Consumer Health Data Privacy Policy

Why this is a separate 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 wellness.

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.

What counts as consumer health data here

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 and progress derived from them
• Pre-conversation mood selections
• Severity classifications and communication-pattern signals our system detects
• The content of Circle messages, letters, 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.

What Rooni remembers

For each relationship you add, Roonify keeps a page called "What Rooni remembers". Only you can see it, and you approve every line Rooni adds to it.

• Lines about you. Short notes about how you show up in that relationship. Rooni adds a line only after asking you, and you can write, edit or remove lines yourself.
• The story so far. A list of the Circles you shared with that person. What you both wrote stays in those Circles, and Rooni may quote it, with its date, when it helps your growth.
• How it is used. When Rooni coaches you about that relationship, the relevant lines are sent with your request to our AI providers, under the same zero data retention rules as the rest of your content.
• How it is protected. Memory lines are encrypted with a key held on your device.
• Your control. You can delete everything Rooni remembers about a relationship at any time from that page; your Circles stay. Deleting your account deletes it all.

Where this data comes from

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.

How we use consumer health data

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 and Relational Vitals
• 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.

Two distinct kinds of AI processing

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.

How "Help improve Roonify" works

If you turn on Help improve Roonify, Roonify keeps de-identified, pseudonymized signals from your practice, like which exercises you finish, the patterns Rooni flags and how open items close. Your words are never used. Signals are stored under a random research ID, not your account, and results are shared only as group statistics. Turning the setting off, or deleting your account, deletes your research data right away.

Who we share consumer health data with

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. Every request goes only to providers listed as zero data retention, and providers that may use content for training are excluded.
• Hosting and database providers store your data under contractual protections.
• If you enable a practice reminder, your browser vendor's push service receives a technical subscription and a generic notification payload. The payload does not include messages, scores, or other consumer health data.

The Roonify app does not use a third-party 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.

Your rights

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.

No sale, no sharing for which authorization would be required

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.

Children

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.

Changes

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.