This Consumer Health Data Privacy Policy explains how Harel Levy, doing business as OTRERA ("OTRERA," "we," "us," or "our") collects, uses, shares, and deletes consumer health data. It is written to meet the Washington My Health My Data Act, Nevada's consumer health data law, and the consumer health data provisions of the Connecticut Data Privacy Act. We apply it to everyone who uses OTRERA, wherever you live in the United States.
This is a standalone policy. Our Privacy Policy covers our other data practices. If the two policies differ on consumer health data, this policy controls.
1. Where things stand today
OTRERA is a strength program for women who train hard. It is not available yet. Right now we run a short online quiz to learn whether people want it.
- You answer questions about your training and goals. Before any question about pain or nagging issues, we ask for your consent in a separate checkbox.
- You enter your email to get your plan.
- You may see a price page. If you click to pay, we tell you that your plan isn't ready yet and that you have not been charged. We do not collect card or payment details.
- We email you right away to explain this. You can unsubscribe, and you can ask us to delete your email and answers at any time, including with the "Delete my answers" button on the quiz's final screen.
2. What "consumer health data" means here
Consumer health data is personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. For OTRERA, this means your quiz answers about pain, nagging issues, and past injuries, anything we infer from those answers, and your email address or other identifiers when they are linked to those answers.
OTRERA is a fitness program. It does not provide health care services, and we do not diagnose or treat any condition.
3. Categories of consumer health data we collect
| Category | Examples |
|---|---|
| Current or past nagging issues | Whether something nags you in training now, or did in the past, and whether it stopped you |
| Body area | Knees, shoulders, lower back, hips, ankles or feet, or another area |
| Duration and timing | How long it has been around, and when you notice it most (for example, when you add load or after training) |
| Effect on training | Whether you keep training when something nags you, whether you hold back on load, and what it has cost you |
| What you have tried | What you have tried for it, whether it helped, and why it didn't stick |
| Inferences | Conclusions we draw from these answers to tailor a plan, such as which area to focus on |
| Linked identifiers | Your email address and the quiz session identifier that connects your answers |
What we do not collect: precise geolocation, biometric data, genetic data, reproductive or sexual health data, gender-affirming care information, medications, diagnoses from a clinician, or information about health care services you receive. We do not use geofencing anywhere, including around health care facilities.
4. Why we collect and use it
We collect and use consumer health data only with your consent, and only to:
- show your quiz results, adjusted to what you told us;
- build and tailor your training plan so it accounts for what nags you;
- email you about your plan and early access, including plan details that reflect your answers;
- measure interest in OTRERA using aggregated or de-identified counts (for example, how many people mention knees); and
- keep the Service secure, prevent fraud, and comply with the law.
We do not use consumer health data for advertising, and we do not use it to target ads to you or anyone else.
5. Categories of sources
We collect consumer health data only from:
- you, directly, when you answer the quiz; and
- our own inferences drawn from your answers.
We do not buy consumer health data, and we do not collect it from data brokers, social media, or any other outside source.
6. Categories of consumer health data we share
- With processors (service providers): all categories listed in Section 3, only so they can host, run, store, and support the quiz and our emails on our behalf.
- With anyone else: none. We do not share consumer health data, or inferences from it, with advertisers, social media platforms, data brokers, or any other third party.
We do not sell consumer health data, and we will not.
7. Categories of third parties and affiliates that receive consumer health data
We disclose consumer health data only to processors that act on our instructions under written contracts that limit their use of the data and require them to protect it.
| Category of processor | What it does | Consumer health data it receives |
|---|---|---|
| Quiz platform | Hosts the quiz and stores your answers | All quiz answers, including consumer health data |
| Email service provider | Sends our emails | Your email address and, if an email includes plan details, the details that reflect your answers |
| Hosting and cloud storage providers | Host our systems and store data | Data stored on their systems |
Affiliates: we do not share consumer health data with any affiliate.
Analytics and session-recording tools do not receive consumer health data. They load only if you accept analytics cookies, and we configure them to mask quiz answers.
Advertising platforms (Meta). Meta does not receive consumer health data from us. If you accept advertising cookies, our Meta Pixel sends only a generic page-view event and a generic sign-up ("Lead") event with no parameters, plus standard browser data. Our page addresses do not contain health terms. We never send Meta your email, your quiz answers, or any information about pain or injuries.
You can ask us for the names of the specific processors that have received your consumer health data, with an email address or other online contact for each (see Section 8).
8. Your rights and how to use them
Wherever you live, you have these rights over your consumer health data:
- Confirm and access. Ask whether we collect, share, or sell your consumer health data, and get a copy of it.
- List of recipients. Get a list of all third parties and affiliates with which we have shared your consumer health data, with an active email address or other online contact for each.
- Withdraw consent. Withdraw your consent to our collection and sharing of your consumer health data at any time. We will stop using it and delete it.
- Delete. Ask us to delete your consumer health data, and your email and other answers if you wish.
- Review and correct. Review your consumer health data and ask us to correct anything that is wrong.
How to make a request:
- email [email protected] with the subject "Health Data Request" and tell us which right you want to use;
- use the "Delete my answers" button on the quiz's final screen or the delete link in any of our emails.
Verification. To protect you, we will confirm the request comes from you, usually by asking you to reply from, or click a link sent to, the email address you used in the quiz. We will ask only for what we need. You may use an authorized agent where the law allows, and we may ask for proof that you authorized them.
Timing. We will respond within 45 days of receiving your request. If we reasonably need more time, we may extend this once by up to 45 more days, and we will tell you why within the first 45 days.
Cost. Requests are free, up to twice in any 12-month period. If requests are clearly unfounded, excessive, or repetitive, we may charge a reasonable fee or decline, and we will explain why.
What deletion covers. When we delete your consumer health data, we delete it from our records, instruct every processor and third party that holds it to delete it, and delete it from archives and backups within six months.
We will never treat you differently, or deny you the Service, because you used these rights.
9. Appeals
If we decline your request in whole or in part, you can appeal. Email [email protected] with the subject "Health Data Appeal" and tell us why you disagree. We will respond in writing within 45 days of receiving your appeal, explaining what we did or did not do and why.
If we deny your appeal, you may contact your state attorney general, for example:
- Washington: Washington State Office of the Attorney General, www.atg.wa.gov
- Nevada: Nevada Office of the Attorney General, ag.nv.gov
- Connecticut: Connecticut Office of the Attorney General, portal.ct.gov/ag
10. Consent
- Collection and use. We ask for your consent in a separate checkbox, which is not pre-checked, before any question about pain or nagging issues. The checkbox links to this policy. If you do not check it, we do not collect those answers.
- Sharing. Before sharing consumer health data with anyone other than a processor, we would ask for your separate consent. We do not do this today.
- Sale. Selling consumer health data would require your separate signed authorization. We do not sell it and will not.
You can withdraw consent at any time (see Section 8). Withdrawal does not affect use that happened before, but we will stop going forward and delete the data.
11. How long we keep it
We keep consumer health data only as long as we need it for the purposes in Section 4, or until you withdraw consent or ask us to delete it, whichever comes first.
If OTRERA does not launch, we will delete all consumer health data by March 31, 2027. If we decide to launch before then, we will email you first. We will not use your consumer health data for any new purpose without asking for your consent again, and we will give you an easy way to have it deleted.
12. Security
Only people and processors who need consumer health data to do the work described here can access it. We protect it with reasonable administrative, technical, and physical safeguards, including access controls, encryption in transit, and contracts with our processors. No system is completely secure. If a breach affects your data, we will notify you as the law requires.
13. Tracking across websites
No third party collects consumer health data through OTRERA to track you over time and across other websites or online services. Advertising tools receive only the generic events described in Section 7, never consumer health data, and only after you accept advertising cookies.
14. Adults only
OTRERA is for adults 18 and older. It is not directed to children or teens, and we do not knowingly collect data from anyone under 18. If we learn that someone under 18 has given us data, we will delete it. If you believe this has happened, email [email protected].
15. Where your data is processed
OTRERA serves users in the United States. Our team and processors may handle data in the United States, Israel, and other countries. Wherever it is processed, we protect it as this policy describes.
16. Changes to this policy
If we change this policy, we will post the new version on this page and update the effective date. If we make a material change, such as collecting new kinds of consumer health data, using it for a new purpose, or sharing it with a new category of recipient, we will email you before the change takes effect and ask for your consent again where the law requires.
17. Contact us
Harel Levy, doing business as OTRERA
Email: [email protected]