Consumer Health Data Privacy Policy
This policy applies to consumer health data as defined by the Washington My Health My Data Act. It is separate from our general Privacy Policy and covers only health data.
Peak 65 LLC, a Washington limited liability company, operates Peak 65, a Hyrox and hybrid training coaching service.
1. The consumer health data we collect, and why
We collect the following categories of consumer health data:
- Cardiovascular and recovery measurements — heart rate during training, peak and average heart rate, heart rate recovery, time spent in heart rate zones, heart rate variability, and resting heart rate.
- Sleep measurements — sleep duration.
- Physical activity measurements — training sessions completed, perceived exertion, paces and distances, weights lifted, step count, and calories where your wearable provides them.
- Bodily measurements — height, weight, body composition estimate, and reported strength maximums.
- Injuries and physical limitations — injuries, limitations, and related notes you report to us or to your coach.
- Images containing health data — screenshots of heart rate data from your own device that you choose to upload.
We collect this data for one purpose: to provide you with coaching. Specifically, we use it to write and adjust your individual training program, to let your coach evaluate how you are responding to training and change it, and to produce the weekly training summary your coach reviews.
We do not use consumer health data for advertising, marketing, or profiling unrelated to your coaching.
2. Where we collect it from
- Directly from you — information you enter when you sign up, what you log after each session, what you tell your coach, and screenshots you upload.
- From wearable devices and services you choose to connect — Whoop and Oura through a direct connection, and Apple Health, Apple Watch, Garmin or Zepp where your phone provides the data. We only receive this data after you authorize the connection, and only for as long as it remains connected.
- Derived from the above — values we or our service providers read from your uploaded screenshots, and measurements calculated from your logged sessions and wearable data.
3. The consumer health data we share
We share the categories listed in section 1 with the service providers in section 4, to the extent each needs it to perform its function. This includes your uploaded heart rate screenshot images.
We do not sell consumer health data. We have never sold it and we do not share it with advertisers or data brokers.
4. Who we share it with
We do not have affiliates. We share consumer health data with the following categories of third parties, each acting as a service provider to us:
- Cloud database, authentication and file storage providers — store your data and your uploaded screenshots (Supabase).
- Application hosting providers — operate the servers your data passes through (Vercel).
- Artificial intelligence processing providers — generate your training program and read values from your uploaded heart rate screenshots, which are transmitted to them as images (Anthropic).
- Email delivery providers — deliver the weekly training summary to your coach, which contains your recovery data and heart rate screenshots (Resend).
- Email inbox providers — receive coaching applications sent to us, which include any injuries or limitations you report in the application (Google).
- Push notification providers — deliver notifications to your phone. A notification preview can include the opening words of a message from your coach, which may reference your training or your health (Apple, Expo).
- Wearable device providers — the source of your recovery data, when you connect them (Whoop, Oura, and Apple Health, Apple Watch, Garmin or Zepp where your phone provides the data).
- Your coach — the individual coaching you through Peak 65 has access to your consumer health data in order to coach you.
We may also disclose consumer health data where required by law.
5. Your rights and how to use them
You have the right to:
- Confirm whether we are collecting, sharing, or selling your consumer health data, and to access that data.
- Receive a list of all third parties with whom we have shared your consumer health data, and a way to contact them.
- Withdraw your consent to our collection and sharing of your consumer health data.
- Delete your consumer health data.
To delete your data immediately: open the Peak 65 app, go to Profile, and choose Delete Account. This permanently deletes your consumer health data, including your uploaded heart rate screenshots.
To withdraw consent for wearable data: open the Peak 65 app, go to Profile, and disconnect Whoop or Oura. For data reaching us through your phone — including Apple Health, Apple Watch, Garmin and Zepp — revoke the Peak 65 app's health permissions in your phone's settings. We stop receiving new data at once.
For any other request, email peak65app@gmail.com with the subject line "Washington Health Data Request". We will respond within 45 days. If we need more time we will tell you why, and we may extend by a further 45 days.
If we deny your request, you may appeal by replying to our response or emailing peak65app@gmail.com with the subject line "Appeal". We will respond in writing within 45 days explaining our reasoning. If we deny your appeal, you may submit a complaint to the Washington State Attorney General at https://www.atg.wa.gov/file-complaint
Contact
Peak 65 LLC
Kenmore, Washington
peak65app@gmail.com