Last updated: October 26, 2026
This policy explains how DesignX Inc. (“Aspiro”, “we”, “us”), 851 W Front St Ste 1501, Boise, ID 83702, United States, handles consumer health data in the Aspiro WINS app (the “App”, shown on your home screen as “Aspiro”). It is written for the Washington My Health My Data Act, Nevada’s consumer health data law (NRS 603A.400 to 603A.550) and Connecticut’s rules for consumer health data. We apply it to everyone who uses the App, wherever they live.
Consumer health data is information linked to you that shows your past, present or future physical or mental health. In a fitness, nutrition and coaching app, that is most of what you put in. Everything else, and more detail on each item below, is in our general Privacy Policy at https://aspirohealth.com/app-privacy-policy/.
We never sell consumer health data, and we never use it for advertising.
1. The consumer health data we collect, and how we use it
| Category | What it includes | How we use it |
|---|---|---|
| Body and health details | Sex, age (worked out from your date of birth), height, weight and goal weight, body fat, lean mass and body measurements, activity level and fitness goal | To set your calorie and macro targets, build and adjust your programs, show your progress, and give the AI coach the context to answer you |
| Pregnancy (only if you tell us) | That you are pregnant or postpartum, and the related dates | To keep your programs and nutrition targets safe for that stage |
| Injuries, limits and allergies | Injuries and movement limits you track and how serious each is, food allergies and foods you avoid | To leave out exercises your injuries rule out, and foods you cannot eat |
| Fitness activity | Workouts, sets, reps and weights, programs, personal records, mobility and meditation sessions, streaks and points, and workouts from other apps that Apple Health gives us (type, start and end time, length) | To track your training, count your progress and points, and plan what comes next |
| Nutrition | Meals and foods you log, portions, water, supplements, barcodes you scan, recipes and meal plans, and the history of your nutrition goal and daily targets | To track your eating against your targets and suggest meals |
| Meal, menu and gym photos | Photos you choose to analyse | To estimate what is on a plate or a menu, or which equipment a gym has. We use each photo for that one request and do not store it |
| Progress photos | Photos of your body you choose to keep | To let you compare your progress. They are kept in private storage that only you can see |
| Wellbeing and journaling | Daily check-ins (energy, soreness and stress, 1 to 5), intentions, commitments, journal entries and your “My Why” items | To show your trends and keep your goals in front of you. Journal text is never sent to the AI coach |
| Smart meditations | The feeling you pick, anything you type or say in What’s on your mind?, the script written for you and its recording | To write and record a meditation for you |
| Apple Health readings (only the types you allow) | Active energy, steps, workouts, weight, body fat, lean mass, height, sleep, resting heart rate, heart rate variability, heart rate, VO2 max, exercise time, distance, flights climbed and mindful minutes; menstrual cycle and State of Mind only if you switch them on | To add your burned calories to your food budget, count your activity, and show sleep and recovery. Most of these readings stay on your iPhone (section 2) |
| Conversations with the AI coach | What you type or say to the coach, photos you attach, the facts it remembers about you and the summaries it writes of your chats | To answer you, carry out what you ask it to (such as logging a meal), and remember what you told it |
| What you write to others | Messages, comments and posts, and anything about your health you put in them | To deliver them to the people you choose, and, if you message one of the AI-powered training buddies in the Community while AI features are on, to write its reply |
| Your human coach’s records (only if you work with one) | Your answers to your coach’s intake form and check-ins, the habits your coach gives you and whether you did them, and the goals and targets your coach suggests | To run your coaching |
| What we work out from the above | Readiness and recovery levels, calorie and macro targets, exercise and food filters, and the coach’s notes and summaries | To personalise your training, nutrition and coaching |
| Feature use | Records that you used a feature, such as that you finished a workout, logged a meal or completed a meditation, with rough size ranges (for example, workout length in bands). Never your health values, foods, photos or text | To find out which features work and where the App is confusing |
Notes from your own Second Brain library (section 1 of the Privacy Policy) can contain anything you choose to save, including health information. They are private to you and are used only when you act on them.
We do not collect genetic data or biometric identifiers (such as face or voice prints). We receive the text of what you say to the coach, never the recording. We do not collect precise location: the App’s restaurant search uses a point rounded to about 1 km, only when you ask for it, and does not store it.
We do not use your consumer health data to train AI models, and under their API terms the AI providers we use do not train their models on it either.
2. Where it comes from
- You, when you type, tap, speak or photograph something in the App.
- Apple Health on your iPhone, when you connect it and allow each type. The App reads those types on your iPhone. Of what it reads, only three things are saved to your account: weight, body fat and lean mass readings; a simple marker for each workout recorded by another app; and, only if you turn on Include sleep in my weekly recap, a weekly sleep summary for that email. If you turn on Share sleep and recovery with my coach, one line summarising last night’s sleep and recovery is sent with your AI coach requests. Cycle and State of Mind data are held in memory only and are never stored or sent anywhere.
- Your human coach, if you work with one: the intake form, check-in questions, habits, programs and goal suggestions they send you.
- The App and our servers, which work out targets, levels and summaries from the data above, and record which features you use.
3. When we collect it, and when we ask first
We collect consumer health data when you enter it, connect a source, or use a feature that needs it, and we use it for that feature (section 1).
Some uses wait for your yes, or stay off until you turn them on:
- AI features. Before any AI feature sends anything, the App asks whether you agree to send what you share with it to the AI service providers we use. Nothing is sent unless you choose Allow. Change it at any time in Settings › Coaching › AI features.
- Apple Health. Nothing is read until you tap Connect Apple Health and allow each type on Apple’s screen. Change it in iOS Settings › Health › Data Access & Devices.
- Off until you turn them on: Share sleep and recovery with my coach (Settings › Health › Apple Health), Include sleep in my weekly recap (Settings › Notifications), Share workouts to Community (Settings › Sharing), Search by meaning for Second Brain (Settings › Data), and every human-coach category marked “off” in section 4.
- Your health data. The App asks once, in a screen called Your health data (for a new member, the first step after creating the account), before it keeps your health data: Allow and continue, or Choose what’s collected to set each choice below. The same screen asks about sharing with each team you are already in and each coach you already work with, one row each (see section 4); if you have already answered about your health data, the App asks only about those, in a screen called Your sharing. You can change any of them at any time in Settings › Privacy & safety › Your health data.
- Off until you turn it on: Share usage analytics, which sends the feature-use records in section 1. (If you joined before 2026-10-25 it stays as you had it until you answer Your health data.)
- On until you turn them off: Remember our conversations (Settings › Coaching › Coach memory, also Coach remembers me in Your health data), which lets the coach write summaries of your chats; and sharing your finished workouts with teams you were in before the App started asking (a row for each of them on Your health data, or on Your sharing if you already answered about your health data; Settings › Your health data › Teams).
4. Who we share it with
We share consumer health data only with the people and services below, and only as described. We have no affiliates that receive it.
People you choose:
- Your human coach, only if you connect with one. On the connect screen the App shows what your coach will see, and you can change any category at any time in Settings › Coaching › Your coach › What <your coach> can see. However you connect, every category starts off; when you connect with a coach’s code you choose what to share right there (or connect without sharing). If you connect another way (for example by paying for coaching on the web), the App asks what your coach can see the next time you open it (on Your health data, or on Your sharing if you already answered about your health data), and nothing is shared until you answer. The categories you can turn on: workouts and streaks; body measurement trends; your chats with your coach’s AI twin, which your coach reviews to keep it accurate; nutrition (daily totals only), intentions and commitments (counts only, never what you wrote), progress photos, challenges and teams, injuries and limits (the areas and how serious each is, never your own notes), sleep and recovery (your energy, soreness and stress check-ins), daily activity, connection (counts of cheers and commitments kept), and habits from your coach. Your coach also sees your answers to their intake form and check-ins, and, while you share nutrition, your goal, daily calorie and protein targets and program. Your coach never sees what the AI coach remembers about you or its summaries of your chats. If your coach uses the AI tools in their web portal, the categories you share can be summarised by the AI service providers below, only while you have AI features on. Human coaches are independent professionals, not Aspiro staff.
- Teams you join. When you join a team, the App asks whether to share your finished workouts, streaks, levels and kept commitments with it (for example, a workout’s name, length and a new personal record). If you say no, nothing more is shared with that team, and it also stops seeing what you shared before. Teams you were already in keep sharing until you answer their row on Your health data (or Your sharing), which the App shows once. Change it for each team at any time in Settings › Your health data › Teams.
- The Community, only if you turn on Share workouts to Community, and only for workouts you finish after that.
- People you message or comment to, who see what you send them.
Public food databases. When you search for a food or scan a barcode, your iPhone sends the search words or the barcode, with no account id, to Open Food Facts and to USDA FoodData Central.
Legal and safety. When the law requires it, or to protect someone’s safety. If Aspiro is part of a merger, acquisition or sale of assets, with notice to you.
Service providers. These companies handle consumer health data for us, only to provide their service to us, under contracts that limit what they may do with it:
| Service provider | What it receives |
|---|---|
| Supabase (on Amazon Web Services, US) | Everything saved to your account (hosting, database, storage, sign-in) |
| Google (Gemini API), with OpenRouter as a backup route to the same Google models, OpenAI and Anthropic | What an AI feature needs for your request: your message and attached photos, the profile, training, nutrition, check-in and memory context the coach uses, and the sleep and recovery line if you turned it on. Only with AI features on |
| Fish Audio | The text of spoken coach replies and of your smart meditation scripts, to turn into speech. Only with AI features on |
| Apple | Speech recognition, when your iPhone cannot do it on the device (it turns your speech into text under Apple’s privacy terms) |
| PostHog (US) | The feature-use records in section 1, linked to your account id. Only while Share usage analytics is on |
| Expo (650 Industries) | The text of the push notifications you turn on, which can mention your workouts, check-ins or messages |
| Resend | The emails we send you, including the weekly sleep summary if you turned it on |
| Vercel | Hosts the web portal your human coach uses to see what you share with them |
5. Your rights
You can:
- See and correct most of your data in the App, and edit or delete entries there.
- Get a copy of your consumer health data, and a list of every third party and service provider we have shared it with or that has received it, with a way to contact each one.
- Delete it. Settings › Account › Delete account erases your account and your consumer health data from our servers right away. You can also ask us to delete particular data. When we delete at your request, we also tell the service providers and third parties that received it to delete it. Copies in our hosting provider’s automatic backups are replaced as those backups expire, within 30 days. AI providers keep request data only for a limited time under their own terms (typically up to 30 to 55 days) to detect abuse, and then delete it; we cannot shorten that. When you delete your account, your human coach loses access, and the coaching records in Aspiro tied to your account are deleted, except the payment records the law requires us to keep, which are kept without your name.
- Withdraw consent at any time with the switches in section 3, or by disconnecting Apple Health or ending coaching. Withdrawing does not affect what was done before. Turning off Allow AI features stops every AI request right away, and our servers refuse AI requests for your account.
How to ask. Email contact@aspirohealth.com from the address on your account, with “Consumer health data request” in the subject, or use aspirohealth.com/contact. We confirm it is you by replying to that address. You do not need to create an account to ask. Requests are free, up to twice in any 12 months.
When we answer. Within 45 days of receiving your request. If we need more time, we may extend that once by up to 45 more days when it is reasonably necessary, and we will tell you why within the first 45 days.
Appeals. If we decline your request, in whole or in part, you can appeal by replying to our answer or emailing contact@aspirohealth.com with “Appeal” in the subject. We will decide within 45 days of receiving your appeal and explain our decision in writing. If we deny your appeal, you can contact your state Attorney General:
- Washington: https://www.atg.wa.gov/file-complaint
- Nevada: https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/
- Connecticut: https://portal.ct.gov/ag/common/complaint-form-landing-page
We will not treat you differently for using any of these rights.
6. Tracking across other apps and sites
No third party collects consumer health data about your activity over time and across other apps or websites through the App. We do not use advertising identifiers or advertising and tracking tools.
7. Changes to this policy
We will post any change here and update the date at the top. If a change is material, we will tell you in the App before it takes effect. Before we collect a new category of consumer health data, or use or share it for a new purpose, we will update this policy and ask for your consent first.
8. Contact
DesignX Inc.
851 W Front St Ste 1501, Boise, ID 83702, United States
contact@aspirohealth.com · aspirohealth.com/contact