Kinase Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy ("Health Data Policy") supplements, and is incorporated into, the Kinase Privacy Policy. It applies specifically to "consumer health data" as defined under applicable state consumer-health-data laws, including the Washington My Health My Data Act ("MHMDA"), the Nevada consumer health data privacy law (SB 370), and similar laws (together, the "Health Data Laws"). It describes the categories of consumer health data that Opsin App, LLC ("Opsin App," "we," "us," or "our") processes on your device through Kinase (the "App"), how that data is used, the fact that Opsin App does not receive or share it, and the rights you have with respect to it.

Opsin App processes this consumer health data only on your device. It is never transmitted to, stored by, shared by, or sold by Opsin App. The rights and controls below are exercised primarily through your device.

If there is any conflict between this Health Data Policy and the general Privacy Policy with respect to consumer health data, this Health Data Policy controls. Capitalized terms that are not defined here have the meaning given to them in our Privacy Policy.

1. Who This Policy Applies To

This Health Data Policy applies to "consumers" as defined under the Health Data Laws (generally, natural persons who are residents of, or whose consumer health data is collected in, a state with a consumer-health-data law, and who are acting in an individual or household capacity). It does not apply to information processed in an employment context or to individuals acting in a commercial or business-to-business capacity. Depending on your state of residence, some or all of the rights and protections described below may apply to you.

2. What "Consumer Health Data" Means

"Consumer health data" means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. It can include information that is derived or inferred from non-health information, including through algorithms or machine learning. Because Kinase provides activity, movement, light-exposure, screen-time, and related wellness features, certain data the App processes may qualify as consumer health data, as described in the next section.

3. Categories of Consumer Health Data We Collect

Opsin App does not collect consumer health data. The App processes the following categories of consumer health data only on your device, and this information is never transmitted to, or received by, Opsin App:

Activity and exercise data obtained through Apple HealthKit with your permission, for example step counts, walking and running distance, workouts and their type and duration, and exercise minutes;

Light-exposure data obtained through Apple HealthKit with your permission, specifically time spent in daylight;

Activity you log yourself in the App, which the App writes into Apple Health on your device at your direction;

Precise location (through Apple Core Location), used on your device to calculate local sunset times;

Video and audio recordings you create in the App, and the on-device check of whether a face appears in them, to the extent any of that may be considered health-related. The App does not identify you, does not create or store a faceprint or scan of face geometry, and does not compare faces across recordings or against any database; and

Screen-time and app-shielding information, namely the apps or categories you have chosen to shield and whether you have met the conditions you set. The App does not receive or record which apps you open or how long you use them.

Any progress, streaks, or insights the App derives from this data are also generated and stored only on your device.

4. Sources of Consumer Health Data

Because Opsin App does not receive consumer health data, it has no sources of such data. On your device, the App obtains this data from: information you enter; recordings you create; your device's sensors and camera; and Apple HealthKit, Core Location, and Family Controls, in each case only with the permission you grant.

5. How and Why We Use Consumer Health Data

The App uses consumer health data on your device to determine whether you have met the conditions you set for unlocking the apps you chose to shield, to show your own progress and history, and to write activity you log manually into Apple Health at your direction. Because this data never leaves your device, Opsin App does not use it for any other purpose, and never for advertising. We do not use or disclose it beyond providing the on-device features you request.

6. How and With Whom We Share Consumer Health Data

We do not share consumer health data with anyone. It is processed only on your device and is never transmitted to Opsin App or any third party. If you enable the optional setting to save your recordings to your photo library, copies are placed in Apple Photos on your device and are then subject to your own device and iCloud settings; they are still never transmitted to Opsin App.

7. We Do Not Sell Consumer Health Data Without Your Authorization

We do not sell consumer health data. It never leaves your device, so there is nothing for us to sell or to authorize for sale.

8. Consent

The App accesses health, location, camera, microphone, photo-library, and Screen Time data only after you grant permission through your device's standard system prompts. You may withdraw any of those permissions at any time in your device settings. Permission to read from Apple Health and permission to write to Apple Health are granted and withdrawn separately.

9. Your Rights

Subject to the Health Data Laws and any applicable exceptions, you have the right to:

Confirm and access: confirm whether Opsin App collects, shares, or sells your consumer health data (it does not), and access the data, which resides on your device;

Withdraw consent: withdraw the permission you granted the App to access Health, Location, Camera, Microphone, Photos, or Screen Time data, at any time in your device settings;

Delete: delete your consumer health data by deleting recordings in the App, deleting entries in the Apple Health app, revoking the App's access in your device settings, or deleting the App, which removes the data the App stored on your device. Because Opsin App never receives this data, there is no server copy for Opsin App to delete; and

Appeal: appeal a decision if we decline to act on your request, as described in Section 10.

To exercise these rights, contact us using the information in Section 15. We will not discriminate against you for exercising your rights. We may need to verify your identity before responding, and, where permitted, may ask for information such as your email address or account details. You may use an authorized agent to submit a request; we may require the agent to provide proof of authorization and may require you to verify your identity directly. We will respond within the timeframes required by applicable law. Because this data stays on your device, you exercise these rights directly: revoke the App's access in your device settings, or delete the App to remove the data it stored on your device.

10. Appeals

If we decline to take action on your request, we will notify you of our decision and the reasons for it, and we will provide instructions for how to appeal. You may appeal by contacting us at the address in Section 15. If your appeal is denied, Washington residents may submit a complaint to the Washington State Attorney General at https://www.atg.wa.gov/file-complaint, and residents of other states may contact their state attorney general.

11. Employee, Contractor, and Processor Access

Because consumer health data is processed only on your device and is never transmitted to Opsin App, no Opsin App employee, contractor, or service provider has access to it.

12. Data Security

Consumer health data is protected by the security of your device and Apple's HealthKit, Core Location, Family Controls, and media frameworks, because it remains on your device. Recordings are held in the App's private on-device storage. Opsin App does not maintain a copy to secure. No system is completely secure, and we cannot guarantee absolute security.

13. No Geofencing

We do not use a geofence to establish a virtual boundary around any entity that provides in-person health care services in order to identify or track consumers seeking health care services, collect consumer health data, or send notifications, messages, or advertisements related to consumer health data or health care services.

14. Data Retention

Opsin App does not retain consumer health data, because it never receives it. The data remains on your device and is removed when you delete it in the App or the Apple Health app, revoke the App's access, or delete the App. Copies you chose to export to your photo library remain there until you remove them.

15. How to Contact Us and Submit Requests

If you have questions about this Health Data Policy, or wish to exercise any of the rights described above, you may contact us at:

Email: privacy@kinaseapp.co

Mail: Opsin App LLC, 21750 Hardy Oak Blvd, Suite 104 #616929, San Antonio, Texas 78258

16. Changes to This Policy

We may update this Health Data Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, provide additional notice. We will not collect, use, or share consumer health data for purposes that are materially different from those disclosed at the time of collection without first obtaining your consent. This Health Data Policy is available at all times through the Website and App.