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Consumer Health Data Privacy

How Noongil handles consumer health data under US state health privacy laws.

Noongil Consumer Health Data Privacy Policy

Last Updated: August 3, 2026 Effective Date: August 3, 2026

This Consumer Health Data Privacy Policy describes how Noongil collects, uses, and shares consumer health data as defined by the Washington My Health My Data Act (RCW 19.373) and similar state laws. This policy applies to all users of the Noongil application.

This is a separate document from our general Privacy Policy, which provides additional information about our overall data practices.

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1. Categories of Consumer Health Data We Collect

| Category | Specific Data Types | |----------|-------------------| | Mental and emotional health status | Mood descriptions, mood scores, emotional state during conversations | | Physical health status | Self-reported symptoms (type, severity, location), sleep quality and duration, activity descriptions | | Medication information | Medication names, dosages, schedules, adherence records | | Health-related conversation records | Transcripts of voice check-in conversations, AI-generated summaries of conversations | | Caregiver communications | Short caregiver voice messages and related sender, recipient, delivery, and playback metadata | | Health concerns and observations | Self-reported concerns, triggers, and personal observations about daily experiences | | Neutral log comparisons | Recorded averages or counts across groups of self-reported check-in days, without an explanation of why a change occurred | | Health-related care memories | Key health-related moments extracted from your conversations |

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2. Sources of Consumer Health Data

| Source | Description | |--------|-------------| | Directly from you | Information you provide through voice conversations, text input, and account setup | | Generated by AI | Summaries and organized observations generated by artificial intelligence from your self-reported data | | Derived from your data | Neutral comparisons of recorded averages or counts across groups of self-reported check-in days |

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3. Purposes for Collection and Use

| Purpose | Data Used | |---------|-----------| | Care journaling | All health data categories — to help you journal and reflect on your daily experiences | | Medication reminders | Medication names, dosages, schedules — to send you timely reminders | | Neutral log comparison | Relevant self-reported check-in categories — to show recorded differences without inferring or explaining why a symptom changed | | AI conversation | Conversation transcripts, health context — to provide relevant and personalized conversational responses | | Caregiver sharing | Check-in summaries and caregiver-facing updates — to share information with people you designate, at your request | | Family voice messages | Short recordings — to let a linked caregiver send a familiar voice message to the member | | Doctor Visit Reports | All health data categories — to generate summaries you can share with your healthcare provider |

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4. Categories of Third Parties and Affiliates That May Receive Consumer Health Data

We may share consumer health data with the following categories of service providers and authorized recipients in order to operate the App:

| Category | Data Received | Purpose | |----------|---------------|---------| | Cloud infrastructure and storage providers | Account data, care check-ins, summaries, medications, caregiver voice messages, and related care context | Secure storage, synchronization, and product operations | | Google LLC — Gemini API (AI and speech processing) | Live microphone audio when cloud voice is enabled; check-in transcripts; self-reported sleep, mood, symptoms, activity, medication timing, and other care context; report text submitted for generation or narration | Real-time transcription and responses, organizing saved check-ins, summaries, Doctor Visit Reports, and report narration | | Data analysis and product infrastructure providers | Self-reported entries, neutral comparison aggregates, usage signals, and related technical data | Product performance, reliability, and log-comparison processing | | Authorized caregivers and linked members | Check-in summaries, caregiver-facing updates, and caregiver voice messages that are deliberately shared | Supporting the caregiver features you enable |

We do not sell your consumer health data to any party. We do not share your consumer health data for advertising purposes.

The production Gemini API project is configured as a paid service. Under the Gemini API Additional Terms, Google states that paid-service prompts and responses are not used to improve Google products. Google may log prompts and responses for a limited period solely for safety and abuse prevention and required legal or regulatory disclosures. Noongil does not claim zero data retention and does not use Google Search or Google Maps grounding with check-in data.

Through the applicable service terms and data-processing agreements, we require service providers, including Google, to provide the same or equal protection of consumer health data described in this Policy and to process it only for the disclosed purposes.

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5. How to Exercise Your Rights

Right to Access

Request a copy of your consumer health data by using "Export My Data" in the App settings, or by emailing privacy@noongil.ai.

Right to Delete

Request deletion of your consumer health data by using "Delete Account" in the App settings, or by emailing privacy@noongil.ai. We will process your request within 30 days.

Right to Withdraw Consent

You may withdraw consent for collection or sharing of your consumer health data at any time:

  • Stop future health data processing: Withdraw Health Data consent in App settings. Health-processing features remain blocked unless you grant the current consent version again. You may also delete your account and existing data.
  • Stop cloud voice transmission: Withdraw Cloud Voice consent in App settings. Cloud voice remains disabled unless you grant the current consent version again.
  • Stop caregiver sharing: Remove the caregiver in App settings
  • Contact us: Email privacy@noongil.ai

Withdrawal of consent takes effect immediately for future data collection. It does not affect data already collected, which you may separately request to be deleted.

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6. How Consent Is Obtained

Before collecting any consumer health data, we obtain your affirmative consent through an in-app consent flow that specifically describes:

  • The categories of health data we collect
  • The purposes for collection
  • That check-in transcripts and the health details you report are sent to Google LLC's Gemini API for the disclosed AI-organization purposes
  • That microphone audio is transmitted to Google LLC's Gemini API only when you separately enable cloud voice
  • That caregiver voice messages are intentionally stored for playback for up to 30 days
  • Your right to withdraw consent at any time

Separate consent is obtained for:

  • General health data collection (required to use the App)
  • AI analysis of health-related content (required only for AI processing)
  • Voice audio processing by cloud AI (required only for live conversation modes)
  • Caregiver data sharing (required only if you choose to link a caregiver)
  • External product analytics (optional and not required for health features)

Consent is obtained through clear, affirmative actions (toggling consent switches and tapping "I Agree"). We do not use pre-checked boxes or bundled consent.

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7. How to Withdraw Consent

Withdrawing consent is as easy as giving it:

  • In the App: Navigate to Settings to adjust consent preferences, remove caregivers, or delete your account
  • By email: Send your request to privacy@noongil.ai
  • Effective immediately: Changes to consent take effect immediately for future data processing

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8. Contact Us

If you have questions about this Consumer Health Data Privacy Policy or wish to exercise your rights, contact us at:

Noongil Email: privacy@noongil.ai

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