Consumer Health Data

This Consumer Health Data Privacy Policy describes how Otty (“we,” “our,” or “us”) collects, uses, and shares “consumer health data” in the Otty mobile application (“the App”). We provide this policy in accordance with the Washington My Health My Data Act and similar U.S. state consumer health data laws. It supplements, and should be read together with, our Privacy Policy.

“Consumer health data” means personal information linked to you that identifies your physical or mental health status. For Otty, this primarily means your menstrual cycle information.

Consumer Health Data We Collect

• Menstrual cycle data: period (menstrual flow) start dates, cycle length, period length, cycle history, and, if you connect Apple Health, ovulation test results, basal body temperature, and cervical mucus quality.
• Derived cycle information: the cycle phase, estimated next period, and, where Apple Health data confirms it, the ovulation day that the App calculates from the data above.

We do not collect any other category of health data.

Where This Data Comes From

• Directly from you, when you enter your period dates in the App.
• From Apple Health (HealthKit), on a read-only basis, if you are the cycle owner and choose to connect it. We read only menstrual flow, ovulation test results, basal body temperature, and cervical mucus quality, and no other Apple Health data.
• Calculated on your device from the information above.

How and Why We Use It

We use consumer health data only to:

• Provide the App’s cycle-tracking features, including showing your current cycle phase, confirming your ovulation day, and estimating your next period.
• Share your cycle phase, period dates, and confirmed ovulation day with a partner you choose to pair with.

We do not use consumer health data for advertising or marketing, we do not use it for cross-context behavioral advertising, and we do not use it for any purpose beyond providing the App.

How We Share It

• With a partner you choose: if you pair with another user, the cycle phase, period dates, and confirmed ovulation day you choose to share are visible to that partner. Ovulation test results, temperature, and cervical mucus readings themselves are never shared. You control this and can unpair at any time in the App’s Settings.
• With service providers that process data for us: we use Google Firebase (operated by Google) to securely store and sync your data, and we use Google Firebase Analytics and PostHog (hosted in the European Union) to measure how the App’s features are used; this usage information can include cycle-phase context, but not the cycle dates you enter or any data read from Apple Health. These providers act on our behalf under contract and may not use your data for their own purposes.

We do not sell consumer health data, and we have not sold it. We do not share consumer health data with third parties for their own purposes, with advertisers, or with data brokers.

We Do Not Use Geofencing

We do not use a geofence around any location, including health care facilities, to identify or track consumers or to send notifications related to consumer health data.

Your Rights

You have the right to:

• Access: confirm whether we collect, use, or share your consumer health data, and access that data.
• Withdraw consent: withdraw your consent to our collection and sharing of your consumer health data.
• Delete: request deletion of your consumer health data.

You can exercise most of these directly in the App at any time:

• Stop the Apple Health connection in the App’s Settings, or in the iOS Settings app under Privacy & Security, then Health, then Otty.
• Stop sharing with a partner by unpairing in the App’s Settings.
• Export or delete your data, including deleting your account and all associated data, from the App’s Settings.

You can also email us at ottyteam@gmail.com to make a request. We will respond within the timeframe required by applicable law. If we deny your request, you may appeal by replying to our decision. If you are a Washington resident and have concerns about our response, you may contact the Washington State Attorney General at atg.wa.gov/file-complaint.

Contact Us

For questions about this Consumer Health Data Privacy Policy or to exercise your rights, contact us at:
ottyteam@gmail.com