Consumer Health Data Privacy Policy
Wolvec L.L.C., a Wyoming limited liability company
Effective Date: · Last Updated:
1. Introduction
This Consumer Health Data Privacy Policy describes how Wolvec L.L.C. ("Wolvec," "Company," "we," "us," or "our") collects, uses, shares, protects, and retains consumer health data.
This Consumer Health Data Privacy Policy applies to individuals who interact with Wolvec in circumstances where Wolvec collects consumer health data, including prospective Clients who apply through a public Coach page and Clients of fitness coaches who use Wolvec. It supplements Wolvec's general Privacy Policy, which governs all other personal information we collect.
This Policy is intended to address consumer-health-data obligations under laws that may apply to Wolvec's fitness and wellness technology platform, including the Washington My Health My Data Act, Nevada consumer health data law, the Connecticut Data Privacy Act, and California health privacy laws where applicable.
Wolvec is a fitness and wellness technology platform. Wolvec is not a medical provider, health plan, healthcare clearinghouse, physical therapy provider, mental health provider, or dietetics provider. Nothing in this Policy or on the Wolvec platform constitutes medical advice, diagnosis, treatment, physical therapy, mental health counseling, or emergency support.
Contact: privacy@wolvec.ai
2. What We Mean by Consumer Health Data
For purposes of this Policy, "consumer health data" means personal information that is linked or reasonably linkable to an individual and that identifies or may reasonably indicate the individual's past, present, or future physical or mental health status, where such information is covered by applicable consumer health data law.
Depending on the context and applicable law, consumer health data may include information a client provides directly, information a coach provides about a client, information generated through the client's use of the Wolvec platform, and health-related inferences or safety flags generated from that information.
Under applicable law, consumer health data does not include information that qualifies as deidentified data, publicly available information, or other information excluded from coverage.
3. Categories of Consumer Health Data We Collect
Wolvec may collect the following categories of consumer health data.
3.1 Pre-Participation Health Screening Data
Before using AI-assisted coaching features, clients may be required to complete a pre-participation health screening based on the Physical Activity Readiness Questionnaire for Everyone, commonly known as PAR-Q+.
This may include responses about:
- Exercise readiness
- Known physical limitations
- Cardiovascular, metabolic, renal, or other health conditions relevant to exercise readiness
- Symptoms such as chest pain, dizziness, fainting, shortness of breath, or similar concerns
- Prior injury or illness history relevant to training
- Whether the client has been advised to obtain medical clearance before physical activity
Purpose: Wolvec uses this information for safety screening, coach review, and to help ensure that AI-assisted coaching features are not unlocked until the required screening and coach acknowledgment steps are complete.
3.2 Injury, Illness, Pain, and Safety Disclosures
Clients may voluntarily disclose injury, illness, pain, dizziness, symptoms, medication changes, medical appointments, or other health-related information during check-ins, chat interactions, onboarding, or other coaching interactions.
Purpose: Wolvec uses covered physical-symptom information to apply limited safety controls that may pause AI-assisted coaching, create a safety workflow record, or flag an issue for the assigned Coach. Other health-related information disclosed during coaching interactions may be stored and processed as part of the coaching service as described in this Policy.
3.3 Fitness, Training, and Wellness Data
Wolvec may collect fitness and wellness information, including:
- Fitness goals
- Training history
- Workout logs
- Exercises performed
- Sets, repetitions, weight, duration, distance, or other training metrics
- Rate of perceived exertion
- Program completion records
- Soreness, energy, mood, sleep quality, or similar self-reported wellness indicators
Purpose: Wolvec uses this information to support fitness coaching, program personalization, coach review, check-in summaries, and AI-assisted coaching features.
3.4 Coaching Conversations and Check-In Responses
Wolvec may collect coaching chat messages, check-in responses, and related conversation history. These interactions may include consumer health data if the client discusses physical symptoms, injury, illness, readiness to train, recovery, wellness, or other health-related topics.
Purpose: Wolvec uses this information to operate AI-assisted coaching, support Coach review and Client communication, and apply limited physical-safety controls where applicable.
3.5 Health Screening Status and Safety Workflow Records
Wolvec may record safety workflow information, including:
- Whether the client completed health screening
- Whether the coach reviewed or acknowledged the health screening
- Whether the AI-assisted coaching feature is locked or unlocked
- Whether a safety escalation was triggered
- Whether coach follow-up or review is required
Purpose: Wolvec uses this information to enforce safety gates, document safety workflow completion, and support legal, audit, compliance, and platform-safety records.
3.6 Age Eligibility Information
Wolvec is intended only for users who are at least 18 years old. Wolvec may collect an 18+ attestation, age-confirmation status, or related account information used to enforce age eligibility.
Purpose: Wolvec uses this information to prevent underage access to AI-assisted coaching features.
3.7 Health-Related Inferences and Safety Flags
Wolvec may generate limited safety flags from Client-provided information. For example, Wolvec may identify certain reports of pain, injury, illness, dizziness, chest or breathing symptoms, or other physical distress for purposes of applying the Platform's limited safety controls.
Wolvec does not use these flags to diagnose, treat, or provide medical advice, and the safety controls may not identify every health or safety concern.
3.8 Prospective Client Application Information
Prospective Client Application Information. Where applicable law treats information identifying an individual as seeking fitness or health-related services as consumer health data, Wolvec treats covered information submitted through a prospective Client application accordingly.
4. Sources of Consumer Health Data
Wolvec collects consumer health data from the following sources:
- Directly from clients during onboarding, health screening, check-ins, chat interactions, and platform use
- From assigned coaches when they provide client context, program information, training limitations, or coaching notes
- From client activity within the Wolvec platform, such as workout completion and check-in history
- From Wolvec's internal systems when generating safety flags, coaching summaries, or workflow status records
- From service providers that process information on Wolvec's behalf to operate the platform
- directly from a prospective Client when the application is submitted; and
- from the selected Coach when the Coach approves or declines the application.
Wolvec does not collect consumer health data from data brokers and does not purchase consumer health data from third parties.
5. Purposes for Collecting and Using Consumer Health Data
Wolvec collects and uses consumer health data for the following purposes:
- Providing and operating AI-assisted fitness coaching features
- Supporting the relationship between clients and their assigned coach
- Completing pre-participation health screening and safety gating
- Enabling coach review of health screening, check-ins, and safety flags
- Generating AI-assisted program recommendations, check-in summaries, and coaching support
- Personalizing fitness programs, habits, and accountability support
- Applying limited safety controls to certain reports of pain, injury, illness, dizziness, chest or breathing symptoms, and other physical distress
- Preventing AI-assisted coaching from continuing when a safety escalation requires human coach review
- Maintaining platform reliability, security, auditability, and compliance
- Responding to user requests, legal requests, security incidents, unauthorized disclosures, or regulatory obligations
- To receive and administer prospective Client applications, including making application information available to the selected Coach for review and recording the Coach's approval or decline.
Wolvec does not use consumer health data for targeted advertising, marketing profiling, sale to data brokers, or unrelated third-party marketing.
6. How We Share Consumer Health Data
Wolvec may share consumer health data only as described in this Policy, the general Privacy Policy, and the Client Consent.
6.1 Selected or Assigned Coach
For a prospective Client, Wolvec may disclose the application information to the Coach the individual selected so that Coach can review and approve or decline the application. Once someone becomes a Client, the existing Client-stage disclosures apply.
Wolvec may make a client's consumer health data available to the client's assigned coach. This may include health-screening responses, check-ins, conversations, injury or illness disclosures, safety flags, workout logs, and related coaching context.
Purpose: Coaching, safety review, program personalization, client follow-up, and coach oversight.
6.2 AI Model Provider
Wolvec may share client health-related coaching content with Anthropic for AI text generation, reasoning, check-in analysis, chat responses, and AI-assisted coaching functionality.
Purpose: Operating the AI-assisted coaching features requested by the client and coach.
6.3 Hosting, Database, Infrastructure, and Security Providers
Wolvec uses infrastructure providers to host, secure, transmit, and store platform data. These may include database, hosting, cloud infrastructure, edge security, and platform operations providers.
Purpose: Platform hosting, storage, security, reliability, data transmission, and platform operations.
6.4 Error Monitoring and Diagnostics
Wolvec uses error monitoring and diagnostic tools to maintain platform reliability and security. Wolvec configures its systems to exclude message bodies, health-screening responses, health content, session cookies, IP addresses, and other personal information from error-monitoring transmissions where reasonably feasible. Error-monitoring providers may process technical metadata needed for debugging, reliability, and security.
Purpose: Debugging, reliability, security, and incident response.
6.5 Other Service Providers
Wolvec may use other service providers for email delivery, support, bug triage, security, and platform operations. These providers may process personal information as described in the general Privacy Policy. Wolvec does not authorize these providers to use consumer health data for unrelated purposes.
7. Current Named Service Providers
As of the Last Updated date, Wolvec uses the following providers in connection with platform operation:
- Anthropic: AI text generation, reasoning, check-in analysis, chat responses, and AI-assisted coaching functionality involving client coaching content
- Neon: database storage and managed PostgreSQL infrastructure
- Vercel: hosting and platform operations
- Cloudflare: edge security, DDoS protection, and web application firewall services
- Sentry: error monitoring and performance diagnostics, configured to exclude health content and other personal information where reasonably feasible
- Resend: email delivery for account and agreement communications
- Notion: internal support, bug triage, and product-support workflows where applicable
- OpenAI: Voice transcription and text embeddings. When a Coach or a Client records voice input in the Platform, Wolvec transmits that audio recording to OpenAI for transcription and stores only the returned text. Client voice input can contain consumer health data, and OpenAI therefore does receive client consumer health data when a Client uses voice input. Wolvec also transmits Coach onboarding and methodology content to OpenAI to generate text embeddings, which Wolvec stores and does not currently use to generate coaching responses.
8. What Wolvec Does Not Do
Wolvec does not:
- Sell consumer health data
- Share consumer health data for targeted advertising
- Disclose consumer health data to data brokers
- Disclose consumer health data to employers
- Disclose consumer health data to insurance companies
- Use consumer health data for unrelated advertising, retargeting, or marketing profiling
- Use geofencing around healthcare facilities to identify, track, collect data from, or send advertising or notifications to consumers related to healthcare services
- Use individual client conversations to train a generally available AI model
9. Consent and Other Permitted Processing
Where Wolvec relies on consent to collect or share consumer health data, Wolvec obtains affirmative consent before the applicable processing and provides the disclosures required by applicable law.
Wolvec may also collect or share consumer health data to the extent necessary to provide a product or service the consumer requested or as otherwise permitted by applicable law.
Where applicable law requires consent to sharing to be separate and distinct from consent to collection, Wolvec will obtain separate consent if consent is the basis for that sharing.
A consumer may withdraw consent prospectively by contacting privacy@wolvec.ai. Withdrawal affects two categories of processing differently, and this Policy states each separately.
Processing that Wolvec carries out because the consumer consented to it, and that is not necessary to provide a service the consumer continues to request, stops when consent is withdrawn. Wolvec ceases that collection, use, or sharing going forward.
Processing that is necessary to provide a product or service the consumer has requested, or that applicable law otherwise permits without consent, continues after withdrawal for as long as the consumer continues to request that service.
Wolvec's safety controls are part of how the coaching service itself operates. They are not an optional feature a consumer consents to separately, and Wolvec does not switch them off in response to a withdrawal request. If withdrawing consent would leave a service unable to operate lawfully or as designed, Wolvec's response is to stop providing that service to the consumer. Wolvec does not continue providing a service without its safety controls.
Withdrawal does not affect processing that occurred before withdrawal.
10. Retention and Deletion
We retain consumer health data for as long as reasonably necessary for the purposes described in this Policy, including administering prospective Client applications and, where applicable, supporting a Client's relationship with Wolvec and the applicable Coach, subject to the specific retention periods and deletion rights described below.
Retention depends on the category of information, the Client's relationship with Wolvec and the assigned Coach, safety and security needs, and applicable legal requirements.
When Wolvec receives a valid deletion request, Wolvec deletes covered consumer health data and notifies applicable recipients as required by applicable law. Data stored in archived or backup systems may be deleted on a different schedule where applicable law permits additional time.
Wolvec may retain limited information where permitted by applicable law for purposes such as security, fraud prevention, system integrity, dispute resolution, legal holds, regulatory compliance, or enforcement of legal rights.
Agreement and consent evidence may be retained to document what was presented and accepted, but only to the extent permitted by applicable law. Wolvec does not apply a blanket seven-year retention period to records that themselves constitute consumer health data.
Information retained solely for legal, security, compliance, or dispute purposes is not used for marketing or ordinary product personalization.
11. Consumer Health Data Rights
Depending on where you live, where your consumer health data is collected, and the law that applies, you may have rights relating to consumer health data, including the right to:
- Confirm whether Wolvec collects, shares, or sells consumer health data about you;
- Access consumer health data;
- Request deletion;
- Request correction where applicable law provides that right;
- Withdraw consent to future collection or sharing where applicable;
- Obtain information about third parties or affiliates that received consumer health data where applicable; and
- Appeal certain denials of a rights request where applicable.
Wolvec will honor consumer health data rights to the extent required by applicable law.
12. How to Exercise Your Rights
To exercise your consumer health data rights, contact:
Use the subject line: Consumer Health Data Request
Please include:
- Your full name
- The email address associated with your account or application
- The specific right you are exercising
- Any information reasonably necessary for Wolvec to verify your identity and locate your account
Wolvec will respond to authenticated or verified requests within the timeframe required by applicable law. Wolvec may request additional information reasonably necessary to authenticate or verify a request. Where applicable law permits an extension, Wolvec may extend the response period and will provide any notice required by that law.
If Wolvec cannot verify your identity using commercially reasonable efforts, Wolvec may request additional information reasonably necessary to authenticate the request.
Wolvec will not discriminate against you for exercising your consumer health data rights.
13. Washington State Residents
If you are a Washington State resident or your consumer health data is collected in Washington, your consumer health data may be protected by the Washington My Health My Data Act.
This Policy is intended to serve as Wolvec's consumer health data privacy policy for Washington purposes.
Categories of consumer health data collected: the categories listed in Section 3.
Sources of consumer health data: the sources listed in Section 4.
Purposes for collection and use: the purposes listed in Section 5.
Categories of consumer health data shared: health-screening responses, injury or illness disclosures, coaching conversations, workout and wellness data, safety flags, related coaching context, and prospective Client application information shared with the selected Coach for application review, where necessary to provide the Wolvec platform.
Third parties and affiliates with whom consumer health data may be shared: the assigned coach and the service providers described in Sections 6 and 7. Wolvec does not currently share consumer health data with affiliates.
Washington rights: If the Washington My Health My Data Act applies to you, you may request confirmation of whether Wolvec collects, shares, or sells consumer health data about you; access covered consumer health data and applicable recipient information; withdraw consent to future collection or sharing where consent applies; request deletion; and appeal a refusal to act on a request.
Appeals: If Wolvec denies your request, you may appeal by contacting privacy@wolvec.ai with the subject line "MHMDA Appeal." Wolvec will respond to appeals within the timeframe required by Washington law.
No sale or advertising: Wolvec does not sell consumer health data and does not share consumer health data for targeted advertising.
Geofencing: Wolvec does not use geofencing around healthcare facilities to identify or track consumers seeking healthcare services, collect consumer health data from consumers, or send health-related advertising or notifications.
14. Nevada Residents
Nevada rights: If Nevada consumer health data law applies to you, you may request confirmation of whether Wolvec collects, shares, or sells consumer health data about you; obtain the applicable third-party recipient list; request that Wolvec cease covered collection, sharing, or sale; request deletion; and appeal a refusal to act on a request.
Wolvec does not sell consumer health data and does not share consumer health data for advertising or marketing purposes.
15. California Residents
California privacy or health-information laws may provide additional rights depending on Wolvec's activities and whether the applicable law covers the information at issue.
Wolvec does not sell consumer health data or disclose it for unrelated advertising or marketing purposes.
Wolvec will honor applicable California privacy rights to the extent required by law. Requests may be submitted to privacy@wolvec.ai.
16. Connecticut Residents
Where the Connecticut Data Privacy Act applies, consumer health data may constitute sensitive data requiring consent before processing.
Wolvec provides an effective mechanism to revoke consent where required. Consent-based processing will cease as soon as practicable and, where Connecticut law applies, no later than 15 days after receipt of the revocation request.
Withdrawal does not affect processing that lawfully occurred before the withdrawal.
Connecticut consumers may exercise applicable rights or submit an appeal through privacy@wolvec.ai.
17. Security
Wolvec uses administrative, technical, and organizational safeguards designed to protect consumer health data. These safeguards include encryption in transit, encryption at rest, access controls, authentication requirements, error-monitoring safeguards, vendor controls, incident response procedures, and internal access restrictions.
No system can be guaranteed perfectly secure, but Wolvec works to protect consumer health data in a manner appropriate to the nature and sensitivity of the data.
18. Changes to This Policy
Wolvec may update this Policy from time to time. Material changes will be communicated by posting the updated Policy on Wolvec's website and, where required by law, by direct notice or in-platform notice.
Wolvec will not collect, use, or share additional categories of consumer health data, or use consumer health data for additional purposes, without first providing notice and obtaining consent where required by applicable law.
19. Contact Us
For questions about this Policy or to exercise your consumer health data rights, contact:
Wolvec L.L.C.
Email: privacy@wolvec.ai
Please include your full name, the email address associated with your Wolvec account, and the right you are exercising.