Spur Consumer Health Data Privacy Policy

Last updated: August 3, 2026

This policy supplements the Spur Privacy Policy and describes how Shotz App LLC, doing business as Spur, handles “consumer health data” under laws such as Washington’s My Health My Data Act. It applies even when that information is not protected by HIPAA. Spur is not a healthcare provider and does not provide medical or mental-health advice.

Depending on what you choose to enter, consumer health data may include health or wellness goals; exercise and movement routines; available energy; accessibility or physical constraints; symptoms, injuries, conditions, medications, treatment information, mental-health or crisis-related statements; and inferences that could identify your health status. Please do not enter clinical details that Spur does not need.

We collect this data directly from you through onboarding, goal setup, check-ins, settings, support messages, and other text you submit. We may derive limited inferences from those entries to select or size an action. We do not collect precise location, camera evidence, medical records, or connected financial-account data as part of current app functionality.

We use consumer health data only as reasonably necessary to provide requested planning and action features, save your choices, maintain safety boundaries, respond to support or privacy requests, secure the Service, and comply with law. Safety screening may stop a normal recommendation when text indicates urgent risk or a request outside Spur’s boundaries.

We may share consumer health data with Supabase, our hosting, authentication, database, and backend processor, to store and operate the Service.

If—and only if—you separately enable AI personalization, we may send consumer health data to OpenAI when it appears in the fields used to generate a synthesis, goal, or next action. Those fields include your direction, goal, milestone, success signal, goal category and phase; life stage, change mode, current situation or progress, blocker, normal capacity, aspiration, and boundaries; current time, energy, focus, resources, and context; and recent action titles, types, targets, outputs, completed-output labels, and outcomes. OpenAI is the category of recipient “AI processing provider,” and it receives this information only to generate the requested personalized output.

OpenAI states that API data is not used to train its models by default. Spur disables application-state storage on these requests, but standard OpenAI abuse-monitoring logs may retain prompts, responses, and related metadata for up to 30 days unless Spur's OpenAI project has an approved stricter retention control, and longer where required by law or reasonably necessary to prevent harm.

You may decline AI sharing or later withdraw consent in Review; deterministic features remain available. Withdrawal stops future OpenAI requests but cannot recall a request already transmitted or content retained under OpenAI's applicable retention rules.

RevenueCat may be contacted before a purchase to provide subscription offerings and entitlement status. It may receive an SDK-generated anonymous identifier and, after sign-in, your Supabase account identifier, along with device, app, network, diagnostic, offering, subscription, and transaction information. Spur does not deliberately send Apple or RevenueCat the goals, reflections, health-related text, or other consumer health data you enter in Spur.

We do not sell consumer health data. We do not share it for cross-context behavioral advertising. We have no affiliates with access to consumer health data. If this changes, we will update this policy and obtain consent where required.

The optional Meta Pixel used on general public marketing pages does not run on this Consumer Health Data Privacy Policy page and is not configured to receive Spur goals, reflections, form entries, app activity, or consumer health data.

The mobile app offers separate optional advertising measurement through Meta. If you enable it and also authorize tracking through iOS, Spur may send only limited device identifiers and coarse install, registration, onboarding, paywall, checkout, trial, subscription, renewal, and purchase events for advertising attribution. RevenueCat may send verified subscription lifecycle and revenue events to Meta. Spur contractually and technically scopes this integration so it does not receive goals, reflections, check-in answers, health or fitness information, symptoms, constraints, recommendations, AI prompts, or other consumer health data. Advertising consent is not required to use Spur and can be withdrawn in the app and iOS Settings.

You may:

• Access or obtain a copy of consumer health data associated with you.
• Correct inaccurate data, including through available goal-editing controls.
• Delete your account and active Spur product data in the app.
• Withdraw optional AI-sharing consent in Review; withdrawal applies to future sharing.
• Withdraw optional mobile advertising measurement in the Privacy center and change Apple's tracking permission in iOS Settings; withdrawal applies to future sharing.
• Appeal a refusal of a privacy request.

To exercise access, correction, deletion, withdrawal, or appeal rights, use the app’s Privacy center or email simon@shotzapp.app with “Privacy request” in the subject. We will verify your identity and respond without undue delay, generally within 45 days. If reasonably necessary, we may extend once by up to 45 additional days and will explain the extension. Appeals will be reviewed by a person not responsible for the original decision where practicable. If an appeal is denied, Washington residents may contact the Washington State Attorney General.

In-app account deletion removes the authentication account and active Spur product records from our primary systems. We will instruct processors to delete consumer health data where required and technically applicable. Limited legal-acceptance, security, fraud-prevention, subscription, transaction, or backup records may remain where required or permitted by law; backups are isolated from ordinary use and expire under our retention process. De-identified information may be retained only where it cannot reasonably be linked back to you.

We use role-based access, row-level database controls, encrypted transport, server-only credentials for authoritative writes, data minimization, and deletion procedures designed to protect consumer health data. Access is limited to people and processors who need it for authorized purposes. No system is completely secure.

We will post material changes and obtain consent when required before collecting or sharing consumer health data for a materially different purpose.

Shotz App LLC 1040 Spring Street, Apt D Madison, WI 53715 United States Email: simon@shotzapp.app