EMBRAYA CONSUMER HEALTH DATA PRIVACY POLICY
Effective Date: 18 January, 2026
Last Updated: 27 February, 2026
This Consumer Health Data Privacy Policy (“CHD Policy”) explains how Embraya handles Consumer Health Data under applicable law (including Washington’s My Health My Data Act (“MHMD”) and the Nevada’s Consumer Health Data Privacy Law (“CHDP”), and similar state laws governing health-related data beyond HIPAA). This CHD Policy applies to U.S. consumers and is incorporated into the Privacy Policy by reference.
1. Consumer Health Data We Collect and Use
Consumer Health Data means data that relates to your health condition, reproductive health, medical treatments, symptoms, tracking inputs, or other personal health information that you yourself provide to us as part of using the Services.
We collect Consumer Health Data only when you voluntarily enter it into the Services, such as through tracking, journaling, reminders, and other interactive features. We do not use Consumer Health Data to make medical diagnoses or treatment decisions.
How We Use Consumer Health Data
We use this data to operate, personalize, and improve the Services. For example, we may use it to:
Enable tracking and reminder features,
Provide personalized insights and analytics,
Improve Service performance and user experience,
Conduct internal research and product development (in de-identified form). De-identified data cannot reasonably be used to identify you, and may be retained by us indefinitely.
Categories of Consumer Health Data may include, where voluntarily provided by you:
reproductive and fertility-related information (e.g., cycle tracking, medication reminders);
health symptoms and journaling inputs;
wellness and treatment-related tracking data;
inferences derived from the above data to provide insights or reminders.
2. How We Share Consumer Health Data
We do not share Consumer Health Data with third parties for their own marketing or analytics purposes without your explicit consent. Embraya does not sell personal information or Consumer Health Data.
We may share Consumer Health Data only:
With your consent (e.g., if you choose to share with a clinician or third-party integration);
With service providers performing work on our behalf under contract, including but not limited to, cloud hosting providers, analytics providers, communications vendors, and security providers, each acting solely on our behalf under contractual confidentiality and data-use restrictions;
To comply with law enforcement or legal process;
To protect safety, legal rights, or to enforce our Terms.
3. Your Rights Over Consumer Health Data
Certain state laws give you specific rights, including:
Access: You may request access to Consumer Health Data we hold about you.
Deletion: You may request deletion of your Consumer Health Data.
Correction: You may request correction of inaccurate data.
Withdraw Consent: Where applicable, you may withdraw consent for certain processing.
To exercise these rights, contact us at support@embrayaapp.com
4. Data Security and Safeguards
We apply security controls designed to protect Consumer Health Data, including access controls, encryption, and monitoring. However, no system is perfectly secure; absolute protection is not guaranteed.
5. Changes to This Policy
Embraya reserves the right, in its sole discretion, to modify, amend, supplement, or replace this CHD Policy at any time. We may provide notice of material changes as required by applicable law. You should consult this Policy regularly for any changes. Your continued access to or use of the Services after any modification becomes effective constitutes your binding acceptance of the revised CHD Policy, and if you do not agree to the modified CHD Policy, your sole remedy is to discontinue use of the Services and close your account.
6. Contact Information
If you have questions regarding this Policy, email: support@embrayaapp.com
614 N DuPont Hwy, Suite 210
Dover, DE 19901
County of Kent