sell consumer health data, and we never use it for advertising.
1. What consumer health data is involved
| Where | What | Who has it |
|---|---|---|
| The app | Medications and doses, injection sites, symptoms and check-ins (appetite, "food noise", side effects), weight and body measurements, progress photos, lab results, food, water, fasting, and Apple Health data you allow | Only your iPhone. The app processes it there to provide its features. We don't receive it, and we have no copy and no access. |
| The waitlist | Your email address, your optional answer to "How did you hear about Wholeday?", when you joined, and which version of the sign-up wording you agreed to | Us, stored with our service provider (section 4). |
| Visit counts | Totals such as page views, referring site, country and browser type, without cookies | No individual-level data that identifies you. |
2. Why we collect it
- Waitlist: only to email you about Wholeday's beta and launch, and to count which channels bring people to the waitlist.
- App: we don't collect app data. The app uses your information on your iPhone only to provide its features to you.
3. Where it comes from
- Waitlist: from you, when you sign up on wholedayapp.com.
- App: from you, and from Apple Health with your permission. It stays on your iPhone.
4. Who we share it with
We don't sell consumer health data, and we don't share it with third parties. We disclose waitlist data only to these service providers (called "processors" under the law), who handle it on our behalf, under contract, and only to provide their service to us:
| Processor | What they handle | Why |
|---|---|---|
| Cloudflare, Inc. | Waitlist entries (stored in our own Cloudflare account) and website hosting | To run the website and store the list |
We don't use an email-sending service yet. If we add one for launch emails, we'll name it here before sending.
Disclosures you start yourself (app): when you choose to, the app sends data from your iPhone to places you pick: Apple Health; a backup folder (such as iCloud Drive); a report or export you share; Reminders (grocery list); or, if you add your own Anthropic API key and turn it on, Anthropic's Claude, with only the kinds of data you switch on. These go directly from your iPhone at your direction; we don't receive them.
5. Your consent
- Waitlist: the sign-up form tells you what we collect, why, which kinds of service providers handle it, and how to withdraw, and asks you to agree before you join. We record the date and the version of the wording you agreed to. You can withdraw at any time with the unsubscribe link in any email, or by writing to [email protected], and we'll delete your entry.
- App: you choose what the app reads from Apple Health and what it sends anywhere, one item at a time, and can change those choices in Settings and in the Health app.
6. Your rights
You have the right to:
- confirm whether we collect, share or sell your consumer health data;
- access the consumer health data we hold about you, and a list of everyone we've shared it with;
- delete it;
- withdraw consent;
- appeal if we refuse a request.
How to use them:
- Waitlist: email [email protected] from the address you signed up with. We'll confirm the request comes from you, then:
- respond within 45 days; if we need more time, we may extend once by up to 45 more days and will tell you why within the first 45 days;
- for deletion, delete your entry and tell our processors to delete it. If you're a Nevada resident, we delete it within 30 days of confirming the request comes from you. A copy in a backup is deleted the next time that backup is restored or overwritten, as the law allows.
We aim to answer well before these deadlines.
- App: everything is on your iPhone, so you can see, export or delete it yourself (Settings → Delete all data). We hold no copy to look up.
- Appeals: reply to our response and say you're appealing. We'll answer within 45 days and explain our decision. If we deny your appeal, Washington residents may contact the Washington State Attorney General at atg.wa.gov/file-complaint, and Nevada and Connecticut residents their state Attorney General.
We won't treat you differently for using these rights.
7. How long we keep it
- Waitlist: until 12 months after launch, or sooner when you ask.
- App: on your iPhone until you delete it.
8. Security
The waitlist is stored in our own Cloudflare account with restricted access. We don't store IP addresses, device or browser details with sign-ups. To stop automated sign-ups, we briefly use a scrambled (hashed) form of your IP address, held in memory for about a minute and never saved. The app keeps your data on your iPhone, protected by its passcode and Apple's data protection, and there are no Wholeday servers holding app data.
9. Geofencing
We don't use geofencing around health care facilities.
10. Changes
If we change this policy, we'll update this page and its effective date. If we ever want to collect or share consumer health data in a new way, we'll ask for your consent first.
11. Contact
[email protected]
STI Financial LLC, doing business as Wholeday, Temecula, California