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Privacy Policy

Last updated: October 8, 2026

This Privacy Policy explains how Brizo Finance LLC, the operator of MinervaOS ("MinervaOS," "we," "us," or "our") collects, uses, shares, and protects information when you use the MinervaOS iPhone application and related services (the "Service"). By using the Service, you agree to this Privacy Policy. Capitalized terms not defined here have the meaning given in our Terms of Service.

Our commitments, in plain terms: We do not sell your personal information. We do not show ads in the app, and we never give your health, food, body, workout or account data to any advertising company. We measure which of our ads bring people to MinervaOS in two ways: Apple's SKAdNetwork, which needs no permission and carries no identifier; and, only if you tap Allow on Apple's tracking prompt and leave Share with ad partners on in Settings, Meta's SDK, which then sends Meta three events (app install/activation, first open, and free trial started) with your device's advertising identifier (Section 2h). That counts as "sharing" under California law, and you can stop it at any time (Section 13.13). We use no other third-party analytics, advertising, or tracking SDKs. Data we read from Apple Health is used on your device to compute your estimates. Raw step, heart-rate and sleep streams are not sent to our servers. Imported workouts, automatic scale weigh-ins and body measurements saved to your profile or weight history are stored with your account, including in its backup. Daily step and calorie-burn figures also reach our servers when you enable sharing (Section 2b). Cloud wearables you connect through our wearable-connection provider (Junction) are different: their data does reach our servers, because that is how it gets to your phone. It is stored for your account alone, kept on a rolling 35-day window, deleted when you delete your account, and never sold or used for advertising (Section 2b).

If you are a California resident, please also see Section 13 (Your California Privacy Rights), which includes the disclosures required by the CCPA/CPRA and CalOPPA.

If you live in Virginia, Colorado, Connecticut, Texas, Oregon, or another U.S. state with a comprehensive privacy law, see Section 14 (Other U.S. State Privacy Rights), including how to appeal if we refuse a request.

If you are a resident of Washington, Nevada, or another state with a consumer health data law, our separate Consumer Health Data Privacy Policy also applies to your health data and controls where it is more specific.

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 2a now lists them. You can also now send us feedback from inside the app; Sections 2i and 9.1 describe what we keep.

What changed on September 29, 2026. Supported app versions can now send a small number of advertising-measurement events to Meta, but only if you tap Allow on Apple's App Tracking Transparency prompt and keep the new Share with ad partners switch on (Settings → Privacy, on by default). When both are true, Meta receives three events (app install/activation, first open, and free trial started) with your device's advertising identifier (IDFA) and basic device information, so we can see which of our ads bring people to MinervaOS. Meta never receives your health, food, body, weight, workout or account data, your name, or your email, and nothing is sent to Meta for an account we know belongs to someone under 18. Under California law this is "sharing" for cross-context behavioral advertising, so Section 13.4 no longer says we do not share, and the new Section 13.13 explains how to opt out. The new Section 2h describes it in full, and Sections 2c, 3, 7, 8, 9.1, 11, 12, 13, 14.1, 15.2 and 18 were updated to match. SKAdNetwork install measurement (September 19) is unchanged and needs no permission. We still do not sell your personal information, and we still do not show ads in the app.

What changed on September 19, 2026. Supported app versions register an install and first open with Apple’s SKAdNetwork so advertising networks can receive privacy-preserving install attribution. Apple controls matching, delays, and privacy thresholds. We do not attach your account, email, health data, advertising identifier, or purchase details to this registration. This does not track you across apps or introduce a third-party advertising SDK. (The separate, permission-based Meta measurement added on September 29, 2026 is described in Section 2h.)

What changed on September 15, 2026. We clarified automatic scale imports. Weight and available body-fat readings from Apple Health or a connected scale can update your profile and saved weight history; these saved records are synced and backed up with your account. Imported history is kept until you delete it or your account, even after the original cloud wearable record expires. Connecting a source does not publish those measurements to other people. Sections 2b, 9.1, 11 and 17 now describe this explicitly. No saved records or backups are removed by this clarification.

What changed on September 14, 2026. We added referrals. Section 2g describes the two records this creates: who referred you, and — only when somebody taps a referral link on an iPhone that does not yet have the app — a short-lived, one-way hash of the tapping device's IP address, so the code can be applied automatically after the App Store visit. The address itself is never stored, the record is deleted as soon as it is used and within 25 hours either way, and it is used for nothing else. Section 9.1 gives the retention period. Section 13.12 discloses the free month earned through referrals as a financial incentive, as California requires, and states that it is delivered as an App Store offer code redeemed with Apple. Nothing about selling or advertising changed: we still do neither.

What changed on August 17, 2026. Three corrections so this Policy matches the app. Section 2b now says exactly which Apple Health-derived figures can reach our servers: none of the raw samples, but a workout you import becomes a logged workout, and while Workouts (on by default), Burned, or Eaten is on under What followers see (or when you share a daily summary to a group or your feed) the day's step count and calorie-burn figures are stored so the people you allow to see your profile can see them. Section 6 now lists the five follower switches as they exist in the app. Section 2c now discloses the crash and performance diagnostics (Apple's MetricKit reports) the app sends us when it crashes or hangs, and corrects the microphone sentence: a video you record for a post or group chat is stored with its audio track. Nothing about selling or advertising changed: we still do neither.

What changed on August 8, 2026. Corrections so this Policy describes what the Service actually does. Section 2b now sets out what happens to data from the cloud wearable platforms you connect through our wearable-connection provider, Junction: those platforms deliver it to our servers, where it is stored for your account alone on a rolling 35-day window and deleted when you delete your account. Junction is named as a processor in Sections 7 and 13.3, and the list of platforms you can connect is brought up to date. Sections 6a and 7 now state that our first-pass moderation classifier (OpenAI) reads images and sampled video frames as well as text, so photos and video you publish to a social surface are transmitted to it. Our separate Consumer Health Data Privacy Policy was corrected the same way. Nothing about selling or advertising changed: we still do neither.

What changed on July 30, 2026. We added retention periods for each category of data (Section 9.1), a breach-notification commitment including the FTC Health Breach Notification Rule (Section 19), rights and an appeals route for U.S. states beyond California (Section 14), default protections for users under 18 (Section 15.2), and a fuller account of how AI is used and what we do not do with it (Section 4). Nothing about what we collect, or our commitment never to sell it, changed.

1. Who We Are

MinervaOS is a nutrition, fitness, and wellness tracking app for iPhone. The business responsible for your information (the "data controller") is Brizo Finance LLC, contactable at support@minervaos.app.

2. Information We Collect

a. Information you provide

b. Health and wearable data

c. Information collected automatically

d. Purchase information

If you buy a subscription, the purchase is processed by Apple. We receive your subscription/entitlement status from Apple; we do not receive your full payment-card details.

e. Information from third parties

If you sign in with Apple (or another provider we may offer), that provider gives us a token confirming your identity and, if you allow it, your name and email.

f. Early access waiting list (no account required)

If you fill in the sign-up form at minervaos.app/early, we collect the name, email address and Instagram handle you type, anything you write in the optional "what would you like to see" box, and the date and time you submitted it. This is the only information we collect from people who do not have an account, and it is collected on the website rather than in the app.

We use it for one purpose: to recognize you when you sign up in the app, so the free first month can be applied to the first 100 people who joined the list (Section 13.12). We match on the email address you give us here, and we do not send you a mailing list. We do not use it for advertising, we do not add it to any other profile, and we do not share or sell it. The list is stored in our backend provider's database (Supabase, Section 7) and is not readable by the app.

To be removed, email support@minervaos.app and we will delete your entry; there is no account to close and you do not need one. Asking to be removed does not require a reason. If you are in the EEA or UK, the legal basis is your consent, given by submitting the form, and you may withdraw it the same way (Section 8).

g. Referrals

Each account can generate a referral code and a link that contains it (minervaos.app/r/<code>). If you use somebody's code, we store the fact that your account was referred by theirs, when, and whether it came from a typed code or a link. Your friend can see how many people have used their code and how many of those count toward a free month; they are not shown who you are, what you log, or anything else about your account, and you are not shown anything about theirs beyond the username whose code you used. You can only be referred once, and only by someone who is not already referred by you.

Link taps on a device without the app. A tapped link cannot carry the code through a visit to the App Store, so we make the connection on our server instead. When a referral link is opened on an iPhone or iPad, the landing page sends us the code together with a one-way cryptographic hash of the IP address our server observed. We do not store the address itself, we do not store the browser's user agent, and we do not set a cookie or any other identifier on your device. When the app is then opened for the first time, it asks whether a link was tapped from the same network within the past 24 hours, and if exactly one code matches, that referral is applied; if two different codes match — which is what happens on a shared network such as a gym or a café — none is applied and the code has to be typed in by hand. The record is deleted as soon as it is used, and in any case within 25 hours (Section 9.1). It is used for this single purpose and never to identify you, to profile you, to build an audience, or for advertising.

Referral links open a web page on our own site. That page uses no attribution or ad-measurement provider, and nothing about a tap is shared with anyone outside the processors already named in Section 7; the advertising measurement in Section 2h plays no part in referrals. If you would rather not take part, simply do not use a code; nothing else about the app changes.

h. Advertising measurement

We advertise MinervaOS in other apps and on other websites, and we want to know which ads work. We do that in two ways. Neither one ever involves your health, food, body, weight or workout data, your Apple Health or wearable data, your photos or messages, or your name, email or account.

To stop it at any time, turn off Share with ad partners, or turn off tracking for MinervaOS in iOS Settings → Privacy & Security → Tracking. See Section 13.13.

i. Feedback you send us

Settings → Share feedback lets you tell us what you like and what we should fix or add. We store what you write, your account, the app version and the date. Only we read it, to decide what to build and fix; it is never posted, shown to other users, used for advertising, or sent to anyone outside the processors already named in Section 7. Please don't put health details you would rather keep to yourself in it. Sending feedback is optional, and it is never tied to a rating or review on the App Store.

3. How We Use Information

We use information to: provide, operate, and secure the Service and your account; generate your estimates, targets, and AI outputs (calorie/macro/micronutrient estimates, calorie-burn and metabolism calculations, food recognition, and suggestions); sync and back up the data you log; operate Group features you choose to use; deliver notifications and reminders you enable; look up products you scan by barcode; provide support; prevent fraud and abuse and enforce our Terms; comply with legal obligations; maintain and improve the Service; and measure which of our ads bring people to MinervaOS (Section 2h: Apple's SKAdNetwork for everyone, and Meta only with your permission). We do not use your health data, food photos, or personal content to serve advertisements, and we do not sell this information.

4. AI Processing and Third-Party AI Provider

4.1 What is sent, and to whom

To provide AI features, content you submit is transmitted through our backend to third-party AI providers, Anthropic (Anthropic PBC, USA) and Google (Google LLC, USA, via Vertex AI in the United States), through their APIs and processed to return a result to you. This includes: food/label photos and any description or correction you add; body-composition report images you upload (DEXA/InBody/smart-scale); text you send to the AI assistant (and recent conversation turns) together with that day's logged food and workout entries, which are sent with the message so the assistant can answer about your day; and the free-text workout and cardio descriptions you type into Quick Log. We instruct our AI provider to process this content only to return results to you and not to use it to train its models, consistent with its API terms. We do not retain your food-scan or report photos on our servers; a copy of a food-scan photo is kept on your device so you can review or edit the entry. If you prefer not to use AI photo analysis, you can enter foods manually instead.

Your name and email address are not included in what we send to these providers.

4.2 You are interacting with AI, not a person

Every AI feature in the Service (the assistant, food recognition, report parsing, and the suggestions and estimates they produce) is automated software, not a human being and not a licensed professional. We label AI features as such in the app. No AI output is reviewed by a clinician before you see it. This disclosure is made so that you are never misled into thinking you are communicating with a person, consistent with California Business & Professions Code §22601 et seq., California Health & Safety Code §1339.75 et seq., and Article 50 of the EU AI Act.

4.3 We do not train AI models on your data

We are a deployer of general-purpose AI models, not a developer of them. We do not build, train, fine-tune, or substantially modify generative AI models, and we do not use your content (food logs, photos, messages, health data, or group content) as training data for any model, ours or anyone else's. Because we do not develop or substantially modify a generative AI system, the training-data documentation duty in California AB 2013 falls on the model developers whose systems we call, not on us; their disclosures are published by those developers.

4.4 AI content provenance (California AI Transparency Act, SB 942)

California's AI Transparency Act imposes duties (a public AI-detection tool and provenance marking of AI-generated content) on "covered providers": generative AI systems with more than one million monthly users in California. MinervaOS is below that threshold and is not currently a covered provider. We do not generate synthetic images, audio, or video for publication; our AI outputs are numeric estimates and short text shown to you. If we cross that threshold or begin producing synthetic media, we will implement the required provenance disclosures and update this Policy before doing so.

4.5 Safety limits on AI outputs

Our AI assistant is a nutrition and fitness tracking tool. It is not a companion, a therapist, or a crisis service. It is instructed to refuse to provide extreme-restriction, purging, or other disordered-eating guidance, and to surface crisis resources rather than engage when a conversation indicates risk of self-harm or an eating disorder. You can reach those resources at any time in the app under Settings → Safety & Crisis Resources. If you are in immediate danger, contact your local emergency number; in the US you can call or text 988 (Suicide & Crisis Lifeline), and the National Alliance for Eating Disorders helpline is 1-866-662-1235.

5. Barcode Lookup

When you scan a product barcode, the barcode number is sent to Open Food Facts (a third-party open food database) to look up product and nutrition information. Only the barcode is sent for this lookup; no account information is included.

6. Group and Social Features

Social features are optional. Groups: the content you share to a group (posts, messages, photos you attach, comments, and reactions) is stored on our backend and is visible to the other members of that group. Follows and public profiles: your profile is private by default. If you make it public, your posts, display name, username, bio, and avatar are visible to any signed-in user, and anyone may follow you; if it stays private, followers you approve see only what your follower-visibility settings allow. Those settings (Profile → Privacy & sharing → What followers see) are five switches, each governing one line of your profile panel for today and the past week: Workouts (on by default, the sessions you logged, plus the day's step count and resting burn), Burned (the day's total burn), Eaten (calories and macros against your targets), Meals (the list of what you ate), and Weight trend (your actual weight chart and average over the last 30 days, including earlier readings, with progress photos as a separate switch). Personal records are shared by default and can be switched off. Everything other than Workouts and personal records is off until you turn it on. Your handle appears in user search unless you turn off discoverability in Settings. Group chat photo attachments are stored in a private storage area accessible to that group's members; your profile avatar is stored in a storage area readable by other signed-in users so they can display it, so avoid using a photo you wish to keep private. You can block users and report content; blocks and reports are stored to operate those features and for safety.

6a. Content Moderation

Because the Service carries user-generated content, we screen it. This is a condition of using the social features, and it is not optional for content you post.

What we screen. Everything you post or send through a social surface (group messages, posts and captions, comments, group names and descriptions, usernames and display names) passes the automated word/pattern check that runs on our own servers, and any of it can be reported and reviewed by us. The classifiers described below read the subset that is public or widely visible: posts and their captions, comments, usernames and display names, profile avatars, and the images and video uploaded to those surfaces. What you send inside an invite-only group (chat messages, the workouts and meals you share there, and the photos you attach) is a closed room between people who chose each other, so no classifier reads it; reporting, blocking, suspension and the word/pattern check all still apply. We do not apply any of this to your private food logs, weights, workouts, notes, Apple Health data, or connected-wearable records. Those are not published to anyone and are never sent to a moderation classifier.

How. In layers. First, an automated word/pattern check that runs on our own servers as content is written. Second, where it is enabled, a fast first-pass classifier operated by OpenAI (its moderation endpoint, which OpenAI states is not used to train its models). That pass reads text and images: the text you wrote, and (for a photo, an avatar, or a video) the image itself, sent to OpenAI as the picture, not as a description of it. When that pass is not enabled, the next layer does all of the work. Third, for nuanced cases and for all images and video, an automated classifier run by Anthropic (Claude). Content a classifier cannot assess, and any content another user reports, is queued for review by an authorized human reviewer on our team.

What that means for your data. The content itself (the text, the image, or sampled frames of the video) is transmitted to both of those providers for the sole purpose of classification: photos you post, photos attached to a public surface, your profile avatar, and frames sampled from a video you upload all leave our servers as images, not as descriptions of images. Photos sent inside a private group room are the exception described above, registered, but not read by a classifier unless someone reports them. The providers act as our processors under contracts limiting their use of the content. Uploaded images and video are held and not shown to anyone but you until they pass this check.

What we keep. The verdict (approved / rejected), the category, and a timestamp, attached to the content. Reports you file and reports filed about you, and any enforcement action taken on your account, are retained as described in Section 9. Where content is unlawful we retain what the law requires us to retain and report it to the appropriate authority; apparent child sexual abuse material is reported to the National Center for Missing & Exploited Children (NCMEC).

Your rights. If content of yours is removed or your account is restricted, you can appeal to support@minervaos.app (Terms, Section 9.4). Decisions are supported by human review, not made by automated processing alone where that would carry legal or similarly significant effects for you.

7. How We Share Information

Every third party we share your data with provides the same or equal protection of your data as is stated in this Privacy Policy. We share personal data with service providers acting on our behalf only under written contracts that (a) limit them to processing the data solely to perform the service we have engaged them for, (b) prohibit them from selling it, sharing it for cross-context behavioural advertising, retaining it beyond what the service requires, or using it for their own purposes including training their own models, and (c) require security and confidentiality protections at least equivalent to those described in this Policy. The one recipient that is not our service provider is Meta, which receives the limited advertising-measurement events described in Section 2h, only with your permission, under Meta's Business Tools Terms; those terms forbid us from sending Meta health or other sensitive information, and this Policy states exactly what Meta receives and what it may do with it. We do not permit any other third party (including any parent, subsidiary, affiliate, analytics tool, advertising network or third-party SDK) to receive your data on weaker terms than these.

We share information only as described here. We do not sell it. The only "sharing" for cross-context behavioral advertising, as California law defines it, is the Meta advertising-measurement events in Section 2h, which happen only with your permission and which you can stop at any time (Section 13.13):

8. Legal Bases (EEA/UK Users)

If you are in the EEA or UK, we process your personal data on these bases: performance of a contract (to provide the Service you request); consent (for health data, Apple Health/wearable access, AI photo processing, notifications, advertising measurement through Meta in Section 2h, and the early access waiting list in Section 2f, each withdrawable anytime); legitimate interests (to secure, maintain, and improve the Service, balanced against your rights); and legal obligation. Health data is "special category" data, processed based on your explicit consent.

9. Data Retention

We retain your information for as long as your account is active or as needed to provide the Service, and thereafter as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. When you delete your account (Section 12), we delete your account and associated personal data from our active systems; residual copies may persist for a limited period in backups and server logs before being overwritten. Content you shared into a Group may remain visible to that group in de-identified form after your account is deleted.

9.1 Retention period by category

As required by the CCPA, this is how long we keep each category, or the criteria we use to decide:

Safety and moderation records are an exception. Reports (filed by you or about you), moderation verdicts, and enforcement actions such as suspensions and bans are retained for up to two years after the account is closed, and longer where a legal obligation or an ongoing investigation requires it. We keep them because deleting them would let a banned user return by re-registering, and because they are the record that shows we acted on reports. They are kept separately from your account data and are not used for any other purpose.

10. Security

We use reasonable technical and organizational measures designed to protect your information, including encryption in transit, row-level access controls that scope your data to your account, secure Keychain storage for tokens on your device, and reputable infrastructure providers. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. Protect your credentials and notify us of any suspected unauthorized access.

11. Data Sent Off Your Device vs. Kept On It

For transparency: kept on your device (not on our servers): the raw Apple Health data streams, WHOOP data, app preferences, and a local copy of your food-scan photos. Sent to and stored on our servers: your account, profile (including health/body values you enter or import), food/workout logs (including workouts imported from Apple Health), weight history (including automatic scale weigh-ins from Apple Health or connected scales), the daily step count and calorie-burn figures you turn on for followers (Section 2b), group content, avatars, push tokens, crash and performance diagnostics (Section 2c), cloud wearable data from platforms you connect via Junction (Section 2b, 35-day window), Personalized Burn learning and recaps, your tracking-prompt answer and Share with ad partners setting (Section 2h), and a backup of your weight-log history, saved meals and workouts, and custom targets and exercises (see below). Sent for processing but not stored by us: food/report photos and AI-assistant text (to our AI provider) and barcodes (to Open Food Facts). Sent to a third party only with your permission, and not stored by us: install/activation, first-open and free-trial-started events with your advertising identifier and basic device information (to Meta, Section 2h).

Backup of your saved data. So you don't lose your information if you reinstall the app or switch to a new device, we back up your weight-log history, saved meals and workouts, and custom nutrition targets and exercises to our servers, associated with your account. This backup includes measurements you enter and automatic scale weigh-ins imported from Apple Health or connected scales, with available body-fat readings, dates and sources. Imported body measurements can also be saved in your synced profile. Raw Apple Health step, heart-rate and sleep streams are not included in this backup. It is accessible only to you, is never sold or shared, and is deleted when you delete your account (Section 12).

Personalized Burn progress. Your learned burn adjustment, learning status, calibration summaries and recap history are saved privately with your account so they survive signing out, reinstalling the app or changing phones. These are derived estimates, not raw Apple Health or WHOOP sample streams. They are not published to your profile or shared with other users. Signing out does not delete this progress; deleting your account removes it from our active systems under Section 12. A deliberate calibration reset restarts the saved learning.

12. Your Choices and Rights

Revoking consent does not affect processing already carried out before you revoked it.

13. Your California Privacy Rights

This section provides the disclosures required by the California Consumer Privacy Act, as amended by the CPRA ("CCPA"), and the California Online Privacy Protection Act ("CalOPPA"), and applies to California residents.

13.1 Categories of personal information we collect

In the past 12 months we have collected the following CCPA categories (with examples). We collect these from you, your device, and services you connect (Apple Health/wearables, Sign in with Apple):

13.2 Sensitive personal information (SPI)

We collect the following SPI: account log-in credentials (email with password) and health information (the body metrics, nutrition, and fitness data you provide and log). We use and disclose SPI only for purposes permitted under the CCPA, namely to provide the Service you request and as otherwise allowed without a right to limit (e.g. security, preventing fraud, and ensuring the Service works). We do not use SPI to infer characteristics about you for any purpose other than providing the Service. Because we do not use or disclose SPI beyond these permitted purposes, the CCPA "right to limit" does not change how we handle it.

13.3 Purposes, sources, and disclosures

We collect each category to provide, secure, personalize, and improve the Service, as described in Sections 3-7. Sources are described in 13.1. We disclose personal information for these business purposes to our service providers, our hosting/database/storage provider (Supabase); our AI provider (Anthropic); our first-pass moderation classifier provider (OpenAI), which receives the text, images and sampled video frames you publish to a social surface; our wearable-connection provider (Junction), which receives and delivers to us the data from the cloud wearable platforms you connect (Section 2b); our email provider (Resend), which carries moderation reports to our review team; Apple (sign-in, subscriptions, push, and the SKAdNetwork install registration in Section 2h); and Open Food Facts (barcode lookup), and to other group members for content you choose to share. Only if you allow tracking on Apple's prompt and leave Share with ad partners on, we share (as the CCPA defines that word) these categories with Meta, an advertising network, for advertising measurement (Section 2h): identifiers (advertising identifier, an SDK-generated app-installation identifier, and IP address), internet or other electronic network activity (the install/activation and first-open events, the length of the previous app session reported with the activation, and basic device information), and commercial information (that a free trial started). We share no sensitive personal information with Meta.

13.4 No sale; limited sharing, only with your permission

We do not sell your personal information, as that term is defined under the CCPA, and we have not done so in the preceding 12 months. We do share a limited set of personal information for cross-context behavioral advertising, as the CCPA defines "share": if you allow tracking on Apple's prompt and leave Share with ad partners on, the categories listed in Section 13.3 go to Meta for advertising measurement. We did not share personal information this way before September 29, 2026. We never sell or share sensitive personal information, including health information, and we do not sell or share the personal information of anyone we know to be under 18. You can opt out at any time (Section 13.13).

13.5 Your California rights

Subject to verification and legal exceptions, you have the right to: know/access the personal information we have collected about you; delete it; correct inaccurate information; opt out of the sharing described in Section 13.4 (Section 13.13; we do not sell); limit the use of sensitive personal information (we already restrict it to permitted purposes); and not be discriminated or retaliated against for exercising your rights.

13.6 How to exercise your rights

You can exercise most rights directly in the app (edit your data, or Settings → Account → Delete Account), or contact us at support@minervaos.app. We will verify your request using information associated with your account. You may use an authorized agent to submit a request on your behalf with proof of authorization. We will respond within the timeframes required by law. To opt out of sharing, see Section 13.13; an opt-out never requires you to verify your identity.

13.7 "Shine the Light"

California Civil Code §1798.83 lets California residents request information about disclosures of personal information to third parties for their direct marketing. We do not share personal information with third parties for their own direct marketing.

13.8 Do Not Track

Some browsers offer a "Do Not Track" (DNT) signal. Our website does not track visitors across other sites and lets no third party do so, so it does not respond differently to DNT. In the app, the tracking described in Section 2h happens only if you allow it on Apple's App Tracking Transparency prompt, the iPhone's own control for this, and you can refuse it or withdraw it at any time (Section 13.13).

13.9 Opt-out preference signals (Global Privacy Control)

Some browsers and extensions send an opt-out preference signal such as Global Privacy Control (GPC). We treat any GPC signal we receive on minervaos.app as a valid request to opt out of sale and sharing, and we honor it. Our website sets no advertising or analytics cookies and contains no third-party trackers, so nothing about your visit is sold or shared in the first place. The sharing described in Section 13.4 happens only in the app, which a browser signal cannot reach; to stop it, use the in-app switch or the iOS setting in Section 13.13, or email us and we will turn it off for your account.

13.10 Notice at Collection

The disclosures in this Section 13, together with Sections 2, 3, 7 and 9, are our notice at collection. You see a short-form version of it in the app before you provide any health information, on the "Before you start" screen at first launch, which identifies the categories we collect (including the sensitive categories in 13.2), the purposes, that we do not sell your information and share it for advertising measurement only if you allow tracking, and the retention periods in Section 9.1, and links to this full Policy. You can reopen it at any time from Settings → Privacy.

13.11 Retention

We disclose the retention period for each category of personal information, including sensitive personal information, in Section 9.1. We do not keep personal information for longer than is reasonably necessary for the purpose for which it was collected.

13.12 Financial incentives

We do not offer any financial incentive, price difference, or service-level difference in exchange for the retention, sale, or sharing of your personal information, and we do not sell it. The limited sharing in Section 13.4 is never tied to a price, discount, free month or feature: turning it off changes nothing about the Service.

We do run one launch offer, and we describe it here so it is disclosed rather than implied. The first 100 people to submit the early access form at minervaos.app/early (Section 2f) receive their first month of MinervaOS free, a value of $9.99, which is the ordinary price of one month. To take part you give us a name, an email address and an Instagram handle. Taking part is entirely optional; the app is available to everyone on the same terms whether or not you joined the list, and declining costs you nothing but the free month itself. The offer is reasonably related to the value of that information to us, which is the ability to match a sign-up in the app to a place on the list. The free month is applied inside the app when you create an account with the same email address, and we do not email you to deliver it. You may withdraw at any time by emailing support@minervaos.app, which deletes your entry and ends your participation; if you withdraw before you have claimed it, you give up the free month.

We also run a referral programme, disclosed here for the same reason. When three people you referred have each moved from their free trial onto a paid subscription, you receive one month of MinervaOS free, a value of $9.99, which is the ordinary price of one month. Each further three earns another month, up to a maximum of twelve. To take part you share a code tied to your account, and the person who uses it gives us the fact that they were referred by you (Section 2g). Taking part is entirely optional; the app is available to everyone on the same terms whether or not you refer anyone or use a code, and declining costs you nothing but the free months themselves. The offer is reasonably related to the value of that information to us, which is a new subscriber we did not have to pay to reach — a free month is granted only once the person you referred is actually paying, so the incentive is funded by the subscription it produced. A free month is delivered as an App Store offer code issued by Apple: the app shows you the code, you redeem it in the App Store, and Apple adds the month to your subscription. We do not pay cash, we do not email anything to deliver it, and the code is tied to your account so it cannot be passed on. You may stop at any time simply by not sharing your code.

13.13 Your Right to Opt-Out of Sharing

You have the right to tell us not to share your personal information for cross-context behavioral advertising. In MinervaOS the only such sharing is the Meta advertising-measurement events in Section 2h, and nothing is sent unless you tapped Allow on Apple's tracking prompt. You can opt out in any of these ways, and each one works on its own:

Our website shares nothing, so there is nothing for a Global Privacy Control signal to stop there (Section 13.9); a browser signal cannot reach the app, so to stop the app's sharing use one of the ways above.

An opt-out never requires you to verify your identity or give a reason, an authorized agent may submit one for you, and we act on it as soon as we can and in any case within 15 business days. Opting out stops future sharing; it cannot recall events Meta has already received, which Meta holds under its own policy. Opting out costs you nothing: the app works exactly the same, and we will not ask you to opt back in for at least 12 months.

14. Other U.S. State Privacy Rights

If you live in a U.S. state with a comprehensive consumer privacy law (currently including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky and Rhode Island, as those laws come into force) this section describes rights you have in addition to anything above. Where your state's law gives you more than we describe, your state's law wins.

14.1 Your rights

Subject to verification and the exceptions each statute allows, you may:

14.2 Sensitive data requires your consent

Most of these laws treat health data as sensitive, and require opt-in consent before it is processed. Your consent is the affirmative agreement you give on the "Before you start" screen at first launch, and separately at the iOS permission prompt before we read anything from Apple Health or a connected wearable. You can withdraw it at any time by revoking the permission in iOS Settings or deleting your account, and withdrawal is as easy as giving it.

14.3 How to exercise them

Use the in-app controls (Settings → Account → Delete Account, or edit your data directly), or email support@minervaos.app. We will verify the request against the email on your account. We respond within 45 days, extendable once where the law allows, and we will tell you if we need the extension.

You may use an authorized agent. We will ask for proof that you gave them permission.

14.4 Appeals

If we refuse your request, you can appeal. Reply to our decision, or email support@minervaos.app with "APPEAL" in the subject line. A person who was not involved in the original decision will review it, and we will respond in writing within 45 days (60 in some states), explaining the reasoning either way.

If we deny the appeal, you may complain to your state's Attorney General. We will tell you how to do that in the appeal response, because several of these laws require us to.

14.5 No discrimination

We will not deny you the Service, charge you a different price, or give you a worse experience because you exercised any of these rights.

15. Children and Teens

15.1 Under 13

The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13. The date-of-birth control in the app does not accept a date that would make you younger than 13, and you must confirm you are at least 13 to pass the first-run gate. If you believe a child under 13 has provided us personal information, contact support@minervaos.app and we will delete the account and its data promptly, without requiring you to create an account to make the request. We do not condition any part of the Service on a child disclosing more information than is reasonably necessary.

15.2 Teens 13-17

Users between 13 and 17 may use the Service, and where the age of majority or digital-consent age in their jurisdiction is higher, only with the involvement and consent of a parent or guardian. For any account whose date of birth indicates the user is under 18, we apply the following by default, without the teen or their parent having to find a setting:

Parents and guardians may contact support@minervaos.app to review, correct, or delete a teen's information, or to close the account.

15.3 Why this app may not be right for a minor

Calorie and weight tracking is not appropriate for everyone, and can be actively harmful for a young person with, or at risk of, disordered eating. We say so in the app and in our Terms, and we encourage parents to make that judgement with their child and a professional.

16. International Data Transfers

We and our service providers may process and store your information in the United States and other countries whose data-protection laws may differ from yours. Where required, we use appropriate safeguards for international transfers. By using the Service, you understand your information may be transferred to and processed in these countries.

17. Apple Health Data: Specific Commitments

Consistent with Apple's requirements: we will not use Apple Health (HealthKit) data for advertising or marketing; we will not sell it or share it with third parties for advertising, marketing, data-mining, or similar purposes; we will not disclose it to third parties without your authorization except as needed to provide a health service you requested; and we use it only to provide health, fitness, and wellness features within the Service. As noted in Section 2b, raw Apple Health step, heart-rate and sleep streams are processed on your device and are not transmitted to our servers. Imported workouts, automatic scale weigh-ins and body measurements saved to your profile or history are stored with your account and its backup. Daily step and calorie-burn figures are stored when you enable sharing. These saved records are disclosed to other users only with your authorization; you can turn sharing off at any time.

17a. California Confidentiality of Medical Information Act

To the extent any information you store in MinervaOS (such as lab values, thyroid or blood-panel results, or body-composition reports you enter or import) constitutes "medical information" under the California Confidentiality of Medical Information Act (California Civil Code §56 et seq.), we maintain it in a manner that preserves its confidentiality, do not disclose it except as authorized by you or as permitted by that Act, and apply the same protections to it as to all your health data under this Policy. We do not use it for advertising or marketing and we do not sell it.

18. Third-Party Services

The Service integrates with and links to third-party services (Apple, our infrastructure/AI providers, wearable platforms, Open Food Facts, and, only with your permission, Meta for advertising measurement under Section 2h). Their handling of your information is governed by their own privacy policies, which we encourage you to review. We are not responsible for third parties' practices.

19. Security Incidents and Breach Notification

If your personal information is acquired by, or disclosed to, an unauthorized person, we will notify you and the relevant regulators as required by law.

Report a suspected vulnerability or unauthorized access to support@minervaos.app. We do not pursue legal action against good-faith security researchers who report privately and give us a reasonable time to fix an issue.

20. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice (for example, in-app or by updating the "Last updated" date) and, where required, obtain your consent. Your continued use of the Service after an update takes effect constitutes acceptance of the updated Policy.

21. Contact Us

Questions or requests regarding this Privacy Policy or your data: support@minervaos.app

Brizo Finance LLC, operator of MinervaOS. Because we operate exclusively online and have a direct relationship with you, email is our designated method for submitting privacy requests, as the CCPA permits. We respond to verifiable requests within 45 days, extendable once by a further 45 days where the law allows, and we will tell you if we need the extension.