Legal

Consumer Health Data Privacy Policy

Last updated: October 8, 2026

This Consumer Health Data Privacy Policy explains how Brizo Finance LLC, the operator of MinervaOS ("MinervaOS," "we," "us," or "our"), collects, uses, and shares consumer health data through the MinervaOS iPhone application and related services (the "Service"). It supplements our general Privacy Policy and is provided to satisfy the Washington My Health My Data Act (RCW 19.373), Nevada SB 370 (NRS 603A as amended), and similar consumer health data laws. If anything here conflicts with the general Privacy Policy with respect to consumer health data, this policy controls.

In plain terms: your health data exists in MinervaOS for one reason: to run the tracking features you asked for. We do not sell it, we do not use it for advertising, and we do not share it with anyone except the service providers that make the app work. The advertising-measurement events the app sends to Meta, only if you allow tracking, contain none of it (Section 4).

What changed on October 8, 2026. If your goal is a cut or a bulk, you can now enter an optional goal weight and goal body-fat percentage, and an optional date to reach that goal by. They are saved with your profile like your other goals and are used only to size your protein and fat targets and to set the daily calorie deficit or surplus that reaches the goal by that date. Section 1 now lists them.

What changed on September 29, 2026. If you tap Allow on Apple's App Tracking Transparency prompt and keep Share with ad partners on in Settings → Privacy, the app sends Meta three advertising-measurement events (app install/activation, first open, and free trial started) with your device's advertising identifier. Section 4 now describes this, and Sections 5 and 6 say how that permission is given and withdrawn. The events contain none of the consumer health data listed in Section 1: no food, nutrition, body, weight, workout, Apple Health or wearable data, and no goals or AI content. They are never sent for a user under 18. We still do not sell consumer health data or use it for advertising.

What changed on September 16, 2026. Personalized Burn’s learned adjustment, learning status, calibration summaries and recap history are saved privately with your account to preserve progress through sign-out, reinstalling or changing phones. These derived estimates are not raw Apple Health or WHOOP sample streams and are not shared with other users. They remain until account deletion; a deliberate calibration reset restarts the saved learning.

What changed on September 15, 2026. Automatic scale weigh-ins and available body-fat readings from Apple Health or connected scales can update your profile and saved weight history. Those saved records are synced and backed up with your account and remain until you delete them or your account, even after the original cloud wearable record expires. Sections 1 and 2 now distinguish incoming wearable records from saved account history. Connecting a scale does not make its readings public.

What changed on August 8, 2026. Two corrections. Section 1 previously said that data from every connected wearable stayed on your device; that is true of Apple Health and of a direct WHOOP connection, but not of the cloud platforms you connect through Junction. Their data is delivered to and stored on our servers on a rolling 35-day window, and Sections 1, 2 and 4 now say so and name Junction as a processor. Section 4 now states that content you publish to a social surface is screened by OpenAI as well as Anthropic, and that both receive the image itself and frames sampled from a video. Nothing about selling, advertising, or geofencing changed: we still do none of them.

What changed on August 14, 2026. A clarification to Section 1: a workout imported from Apple Health or your Apple Watch becomes a logged workout, and logged workouts (type, duration, intensity, average heart rate where available) are stored on our servers like any workout you log by hand. The raw Apple Health sample streams (step counts, heart-rate series, and the like) are still not transmitted to our servers.

What changed on August 17, 2026. A second clarification to Section 1, for the same reason. Besides imported workouts, one more set of Apple Health-derived figures can reach our servers, and only because you share it: while the Workouts (on by default), Burned, or Eaten switch under What followers see is on (or when you share a daily summary to a group or your feed) the day's step count and calorie-burn figures (total, resting/BMR, and movement), computed on your phone from Apple Health and any connected wearable, are stored on our servers so the people you allow to see your profile can see them. The raw sample streams still do not leave your device.


1. Consumer Health Data We Collect

Depending on how you use the Service, we collect the following categories of consumer health data:

Processed on your device only: data read from Apple Health (steps, heart rate, workouts, sleep, and similar, including data from your Apple Watch) and from a direct WHOOP connection is used on your iPhone to compute estimates; those raw sample streams (step counts, heart-rate series, sleep stages, and the like) are not transmitted to our servers. Saved records are exceptions. First, the exercise data listed above: a workout imported from Apple Health or your Apple Watch becomes a logged workout in your history, and that logged record (type, duration, intensity, and average heart rate where available) is stored on our servers, exactly like a workout you log by hand. Second, the daily figures you let followers see: while the Workouts (on by default), Burned, or Eaten switch under Profile → Privacy & sharing → What followers see is on (or when you share a daily summary to a group or your feed) the day's total step count and calorie-burn figures (total burn, resting/BMR, and the movement portion), which your phone computes from Apple Health and any connected wearable, are stored on our servers so the people you allow to see your profile can see them; your profile is private by default, so nobody sees them until you approve a follower or make it public, and turning the switches off hides the figures and stops new days being published. Third, automatic scale weigh-ins and body measurements: when you permit access, imported weight and available body-fat readings can update your profile and become dated weight-history entries, including the source and any fasting answer you provide. Those saved records are synced and backed up to our servers, associated with your account, and remain until you delete them or your account. They remain private unless you explicitly share them. Revoking access stops new imports without deleting existing history.

Stored on our servers when you connect a cloud wearable: the cloud wearable platforms you can connect (currently Garmin, Oura, Fitbit, Polar, Withings, Wahoo, Ultrahuman, Peloton, Eight Sleep, and Zwift) do not talk to your phone. They send your data to our wearable-connection provider Junction, which delivers it to our servers, where it is stored (visible to your account only) and read back by your phone to compute your estimates. What is stored is the per-day record the platform sends: daily activity and step summaries, workouts, sleep sessions, heart-rate series (averaged into two-minute buckets before storage), body measurements such as weight, body-fat percentage and VO₂max, and any other daily metric that platform reports. We keep those incoming records on a rolling 35-day window and delete anything older. Imported workouts, automatic scale weigh-ins and body values saved to your profile or history become part of your account and its backup, and remain until you delete them or your account. It is used solely to compute your estimates, is never sold, never used for advertising, and never shown to another user. Disconnecting a wearable in Minerva stops using that connection for new imports on this device. It does not revoke the connection between your wearable provider and Junction, so data may continue reaching our servers. To stop those deliveries, revoke the connection in your wearable provider’s account settings, or contact support@minervaos.app for help. Disconnecting does not delete previously saved records. Account deletion removes these records from our active systems and requests deletion from Junction.

2. Sources of Consumer Health Data

3. Why We Collect It (Purposes)

We collect and use consumer health data only to provide the Service you requested: computing nutrition and calorie-burn estimates, keeping your logs and history, syncing your data across your devices, powering the AI logging and estimation features you invoke, and sending notifications you enable. We do not use consumer health data for third-party advertising, marketing unrelated to the Service, or data mining, and we do not use it to train AI models.

4. How We Share It

We do not sell consumer health data, and we have no history of selling it. We share it only with service providers acting on our instructions:

Advertising measurement (Meta), only with your permission. If you tap Allow on Apple's App Tracking Transparency prompt and leave Share with ad partners on (Settings → Privacy), the app sends Meta three events (app install/activation, first open, and free trial started) with your device's advertising identifier and basic device information, so we can measure which of our ads bring people to MinervaOS. Meta receives none of the consumer health data listed in Section 1 (no food, nutrition, body, weight, workout, Apple Health, wearable, goal or AI content) and no name or email. Because Washington's law defines consumer health data broadly enough that the fact that someone uses a health and fitness app could itself be treated as consumer health data, we send these events only with that separate permission, never for a user under 18, and you can withdraw it at any time by turning the switch off or turning off tracking for MinervaOS in iOS Settings → Privacy & Security → Tracking. See the general Privacy Policy, Section 2.

We may also disclose data if required by law, or to protect the rights, safety, or property of you, us, or others. We do not share consumer health data with affiliates for their own use.

What moderation does and does not see. Your private food logs, weights, workouts, notes, Apple Health data, and the cloud wearable records described in Section 1 are never sent to a moderation classifier. Classification applies only to what you publish to a public or widely visible surface: a post and its caption, a comment, your username, display name or profile avatar, and any photo or video you attach to one. That content is transmitted to OpenAI and to Anthropic to be classified, and that includes the image itself and frames sampled from a video, not merely a description of it, so a progress photo you post is a photograph sent to two third parties. What you send inside an invite-only group (chat messages, the workouts and meals you share there, and the photos you attach) is not read by a classifier at all; it is reviewed only if someone reports it. Both providers act as our processors under contracts limiting their use of the content; OpenAI states that its moderation endpoint is not used to train its models, and we instruct Anthropic not to train on the content it classifies. See the general Privacy Policy, Section 6a.

5. Your Consent

We collect consumer health data only after you consent at sign-up (the in-app legal gate), and the app asks your permission separately before reading Apple Health data or connecting a wearable. AI features process your content only when you invoke them.

Consent to collect and consent to share are treated separately, as the Washington My Health My Data Act requires: the sharing described in Section 4 is limited to processors acting on our instructions to deliver the Service, plus the Meta advertising-measurement events, which are sent only if you tap Allow on Apple's tracking prompt and leave Share with ad partners on, and which contain none of the consumer health data listed in Section 1. Section 4 and the general Privacy Policy (Section 2h) set out what those events contain, why they are sent, who receives them and how to stop them. We will obtain your separate, specific consent before any other sharing. You can withdraw consent at any time. See Section 6.

6. Your Rights

You have the right to:

To exercise any right, use the in-app controls or email support@minervaos.app. We will verify the request using your account email and respond within the time required by applicable law (generally 45 days). Exercising these rights costs nothing and will not degrade the Service you receive.

7. No Geofencing

We do not use a geofence around any healthcare facility, and we do not collect precise geolocation at all. The Service asks for no location permission, and nothing in it identifies, tracks, or infers where you are in order to target you with advertising, messages, or offers relating to your health.

8. Security and Breach Notification

Consumer health data is protected by the measures described in the general Privacy Policy, Section 10. If your identifiable health information is acquired without authorization, we will notify you and the appropriate regulators (including the Federal Trade Commission under the Health Breach Notification Rule) as described in the general Privacy Policy, Section 19.

9. Appeals

If we decline a request, you may appeal by replying to our decision or emailing support@minervaos.app with the subject "Health Data Appeal." We will respond within the period required by applicable law. Washington residents may also contact the Washington Attorney General at atg.wa.gov; Nevada residents may contact the Nevada Attorney General.

10. Changes and Contact

If we make material changes to this policy, we will provide notice in the app or on this page and, where required, obtain your consent.

Questions: support@minervaos.app