Consumer Health Data Privacy Policy

1. What this policy covers

This policy explains how Harmony collects and uses consumer health data, including sensitive information about relationships, emotions, communication, and wellness. It is separate from and supplements Harmony's Privacy Policy. It is intended to provide the disclosures and rights required by consumer health data laws, including Washington's My Health My Data Act and Nevada's consumer health data law.

Consumer health data generally means personal information that identifies, or can reasonably be linked to, a person and reveals or permits an inference about that person's health or wellness. This policy applies whether the information comes from the Harmony app, a Harmony website, a connected partner, or a professional connection.

2. Consumer health data we collect

• Relationship and communication information: session messages, softened messages, voice-session transcripts, summaries, relationship concerns, communication patterns, and shared conversation history.
• Reflections and wellness activity: journals, check-ins, moods, goals, milestones, appreciations, nudges, handoffs, letters, plans, and related notes.
• Profile and assessment information: birthday, anniversary, relationship details, onboarding answers, sign-up reasons, and signals about attachment, conflict, communication, and love-language preferences.
• AI-created information: coaching responses, summaries, suggested goals, patterns, scores, predictions, and other inferences created from the information a person provides.
• Partner and professional information: pairing records, sharing choices, counselor exports, professional connections, access permissions, professional questions, and professional guidance.
• Technical and usage information: account identifiers, device and app details, feature activity, and website activity when that information can be linked to a relationship or wellness interest.

Harmony does not collect precise location for consumer health purposes and does not use geofences around healthcare or mental-health facilities.

3. Sources of consumer health data

We receive consumer health data from:

• you, when you create an account, answer questions, write, speak, participate in a session, or choose a feature;
• a partner, when both people use a shared Harmony feature or that partner directs Harmony to share something with you;
• a professional, when you connect that professional and permit guidance or other activity;
• your use of Harmony, including product events needed to operate and secure the service; and
• Harmony's AI systems, which create responses and inferences from information supplied through the service.

4. Why and how we use it

Harmony collects and processes consumer health data to:

• provide solo and couples sessions, private coaching, message softening, journaling, check-ins, goals, plans, letters, and relationship insights;
• personalize questions, suggestions, reminders, and AI responses using the information available for that feature;
• carry out a person's current partner-sharing and professional-access choices;
• create exports or answer professional questions only when the person requests or permits it;
• protect accounts, prevent misuse, diagnose problems, provide support, and maintain limited access and security records; and
• comply with law and respond to valid legal or safety obligations.

Harmony does not sell consumer health data and does not use it for targeted or cross-context behavioral advertising. Harmony does not use intimate relationship content to train its own or a third party's general-purpose AI model.

5. Consumer health data we share

We share only the categories needed for the purpose described:

• With a partner you choose: shared-session content and only the journals, moods, goals, check-ins, handoffs, or other items the product identifies as shared.
• With a professional you connect: your identity and only the Harmony areas and date range you currently permit, plus your requests, the professional's questions, and permitted guidance.
• With AI processors: the text, audio, context, or structured information needed to generate the response or feature you requested. Current AI processors include Anthropic and Google.
• With service providers: account, technical, and service information needed for database hosting, authentication, app delivery, notifications, security, support, and website hosting. These providers include Supabase, Apple, Google, and Vercel for the functions listed on our subprocessor page.
• For legal and safety reasons: the minimum information reasonably necessary when disclosure is required by law or needed to protect a person, rights, or the service.

MS Global Holdings LLC operates Harmony. No separate corporate affiliate currently receives consumer health data. We require service providers to use information only for their contracted services and legal duties.

6. Consent and sharing choices

Harmony requests permission through the product experience and this policy before collecting or using consumer health data for the purposes described above. When a feature shares information with a partner or professional, Harmony provides controls for that sharing. You may decline an optional feature or withdraw a sharing choice without losing unrelated free features.

We will request new consent before collecting a new category of consumer health data or using existing data for a materially different purpose that is not described here. If Harmony ever proposes to sell consumer health data, it would first require a separate, signed authorization as required by law. Harmony does not currently sell it.

7. Your consumer health data rights

Subject to applicable law, you may ask Harmony to:

• confirm whether Harmony is collecting, sharing, or selling your consumer health data;
• provide access to the consumer health data Harmony holds about you, including a list of third parties and affiliates with whom it was shared;
• correct inaccurate consumer health data;
• delete consumer health data; and
• withdraw consent for future collection or sharing.

Use the controls in Harmony where available or email privacy@talkharmony.appwith the subject "Consumer Health Data Request." We may verify your identity before completing a request. An authorized agent may submit a request when they provide legally sufficient authority and we can verify the request.

We will respond within the time required by applicable law. Harmony will not discriminate against you for exercising a privacy right, although removing information may make a feature that needs it unavailable.

8. Deletion and withdrawal

Deleting an item in the app removes it from active use according to that feature. An account-deletion request removes or de-identifies consumer health data from active systems, subject to limited information Harmony must retain for security, fraud prevention, legal duties, or dispute records. Encrypted backup copies may remain isolated until overwritten through the normal backup cycle and are not used for product features while retained.

Withdrawing consent stops future collection or sharing covered by that consent after we process the request. It does not reverse a disclosure that you previously directed or that was completed with valid consent.

9. Appeals

If Harmony denies all or part of your request, you may appeal by replying to the decision or emailing privacy@talkharmony.appwith the subject "Privacy Appeal." A person not responsible for the original decision will review the appeal when practicable. We will explain the result and, if the appeal is denied, provide information about contacting the appropriate state regulator.

10. Security and retention

Harmony uses encrypted transport and storage, access controls, database restrictions, encrypted sensitive content, and audit records designed to limit access to people and systems that need it. No online service can promise perfect security. We retain consumer health data only as long as reasonably needed for the feature, the person's choices, security, legal duties, and dispute handling.

11. Changes and contact

We will update the version and effective date when this policy changes. Before a material change takes effect, we will provide additional notice and request consent when the law requires it. Earlier versions may be requested by email.

Harmony is operated by MS Global Holdings LLC, 2108 N St, Suite N, Sacramento, CA 95816, United States. Questions and requests may be sent to privacy@talkharmony.app.