Consumer Health Data Privacy Policy
1. SCOPE AND APPLICATION
This Consumer Health Data Privacy Policy is provided in accordance with the Washington My Health My Data Act, RCW 19.373, and with comparable consumer health data legislation in Nevada and Connecticut. It applies to consumer health data collected, processed, shared or sold by RSF Group B.V., trading as GARD PRO ("GARD PRO", "we", "us", "our").
This Policy applies to you if you are a resident of Washington State, or if your consumer health data is collected in Washington State. Sections 11 and 12 address Nevada and Connecticut respectively.
This Policy supplements, and does not replace, our App Privacy Policy. Where a provision of this Policy conflicts with the App Privacy Policy in respect of consumer health data, this Policy prevails.
2. DEFINITION OF CONSUMER HEALTH DATA
"Consumer health data" means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present or future physical or mental health status. It includes information derived or extrapolated from data that is not itself health data.
3. CATEGORIES OF CONSUMER HEALTH DATA COLLECTED, AND THE PURPOSE OF COLLECTION
| Category | Data | Purpose |
|---|---|---|
| Bodily functions and vital signs | Heart rate, heart rate variability, resting heart rate, heart rate recovery, blood oxygen saturation, respiration rate, blood pressure trend values, skin and body temperature | To calculate and display wellness metrics, trends and scores, and to generate general wellness guidance |
| Sleep | Sleep and wake times, sleep duration, sleep stages | To calculate and display sleep metrics and to generate general wellness guidance |
| Physical activity and exertion | Steps, distance, elevation, energy expenditure, movement and accelerometer data, sedentary and stand time, workout type, duration, pace, cadence, running and swimming form metrics, session effort ratings | To record activity, calculate metrics and generate general wellness guidance |
| Derived health measurements | Training load, recovery time, recovery score, readiness score, stress score, strain, training effect, cardio fitness (VO2 max) estimate, intensity minutes | To provide wellness insight and general wellness guidance |
| Bodily characteristics | Height, weight, sex used for physiological calculations, date of birth | To calculate personalised metrics and to determine which features are available to your account |
| Health-related communications | Content of your conversations with GARD PRO Coach | To generate responses to your messages and to operate safety features |
| Health condition disclosures | The fact that you have disclosed an eating disorder or a pregnancy | To disable features that would be inappropriate for you |
| Behavioural safety indicators | Where your account is held by a user under 18, patterns associated with disordered eating | To disable features automatically where continued access presents a risk of harm |
| Precise location | GPS location recorded during an outdoor workout | To calculate distance, pace, elevation and route |
| Support communications | Content of support communications where they concern your health data | To respond to your enquiry |
We do not collect information concerning gender-affirming care, reproductive or sexual health services, or the seeking of any health care service. We do not collect medication, symptom or diagnosed condition information as structured data.
4. SOURCES OF CONSUMER HEALTH DATA
- Directly from you, where you enter profile information, respond to questions or send messages to GARD PRO Coach
- From sensors in your GARD PRO device, synchronised to the App
- From third-party services you elect to connect, being Apple Health, Google Health Connect, Strava and Komoot
- Derived by us from the above, in the form of calculated scores and trends
5. CATEGORIES OF CONSUMER HEALTH DATA THAT ARE SHARED
The following categories are shared with the third parties identified in Section 6:
- Bodily functions and vital signs
- Sleep data
- Physical activity and exertion data
- Derived health measurements
- Bodily characteristics
- Health-related communications
- Support communications concerning health data
- Precise location, in the limited circumstances described in Section 6
The following categories are not shared with any third party in any circumstances:
- Health condition disclosures
- Behavioural safety indicators
6. THIRD PARTIES WITH WHOM CONSUMER HEALTH DATA IS SHARED
6.1 Service providers acting on our instructions
These parties process consumer health data solely to provide services to us, under contract, and may not use it for their own purposes.
| Third party | Data shared | Purpose |
|---|---|---|
| Hetzner Online GmbH | All stored consumer health data | Hosting and storage |
| OpenAI | Derived values and conversation content, transmitted under a pseudonymous reference with identifying information removed | Generating GARD PRO Coach responses |
| Richpanel | Support communications, which may contain consumer health data | Customer support |
| Cloudflare | File and object storage where applicable | Storage |
Sentry, PostHog, Google (Firebase Cloud Messaging), Apple (APNs) and Resend are engaged by us but do not receive consumer health data. Technical controls exclude health data from crash reports, analytics events, logs and notification content.
6.2 Services you direct us to share with
Where you connect a third-party service, we share the categories you select. These parties are independent controllers and process your data for their own purposes under their own policies.
| Third party | Data shared |
|---|---|
| Apple Health | Categories you select |
| Google Health Connect | Categories you select |
| Strava | Workout, activity and precise location data |
| Komoot | Route and precise location data |
Data shared with these services is not recoverable by us. Deletion of your GARD PRO account and any deletion request made to us does not delete data already transmitted to them. Deletion must be requested from that service directly.
6.3 Affiliates
We do not share consumer health data with any affiliate.
6.4 Legal disclosure
We may disclose consumer health data where required by law or valid legal process. Where permitted, we will notify you.
7. WE DO NOT SELL CONSUMER HEALTH DATA
GARD PRO does not sell consumer health data and has never done so. We will not sell consumer health data. Should that position ever change, we would first obtain your valid authorization in the form and with the content required by RCW 19.373.
We do not share consumer health data with advertising networks, data brokers or marketing partners, and we do not use it for targeted advertising, audience building or any use-based data mining.
8. CONSENT
Consumer health data is collected and shared only with your consent, obtained separately and distinctly from any other terms.
- Consent to collection is obtained before collection begins.
- Consent to sharing is obtained separately from consent to collection.
- Separate consent is obtained for each connected service.
- Consent is not obtained through acceptance of our Terms of Service or any general terms.
- Consent is not inferred from your inaction, from a pre-ticked box, or from your continued use of the App.
- You may withdraw any consent at any time. Withdrawal takes effect on receipt and does not affect the lawfulness of processing carried out before withdrawal.
9. YOUR RIGHTS
You have the following rights in respect of your consumer health data.
9.1 Right to confirm. You may request confirmation of whether we collect, share or sell your consumer health data, and may request access to that data.
9.2 Right to a list of recipients. You may request a list of all third parties and affiliates with whom we have shared your consumer health data, together with an active email address or other online mechanism by which you may contact each of them.
9.3 Right to withdraw consent. You may withdraw consent to the collection of your consumer health data, to the sharing of it, or to both.
9.4 Right to delete. You may request deletion of your consumer health data. Where you do:
- We will delete it from our records, including from archived and backup systems. Removal from backups completes within our 35-day backup cycle.
- We will notify each service provider and contractor to whom we have shared the data of your request, and instruct them to delete it.
- We will not be able to effect deletion by any third party identified in Section 6.2, being a service you directed us to share with. You must request deletion from those services directly, and we will tell you which they are.
9.5 No discrimination. We will not discriminate against you, deny you goods or services, charge you a different price, or provide a different level of quality because you have exercised any right under this Policy.
9.6 How to exercise your rights. Contact support@gardpro.com, or use the corresponding controls in the App under Settings. We will respond within 45 days of receipt. Where reasonably necessary and having regard to the complexity and number of requests, we may extend that period by a further 45 days, and will inform you within the initial period of the extension and the reason for it.
9.7 Verification. We may require you to verify your identity before we act on a request. Where we cannot verify your identity, we will tell you and explain why.
9.8 Appeal. If we decline a request, we will explain why and tell you how to appeal. You may appeal by replying to that decision or by writing to support@gardpro.com. We will respond to an appeal within 45 days, setting out the action taken or not taken and the reasons for it. If your appeal is denied, you may contact the Washington State Attorney General at www.atg.wa.gov/file-complaint.
10. GEOFENCING
GARD PRO does not implement, and will not implement, a geofence around any entity providing in-person health care services. We do not use geofencing to identify or track consumers seeking health care services, to collect consumer health data, or to send notifications, advertisements or messages relating to consumer health data or health care services.
11. NEVADA RESIDENTS
Nevada Senate Bill 370 provides Nevada consumers with rights in respect of consumer health data that are substantially equivalent to those set out above. This Policy applies to Nevada residents, and the rights in Section 9 may be exercised by Nevada residents by the same means. Requests will be handled within the periods prescribed by Nevada law where those differ from the periods stated above.
12. CONNECTICUT RESIDENTS
The Connecticut Data Privacy Act, as amended in respect of consumer health data, provides Connecticut consumers with rights in respect of consumer health data. This Policy applies to Connecticut residents, and the rights in Section 9 may be exercised by Connecticut residents by the same means.
13. CHANGES TO THIS POLICY
We will not collect, share or use consumer health data for any purpose not disclosed in this Policy. Where we intend to collect a category of consumer health data not listed in Section 3, or to share consumer health data with a party not listed in Section 6, we will obtain your consent before doing so.
Where this Policy is amended, we will post the amended version at this address and update the date above.
14. CONTACT
RSF Group B.V., trading as GARD PRO Chocoladeweg 6 1381 DA Weesp The Netherlands
Email: support@gardpro.com Chamber of Commerce (KvK) number: 92424392
For the purposes of the Washington My Health My Data Act, RSF Group B.V. is the regulated entity responsible for the consumer health data described in this Policy.
Last updated: 28-08-2026