Handler Labs
This is the Consumer Health Data Privacy Policy required by Washington's My Health My Data Act (RCW 19.373). It supplements our general privacy policy and applies to Handler Labs apps that handle consumer health data.

Consumer Health Data Privacy Policy

Effective date: May 24, 2026

1. Scope

Washington's My Health My Data Act (MHMDA, RCW 19.373) requires a Consumer Health Data Privacy Policy distinct from a general privacy policy. This policy covers any "consumer health data" processed by Handler Labs apps. It applies whether or not you live in Washington; Washington residents have additional rights enumerated below.

The following Handler Labs apps process consumer health data and are covered by this policy:

2. Categories of consumer health data we process

For each covered app, the categories of consumer health data are:

  • Glucose values you enter in alert and training records (for diabetes-related apps)
  • HealthKit-sourced readings for the data type the app is authorized to read (for example, Blood Glucose for Diabetic Alert Dog Log). For HealthKit data, only a single value at the moment of an alert is stored; the continuous trace is re-fetched on demand and never persisted.
  • Inferred information about a health condition (for example, the fact that you are training a service dog for diabetes implies that you, or someone in your care, have diabetes)
  • Notes you write in training records that may describe symptoms, episodes, medication, or care-team interactions
  • Behavioral training records tied to the management of a health condition (alert events, response logs, accuracy metrics)

3. Sources of consumer health data

All consumer health data is provided by you, directly, in one of two ways:

  • You type it into the app (glucose values, notes, training records)
  • The app reads it from HealthKit after you grant read access on first launch

We do not buy, license, or receive consumer health data from any third party.

4. Purposes for collection and use

Consumer health data is used solely to provide the app's core function: a private training log for service-dog work. Specifically:

  • To display your records back to you
  • To compute training metrics (alert accuracy, sensitivity, specificity) for your own review
  • To generate PDF training summaries and JSON backups that you choose to export
  • To sync records across your own Apple devices via Apple's CloudKit private database

We do not use consumer health data for advertising, marketing, research, sale, or any purpose other than providing the app to you.

5. Categories of consumer health data shared

None. Handler Labs does not share consumer health data with any third party.

6. Third parties and affiliates

Handler Labs has no affiliates and does not share consumer health data with any third party. The only processor involved in handling your data is Apple, which provides the iCloud / CloudKit storage that you yourself control under your own Apple ID. Apple is not a third party with whom Handler Labs shares data; Apple is the platform on which your data sits in your own account.

7. Your rights under MHMDA

If you are a Washington consumer (or fit within the broader categories MHMDA protects), you have the following rights regarding your consumer health data:

  • Right to confirm whether we are processing your consumer health data, and to access that data. Use Settings → Export All Data inside the app to obtain a complete copy in JSON format. The app itself confirms what is being processed: every record is visible to you.
  • Right to a list of third parties with whom your consumer health data has been shared. The list is empty; we do not share consumer health data.
  • Right to delete your consumer health data. Use Settings → Delete All Data inside the app. Deletion propagates to your iCloud private database and is irreversible. You may also delete individual records from the app at any time.
  • Right to withdraw consent to processing of your consumer health data, including HealthKit data. Revoke HealthKit access in Settings → Health → Data Access & Devices. Withdraw consent for all processing by deleting your records (Delete All Data) and uninstalling the app. Withdrawal does not undo processing that occurred before the withdrawal.
  • Right to non-discrimination for exercising any of the above.

To submit a written request (for example, to obtain formal confirmation of deletion), email [email protected] with the subject line "MHMDA request." We will respond within 45 days.

8. Appeals

If we decline a request you make under this policy, we will tell you why. You may appeal by replying to our response within 60 days. We will review and respond to the appeal within 45 days. If the appeal is denied, you may contact the Washington Attorney General's Office at atg.wa.gov/file-complaint.

9. No sale of consumer health data

MHMDA prohibits the sale of consumer health data without a separate authorization. Handler Labs does not sell consumer health data. We will not sell it in the future without first obtaining a valid MHMDA authorization from you.

10. Changes to this policy

If we make material changes to this Consumer Health Data Privacy Policy, we will update the effective date above and provide notice within the app where feasible. We will not expand the categories of consumer health data processed without your fresh consent.

11. Contact

Questions about this policy or about consumer health data? Email [email protected].