Consumer Health Data Privacy Policy

1. Introduction 

Personal Effectiveness Association (“PEA”) is a Texas 501(c)(3) nonprofit organization that operates the PEAHappy mobile application (the “App”). This Consumer Health Data Privacy Policy describes how PEA collects, uses, shares, and protects consumer health data through the App. This policy supplements PEA’s general Privacy Policy and applies to all users of the App. 

2. What Is Consumer Health Data 

Consumer health data is information that identifies or reasonably relates to a consumer’s past, present, or future physical or mental health. For the App, this includes: 

• Mental health self-assessments and mood tracking entries 

• Fitness activity data (exercise type, duration, frequency, and performance) 

• Nutrition and dietary tracking data (food intake, caloric information, and nutritional data) 

Consumer health data does not include de-identified or aggregated data that cannot reasonably be used to identify an individual. 

3. How We Collect Consumer Health Data 

PEA collects consumer health data in the following ways: 

• Directly from you when you use the App’s tracking features (mental health tracker, fitness tracker, and nutrition tracker) 

• Automatically through the App’s functionality (e.g., activity logs and usage patterns related to health features) 

PEA does not collect consumer health data from third-party sources. 

4. Purposes for Collection 

PEA collects and uses consumer health data for the following purposes: 

• To provide and operate the App’s tracking features 

• To display your health data back to you within the App 

• To improve the App’s functionality and user experience (using aggregated, de-identified data only) • To respond to your requests or communications 

• To comply with applicable law 

5. How We Share Consumer Health Data 

PEA does not sell consumer health data. PEA does not share consumer health data for advertising purposes. PEA may share consumer health data only with: 

• Service providers who process data on PEA’s behalf and are contractually required to protect it (e.g., cloud hosting and data storage providers, analytics providers receiving only aggregated or de-identified data, and crash reporting and app performance services) 

• As required by law, such as to comply with a subpoena, court order, or other legal process

6. Your Rights 

Subject to applicable law, you have the right to: 

• Confirm whether PEA collects or shares your consumer health data 

• Access your consumer health data 

• Request deletion of your consumer health data 

• Withdraw your consent to the collection or sharing of your consumer health data 

To exercise any of these rights, contact PEA at info@happypea.org. PEA will respond within 30 days or such shorter period as required by applicable law. PEA will not discriminate against you for exercising your rights. 

7. Consent 

• PEA obtains your affirmative consent before collecting consumer health data through the App’s tracking features. 

• You may use the App without enabling health tracking features. 

• You may withdraw consent at any time by disabling tracking features within the App or by contacting PEA. 

• Consent to collect consumer health data is separate from consent to share. PEA does not share your consumer health data without additional consent unless required by law. 

8. Data Retention and Deletion 

PEA retains consumer health data only as long as necessary to provide the tracking features you use or as required by applicable law. 

You may request deletion of your consumer health data at any time by contacting info@happypea.org. Upon receiving a valid deletion request, PEA will delete your consumer health data and direct its service providers to do the same, unless retention is required by law. 

9. Security 

PEA implements reasonable administrative, technical, and physical safeguards to protect consumer health data, including encryption, access controls, and regular security assessments appropriate to the sensitivity of the data. 

10. Changes to This Policy 

PEA may update this policy from time to time. Any updated version will be posted with a new effective date. Where required by applicable law, PEA will notify you of material changes before they take effect. 

11. Contact 

If you have questions about this policy or wish to exercise your rights, please contact PEA: 

Personal Effectiveness Association 

Email: info@happypea.org