ClearVista Consumer Health Data Privacy Policy

Effective Date: July 31, 2026

See also: Privacy Policy · Terms of Service

This Consumer Health Data Privacy Policy explains how ClearVista Labs LLC ("ClearVista," "we," "us," or "our") collects, uses, discloses, and protects certain wellness-related information in connection with the Bearings mobile application that may be considered consumer health data under certain laws, including the Washington My Health My Data Act and Nevada consumer health data privacy law.

This policy supplements our Privacy Policy. If there is a conflict between this Consumer Health Data Privacy Policy and our Privacy Policy regarding consumer health data, this Consumer Health Data Privacy Policy controls for consumer health data.

The App provides non-medical guided wellness breaks for general wellness and productivity purposes. The App does not provide medical advice, diagnosis, treatment, therapy, emergency support, or professional healthcare services.

1. 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 you and that identifies or may be used to identify certain past, present, or future physical or mental health status, wellness status, goals, interests, or related information, as defined by applicable law.

The App is non-medical, but certain wellness-related information may still be considered consumer health data under some laws.

2. Categories of Consumer Health Data We May Collect

Depending on how you use the App, we may collect the following categories of consumer health data or wellness-related information:

• optional onboarding responses about wellness goals, interests, or reasons for using the App, including stress, anxiety, burnout, sleep, focus, recovery, relaxation, productivity, or similar goals;
• information about stress, anxiety, burnout, sleep, recovery, focus, relaxation, nervous system regulation, emotional processing, mindfulness, movement, productivity, or similar wellness interests, if you choose to provide it;
• selected activity categories, filters, or preferences;
• custom activities you create, including activity titles, descriptions, instructions, categories, tags, and links, to the extent they relate to wellness goals, activities, preferences, or routines;
• activities completed;
• break history;
• favorites;
• timer usage;
• reminder or schedule-related usage;
• recommendation preferences;
• interactions with wellness content, such as breathwork, mindfulness, relaxation, movement, stretching, yoga-inspired practices, focus prompts, or soundscapes; and
• information derived from the above to personalize or improve recommendations.

3. Categories of Consumer Health Data We Do Not Intend to Collect

The App is not designed to collect medical records or clinical information. Unless we expressly update our practices, we do not intend to collect:

• medical diagnoses;
• treatment records;
• therapy notes;
• medication information;
• health insurance information;
• genetic information;
• biometric identifiers for identification;
• emergency/crisis records;
• precise location data for health-service identification;
• Apple Health, Google Fit, or wearable health data; or
• information from healthcare providers.

4. Sources of Consumer Health Data

We may collect consumer health data from:

• you, when you provide onboarding responses, goals, preferences, custom activities, or other inputs;
• your use of the App, including completed activities, favorites, timers, reminders, filters, and break history;
• your device, depending on permissions and technical configuration; and
• service providers that help us operate, analyze, secure, or improve the App.

5. Why We Collect and Use Consumer Health Data

We collect and use consumer health data to:

• provide the App and its features;
• personalize wellness-break and activity recommendations based on optional onboarding responses, favorites, activity history, custom activities and similar App interactions;
• save preferences, favorites, and break history;
• store and display custom activities you create for your own use in the App;
• operate timers, reminders, schedules, and filters;
• understand which features and content are useful;
• improve App functionality, content, and user experience;
• troubleshoot, debug, and maintain App performance;
• secure the App and prevent misuse;
• respond to user requests; and
• comply with law.

We do not use consumer health data to provide medical advice, diagnosis, treatment, therapy, emergency support, or professional healthcare services.

6. Categories of Third Parties and Service Providers That May Receive Consumer Health Data

We may disclose consumer health data to service providers and third parties that help us operate the App, subject to applicable law. These may include:

• hosting and infrastructure providers;
• analytics providers;
• crash reporting and diagnostic providers;
• authentication providers;
• customer support providers;
• email and communications providers;
• subscription-management providers;
• app stores and payment providers, to the extent related to subscriptions or entitlements;
• security and fraud-prevention providers;
• professional advisors, such as attorneys, accountants, or compliance advisors; and
• government authorities or other parties where required by law or necessary to protect rights, safety, or security.

Current service providers and technical tools include Google Firebase, including Firebase Authentication, Cloud Firestore in nam5 US, App Check, Firebase Hosting for legal pages, Firebase Analytics/GA4, Firebase Crashlytics, and Firebase Cloud Messaging; Cloudflare R2 and Workers for media hosting and delivery; RevenueCat for subscription management and entitlement status; Apple App Store and Google Play as merchants of record for app store purchases and subscriptions; Kit for email marketing; and support email systems used to communicate with users, including support emails sent to hello@clearvistalabs.com.

These providers may receive consumer health data only if needed to provide their services or if the App is configured to disclose such information to them. GA4 may receive your selected onboarding response category as an event parameter if you answer the relevant onboarding question. We do not call setUserId in GA4, so GA4 event data is not linked to your ClearVista account by us.

We do not use consumer health data for in app advertising or sale.

7. Affiliates

We may disclose consumer health data to our affiliates, if any, for the purposes described in this policy. As of the effective date of this policy, ClearVista has not identified any affiliates that will receive consumer health data.

8. Sale of Consumer Health Data

We do not sell consumer health data.

9. Advertising

We do not currently plan to use consumer health data for in-app advertising or targeted advertising. If our practices change, we will update this policy and provide any notices, choices, or consents required by applicable law.

10. Consent

Where required by applicable law, we will obtain consent before collecting, using, or disclosing consumer health data. We may ask for consent through the App, during onboarding, through account settings, or through other clear prompts.

If we ask you to provide wellness goals or preferences, we may use those responses to personalize recommendations and improve your App experience. Wellness onboarding questions are optional, and you may choose not to answer them.

You may withdraw consent where required by applicable law, subject to limitations. Withdrawing consent may affect the availability or personalization of certain App features.

11. Your Consumer Health Data Rights

Depending on where you live and subject to applicable law, you may have the right to:

• confirm whether we collect, share, or sell your consumer health data;
• access your consumer health data;
• receive a list of categories of consumer health data collected;
• receive a list of categories of sources from which consumer health data is collected;
• receive a list of categories of third parties and affiliates with whom consumer health data is shared;
• withdraw consent for collection, use, or sharing of consumer health data;
• request deletion of consumer health data; and
• appeal a denial of certain requests, where applicable.

To exercise rights, contact us using the information below or use available in-App settings.

12. Deletion Requests

You may request deletion of consumer health data by contacting us or using available in-App settings. Account deletion is intended to delete account level consumer health data associated with your account, such as onboarding responses, wellness goals, favorites, break history, recommendation preferences, and custom activities, subject to technical feasibility and lawful exceptions.

Certain information may not be deleted immediately or may not be deleted as part of account deletion, including:

• consent audit records retained to document legal consents and accepted policy versions;
• de-identified aggregate engagement counters, such as total times an activity was completed or favorited;
• GA4 event data associated with a per-device app instance ID that we do not link to your account through setUserId;
• Crashlytics crash reports retained according to Firebase's standard retention period;
• RevenueCat subscription records and customer records, which may persist on RevenueCat's servers after account deletion and are retained for subscription administration, app store, payment, tax, accounting, fraud prevention, security, and legal purposes;
• Firestore point in time recovery backups for up to 7 days;
• device local preferences that remain on your device until uninstall or local data clearing; and
• support emails and related communications.

When you delete your account, the App disconnects the device from the RevenueCat customer record, but the RevenueCat customer record may persist on RevenueCat's servers.

13. Retention

We retain consumer health data for as long as reasonably necessary to provide the App, maintain your account, personalize recommendations, comply with legal obligations, resolve disputes, maintain security, and support legitimate business purposes.

GA4 event data is retained according to our GA4 retention setting, currently 14 months, and is not linked to your account by us through setUserId. Crashlytics crash reports are retained according to Firebase's standard retention period, currently 90 days. Deleted Firestore documents may remain recoverable in point in time recovery backups for up to 7 days. Consent audit records may be retained as legally required. Device local settings may remain on your device until uninstall or local data clearing. Support emails may be retained as needed to respond to requests and maintain business records. RevenueCat subscription and customer records may persist after account deletion and may be retained as needed for subscription administration, app store, payment, tax, accounting, fraud prevention, security, and legal purposes.

We may delete or de-identify inactive account or App data after 24 months of inactivity, subject to technical feasibility and legal, security, subscription, backup, and compliance exceptions.

14. No Discrimination

We will not unlawfully discriminate against you for exercising consumer health data rights. However, some App features may require certain information to function. If you delete or withdraw consent for certain information, some personalization or recommendation features may be limited or unavailable.

15. Children

The App is intended for adults and is not directed to children under 13. We do not knowingly collect consumer health data from children under 13.

If you believe a child under 13 has provided consumer health data to us, contact us so we can take appropriate steps.

16. Security

We use reasonable administrative, technical, and organizational measures designed to protect consumer health data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

17. Changes to This Policy

We may update this Consumer Health Data Privacy Policy from time to time. If we make material changes, we will provide notice as required by applicable law, such as through the App, by email, or by posting an updated policy.

18. Contact Us

To submit a request or ask questions about this Consumer Health Data Privacy Policy, contact us at:

ClearVista Labs LLC
Email: hello@clearvistalabs.com
Address: P.O. Box 95457, South Jordan, UT 84095

19. Appeals

If applicable law gives you the right to appeal a decision we make about a consumer health data request, you may submit an appeal by contacting us at hello@clearvistalabs.com and writing "Consumer Health Data Appeal" in the subject line. We will respond as required by applicable law.