Gratelle Consumer Health Data Privacy Policy
Last updated: October 12, 2026 Effective date: October 12, 2026
This policy supplements our Privacy Policy. It applies to "consumer health data" as defined by:
- Washington's My Health My Data Act;
- Nevada's NRS 603A (SB 370);
- Connecticut's data privacy law;
and similar state laws. Gratelle is operated by Ownday Solutions Inc, 184 Aces High Ln, Davenport, FL 33896, USA — gratelleapp@gmail.com.
Gratelle is an attention and self-reflection tool, not a medical service. Even so, some of your responses may reveal information about your mental or emotional health. That is why we treat them as consumer health data.
1. Health data we collect and why
| Category | Examples | Purpose |
|---|---|---|
| Reflections and responses | Check-in responses about attention and distraction, written reflections, morning intentions, thinking traps identified | Show them in your Journal and provide the experience |
| Well-being assessments | Gratelle Awareness Index (GAI) responses and scores on presence, emotional reactivity and self-regulation; pilot surveys | Show your progress and evaluate the pilot |
| Progress and activity | Check-ins completed, active days, streaks | Show your progress and, if you allow it, share it with your coach |
| Reason for leaving | Optional reason given when deleting your account, if it reveals something about your well-being | Understand why people leave |
Optional use to improve content: only if you authorize it separately, an authorized administrator may review your reflections and open-ended responses, labeled with a pseudonymous code instead of your name or email. The goal is to improve the wording of our questions and micro-actions.
What we do not do:
- We do not use this data for advertising, commercial profiling, diagnosis or AI model training.
- We do not use geofencing.
2. Where we get this data
- From you: what you write or answer in the app.
- From the app: what it calculates from your use (scores and progress).
We do not buy health data from third parties.
3. Who we share health data with
| Recipient | What data | Condition |
|---|---|---|
| Your coach (if you signed up through one) | Activity only: check-ins completed, active days, streaks. Never reflections, open-ended responses or GAI scores | Only with your separate consent, revocable in Settings |
| Hosting and operations providers (Lovable Cloud and its infrastructure providers, Cloudflare) | The data needed to host and run the app | They act on our behalf, under our instructions |
| Authorities | Only what is strictly necessary | Only under a valid legal obligation |
We have no affiliates with which we share health data.
We do not sell consumer health data. Stripe processes payments but does not receive your reflections, responses or scores.
4. Your consents
We ask for separate consents, with boxes unchecked by default and independent of accepting the Terms of Service:
- Collection: to store and process your reflections and responses. Without it we cannot provide the app.
- Sharing with your coach: optional. Requested when your coach proposes it.
- Internal improvement: optional, as described in section 1.
You can withdraw consents 2 and 3 at any time in Settings. To withdraw consent 1, delete your data in Settings or email us. Withdrawing it means deleting your account, because the app cannot work without that data.
5. Your rights
You have the right to:
- Confirm whether we collect, share or sell your health data.
- Access it, including a list of all third parties we have shared it with and their contact information.
- Delete it, including copies held by our providers, whom we will notify.
- Withdraw your consent.
How to exercise them:
- Email gratelleapp@gmail.com or use Settings (export or delete).
- You may submit at least two free requests per year.
- We will ask only for information reasonably needed to verify your identity.
Timing:
- We respond within 45 days, extendable once by another 45 days when reasonably necessary. If we extend, we will tell you.
- When you delete your account, your data is removed from our active database immediately. Backups are overwritten within 30 days.
Appeals:
- If we deny your request, you can appeal by emailing us with the subject "Health data appeal". We will respond within 45 days.
- If we deny your appeal, you may file a complaint with your state attorney general:
6. Third-party online tracking
We do not allow third parties to collect information about your online activities over time or across websites through Gratelle.
7. Changes and contact
If we change this policy, we will update the date above. If the change is significant, we will notify you in the app or by email before it takes effect. We will ask for your consent before any new use that requires it.
Contact: Ownday Solutions Inc — gratelleapp@gmail.com — 184 Aces High Ln, Davenport, FL 33896, USA. If the Spanish and English versions differ, the English version prevails.