Consumer Health Data Privacy Policy

• Not medical advice. Lighter is a self-tracking tool, not a medical device. See Not Medical Advice below.
• We are not a medical provider and we are not subject to HIPAA. We are not a “covered entity” or a “business associate,” and we do not claim to be “HIPAA compliant.” The protections in this document come from consumer-privacy law and from our own commitments, not from HIPAA.
• 18+. Lighter is intended for adults 18 and older.

“Consumer Health Data” means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. Consumer Health Data does not include information that is publicly available, de-identified, or aggregated. What Consumer Health Data we collect may differ depending on how you interact with us.

For Lighter, Consumer Health Data reflects the fact that you use a GLP-1 / peptide tracking app together with the entries you make about your medications, body metrics, side effects, and related goals.

The Consumer Health Data we collect may include:

We also draw limited inferences from your entries about your past, present, or future physical or mental health status in order to provide the tracking and progress features you request. Lighter includes optional community features (“Groups”); any content you choose to post there is handled as described in the “Community Features” section below. Lighter has no AI chatbot and no iMessage integration, so we do not collect any data associated with those functions.

Health Entries — the class we protect absolutely

Throughout this policy and our general Privacy Policy, “Health Entries” means, specifically:

• the medications you select, including brand and generic names;
• the route, dose amount and unit, injection site, and pain level you record for a dose;
• the side effects you log and their severity;
• your weight, height, body metrics, starting and goal weight, goal pace, biological sex, and date of birth;
• your food, nutrition, and water logs, and any food photo you take;
• your progress photos;
• your answers to onboarding questions about your health, goals, and journey;
• any free-text note you write; and
• any value read from, or written to, Apple Health.

Health Entries are never used for advertising or marketing, are never disclosed for advertising or marketing, and are never transmitted to an advertising platform or to our attribution provider.

What we do share for advertising measurement — and it includes none of the items above — is described in How We Disclose Your Consumer Health Data below.

As described in the Categories of Sources of Personal Data section of the Lighter Privacy Policy, we may collect Personal Data, including Consumer Health Data, from the following sources:

• Directly from you, when you complete onboarding, log data, upload progress photos, post in community Groups, or contact us.
• From Apple Health, only if you grant permission: profile facts, activity, nutrition, water, and weight may be read; nutrition, water, and weight logged in Lighter may be written to Apple Health. Lighter does not write medications, doses, side effects, or photos to Apple Health.
• From the App Store and our subscription providers, for purchase and entitlement status.
• Automatically from your device, for app functionality, security, the limited coarse-category analytics described below, and the advertising measurement described below.

We collect, use, disclose, or otherwise process your Consumer Health Data as reasonably necessary for the purposes described in the Our Commercial and Business Purposes for Collecting Personal Data and Other Permitted Purposes for Processing Personal Data sections of the Lighter Privacy Policy, but primarily to provide you with products and services as you have requested or authorized.

We use Consumer Health Data to (a) provide, personalize, and maintain the tracking features and progress views you request; (b) secure and monitor our Services, prevent fraud and abuse, and fix errors; (c) honor your privacy choices and legal rights; and (d) perform internal analytics to improve service quality. Your full-fidelity health data (exact weights, dose amounts, medication names, side effects, notes, and photos) is never sent to analytics or advertising services; only coarse categories, tied to your random account identifier rather than your name or email, are used for analytics.

We do not use your Health Entries for advertising, to target ads, to build advertising audiences, or to infer characteristics about you for advertising.

We disclose your Consumer Health Data as reasonably necessary to Third Parties and Affiliates, which may include:

Service Providers. We may disclose your Consumer Health Data to contractors, processors, and vendors to provide and improve our Services to you. They are permitted to use it only to provide those services to us, under contracts that limit them to our instructions.

The service providers who process Consumer Health Data on our behalf, under contracts that limit them to our instructions, currently include:

We do not sell consumer health data for money. Some state definitions of “sale” and “share” are broader than that, and the advertising measurement described below may fall within them; we do not claim otherwise. No Health Entry is any part of that measurement.

We never share your Health Entries — your medications, doses, routes, injection sites, pain levels, weight and body metrics, side effects, food, nutrition and water logs, onboarding answers, notes, progress photos, food photos, or Apple Health data — with advertising or attribution partners, and we never use them to target ads.

Advertising measurement — what actually leaves, and who receives it

We run advertising to help people discover Lighter, and we measure how those ads perform. This is the one place where data about you reaches a company that is not our service provider, so we describe it here as well as in the general Privacy Policy.

Our attribution provider. AppsFlyer assembles this measurement for us as our service provider. It receives standard install and session attribution data — which includes your IP address, your device’s vendor identifier (IDFV), and your device’s user-agent string — an internal Lighter account identifier, and four conversion events: the app was opened; an account was created (with the sign-in method you used, which is “apple”, “google”, or “email” — never your email address); a free trial was started (with nothing attached); and a subscription was started (with the gross price and currency of the purchase).

Our advertising platforms. We advertise on third-party advertising platforms — currently Meta (Facebook and Instagram). At our instruction, AppsFlyer forwards to the platform we advertise on the four conversion events, with the gross price and currency attached to the subscription event, together with device and connection information that includes your IP address, your device’s vendor identifier (IDFV), and your device’s user-agent string. These advertising platforms are not our service providers for this data. They receive it as independent advertising businesses, use it for their own advertising purposes under their own terms, and may combine it with information they already hold about you. Meta is currently the only advertising platform that receives it; if we advertise on additional platforms in the future, they will receive the same limited measurement data, and we will update this policy.

We have configured this to apply to people who installed Lighter after seeing one of our ads on that platform, rather than to everyone who uses the app.

None of your Health Entries is ever included. No medication, dose, route, injection site, pain level, weight, body metric, side effect, food or water log, onboarding answer, note, or photo is part of it. For the avoidance of doubt, the foregoing excludes data that originates from Apple Health — data obtained from Apple Health is used only to provide health and fitness features in the app, is never used for advertising or data mining, is never sold, and never reaches our attribution provider or any advertising platform.

No health value is included in this sharing. Whether identifiers and conversion events of this kind, in this context, are “consumer health data” under Washington, Nevada or Connecticut law is an open question, and we do not claim they are not. That is why this sharing is disclosed in this policy, and why AppsFlyer and Meta will appear on the third-party list we give you if you exercise the Access right below.

Apple’s tracking prompt. Lighter never accesses your device’s advertising identifier (IDFA), and Lighter does not show Apple’s App Tracking Transparency prompt. That means no cross-company advertising identifier ever leaves the app. It does not mean the sharing described above is switched off: Apple’s tracking prompt governs the advertising identifier, and your IP address, vendor identifier, and user-agent string are not governed by it. Because we show no prompt, there is nothing there for you to decline.

Your choices, and their limits. We do not currently offer a control inside the app that turns this measurement sharing off while you keep using Lighter. What exists today: you can delete your account in the app (Settings → Delete Account), which deletes your account and its data and sends our attribution provider a request to erase what it holds about you; or you can email us at [email protected] — you do not need an account — and we will treat your message as a request under Consumer Health Data Rights below. Two limits apply either way: our service providers keep processing data in order to run the app itself; and we cannot compel an advertising platform to delete copies it may have made of conversion events and identifiers already delivered, and we may not be able to locate or delete data already transmitted.

Lighter includes optional community features (“Groups”) that you can choose to use. When you join a Group and post a message, photo, or reaction, that content — together with your display name and logging streak — is visible to the other members of that Group. It is shared content, not private data, so you should not post anything you want to keep confidential, including sensitive health details. Your logs, dose data, weight, and other personal entries are never posted to a Group unless you type them into a message yourself.

Because Groups are visible to other people, we do not guarantee your anonymity in them. Other members may be able to infer who you are from what you post, from your display name, or from other context.

To keep Groups safe and supportive, we provide tools to report messages and block members, and we may remove content or restrict accounts that violate our community guidelines. When content is reported, we retain a copy of the reported message — and, for a reported photo, the image for up to 30 days — so we can review and act on the report even if the underlying message is later deleted, after which we delete it. If you delete your account, your Group memberships, messages, reactions, and community photos are removed. A private Group you created may continue under another member’s leadership, so its name and description may remain, but its link to you is removed. A report record and its content snapshot may also be retained as described above, on a legitimate-interest basis, for safety and to comply with law.

Where required, we obtain your opt-in consent before collecting consumer health data that is not strictly necessary to provide a product or service you requested. Separately, we obtain your opt-in consent before sharing consumer health data for any non-necessary purpose. These consents are presented clearly and conspicuously in the interface where collection or sharing occurs and describe the categories of data, purposes, recipients, and how to withdraw consent. You may withdraw consent at any time, and we will stop the collection or sharing covered by the withdrawn consent.

Advertising measurement is not covered by those consents. It contains none of your Health Entries, and we treat it as non-health measurement rather than as a disclosure of consumer health data. Whether that treatment is correct is an open question, and we do not claim certainty — which is why the practice is disclosed in full in this document, its recipients are named, and it is subject to the rights below.

Withdrawing consent to health-data collection does not stop advertising measurement, because the two are separate: advertising measurement does not draw on the health data you consented to. Stopping advertising measurement is handled through the routes described in Your choices, and their limits above.

We need to collect certain Consumer Health Data in order to provide the Service to you. If you ask us to delete required Consumer Health Data, or withdraw your consent to its future collection, we may not be able to provide the Service or certain features of it.

On our website, non-essential analytics run through Google Analytics, loaded with Google Tag Manager. Google Consent Mode starts with analytics storage denied, so limited cookieless requests may run before you opt in, but analytics cookies and persistent measurement stay off. You can change or withdraw this consent at any time using the “Cookie preferences” link in the website footer.

If you are a resident of, or we have collected your Consumer Health Data from, certain U.S. states, you may have rights afforded to you, including those set forth in this section (subject to certain exceptions).

• Access: You have the right to request confirmation of or access to the Consumer Health Data that we process about you, including a list of all third parties to whom we have disclosed your Consumer Health Data and their contact information. If you make that request today, the list we give you will include our service providers named above, our attribution provider AppsFlyer, and the advertising platform Meta Platforms, with contact information for each.
• Deletion: You have the right to request that we delete the Consumer Health Data that we have collected about you. You can delete your entire account and its data from inside the app (Settings, then Delete Account), or by emailing us. Deleting your account also sends our attribution provider a request to erase the data it holds about you. Conversion events and identifiers already delivered to an advertising platform cannot be recalled: we cannot compel that platform to delete copies it may have made.
• Withdraw Consent: You have the right to withdraw consent from us collecting and disclosing your Consumer Health Data.
• Appeal: If we refuse to take action on your request within a reasonable period of time after receiving it, you may appeal our decision. If we deny your appeal, you have the right to contact the Washington Attorney General at www.atg.wa.gov/file-complaint.

To exercise your rights, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. You do not need an account to submit a Valid Request.

Because a Lighter account can be created without a name or email address, we may not be able to connect a request to a specific account. If that happens we will tell you what we would need in order to do so, rather than simply refusing. We may decline a request where applicable law permits — for example where complying is prohibited by law, where it would harm another person’s rights, where we are unable to authenticate you as the person to whom the data relates, or where the request is unreasonable or excessive — and we will tell you which ground applies.

You may also authorize an agent to exercise your rights on your behalf. To do this, you must give your agent written permission, and we may request a copy of that written permission when the agent makes a request.

You may submit a Valid Request by contacting us at [email protected].

If you have any questions about this section or whether any of these rights apply to you, please contact us at [email protected]. We will not discriminate against you for exercising your rights under applicable law.

• Washington (My Health My Data Act). This document is our consumer health data privacy policy. It discloses the categories of consumer health data we collect and their sources, the purposes of collection and use, the categories of data shared and the categories of recipients — including our attribution provider and the advertising platform named above — and how to exercise your rights, including deletion, access, withdrawal of consent, and appeal. We do not sell consumer health data for money, and we do not collect or use geofencing around health facilities. Some state definitions of “sale” are broader than a sale for money; as described above, the advertising measurement may fall within them, and we do not claim otherwise.
• Nevada (SB 370). We do not sell consumer health data for money. We will not do so in the future without your affirmative, voluntary consent.
• Connecticut. Residents have the rights described above.
• California (CCPA/CPRA). Health data is “sensitive personal information.” We limit its use to providing the Services and the disclosed purposes. For our position on “sale” and “sharing” — which we do not deny as to the advertising measurement described above — see the Your Privacy Choices section of our general Privacy Policy.

Lighter is a self-tracking tool. It provides general tracking and progress features and does not provide medical advice, diagnose conditions, recommend treatments or dose changes, or establish a provider-patient relationship. Always consult a licensed clinician for questions about your health or medications. Do not use the app for emergencies.

If we make material changes, we will update the effective date and, where required, obtain fresh consent before collecting or sharing consumer health data in new ways.

You can reach us with questions or requests at [email protected] — Flame Industries Inc., 7901 4th St N, STE 300, St. Petersburg, FL 33702.