Privacy Policy

1. Introduction

This Privacy Policy ("Privacy Policy") describes how Do Good Data LLC, a Delaware limited liability company doing business as Hoam ("Hoam," "we," "us," or "our"), collects, uses, stores, and shares information about you when you use the Hoam mobile application, including Hoamie, our AI health coach, our website at hoamhealth.com, and our related services (together, the "Services").

Please read this Privacy Policy carefully. It explains our practices and is part of our Terms of Service. We ask for your separate permission in the app before we read your Apple Health data or send any information to our AI providers.

Hoam and HIPAA. Hoam is not a "covered entity" or "business associate" as defined under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Information you share with Hoam, including laboratory results, is not protected by HIPAA. It is protected as described in this Privacy Policy, and we treat all Health Information as sensitive. Your Health Information is governed by this Privacy Policy.

Not medical advice. Hoam and Hoamie support general wellness. They are not medical devices and are not intended to diagnose, treat, cure, monitor, or prevent any disease or condition. Always consult a qualified healthcare provider before making medical decisions.

Definitions. "Personal Information" means any information that identifies, relates to, describes, or could reasonably be linked to you. "Health Information" means Personal Information about your body, health, fitness, sleep, nutrition, laboratory results, supplements, or medications, including information from connected devices. "Member" means a person with a Hoam account.

2. Information We Collect

We collect only the information needed to provide the features you use. If you turn off a health feature or Connected Source, we stop collecting its data.

2.1 Information You Provide to Us

2.2 Information from Connected Sources

With your permission, the Services connect to third-party applications and devices ("Connected Sources") to import information about you. We receive only the data types you approve.

Apple Health data we request. Hoam requests permission to read the following Apple Health (HealthKit) data types: heart rate, resting heart rate, heart rate variability, heart rate recovery, sleep analysis, steps, active energy, exercise minutes, and workouts. You choose which of these to allow, and you can change your choice at any time. Hoam does not write any data to Apple Health.

2.3 Information Collected Automatically

We do not collect your precise location. We do not track you across apps and websites owned by other companies, we do not use advertising identifiers, and we do not allow third parties to collect information about your online activities over time and across other websites through the Services. Our website does not respond to browser "Do Not Track" signals, but we honor Global Privacy Control signals (see Section 12).

3. Where Your Information Is Stored

We store and process your Personal Information in the United States using cloud infrastructure operated by trusted service providers. Information is encrypted in transit and at rest.

4. How We Use Your Information

We use your information only for the purposes below. We never use Health Information for advertising or marketing.

Hoam's scores are estimates calculated from your Connected Sources and the information you provide, using the methodology described in the app. They are not clinically validated measurements. Hoam's scores and Hoamie's suggestions are informational. You decide whether to act on them, and we do not use your information to make decisions that produce legal or similarly significant effects about you.

5. How We Share Your Information

We do not sell your Personal Information. We never share Health Information with advertising networks, data brokers, or social media platforms. We share information only as described below. Every service provider we use is bound by contract to protect your information at least as well as this Privacy Policy does and to use it only to provide services to us.

Partners and affiliates. We do not share your Personal Information with any partner or affiliated business.

At your direction. If you choose to share information with a coach, clinician, or another app, we share it at your direction, and that party's own privacy policy applies to its use.

Legal requests. Where permitted by law, we will notify you of legal process seeking your information before we disclose it, unless doing so would be prohibited or would create a risk of harm.

Aggregated data. We may share information that has been aggregated or de-identified so that it cannot reasonably be used to identify you. We will not attempt to re-identify it. This never includes data obtained from Apple Health, which we do not disclose to third parties in any form except as described in Sections 5 and 6 to provide the Services to you.

6. Hoamie and Third-Party AI Technology

Hoamie is an optional AI feature, available to Members 18 and older, powered by large language models from the third-party AI providers listed below. Hoamie's AI features are off until you turn them on. Before you do, the app tells you what information will be sent and to whom, and asks for your explicit permission. What is sent: your messages, images you choose to share with Hoamie, and the minimum health context needed for each reply. If you do not turn them on, none of your Personal Information or Health Information is sent to our AI providers. You can turn Hoamie's AI features off at any time in the app's settings, and nothing more will be sent.

Our current AI sub-processors are listed below. We will update this list before adding a provider and will notify you if a change affects what is sent.

AI can be wrong. Hoamie's responses are generated by AI and may be inaccurate, incomplete, or inconsistent. They are not medical advice and should never replace care from a qualified healthcare provider. Check with your doctor before changing a medication, diet, or treatment, and call 911 in an emergency.

7. Apple Health and Health Information

If you connect Apple Health, Hoam reads only the data types listed in Section 2.2 that you approve on Apple's permission screen. Hoam does not write any data to Apple Health.

For all Health Information, including data from Apple Health, wearables, and laboratory results, we commit that we:

• never use it for advertising, marketing, or use-based data mining;

• never sell it or share it with data brokers;

• use it only to provide and improve your own health management, and use it for health research only with your separate, explicit consent;

• never store it in iCloud; and

• share it with third parties only as described in Sections 5 and 6.

You can stop Hoam from reading Apple Health at any time in iPhone Settings > Health > Data Access & Devices > Hoam. Information already collected remains in your account until you delete it (see Section 9).

8. Your Choices

You can change your choices at any time in the app, without contacting us.

Turning off a feature may limit what the Services can do, but it never blocks features you have paid for that do not depend on that data.

9. Data Security and Retention

9.1 Information Security

We use commercially reasonable administrative, technical, and physical safeguards to protect your Personal Information, including encryption in transit and at rest and access controls that limit Health Information to personnel who need it. No system is completely secure, and we cannot guarantee the security of your information. If a breach affects your Personal Information, we will notify you as required by applicable law, including state breach notification laws and, where applicable, the FTC Health Breach Notification Rule.

9.2 Retention Periods

We keep Personal Information only as long as needed to provide the Services and as required by law.

9.3 Deleting Your Account

You may delete your account and associated Personal Information at any time directly in the Hoam app by going to Settings > Account > Delete Account. We delete your Personal Information within 30 days and remove it from backups within 90 days. You may also request access to, correction of, or deletion of your information by emailing [email protected]. Requests made by email may require identity verification.

Deleting the app does not delete your account. Deleting the app or your Hoam account does not cancel an App Store subscription. Cancel it in iPhone Settings: tap your name, then Subscriptions. We may keep certain information where we need it to complete a transaction you requested, to detect security incidents or fraud, or to comply with applicable law.

10. Third-Party Links and Services

The Services may contain links to, or let you connect with, third-party websites and services, such as wearable makers and laboratory partners. We do not control those third parties, and their own terms and privacy policies govern their use of your information. A link does not mean we endorse a third party.

11. Minor Users and Children

The Services are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information from a child under 13, we will delete it promptly. If you believe a child under 13 has provided us with Personal Information, please contact us at [email protected].

Members between the ages of 13 and 17 must have permission from a parent or legal guardian to use the Services, and may use only the free features that are not designated as Age-Restricted Features in our Terms of Service. Age-Restricted Features, including laboratory results and lab biomarkers, reproductive health data, Hoamie's AI features, subscriptions and in-app purchases, and other features we designate, are available only to Members 18 years of age or older. We may use age information provided by Apple to apply these rules.

12. U.S. State Privacy Rights

Depending on where you live, including California, Colorado, Connecticut, Virginia, Texas, and other states with consumer privacy laws, you may have the following rights:

To exercise these rights, use the in-app options in Section 8 or email [email protected] (for appeals, include "Appeal" in the subject line). We will respond to verified requests within 45 days and may extend this once by an additional 45 days with notice. You may use an authorized agent, and we may require proof of the agent's authority and verify your identity. We will not discriminate against you for exercising your rights. We honor Global Privacy Control signals on our website.

During the preceding 12 months, we have not sold Personal Information or shared it for cross-context behavioral advertising.

13. International Users

The Services are offered only in the United States, and we store and process information in the United States. If you access the Services from outside the United States, your information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your country.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including when we add new features. We will post the updated policy here and change the "Last Updated" date above. For material changes, such as new categories of Personal Information, new purposes, or new AI providers, we will notify you in the app or by email before the changes take effect and will ask for your consent again where required by law or by the App Store.

15. Contact Us

If you have questions about this Privacy Policy or want to exercise your privacy rights, please contact us: