Effective Date: October 31, 2026
See also: Privacy Policy · Terms of Service
This Consumer Health Data Privacy Policy explains how ClearVista Labs LLC (“CVL,” “we,” “us,” or “our”) collects, uses, discloses, and protects information that qualifies as consumer health data under applicable law, including the Washington My Health My Data Act and Nevada consumer health data privacy law, in connection with the Bearings mobile application and CVL’s related websites, including clearvistalabs.com and bearings-time.web.app. It applies to that information only where applicable consumer health data law covers the information and the processing. Our Bearings App Privacy Policy and Website Privacy Policy describe our other personal information practices.
This policy supplements our Bearings App Privacy Policy and our Website Privacy Policy. If there is a conflict between this Consumer Health Data Privacy Policy and either of those policies regarding consumer health data, this Consumer Health Data Privacy Policy controls for consumer health data.
The App provides nonmedical 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.
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 nonmedical, but certain wellness related information may still be considered consumer health data under some laws.
Depending on how you use the App, we may collect the following categories of consumer health data or wellness related information:
The App is not designed to collect medical records or clinical information. Unless we expressly update our practices, we do not intend to collect:
A sponsoring organization may approve one or more workplace email domains with CVL and provide administrative information to arrange organization sponsored access, as described in our Bearings App Privacy Policy. Staff provide and verify their own workplace email addresses when they create their accounts. The organization does not provide an initial enrollment list, but it may provide workplace email addresses to exclude individuals from sponsored access. That arrangement does not authorize the organization or its staff to provide patient records, therapy notes, treatment information, or any other information that identifies or could reasonably identify a patient or client through the App. This applies to custom activity titles, descriptions, instructions, categories, tags, and links, to support requests, and to any other place in the App where text or links can be entered. Information can identify a client even when it does not include a full name, a diagnosis, or an address.
We may collect consumer health data from:
We collect and use consumer health data to:
We do not use consumer health data to provide medical advice, diagnosis, treatment, therapy, emergency support, or professional healthcare services.
We collect consumer health data only with the consent required by applicable law or to the extent necessary to provide a product or service you request. Where applicable law requires separate consent for sharing, we obtain that consent before sharing. A purpose listed in this policy, your acceptance of our Terms of Service, or your organization’s sponsorship does not itself provide that consent.
For organization sponsored access, we also use App usage information to prepare group level engagement reports for the sponsoring organization, subject to the reporting limits below and any notices or consents required by applicable law. These reports do not provide individual clinical assessments or treatment recommendations.
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:
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.
Providers receive different information depending on their services and the App’s configuration. A provider’s inclusion in this list does not mean it receives every category of consumer health data. We limit disclosures to the information and purposes permitted by applicable law and our arrangements with the recipient. The current App version does not send answers to the discontinued stress, anxiety, or burnout onboarding question to GA4. Our Bearings App Privacy Policy describes the remaining analytics and technical information.
We configure analytics and vendor integrations to limit unnecessary disclosure of sensitive wellness responses as analytics event properties, user properties, or similar vendor data.
We do not use consumer health data for in App advertising, and we do not sell consumer health data.
A sponsoring organization may receive an administrative roster of the workplace email addresses used to claim sponsored access, together with seat information, separately from group level usage reports. When enabled, usage reports are available through the dashboard and may include total monthly users, total weekly users, and the number of weekly users in each frequency category: once, two to three times, or four or more times per week.
We do not provide the organization with individual wellness answers, custom activity content, individual activity histories, or person level usage reports. Usage figures are withheld when fewer than five users are represented in the reported group, including each weekly view and each frequency category. This threshold applies to the users represented in each disclosed usage figure, not merely to the organization’s total enrollment.
These limits are intended to reduce identification risk and do not mean that reports without names are necessarily anonymous. Processing and disclosure of consumer health data remain subject to applicable law and the consent provisions in Section 10. The reporting limits apply to every dashboard view and any export CVL makes available. We may suppress additional figures or delay reports to reduce identification risk.
Organization sponsored access is arranged for eligible staff. It does not give the sponsoring organization access to information about clients who independently download and use the App.
CVL does not currently disclose consumer health data to affiliated companies.
We do not sell consumer health data.
We do not use consumer health data to select advertising audiences, and we do not send wellness responses, custom activity content, or individual activity histories to advertising platforms for targeting. We do not display advertisements inside the App. Our Bearings App Privacy Policy describes separate campaign measurement and install attribution flows. Technical or campaign information is not automatically outside consumer health data protections merely because it does not include your name. Where such information constitutes consumer health data, this policy and applicable law apply. If our practices change, we will update this policy and provide any notices, choices, or consents required by applicable law.
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. Your agreement to our Terms of Service, and your receipt of organization sponsored access, are not substitutes for any consent that applicable law separately requires. Consent to use your wellness responses to personalize your experience is separate from any consent that may be required for a different purpose, such as advertising or a disclosure to a third party. We do not treat your acceptance of the Terms of Service, your use of an organization sponsored account, or your Usage analytics setting as consent to share consumer health data with a third party.
If we ask you to provide wellness goals or preferences, we 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.
Depending on where you live and subject to applicable law, you may have the right to:
To exercise rights, contact us using the information below or use available in App settings.
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 the exceptions and limits described below.
The account deletion feature does not automatically remove every record from every system. The following describes its technical reach, not exceptions to your legal rights. We separately evaluate valid deletion requests and delete additional information where required by applicable law, and we retain requested information only where a specific legal requirement or exception permits it:
RevenueCat customer records associated with your account are deleted when your user account is deleted, subject to backup retention and any separate records maintained by Apple App Store, Google Play, or other providers under their own systems and policies.
These descriptions explain how account deletion operates. They do not limit deletion rights available under applicable law. We will evaluate requests involving information outside the account deletion workflow and arrange additional deletion where required. Where applicable law requires it, we also notify service providers and other recipients so they can delete the data, and we complete deletion within the time the law allows, including any permitted period for archived or backup systems.
An organization administrator’s removal of your organization sponsored premium entitlement does not delete your account or constitute a request to delete consumer health data. You may separately request deletion as described in this section.
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.
Our GA4 user and event level data retention setting is 14 months. This setting does not govern aggregated reports and does not replace any obligation to complete a valid deletion request sooner. Analytics records from earlier App versions are subject to the same request rights. 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 customer records associated with your account are deleted when your user account is deleted, subject to backup retention and any separate records maintained by Apple App Store, Google Play, or other providers under their own systems and policies.
We delete inactive accounts after 24 months of inactivity, subject to legal, security, subscription, backup, and compliance exceptions.
If organization sponsored access ends, information associated with your account remains subject to this policy’s retention and deletion provisions, including the existing inactive account retention rules. Ending sponsored access does not itself delete your account.
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.
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.
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.
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.
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
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 within the period required by applicable law, explain our decision, and, where required, provide information about submitting a complaint to the appropriate state authority.