Privacy Policy

Wholly Health ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services.

1. Information We Collect

Personal Information

We collect information that you provide directly to us, including:

• Name and email address
• Account credentials
• Profile information
• Communication preferences

Health and Wellness Data

With your explicit consent, we may collect:

• Dietary preferences and restrictions
• Wellness assessments and survey responses
• Body composition tracking data
• Meal planning and recipe preferences
• Symptom tracking information
• Hormone cycle and metabolic health data
• Lab result information submitted for educational analysis
• Food, supplement, and product images submitted for AI scanning

Usage Information

We automatically collect certain information when you use our app:

• Device information (type, operating system, unique identifiers)
• App usage data (features accessed, time spent)
• Log data (IP address, access times, pages viewed)
• Subscription and purchase history

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Personalize your wellness experience
• Generate customized meal plans and recommendations
• Power AI-assisted features including food scanning, body composition analysis, lab result education, and the Dr. Lake AI health chat
• Process and manage your subscription through Apple In-App Purchase
• Send you updates, newsletters, and promotional materials (with your consent)
• Respond to your questions and provide customer support
• Monitor and analyze usage patterns and trends
• Detect, prevent, and address technical issues or fraudulent activity
• Comply with legal obligations

3. AI-Powered Features and Data Processing

The following AI features are available in the app and involve data processing:

• Dr. Lake AI Health Chat: Text-based health questions are sent to an AI model to generate educational responses. Conversation history is stored on your device and on our servers to maintain context.
• Food & Product Scanner: Images of food, ingredients, or product labels are sent to an AI model for nutritional and ingredient analysis.
• Body Composition Scanner: Images submitted for body composition estimation are processed by an AI model. Results are returned to your device and stored in your account history.
• Lab Result Reviewer: Lab data or images you submit are sent to our server for AI-assisted educational analysis. This data is processed in memory and is not stored on our servers after the session ends. Results are saved only on your device.

AI-generated responses are for educational purposes only and do not constitute medical advice. Our AI systems use general knowledge models and do not have access to your complete medical history.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers

We may share information with third-party service providers who perform services on our behalf, including:

• RevenueCat — subscription and in-app purchase management
• Apple App Store — payment processing for in-app purchases
• Manus AI — AI model infrastructure for AI-powered features
• GoHighLevel — email automation and customer communication
• Resend — transactional email delivery
• Fullscript — professional supplement dispensary integration
• Cloud hosting and database services — secure data storage and infrastructure

Legal Requirements

We may disclose your information if required by law or in response to valid requests by public authorities.

Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our services. You may request deletion of your account and associated data at any time by contacting us at the email address below. Certain data may be retained as required by law or for legitimate business purposes.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. All data is transmitted over encrypted connections (HTTPS/TLS). However, no method of transmission over the internet or electronic storage is 100% secure.

7. Your Rights and Choices

You have the following rights regarding your personal information:

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information and account
• Opt-Out: Unsubscribe from marketing communications at any time
• AI Data Consent: Withdraw consent for AI data processing at any time in Settings > AI Data Sharing
• Data Portability: Request a copy of your data in a portable format

To exercise these rights, please contact us at the email address provided below.

8. Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately.

9. Third-Party Links

Our app may contain links to third-party websites or services, including Fullscript and podcast platforms. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. Your continued use of our services after changes are posted constitutes your acceptance of the revised policy.

11. Contact Us