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Plan To Win: Consumer Health Data Privacy Policy (Washington)

Effective date: 7 October 2026 · Last updated: 27 October 2026 · Version: 2026-10-27.1


1. Who This Policy Covers

1.1 This Consumer Health Data Privacy Policy applies to you if you are a Washington resident, or if your consumer health data is collected while you are in Washington, and you use the Plan To Win app, the Map of You, our website or our coaching ("the Service"). It is published by Zackery Frank Boyle, carrying on business as Plan To Win, of 4718 Stanley Rd SW, Calgary, Alberta T2S 2R2, Canada ("PTW", "we", "us").

1.2 "Consumer health data" means personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health status, as Washington's My Health My Data Act defines it. Our Privacy Policy describes everything else we collect and remains the full description of our practices; where this policy is silent, the Privacy Policy applies.

2. Consumer Health Data We Collect and Why

We collect the categories below only to provide the features you use, and we use each of them for the purpose next to it. We do not use any of it for advertising, we do not sell it, and we do not use it to train AI models.

CategoryWhat it includesWhy we collect it and how we use it
Body and health profileDate of birth, gender, height, weight, fitness level, diet type, wake and wind-down times, self-rated sleep quality and stress levelTo personalise your plans and compute your LifeScore (a motivational estimate, not a health measure)
Fitness, diet and wellbeing logsWorkouts and walks (including the distance, time and pace of a cardio session or a walk), meals and food photos you scan, supplements, weight, steps, focus and break sessions, and mood check-insTo give you tracking, trends and plans, and to feed your LifeScore
Data from your phone's health app (only if you grant permission)On Android, through Health Connect: steps, heart rate (including resting heart rate), sleep, active calories and weight. Read only; we never write to itTo show those numbers in the app and count them toward your goals
Habits you are working to quitThe habit, your quit date, what it costs you, each day you slipped, and an optional private noteTo count your days and support you
Journal, reflection and AI-chat textAnything you write in a journal entry, a guided reflection, a Map of You quiz answer, or a message to the AI coach, which may describe your health or mental stateTo power reflection and the coach, and to let you look back. Journal text is off for the AI coach unless you switch it on
Health-provider plansA plan you add from a health provider (for example a physio plan)To build it into your schedule and let the coach respect it
Derived dataLifeScore, streaks, trends and the coach's view of your progress, worked out from the data aboveTo show your progress; never to advertise to you
Serious-safety noticesA record that our systems detected signs you may be in serious danger (your account, the time and the part of the app; never what you wrote)So a person can reach out to you (Privacy Policy, Section 7)

We do not collect precise geolocation for health purposes. During a cardio session, if you allow it, your phone uses its own location to show live distance and pace; we store the distance, time and average pace, never your route or coordinates. We do not collect genetic data, and cycle and period tracking is not part of the app today (Privacy Policy, Section 3.4).

Coach memory and look-back. If you tell the coach something about your health (for example an injury), it can remember it only after you say yes, and only in your own words. The coach reads your journal, mood check-ins and activity only when you switch on Look back when you ask, which is off by default, and shows an "I looked at" receipt. You can see and delete what it remembers under Chat history > What I remember about you, and turn either feature off in Settings.

3. Where It Comes From

We do not buy consumer health data and we do not receive it from data brokers.

4. What We Share and With Whom

4.1 We do not sell consumer health data, and we never have. We do not share it for advertising.

4.2 Service providers (processors). The companies below process consumer health data on our behalf, under contracts that limit them to our instructions, so the app can work. This is the only way your health data leaves our systems in the ordinary running of the Service.

ProviderWhat it does for usHealth data it may handle
AnthropicRuns the AI model behind the coach, reflections, plan building, meal estimates and the Map of You readingThe text, photos and documents you use with an AI feature, plus the background the coach is allowed to see (AI and Coaching Disclosure, Section 4)
NeonOur databaseAll of the categories in Section 2
VercelHosts the app and stores uploaded photosEverything the app serves, including food photos you scan and your profile picture
USDA FoodData Central and Open Food FactsFood databases for search and barcode lookupThe food name or barcode you search, never your account

4.3 People you choose to link with. If you use the social features and link with someone, they see only what you choose to share on that link (free/busy times, a shared grocery list, goals you mark shared, plans you make together, an agreed challenge number, workout plans you send). Your health numbers, body measurements, diet, mood, journal, reflections, habits you are quitting, location and LifeScore are never shared through a social feature (Privacy Policy, Section 8).

4.4 Your coach. If you choose optional coaching and confirm your coaching consent, your coach can see your progress, including your logged activity, weight and mood check-ins (AI and Coaching Disclosure, Section 9).

4.5 Affiliates. We have no affiliates. Nothing is shared with one.

4.6 Law and safety. We may disclose consumer health data to comply with the law, a court order or a lawful request, or where we reasonably believe it is necessary to prevent serious harm to someone, and to a successor in a business sale or merger who must protect it as our Privacy Policy describes.

5.1 Collection. We collect consumer health data because you enter it, log it or connect it to use the features you asked for, and because you agreed on the "Before you start" screen, which separately asks you to confirm how health information, the AI and the safety notice work. Health data from your phone is collected only after you grant the permission on your phone; location only after you allow it for a cardio session.

5.2 Sharing. Washington law requires that consent to share consumer health data with a third party be separate and distinct from consent to collect it. Today we share consumer health data only with the service providers in Section 4.2, which process it on our behalf, with your coach if you confirm coaching, and with the people you yourself choose to link with, for the categories you choose, none of which are health numbers. If we ever want to share your consumer health data with a third party in any other way, we will ask for your separate consent on its own screen first, and you will be able to say no without losing the rest of the Service.

5.3 Turning things off. You can turn off the AI coach's access to your journal and other sources in Settings > AI Coach Profile, turn off health-app sharing in your phone's settings, decline location for a cardio session, end any social link, and withdraw coaching consent by telling us.

6. Your Rights and How to Use Them

6.1 Your rights. Under RCW 19.373.040 you have the right to:

6.2 How to use them. The secure ways to make a request are:

6.3 Timing. We respond without undue delay and in any case within 45 days of receiving your request. If a request is unusually complex, or you have made several, we may take up to 45 more days, and we will tell you within the first 45 days why we need the extra time.

6.4 Deletion. When you ask us to delete your consumer health data, we delete it from our records and tell the service providers in Section 4.2 that hold it for us to delete it from theirs. Copies in backups are removed as the backups cycle, within the time the law allows.

6.5 No charge. We do not charge for a request unless the law allows it, and if we ever do we will tell you first.

7. Appeals

If we refuse to act on your request, we will tell you why. You can appeal by replying to our answer, or by emailing hello@plantowin.app with "Appeal" in the subject line, within a reasonable time after our decision. We will answer your appeal in writing within 45 days, with the reasons for whatever we decide. If we deny your appeal, our answer will also tell you how to contact the Washington State Attorney General (atg.wa.gov), who can take complaints about this policy.

8. Security and Retention

We protect consumer health data with the safeguards described in Section 12 of the Privacy Policy (hashed passwords, encrypted connections, limited admin access, rate limits). We keep it only for as long as the Privacy Policy's retention table (Section 11) says: for most categories, while your account is open, and deleted when you delete your account.

A nightly encrypted backup of our database is kept in a private Google Drive folder and the last 30 daily copies are kept, so deleted data can remain in a backup for up to 30 days (Privacy Policy, Section 11.1).

9. Changes and Contact

We will not collect new categories of consumer health data, or use or share it for new purposes, without first updating this policy and, where Washington law requires it, asking for your consent. If we make a material change we will tell you in the app and by email at least 14 days before it takes effect where we can. Questions, requests and complaints: hello@plantowin.app · 4718 Stanley Rd SW, Calgary, Alberta T2S 2R2, Canada.