Consumer Health Data Privacy Policy

This policy explains how Tower of Wellness ("we", "us") handles consumer health data — a specific category of information protected by the Washington My Health My Data Act and similar laws. It is separate from, and in addition to, our general Privacy Policy. Where the two overlap, this policy controls for health data.

The one-paragraph version

The only consumer health data we collect is what you type into our Functional Assessment, and we only keep it if you press save. We use it for exactly one purpose: showing your results back to you in your own account. We do not sell it, we do not use it for advertising, and no person at Tower of Wellness browses it. You can download all of it or permanently delete all of it yourself, at any time, from your account.

What we collect, and why

We collect the following categories of consumer health data:

• Assessment responses — your self-ratings (mild, moderate or severe) across the assessment's symptom categories.
• Derived suggestions — the list of nutritional products the assessment's key associates with your responses.
• Record-keeping details — the date and time of each saved assessment, the questionnaire version it was taken on, and a record of the consent you gave, including the version of this policy it was given against.

Purpose. One purpose only: to keep your saved assessment results in your account so that you can view them, print them, compare them over time, and share them with a practitioner of your choosing. We do not use consumer health data for advertising, profiling, or any secondary purpose, and we do not enrich it with data from anywhere else.

What we deliberately do not collect: we do not save anything unless you press save — an assessment you complete and walk away from is never transmitted or stored. We collect no location data in connection with health data and we do not operate any geofence. We do not infer health conditions from your purchases.

Where it comes from

One source: you, directly. Consumer health data enters our systems only when you complete the assessment and press save while signed in. We do not obtain consumer health data from data brokers, advertising networks, other websites, or any third party.

Consent

Before your first save, you are shown a consent checkbox that is never pre-ticked. We record when you consented and which version of this policy you consented to. If this policy materially changes, your existing consent does not carry over — you will be asked again before anything further is stored. You can withdraw consent at any time (see your rights, below).

What we share, and with whom

We sell no consumer health data, to anyone, ever, and we share it with no one for their own use. The following service providers process it on our behalf, under contract, solely to run this service:

• Cloudflare, Inc. — hosts this website and operates the encrypted database in which saved assessments are stored.
• Shopify Inc. — operates our customer accounts. Shopify verifies who you are when you sign in; your assessment answers are not sent to Shopify and are not stored on Shopify's systems.

That is the complete list. We have no affiliates. If a law enforcement or other legal demand for consumer health data ever compels disclosure, we will disclose the minimum required and, unless legally prohibited, tell you.

Your rights, and how to use them

You can, at any time:

• Confirm and access — see whether we hold consumer health data about you and download all of it — as a readable PDF or as a machine-readable JSON file: Your Wellness Record. Either download includes everything listed in "What we collect" above.
• Withdraw consent — stop future collection by simply not saving again, or withdraw entirely by deleting your history, which also erases your consent record so nothing further can be stored without asking you afresh.
• Delete — erase your entire assessment history: Your Wellness Record → Delete My Assessment History. You will be asked for your password, because this cannot be undone. Deletion is immediate and permanent: your answers, your results and your consent record are removed, and we keep no copy of them and nothing derived from them.
• What survives a deletion, and why. Two things, and neither contains health information. If you paid for a single assessment, we keep a billing record that one was purchased and used on a given date — an account reference and a date, no answers and no results — because it records a payment and deleting it would hand back a credit that was spent. Separately, our database provider retains point-in-time backups of the whole system for up to 30 days before they age out; we cannot exclude individual records from those and we do not use them to restore anything you have deleted.

You can also exercise any of these rights, or ask anything about this policy, by emailing team@towerofwellness.com. We will verify the request comes from the account holder and respond within 45 days.

If we refuse a request, and how to appeal

If we decline a request (for example, because we cannot verify the account), we will tell you why in writing. You may appeal by replying to that decision at the same email address with "Appeal" in the subject line; a person, not an automated system, will review it and respond within 45 days. If your appeal is denied and you are a Washington resident, you may contact the Washington State Attorney General. Residents of other states may contact their state attorney general.

How it is protected

• Encrypted in transit (TLS) and encrypted at rest.
• Readable only through your own signed-in session — requests for assessment data are answered only for the account that saved it.
• No administrative screen shows any individual's answers, and staff do not browse assessment records.

How long we keep it

Until you delete it. Saved assessments are kept so you can compare them over time — that is their purpose — and are removed immediately when you delete them or ask us to close your account.

Children

Our assessment and membership are intended for adults. We do not knowingly collect consumer health data from anyone under 18; if you believe we have, email us and we will delete it.

Changes to this policy

Material changes get a new version number and a new effective date, and existing consents do not carry over — you will be asked to consent again before anything further is stored. The current version is always at this address, which is linked from every page of this site.

Contact

Tower of Wellness · team@towerofwellness.com