Consumer Health Data Privacy Policy.

This Consumer Health Data Privacy Policy applies specifically to consumer health data as defined under the Washington My Health My Data Act (MHMDA) and similar laws. We apply it to everyone who uses Roonify, not only Washington residents, because we think the protections it requires are the right baseline for a product about relational health.

This document sits alongside our general Privacy Policy, which covers all of our data practices. Where this policy and the general Privacy Policy overlap, both apply; this one governs how we handle consumer health data specifically. Terms like "Your Content" carry the same meaning as in the general Privacy Policy.

Roonify helps people work on their communication and relationships, so some of what you create with us can reflect your mental or emotional state. We treat the following as consumer health data:

• Your responses to Relational Vitals self-assessments
• Your Relational Vitals scores across the five pillars, and the patterns, Constellation, and progress derived from them
• Pre-conversation mood selections
• Severity classifications and communication-pattern signals our system detects
• The content of Journal entries, Circle messages, Daily Practice reflections, and drafts, to the extent that content reveals information about your mental or emotional health

We do not infer or collect health data beyond what you create in the course of using the product. We do not buy health data about you, and we do not collect biometric data.

Every category above comes from one source: you, through your direct use of Roonify. We do not acquire consumer health data from data brokers, advertising networks, social platforms, or other third parties.

We use it for the purposes that make the product work, and for nothing else:

• To deliver AI coaching in real time (responding to you, reframes, rehearsal feedback, Daily Practice feedback)
• To detect communication patterns and tone so we can reflect them back to you in your dashboard, Relational Vitals, and Constellation
• To detect content indicating a risk of serious harm, so the product can respond appropriately and direct you to resources (see "Safety processing" below)
• To maintain your account, history, and progress over time

We do not use consumer health data for advertising, for profiling you for marketing, or to make decisions about you on behalf of any third party.

This is the most important section, so we want it to be plain.

1. Delivery AI (necessary to provide the service, not separately consented). Roonify's core function is AI-assisted communication coaching. When you write in a Circle, complete a Daily Practice exercise, or use a coaching feature, your content is processed by AI to generate the response you asked for. This processing is necessary to provide the service you signed up for, in the same way a messaging app must process your messages to deliver them. It is disclosed here rather than offered as an optional consent, because without it there is no product to use.

   Delivery AI includes Rooni's coaching responses, reframes, rehearsal feedback, Daily Practice feedback, and the tone and pattern classification that powers your own dashboard and Vitals.

2. Safety processing (part of delivery, continues while your account exists). As part of delivery, Roonify checks content for signals of serious or imminent harm and routes those moments to the appropriate safety response. This protects you and others and enforces the community standards you agreed to when you joined. Because it is a safety and platform-integrity function rather than coaching, it continues to operate while your account exists, independent of the optional consent described next.

3. Data for training (separate, opt-in, OFF by default). Using your data to help improve Roonify's models is a separate choice that is off unless you turn it on. It is governed by a distinct consent that you control through the "Help improve Roonify" setting, available during onboarding and any time in Settings. We will never enable it for you, and we will never assume it.

It is off by default. If you never touch it, none of your responses are ever used to improve our models.

Turning it on lets us use your responses to improve Roonify's communication coaching. When this consent is on, we de-identify each contribution at the moment it is stored: your account and Circle identifiers are stored as null, free text and outcome labels are run through automated removal of structured identifiers (such as email addresses, phone numbers, handles, and Circle participant names), and a one-way keyed identifier is used only so you could view your own contributions. We retain outcome labels (for example, whether a suggestion was accepted, edited, or dismissed, and classification and reframe feedback) because those are what make the improvement work.

Turning it off stops all future use immediately and excludes your responses going forward. The server enforces this: when the consent is off, the system writes nothing for training purposes. Because we de-identify before anything is stored, contributions already incorporated into earlier versions of our models cannot be traced back to you and cannot be retroactively pulled out of a model that has already learned from de-identified data; turning the setting off prevents any further contribution.

A word we won't misuse. We say de-identified, not "anonymous." Our process removes structured identifiers, but free text can contain details we cannot guarantee to catch. The training corpus is a pseudonymized internal dataset, handled with restricted access; it is not, and we will not call it, perfectly anonymous.

We do not sell consumer health data, and we do not share it for anyone else's commercial purposes. We never share it for advertising.

We rely on a small number of processors to operate, each contractually bound to handle data only as we instruct:

• AI inference is routed through OpenRouter to open-weight language models, under a Data Processing Agreement that prohibits providers from retaining your content or using it to train their own models.
• Hosting and database providers store your data under contractual protections.
• Billing is handled by Stripe and does not involve consumer health data.

We do not share consumer health data with our analytics provider. If we are ever legally compelled to disclose data, we will comply with the law and make reasonable efforts to notify you unless prohibited.

Under MHMDA and similar laws, you have the right to:

• Confirm and access the consumer health data we hold about you.
• Withdraw consent. You can turn off "Help improve Roonify" at any time in Settings. (Delivery AI and safety processing are necessary to provide the service and are not separately consented; if you do not want them, you can delete your account.)
• Delete your consumer health data. When you delete your account, we delete your data from active systems, and backups are purged on a rolling schedule. De-identified data that can no longer be linked to you may remain.
• Appeal. If we decline a rights request, you may appeal by replying to our decision or writing to the address below. We will respond with our decision and reasoning. If your appeal is denied, you may contact the Washington State Attorney General.

To exercise any of these rights, email policy@roonify.com. We aim to respond within the timeframe required by applicable law.

We do not sell consumer health data as "sale" is defined under MHMDA, and we do not engage in sharing that would require a separate, written authorization. If this ever changes, we would first obtain your valid authorization that meets the law's requirements, separately from the consents described above. We do not anticipate doing so.

Roonify is for adults (18+, or older where local law requires). We do not knowingly collect consumer health data from anyone under the applicable age, and we will delete it if we learn we have.

If we make material changes to how we handle consumer health data, we will update the date above, post the revised policy, and make reasonable efforts to notify you before the changes take effect. We will never quietly reduce these protections.

Roonify Inc.
5 Calle Pineiro Unit 52
Isabela, Puerto Rico 00662
policy@roonify.com