Consumer Health Data Privacy Policy

This policy supplements our Privacy Policy and describes how MotorNation Holdings LLC handles “consumer health data” in TORCH™, as that term is used in U.S. state laws such as Washington's My Health My Data Act, Nevada SB 370 and similar laws. TORCH is a consumer wellness app. It is not a healthcare provider, and HIPAA does not apply to TORCH.

1. Consumer health data we collect

• Body information you enter or allow: height, weight and weigh-in history, body measurements, the sex option you choose, and your BMI calculated from height and weight.
• Nutrition: meals, calories, macronutrients, water, dietary style, food likes and dislikes, and allergies you choose to enter.
• Goals and behaviors: weight-loss goal and pace, activity level, optional fasting sessions, habits, streaks and badges.
• From Apple Health, if you allow it: steps, workouts, heart rate during sessions you record, sleep, resting heart rate, heart rate variability and weight; and blood glucose only if you connect a glucose monitor (glucose stays on your iPhone and is never uploaded or sent to any AI).
• Runs, walks and rides you record on the Train tab: GPS route, time, distance, pace, calories and heart rate (from Apple Health or a Bluetooth sensor you connect). These stay on your iPhone, and in Apple Health if you allow it.
• Progress and body photos, which stay only on your iPhone.
• What you choose to tell Alex.

We do not upload precise location: the GPS route of a session you record stays on your iPhone and in Apple Health. We do not collect biometric identifiers, reproductive or sexual health information, gender-affirming care information, medical diagnoses, medications, or lab results.

2. Sources

You (what you enter and say), Apple Health on your iPhone (only with your permission), and TORCH's own calculations.

3. Purposes

Only to provide the features you ask for: calculating your plan, tracking, reports, reminders, badges and coaching from Alex, and keeping the service secure. We do not use consumer health data for advertising, and we do not sell it.

4. Sharing

Anonymized usage analytics (TelemetryDeck) never include health values. We share consumer health data with no one else except as required by law.

5. Consent

We collect consumer health data only with your consent, which you give during setup and through Apple's Health permission screen. You can withdraw consent at any time by turning off Apple Health access in the Health app, deleting individual entries, or deleting your account.

6. Your rights

• Access: see your data in the app, and export it (Settings → Privacy & Security → Data & Privacy → Export My Data), including a list of the processors above.
• Correction: edit your profile and entries in the app.
• Deletion: delete individual entries, or your whole account in Settings. Account deletion removes your data from our live database immediately and from backups within the provider's backup window.
• Withdraw consent as described above.
• Appeal: if we decline a request, reply to our decision to appeal; if you're still unsatisfied you may contact your state attorney general.

To make a request, email info@motornationleasing.com from any address and tell us the request. For security we will verify the request inside your signed-in app before acting on it. We respond within 45 days.

7. Security

Encryption in transit, per-user access controls on every table, server-side-only credentials, iOS file protection for local data, and no routine human access to health data. See the Privacy Policy section 6.

8. Contact

MotorNation Holdings LLC · [BUSINESS MAILING ADDRESS REQUIRED BEFORE LAUNCH] · info@motornationleasing.com