ARAVEY: Consumer Health Data Privacy Policy

ARAVEY, Consumer Health Data Privacy Policy
Last updated: September 12, 2026
Operated by Prime Legacy Brand LLC

This Consumer Health Data Privacy Policy supplements the ARAVEY Privacy Policy. It applies to data collected through the ARAVEY mobile application that falls within the definition of “consumer health data” under applicable United States state laws, including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Act, and Connecticut’s Data Privacy Act.
It is provided as a separate policy because Washington’s My Health My Data Act requires a distinct policy covering this category of data.
Where a right described below is specific to residents of a particular state, that is noted.

1. Categories of consumer health data we collect
Through the ARAVEY app, we may collect the following categories of consumer health data:
Mood check-ins. The mood you most recently selected, and the date of that check-in. We do not store a history of previous check-ins.
Journal entries. Written reflections you create in the app, including any prompt you selected and the practice category you chose.
Word selections. Words you tap in the Word Drift practice, and any words you add yourself.
Practice activity. Which practices you open or complete, including breathwork exercises, meditations, sound baths, and other rituals, and how many times you have practiced.
Saved preferences. Practices you mark as favorites.
We do not collect biometric data, genetic data, precise location data, diagnoses, medications, or clinical records through ARAVEY.

2. How we collect consumer health data
We collect this data directly from you when you use the app. Specifically:
When you complete a mood check-in
When you write and save a journal entry
When you interact with a practice in the app
When you mark something as a favorite
We do not purchase consumer health data from third parties, and we do not collect it from data brokers, public sources, or other outside sources.

3. Why we collect consumer health data, and how we use it
We use this data to:
Display your own journal entries, your current mood and check-in date, and practice activity back to you within the app
Show your practice count
Save your preferences so the app works the way you left it
Maintain and operate the app, including diagnosing technical problems
We do not use consumer health data for advertising.
We do not use it to build profiles for marketing purposes.
We do not use it to train machine learning models.
We do not use consumer health data for any purpose other than those described in this policy.

4. Categories of consumer health data we share
We do not sell consumer health data, and we never have. “Sale” under Washington law includes exchanging consumer health data for monetary or other valuable consideration. We do not engage in such activity.
We share consumer health data only with service providers who process it on our behalf in order to operate the app. The categories shared with these providers are the same categories listed in Section 1, above.
We do not share consumer health data with advertisers, data brokers, analytics partners for marketing purposes, or any party that uses consumer health data for its own independent purposes.

5. Third parties and service providers with whom we share consumer health data
We share consumer health data with the following service providers:
Google LLC, through Firebase (Cloud Firestore, Firebase Authentication, Cloud Storage, Cloud Functions, and Firebase Cloud Messaging). Firebase stores and processes your data so the app can function.
FlutterFlow, Inc., the platform used to build and maintain the ARAVEY app. FlutterFlow has administrative access to our app database for development and maintenance purposes.
Prime Legacy Brand LLC has no affiliates with whom consumer health data is shared.
Apple Inc. and Google LLC process subscription payments for ARAVEY. They do not receive consumer health data from us.

6. Your rights
Depending on where you live, 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 and affiliates with whom we have shared your consumer health data, together with contact information for those parties
Withdraw consent to our collection and sharing of your consumer health data
Delete your consumer health data
Washington residents may exercise the right of access free of charge at least twice per year.
Residents of Colorado and Connecticut may designate an authorized agent to exercise these rights on their behalf. If you designate an authorized agent, we may require proof of authorization and may ask you to verify your identity directly.
We will not discriminate against you for exercising any of these rights. We will not deny you the app, charge you a different price, or provide you a different level of service because you made a request.

7. How to exercise your rights
To delete your consumer health data, you can delete your account directly in the app at any time, under More → Delete Account or Profile → Delete Account. This permanently removes your journal entries, your current mood and check-in date, practice activity, and saved preferences, and withdraws your consent to our collection and use of consumer health data.
For any other request — access, a list of third parties, or withdrawal of consent — email us at grwnded@primelegacybrand.com.
You do not need to create an account to submit a request. If you already have an account, we may ask you to sign in so we can verify your identity. If we cannot reasonably verify who you are, we may ask for additional information or decline the request, and we will tell you why.
We will respond within 45 days of receiving your request. If we need more time, we will tell you within that period and may take up to 45 additional days.
If we deny your request, you may appeal by replying to our response or emailing grwnded@primelegacybrand.com with the word “Appeal” in the subject line. We will respond to your appeal within 45 days. If we deny your appeal, we will provide you with a method to contact the Washington State Attorney General to submit a complaint.

8. Retention and deletion
We retain consumer health data only for as long as your account remains active.
When you delete your account, your consumer health data is deleted immediately. Your journal entries, current mood and check-in date, practice activity, and saved preferences are removed from our database at the moment you confirm deletion. Deletion cannot be undone, and we cannot recover your data for you afterwards.
Our database keeps a rolling seven‑day recovery window, which exists so that data lost to a technical fault can be restored. Deleted data may persist in that window for up to seven days before it is permanently removed. It is not accessible through the app, is not used for any purpose, and is not retained beyond that period.
We retain a limited record of your acceptance of our Terms of Use, Privacy Policy, and this policy — the email address used, the date, and the policy version. This record contains no consumer health data.

9. Consent
We collect consumer health data only with your consent. When you create an account, ARAVEY presents a separate, specific consent step for consumer health data, distinct from your acceptance of our Terms of Use and Privacy Policy. You may withdraw that consent at any time by deleting your account.

10. Children’s data
ARAVEY is not intended for individuals under 18, and we do not knowingly collect consumer health data from individuals under 18.

11. Storage location
Consumer health data is stored and processed in the United States.

12. Security
We rely on industry‑standard security measures provided by our service providers to protect consumer health data.

13. Changes to this policy
If we make material changes to this policy, we will update the date above and provide notice as required by law. We will not make material changes to how we collect, use, or share consumer health data without your consent.

14. Contact
Prime Legacy Brand LLC
PO Box 92
Prospect, KY 40059
United States

Email: grwnded@primelegacybrand.com