Opsin

Consumer Health Data Privacy Policy

Last updated: July 22, 2026

This Consumer Health Data Privacy Policy (“Health Data Policy”) supplements, and is incorporated into, the Opsin Privacy Policy. It applies specifically to “consumer health data” as defined under applicable state consumer-health-data laws.

These laws include the Washington My Health My Data Act (“MHMDA”), the Nevada consumer health data privacy law (SB 370), and similar laws (together, the “Health Data Laws”). This policy describes the categories of consumer health data that Opsin App, LLC (“Opsin,” “we,” “us,” or “our”) processes on your device, how that data is used, the fact that Opsin does not receive or share it, and the rights you have with respect to it.

Opsin processes this consumer health data only on your device. It is never transmitted to, stored by, shared by, or sold by Opsin. The rights and controls below are exercised primarily through your device.

If there is any conflict between this Health Data Policy and the general Privacy Policy with respect to consumer health data, this Health Data Policy controls. Capitalized terms that are not defined here have the meaning given to them in our Privacy Policy.

1Who This Policy Applies To

This Health Data Policy applies to “consumers” as defined under the Health Data Laws (generally, natural persons who are residents of, or whose consumer health data is collected in, a state with a consumer-health-data law, and who are acting in an individual or household capacity). It does not apply to information processed in an employment context or to individuals acting in a commercial or business-to-business capacity. Depending on your state of residence, some or all of the rights and protections described below may apply to you.

2What “Consumer Health Data” Means

“Consumer health data” means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. It can include information that is derived or inferred from non-health information, including through algorithms or machine learning. Because Opsin provides sleep, circadian-rhythm, light-exposure, and related wellness features, certain data we process may qualify as consumer health data, as described in the next section.

3Categories of Consumer Health Data We Collect

Opsin does not collect consumer health data. The app processes the following categories of consumer health data only on your device, and this information is never transmitted to, or received by, Opsin:

Any recommendations or insights the app derives from this data are also generated and stored only on your device.

4Sources of Consumer Health Data

Because Opsin does not receive consumer health data, it has no sources of such data. On your device, the app obtains this data from: information you enter; your device’s sensors; and Apple HealthKit and Core Location, in each case only with the permission you grant.

5How and Why We Use Consumer Health Data

The app uses consumer health data on your device to generate your circadian, sleep-timing, light-exposure, and jet-lag guidance. Because this data never leaves your device, Opsin does not use it for any other purpose, and never for advertising. We do not use or disclose it beyond providing the on-device features you request.

6How and With Whom We Share Consumer Health Data

We do not share consumer health data with anyone. It is processed only on your device and is never transmitted to Opsin or any third party.

7We Do Not Sell Consumer Health Data Without Your Authorization

We do not sell consumer health data. It never leaves your device, so there is nothing for us to sell or to authorize for sale.

8Consent

The app accesses health and location data only after you grant permission through your device’s standard Health and Location prompts. You may withdraw that permission at any time in your device settings.

9Your Rights

Subject to the Health Data Laws and any applicable exceptions, you have the right to:

To exercise these rights, contact us using the information in Section 15. We will not discriminate against you for exercising your rights. We may need to verify your identity before responding, and, where permitted, may ask for information such as your email address or account details. You may use an authorized agent to submit a request; we may require the agent to provide proof of authorization and may require you to verify your identity directly. We will respond within the timeframes required by applicable law. Because this data stays on your device, you exercise these rights directly: revoke the app’s access in your device settings, or delete the app to remove the data it stored on your device.

10Appeals

If we decline to take action on your request, we will notify you of our decision and the reasons for it, and we will provide instructions for how to appeal. You may appeal by contacting us at the address in Section 15. If your appeal is denied, Washington residents may submit a complaint to the Washington State Attorney General at atg.wa.gov/file-complaint, and residents of other states may contact their state attorney general.

11Employee, Contractor, and Processor Access

Because consumer health data is processed only on your device and is never transmitted to Opsin, no Opsin employee, contractor, or service provider has access to it.

12Data Security

Consumer health data is protected by the security of your device and Apple’s HealthKit and Location frameworks, because it remains on your device. Opsin does not maintain a copy to secure. No system is completely secure, and we cannot guarantee absolute security.

13No Geofencing

We do not use a geofence to establish a virtual boundary around any entity that provides in-person health care services in order to identify or track consumers seeking health care services, collect consumer health data, or send notifications, messages, or advertisements related to consumer health data or health care services.

14Data Retention

Opsin does not retain consumer health data, because it never receives it. The data remains on your device and is removed when you revoke the app’s access or delete the app.

15How to Contact Us and Submit Requests

If you have questions about this Health Data Policy, or wish to exercise any of the rights described above, you may contact us at:

16Changes to This Policy

We may update this Health Data Policy from time to time. When we do, we will revise the “Last updated” date above and, where appropriate, provide additional notice. We will not collect, use, or share consumer health data for purposes that are materially different from those disclosed at the time of collection without first obtaining your consent. This Health Data Policy is available at all times through the Website and App.