Consumer Health Data Privacy Policy

This policy is provided by the entity identified in Section 8 (“we”, “us”, “DailyBeBetter”) as the entity that determines the purpose and means of processing consumer health data for the DailyBeBetter Coach.

Who this applies to. Washington’s My Health My Data Act applies extraterritorially to any entity that conducts business in Washington or provides products or services targeted to Washington consumers and that determines how consumer health data is processed — regardless of where the entity is incorporated or where the data is hosted. Because DailyBeBetter is offered to consumers worldwide, including Washington residents, this policy applies to consumer health data we collect from or about Washington consumers. Our UAE incorporation and our EU (Paris) data hosting do not exempt us, and our wellness / coaching positioning is not a carve-out from the Act.

What “consumer health data” means here. Under RCW 19.373, consumer health data expressly includes a person’s mental-health status and data that is inferred or extrapolated from non-health information via algorithms or machine learning. The DailyBeBetter Coach collects emotional and wellbeing self-reports and generates AI-derived inferences about emotional and mental state, so those self-reports and AI-derived inferences are consumer health data within scope.

1. What Consumer Health Data We Collect

We collect only the consumer-health-data categories below:

• Health and wellbeing self-reports — information you choose to share about how you are doing, including stress, sleep, habits, mood, and overall wellbeing.
• Emotional and mental-state inferences — patterns and summaries the AI coach derives about your emotional and mental state from what you share. This includes the Client Graph (your evolving map of inner patterns) and the AI session recaps. Data inferred or extrapolated via algorithms or machine learning is expressly consumer health data under the Act.
• Spiritual or religious beliefs — where you choose to share them in coaching.
• Biological sex — where you choose to provide it, including a “prefer not to say” choice, which is itself recorded.
• Family and relationship narratives — where what you share may reveal health or wellbeing information.

We do not collect or use this data for advertising, and we do not sell it.

2. How We Collect It

We collect this data in two ways:

• The in-app intake conversation — when you tell us about your goals, wellbeing, and situation as you set up your coaching.
• The live coaching session — your voice or text is streamed to our voice processor (ElevenLabs) so the AI coach can respond in real time, and a written transcript and AI recap are generated.

Your voice is streamed live during a session and is never stored as an audio recording — we keep the written transcript and the AI recap, not an audio file.

3. Purposes

We process consumer health data only to deliver and improve the coaching service you requested — to let the AI coach understand you across sessions, surface patterns, and support you over time. We do not use consumer health data for advertising or marketing, and we do not sell it.

4. Sources

We obtain consumer health data from two sources:

• Directly from you — what you tell us in the intake conversation and in your coaching sessions.
• Inferred by the AI coach — emotional and mental-state inferences the AI derives from what you share (the Client Graph and the AI session recaps).

5. Who We Share It With

We share consumer health data only with the processors that are necessary to operate the coaching service, and we name them here. This is the same canonical coaching-recipient set named in our general Privacy Policy.

• AWS — hosting of all coaching data at rest (DynamoDB + S3), in the EU (Paris) region.
• ElevenLabs — the live voice / transport processor; it also orchestrates the AI coaching model (Claude Haiku 4.5) under its own data-processing agreement.
• Cognito (AWS) — authentication and account identity, including Sign in with Apple and Google.
• Apple — App Store distribution, Sign in with Apple, and in-app purchases.
• Google — Google Play distribution, Sign in with Google, and in-app purchases.

We share consumer health data with a third party only after you give the separate Washington share consent described in Section 6. If you do not give that share consent, we do not share your consumer health data with third parties for purposes beyond delivering the coaching you requested. We do not sell consumer health data, and we do not share it for advertising.

6. Consent (RCW 19.373.030)

Washington’s Act requires two distinct, freely given, specific, informed, opt-in consents — one to collect consumer health data beyond what is necessary to provide the requested service, and a separate and distinct one to share it. In the DailyBeBetter app these are presented as two distinct, default-unchecked choices:

• (a) Collection consent — a default-unchecked opt-in to our collecting consumer health data beyond what is strictly necessary to deliver core coaching. You give this by an affirmative act; it is not pre-ticked and not bundled with any other consent.
• (b) Share consent — a separate, distinct, default-unchecked opt-in, presented apart from the collection consent, before any third party receives your consumer health data. It is optional: declining it still lets you use coaching.

Leaving the share consent unchecked records your choice not to share — that choice is itself recorded as a deliberate not-share decision. You can change either consent at any time.

7. Your Washington Rights

Under RCW 19.373.040 and 19.373.060 you have the right to:

• Access the consumer health data we have collected about you.
• Withdraw consent to our collection or sharing of your consumer health data.
• Delete your consumer health data.

How to exercise these rights. You can withdraw consent and request deletion in the app, and you can delete your account and associated data in-app or via /delete-account. Account deletion wipes your coaching data from our systems; because our production voice processor (ElevenLabs) runs in Zero Retention Mode, it holds no copy to delete.

Enforcement. The Act creates no standalone private right of action; a violation of the Act is treated as a per se violation of Washington’s Consumer Protection Act (chapter 19.86 RCW), enforceable by the Washington Attorney General and through the Consumer Protection Act’s private right of action.

8. Controller and Contact

The controller is Daily Be Better - F.Z.C, a UAE Ajman Free Zone company (License No. 55075), Ajman Free Zone C1 Building, B.C. 1308557, Ajman Free Zone, Ajman, United Arab Emirates.

This document remains a draft pending counsel review.

Email: office@dailybebetter.com

Last updated: June 2026 (draft — pending counsel review and entity incorporation).