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Version: v1.0
Effective Date: March 14, 2026
Applies to: "Consumer health data" as defined by applicable US state laws (including Washington My Health My Data Act and similar laws)

This notice supplements our Privacy Policy and provides additional information required by certain US state consumer health data laws.

1. What Is "Consumer Health Data"?

Under applicable laws, "consumer health data" may include personal information linked or reasonably linkable to you that identifies your health status. In Doserly, this includes:

Category

Medication Information

Examples
Medications, supplements, compounds, dosages, schedules

Category

Adherence Data

Examples
Dose logs, adherence patterns, missed doses

Category

Symptom Data

Examples
Symptoms you track, severity ratings, notes

Category

Lab & Measurement Data

Examples
Lab results, vital signs, measurements you enter

Category

Health Insights

Examples
Patterns, correlations, or AI-generated observations based on your entries

Category

Health-Related Photos

Examples
Images you upload related to health tracking

2. Why We Collect Consumer Health Data

Purpose

Provide medication tracking and reminder features

Necessary for Service?
Yes

Purpose

Synchronize data across your devices

Necessary for Service?
Yes

Purpose

Generate adherence reports and insights

Necessary for Service?
Yes

Purpose

Provide export and data portability tools

Necessary for Service?
Yes

Purpose

Maintain security and prevent fraud/abuse

Necessary for Service?
Yes

Purpose

Generate AI reports (if you use this feature)

Necessary for Service?
Optional (user-initiated)

Purpose

Product analytics (if you opt in)

Necessary for Service?
Optional

Purpose

Generate aggregate statistical insights

Necessary for Service?
Yes (de-identified only)

3. Categories of Sources

We collect consumer health data from:

Source

You (direct entry)

Examples
Information you type, select, or upload

Source

Your device

Examples
Automatic timestamps, device identifiers for sync

Source

Service providers

Examples
Data returned from sync, notification, or AI services

4. Sharing and Disclosure

We disclose consumer health data only:

Recipient

Service providers

Purpose
Operating the app (infrastructure, sync, notifications)
Your Control
Required for service

Recipient

AI providers

Purpose
Generating AI reports
Your Control
Only when you use AI features

Recipient

Your designees

Purpose
Caregivers or others you share with
Your Control
You control sharing

Recipient

Legal authorities

Purpose
When required by law
Your Control
N/A

We do NOT sell consumer health data.

5. Your Rights

Depending on your state of residence, you may have the right to:

Right

Confirm

Description
Confirm whether we process your consumer health data

Right

Access

Description
Obtain a copy of your consumer health data

Right

Delete

Description
Request deletion of your consumer health data

Right

Withdraw Consent

Description
Withdraw consent for processing beyond what's necessary for the service

Right

Appeal

Description
Appeal a decision regarding your request

How to Exercise Rights:

We will respond within the timeframe required by applicable law (typically 45 days, with possible extension).

6. Aggregate Health Insights & De-Identification

We may use consumer health data in de-identified, aggregate form to generate statistical insights about health and wellness trends (such as dosing patterns, adherence rates, and demographic distributions). Our de-identification practices include:

  • Identifier removal: All personal identifiers (user IDs, names, email addresses, dates of birth, device identifiers, IP addresses) are excluded from aggregate analyses
  • Minimum group thresholds: We do not compute or report statistics for groups smaller than a meaningful minimum size, to prevent re-identification through small populations
  • Aggregate-only queries: We use statistical functions (counts, averages, distributions) across user groups — individual records are never extracted, exported, or reviewed
  • No re-identification attempts: We do not attempt to re-identify individuals from aggregate data, and we contractually prohibit any downstream recipient from doing so

These aggregate insights may be used to improve the Services, provide contextual information to users (such as how their adherence compares to general trends), and inform product development. Aggregate insights never contain information that identifies or could reasonably be used to identify you.

Where required by law:

  • We obtain consent before collecting consumer health data for purposes beyond providing the Services
  • We obtain separate consent before sharing consumer health data with third parties for purposes other than operating the Services
  • You may withdraw consent at any time; withdrawal applies to future processing
  • De-identified aggregate analysis (described in Section 6) does not constitute collection or sharing of consumer health data under applicable law, as it contains no information that identifies or is reasonably linkable to any individual

AI Report Features — Separate Consent for Sharing

AI-generated report features involve sharing a subset of your consumer health data (including medications, adherence patterns, symptoms, and lab results) with third-party AI and large language model (LLM) providers, including OpenAI, on servers in the United States. This sharing is separate from the collection of your consumer health data for core app functionality.

By choosing to use AI report features, you provide your separate, specific consent for this sharing. AI report features are entirely optional and user-initiated �� your data is shared with AI providers only when you actively request a report. If you do not wish to share your consumer health data with AI providers, do not use AI report features. All other features of the Services remain fully available without AI data sharing.

You may withdraw this consent at any time by ceasing use of AI report features. Withdrawal does not affect the lawfulness of processing performed before withdrawal.

8. Geofencing

We do not use geofencing technology to identify or track consumers seeking health care services, nor do we collect consumer health data within a geofenced area around health care facilities for purposes prohibited by law.

9. Contact

For questions about this notice or to exercise your rights:
Email: privacy@doserly.com