Effective date: October 6, 2026

This Consumer Health Data Privacy Policy explains how That Paleo Chick, LLC ("That Paleo Chick," "we," "us," or "our") collects, uses, shares, and protects consumer health data, and the rights you have over it. We publish it to meet the Washington My Health My Data Act (RCW 19.373) and similar laws in Nevada, Connecticut, and other states, but we apply it to every member, wherever you live.

It sits alongside our main Privacy Policy, which covers everything else we collect. Where the two overlap, this policy governs consumer health data.

That Paleo Chick, LLC is a Tennessee limited liability company located in Tennessee, United States, and is the "regulated entity" responsible for the data described here. For any question about it, or to exercise any right below, email [email protected]. We answer every message ourselves.

1. What we treat as consumer health data

Consumer health data is personal information that identifies your past, present, or future physical or mental health, or that is derived from it. On our Services, that means only what you choose to record in the That Paleo Chick App (the "App") or in the members area of thatpaleochick.com (the "Site"). We collect it in these categories:

  • Your health profile. The foods you avoid, your allergies and intolerances, and whether you have turned on cycle tracking. The cycle-tracking setting is reproductive health information, and we treat it with particular care.
  • Daily check-ins (your journal). For each day you check in: whether you stayed on plan, your 1 to 5 ratings for things like digestion, energy, bloating, and sleep, the symptoms you tick on a checklist, any foods you ate off plan, notes about meals, a free-text note, and which guided program you were following that day.
  • Information we derive from your entries. Which food groups appear in the meals you logged, whether particular food groups line up with how you rated your symptoms, your averages, your adherence rate, and your streak. These are consumer health data too, and are treated the same way.
  • Meal plans, meal log, and program enrolment. On their own, a saved meal plan is a list of recipes. But because you can choose plans and programs for a particular need (for example a gut reset, celiac-friendly, or low-histamine), and because we compare what you logged eating with how you felt, we treat your meal plan calendar, your daily meal log, and your program enrolments as consumer health data when they are linked to your account.
  • Devotional journal. The reflections, copied passages, and notes you write in the faith features. The law does not call this health data, but it is personal, so we protect it under this policy as if it were.
  • Coach chat messages. If you turn on the optional coach chat, the questions you type. We process them to produce a reply; we do not store them (see Section 5).

We also keep a record of each consent you give or withdraw (which version you agreed to and when). That record is not health data, but it travels with your data and is deleted with it.

What is not consumer health data. Your email address and membership record, which live in our separate membership system. Reading an article about a health topic on the Site. Browsing recipes without signing in. We never infer health information from your browsing, your purchases, or the content you read.

2. Where it comes from

  • Directly from you, when you type it into the App or the Site's members area.
  • From your other devices, when you sign in and your entries sync between the App and the Site.
  • From our own calculations, when the Services derive the patterns described in Section 1 from what you entered.

That is all. We do not buy consumer health data, we do not receive it from data brokers, advertisers, or other companies, and we do not derive it from anything other than what you chose to record.

3. Why we collect it and how we use it

We collect and use consumer health data for one purpose: to provide the features you asked for. Specifically, to:

  • show you your own history and the patterns within it, inside the App and the members area;
  • keep your entries in sync between your devices;
  • phrase your daily insight in plain English and answer your coach-chat questions, if and only if you have separately agreed to those features (Section 5);
  • send you the reminders you turned on;
  • respond to a request you make about your data;
  • keep the Services secure and meet our legal obligations.

We do not use consumer health data for advertising, to build a profile of you for any other purpose, to make decisions about you with legal or similarly significant effects, or to train artificial-intelligence models. The advertising and analytics services on the Site never receive it.

4. Who we share it with

We do not sell consumer health data, we have never sold it, and we will not sell it without your separate, written authorization as the law requires. We do not share it with advertisers, data brokers, analytics partners, or social-media platforms.

Affiliates and third parties. That Paleo Chick, LLC has no affiliates. We share consumer health data with no third party. The only organizations that handle it are the processors below, which act on our written instructions and may not use it for their own purposes. If that ever changes, we will update this list before sharing anything and, where the law requires, ask for your consent first.

Processors who handle it for us. Each receives only what it needs to do its job:

  • Amazon Web Services (AWS). Hosts the encrypted database that holds every category in Section 1, provides the hardware-backed key-management service (AWS KMS) that protects the encryption keys, and stores our encrypted backups. AWS cannot read your entries.
  • Cloudflare. Carries the encrypted traffic between the App, the Site, and our servers and protects them from attack. It passes your entries through and does not keep them.
  • Anthropic, PBC. Only if you have separately agreed to the daily insight or the coach chat (Section 5). For the daily insight, Anthropic receives a short summary of results already calculated from your entries. For the coach chat, it also receives the question you typed and a structured summary of your recent check-ins (dates, ticked symptoms, ratings, and food groups). Your notes, the free text you write about meals, your name, and your email address are never sent, and what is sent is not linked to your identity. Under Anthropic's commercial terms it may not train its models on this content, and it deletes what we send within 30 days unless the law requires it to keep it longer or its automated systems flag a request as a possible violation of its usage policy.
  • Apple. If you allow notifications, Apple issues a push token for your device and delivers the reminders we send. Reminders never contain your entries, and Apple does not receive them.

When the law compels us. We would disclose consumer health data if required by a valid subpoena, court order, or other legal process, or to protect someone's safety. We would tell you first unless the law forbade it.

We ask for your explicit, separate agreement before the App or the Site records any consumer health data. That consent is a step of its own in the App, after the wellness disclaimer; it is not bundled into the Terms of Use, a signup form, or anything else, and declining it leaves the rest of the Services usable.

We ask separately again before any of your data is used by an automated language service: once for the daily insight and once for the coach chat. Each consent is recorded with the version you agreed to and the date.

You can withdraw any of these consents at any time:

Withdrawal stops future collection or processing for that purpose. It does not by itself delete what is already recorded, which you can ask us to do under Section 6.

6. Your rights

You have the right to:

  • Confirm whether we are collecting, sharing, or selling consumer health data about you.
  • Access it, including a copy of every entry we hold and a list of everyone we have shared it with, together with an email address or other way to contact each of them. (Today that list is empty; see Section 4.)
  • Withdraw consent to our collection or sharing of it (Section 5).
  • Delete it, including every revision of every entry and everything we derived from it.
  • Appeal a decision we make about your request (Section 7).

How to exercise them. Use the controls in the App under Account, then Your data (export, consent, and erase), the same controls on the Site at thatpaleochick.com/members/account/, or email [email protected] from the address on your account and tell us which right you want to use. We will not charge you, and we will not treat you differently for asking. You may make up to two requests a year free of charge; we expect never to charge for more, but the law allows a reasonable fee for excessive or repetitive requests.

Verifying it is you. We need to be reasonably sure a request comes from you. Usually a reply from the email address on your account is enough. We will not ask for more than we need. If we cannot verify a request, we will tell you.

Timing. We will respond within 45 days of receiving your request. If a request is unusually complex, we may take up to 45 more days, and we will tell you within the first 45 days why we need the extra time.

What deletion does. When you delete, we remove every revision of every entry from our live systems, together with everything we derived from it and your consent records, and we destroy the encryption key that protects your records so that any remaining copy is permanently unreadable. We instruct each processor in Section 4 that holds a copy to delete it too; Anthropic in any case deletes what we send within 30 days. Encrypted backups are rotated within 90 days, well inside the six months the law allows for archived or backup systems, and your records in them become unreadable the moment your key is destroyed. Closing your member account triggers the same deletion.

7. Appeals

If we decline all or part of a request, we will tell you in writing why. You may appeal by replying to that decision email, or by emailing [email protected] with the subject "Appeal". We will answer your appeal in writing within 45 days of receiving it, explaining what we did or did not do and why.

If we deny your appeal, you may contact the Washington State Attorney General to submit a complaint at www.atg.wa.gov/file-complaint, or your own state's attorney general. We will include that information in our response.

8. How we protect it, and who can see it

Your entries are held in a database that encrypts data at rest, is not reachable from the public internet, and is separate from the systems that run the Site. Your check-ins are filed under an internal identifier rather than your email address, and the free text you write carries an additional layer of encryption. We are extending that record-level encryption to every record we hold for you, using a data-encryption key unique to you that is managed by AWS KMS and never stored on the server that holds the data, and removing email addresses from that database entirely. Logs never contain the content of an entry.

Our systems decrypt your records only to show them to you, to sync them between your devices, and, if you have consented, to compute your insights. Access by the people who run That Paleo Chick is limited to what is needed to operate the service and is logged.

We do not use geofencing, and we will never set up a virtual boundary around any facility that provides in-person health care in order to identify, track, or send messages to anyone near it.

9. How long we keep it

Because the value of a check-in comes from comparing it over time, we keep your entries until you delete them or close your account. Entries are stored as a revision history rather than overwritten, so an earlier version of a day can persist after you edit it; a deletion request removes every revision. Coach chat messages are not stored at all; we keep only a count of how many chat turns you used this month and a count of safety messages shown, neither of which contains anything you wrote.

10. This is not medical care

The App and the members area are wellness tools. The patterns they show you come from your own logs and describe correlations, not causes. They do not diagnose, treat, or give medical advice, and nothing in them replaces a qualified professional. We are not a HIPAA covered entity, and the Services are not subject to HIPAA; the Federal Trade Commission's Health Breach Notification Rule applies to the health records we hold, and we will notify you and the authorities as it and state law require if your consumer health data is ever breached. If something you record worries you, please talk to a doctor.

11. Changes to this policy

If this policy changes we will update the effective date above. If a change materially affects how your consumer health data is collected, used, or shared, we will tell you in the App or by email before it takes effect and, where the law requires, ask for your consent again.

12. Contact us

That Paleo Chick, LLC, a Tennessee limited liability company, Tennessee, United States.

Email: [email protected]

Previous version: September 1, 2026.