QALO Holdings LLC

Consumer Health Data Privacy Policy

Last Updated: September 18th 2025

QALO Holdings LLC (referred to as “QALO,” “we,” “us,” or “our”) is committed to protecting the privacy and personal information of our customers, website visitors, mobile application end users, as well as individuals whose information we collect (“you,” or “yours”) in connection with your use of our products (including any wearable devices or other devices that collect, process, or provide information) (“Products”) or services, and interaction with any of our websites or mobile applications (collectively, including the Products, the “Services”). This Consumer Health Data Privacy Policy (“Consumer Health Data Privacy Policy”) describes how we collect and use consumer health data about you, and supplements the QALO website privacy policy, available at https://qalo.com/pages/privacy-policy (“Privacy Policy”). 

This Consumer Health Data Privacy Policy contains the following information, which you can access by scrolling down: 

  • What is “Consumer Health Data”?

  • Consumer Health Data We Collect

  • How We Collect Consumer Health Data

  • How We Use Collected Consumer Health Data

  • Disclosing Your Consumer Health Data

  • Additional Rights of Individuals in Washington and Nevada

  • Nevada Consumer Health Data Rights

  • Washington Consumer Health Data Rights

  • How to Exercise Your Rights

  • Modifications to this Consumer Health Data Privacy Policy

  • How to Contact Us

What is “Consumer Health Data”?

For purposes of this Consumer Health Data Privacy Policy, consumer health data is defined as personal information that is linked or reasonably could be linked to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. Relevant statutes include in the definition of “consumer health data” a wide variety of information that we do not collect. For the purposes of this Consumer Health Data Privacy Policy, QALO collects the following information relating to physical or mental health status:

  • Bodily functions, vital signs, or symptoms

  • Reproductive or sexual health care information 

  • Biometric data (data that is generated from measuring physiological, biological, or behavioral characteristics of an individual)

  • Any information that QALO may process to associate or identify a consumer with consumer health data that is derived or extrapolated from non-health information in order for QALO to infer or derive data related to the above consumer health data.

Consumer health data does not include personal information that is used to engage in public or peer-reviewed scientific, historical, or statistical research that adheres to all other applicable ethics and privacy laws and is monitored or governed by an independent oversight entity. 

We also do not consider consumer health data to include information that can no longer be used to identify a specific natural person, whether in combination with other information or otherwise (such as de-identified or aggregated consumer information). 

For information regarding how we use and disclose other personal information, and your rights with respect to your personal information and how you may exercise them, please visit our Privacy Policy.

Consumer Health Data We Collect

Most of the consumer health data we receive relates to your use of our Products and participation in our Services. We will offer you choices when we ask for consumer health data whenever reasonably possible. 

QALO may collect the below-mentioned pieces of consumer health data for the purpose of providing our Products and Services to our customers, website visitors, mobile application end users, as well as individuals who use, request, or engage with our Products or Services:

Categories of Information

Categories of Sources

Business or Commercial Purposes for Collection (as further described below)

Bodily functions, vital signs, or symptoms

Direct contact with users through the Products and  Services, including: 

  • Use of the Products in connection with the QALO mobile application or other Services

  • Email, phone calls, and text communication

  • Interacting with QALO’s customer support, including communications with support chatbots and form submissions

  • Provision of requested materials and Services

  • Store information about you within the Services

  • To allow you to participate in interactive features offered as part of the Services

  • To allow you to participate in programs, trials, or events offered in connection with the Products and Services

  • Recognize you when you return to the Services

  • Communication

  • Cooperation with our vendors and business partners

  • To fulfill any other purpose for which you provide it

Reproductive or sexual health care information

This may include menstrual cycle information, (such as period length), and depending on the data you provide, it may also contain other sensitive data about your experiences (such as period-related pain, sleep quality), and pregnancy status 

Direct contact with users through the Products and Services, including: 

  • Use of the Products in connection with the QALO mobile application or other Services (both as collected automatically and as voluntarily provided by a consumer when using the Products or Services)

  • Email, phone calls, and text communication

  • Interacting with QALO’s customer support, including communications with support chatbots and form submissions

  • Provision of requested materials and Services

  • Store information about you within the Services

  • To allow you to participate in interactive features offered as part of the Services

  • To allow you to participate in programs, trials, or events offered in connection with the Products and Services

  • Recognize you when you return to the Services

  • Communication

  • Cooperation with our vendors and business partners

  • To fulfill any other purpose for which you provide it

Biometric Data (data that is generated from measuring physiological, biological, or behavioral characteristics of an individual)

This may include heart rate and body temperature

Direct contact with users through the Products and Services, including: 

  • Use of the Products in connection with the QALO mobile application or other Services

  • Email, phone calls, and text communication

  • Interacting with QALO’s customer support, including communications with support chatbots and form submissions


  • Provision of requested materials and Services

  • Store information about you within the Services

  • To allow you to participate in interactive features offered as part of the Services

  • To allow you to participate in programs, trials, or events offered in connection with the Products and Services

  • Recognize you when you return to the Services

  • Communication

  • Cooperation with our vendors and business partners

  • To fulfill any other purpose for which you provide it

Any information that we, or our respective third-party vendors, process to associate or identify a consumer with the data described above that is derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning).

This may include inferences such as information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your behaviors (e.g., you go to the gym every Tuesday and Thursday).

Direct contact with users through the Products and Services, including: 

  • Use of the Products in connection with the QALO mobile application or other Services

  • Email, phone calls, and text communication

  • Interacting with QALO’s customer support, including communications with support chatbots and form submissions


Third-party data and analytics providers

  • Provision of requested materials and Services

  • Store information about you within the Services

  • To allow you to participate in interactive features offered as part of the Services

  • To allow you to participate in programs, trials, or events offered in connection with the Products and Services

  • Recognize you when you return to the Services

  • Communication

  • Cooperation with our vendors and business partners

  • To fulfill any other purpose for which you provide it

How We Collect Consumer Health Data

There are several different ways QALO collects consumer health data. The categories of sources in which we may have collected your consumer health data or other personal information includes the following: 

  • Directly from you, usually from the use of our Products and Services. You or your authorized/legal representatives, family members, caregivers, and physicians also may via your interaction with webforms and website forums on our Site, engagement with our Services, and e-mail, phone calls, and text communications provided by you, interact with us.

  • Third parties who provide digital marketing and analytic services regarding your use of our website.

  • Social Network Sites such as X (formerly known as Twitter), Facebook, Instagram, LinkedIn, or YouTube.

How We Use Collected Consumer Health Data

The consumer health data collected by us may be used in several ways, including for the following business and commercial purposes: 

  • Provision of requested materials and Services

    • Fulfilling the purpose for which the information was provided (e.g., to perform a contract), to identify you in order to respond to requests, provide services or products, personalize information we provide to you, or otherwise as described below

    • Providing customer services

    • Allowing you to participate in interactive features offered as part of the Services

  • Store certain information about you

    • Store information about your preferences, allowing us to customize the Services according to your individual interests 

    • Recognize you when you return to the Services

  • Communication with you about our Products, Services, or our relationship

  • Advertising

    • Providing you with promotional materials such as notifying you regarding certain services we or third parties provide

    • Marketing our services or services of our marketing partners

  • Metrics and Analytics

    • Performing analytics and quality control

    • To detect security incidents and monitor for inappropriate activity

    • Improving our services, including understanding what information and services consumers want most

  • Cooperation with our vendors and business partners

    • To investigate fraud or respond to government inquiries

    • Business transfers, in the unlikely event that a portion or substantially all of QALO’s assets are sold or transferred to a third party, consumer health data would likely be included in business assets transferred to the purchasing entity;

    • To comply with laws, regulations, or other legal process.

  • Otherwise use your consumer health data with your consent or to fulfill any other purpose for which you provide it.

Disclosing Your Consumer Health Data

QALO does not sell consumer health data. QALO will not disclose or allow access to any of your consumer health data collected by us to third parties without your consent, except for:

Type of Information Shared

Third parties and/or affiliates to whom information is shared

Business or commercial purposes for sharing

Bodily functions, vital signs, or symptoms

  1. Third-party integrations, including Apple Inc.


  1. Our service providers and vendors, including Fly.io


  1. Metrics and analytics providers, including Sentry 

  1. To integrate with Apple’s HealthKit and health platform


  1. To host our databases and support functionality of the Application and Services


  1. To conduct analytics regarding the operation and function of our Application and Services (by way of example, when analyzing error reporting, Sentry’s SDK tracks originating IP addresses for error event location context, but raw IP addresses are not retained; no other consumer health data is collected or linked unless provided in feedback forms)

Reproductive or sexual health care information

This may include menstrual cycle information, (e.g. period length), and depending on the data you provide, it may also contain other sensitive data about your experiences (e.g. period-related pain, sleep quality), and pregnancy status

  1. Third-party integrations, including Apple Inc.


  1. Our service providers and vendors, including Fly.io


  1. Metrics and analytics providers, including Sentry




  1. To integrate with Apple’s HealthKit and health platform


  1. To host our databases and support functionality of the Application and Services 


  1. To conduct analytics regarding the operation and function of our Application and Services (by way of example, when analyzing error reporting, Sentry’s SDK tracks originating IP addresses for error event location context, but raw IP addresses are not retained; no other consumer health data is collected or linked unless provided in feedback forms)

Any information that we, or our respective third-party vendors, process to associate or identify a consumer with the data described above that is derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning).

  1. Third-party integrations, including Apple Inc.


  1. Our service providers and vendors, including Fly.io


  1. Metrics and analytics providers, including Sentry 

  1. To integrate with Apple’s HealthKit and health platform


  1. To host our databases and support functionality of the Application and Services


  1. To conduct analytics regarding the operation and function of our Application and Services (by way of example, when analyzing error reporting, Sentry’s SDK tracks originating IP addresses for error event location context, but raw IP addresses are not retained; no other consumer health data is collected or linked unless provided in feedback forms)

For clarity, with respect to our metrics and analytics providers, those entities may have incidental access to consumer health data in connection with recording usage metrics such as clicks within the Service, use of certain features/tools, and the like, but do not need to collect identifiable consumer health data to perform their services. 

Additional Rights of Individuals in Washington and Nevada

If you live or receive services in Washington or Nevada, you may have certain rights with respect to consumer health data that we have collected and used under certain circumstances, which may include the following: 

  • Right to Know About Consumer Health Data Collected, Shared, or Sold. Residents and consumers in the states of Washington and Nevada have the right to request that QALO confirm whether it collects, uses, shares, or sells your consumer health data. This is called the “Right to Know”.

  • Right to Access. The right to confirm whether QALO is collecting, sharing, or selling consumer health data and the right to access and obtain a copy of the consumer health data in a portable, and to the extent technically feasible, readily usable format. Additionally, consumers in the states of Washington and Nevada may receive a list of all third parties and affiliates with whom QALO has shared their consumer health data. 

  • Right to Request Deletion. The right to request deletion of your consumer health data provided by you or obtained by QALO.

  • Right to Withdraw Consent / Authorization: The right to withdraw any previous consent or authorization received by QALO regarding the collection, sharing, or disclosure of consumer health data. For more information about your right to withdraw consent, please see your state’s section below. 

  • Right to Appeal. The right to appeal if your privacy rights-related request is denied in whole or in part. 

  • Right to Non-Discrimination for Exercise of a Consumer’s Privacy Rights. You have a right not to receive discriminatory treatment by QALO for exercising any of your rights conferred by your state’s consumer privacy laws. QALO will not discriminate against any consumer because such person exercised any of the consumer’s rights under these privacy laws, including but not limited to: 

    • denying goods or services;

    • charging different prices or rates for goods and services, including through the use of discounts or other benefits of imposing penalties;

    • providing a different level or quality of goods or services; or

    • suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

QALO may, however, charge a different price or rate, or provide a different level or quality of goods or services, if that difference is related to the value provided to you by your data. 

Please note that these specific rights awarded to Washington and Nevada residents, or consumers seeking our services in those states, will not apply if the consumer health data QALO collects from you or if all of the information we collect is exempt from the statute (for example, the Washington State’s law regarding consumer health data does not protect information that is already protected by certain other privacy laws, and does not protect information that is already publicly available).  Additionally, these Washington specific privacy rights do not apply to QALO employees, applicants or sub-contractors.

To make a request regarding one of the aforementioned consumer health data rights, please follow the instructions below under the section titled “**How to Exercise Your Rights**”.  

When you exercise any of the rights described above, you can expect the following:

  • We will verify your identity. You will need to provide us with certain information such as your name, email address, physical address, or other information, as relevant, so that we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information requested. If we are unable to authenticate your request, e.g., confirm that you are who you say you are, we are not required to comply with your request and we may request additional information to authenticate you and your request. 

  • We will promptly confirm our receipt of your request. QALO will respond to the substance of your rights request without undue delay, but in all cases within 45 days of receipt of the request submitted as described in the “**How to Exercise Your Rights**” section below; provided that a Request to Delete submitted by a Nevada consumer will be responded to within 30 days. The response period may be extended by an additional 45 days if reasonably necessary, but we will inform you of any such extension within the initial 45-day period. 

  • If QALO declines to take action regarding your request, we will let you know within 45 days of receipt of the request the reasons for declining to take the action requested and provide you with instructions for how to appeal the decision. 

  • You will not be charged for submitting up to two consumer requests per year unless your request is clearly unfounded, excessive, or repetitive. In those events, we may charge you a reasonable fee to cover our administrative costs or decline to act on the request.

  • If we refuse to take action on your request, you can appeal our determination. You can submit an appeal by contacting us as provided in the “**How to Exercise Your Rights” section. We will respond to your appeal within 45 days of receipt and provide a written explanation of the reasons for the decision. If your appeal is denied, we will provide you with information on how to contact the relevant Attorney General to submit a complaint. For more information about your right to appeal, please see your state’s section below. You may make an appeal as described in the “How to Exercise Your Rights**” section below.

Nevada Consumer Health Data Rights

Nevada’s Consumer Health Data Privacy Law is a law that is intended to provide consumers in the state of Nevada privacy rights and protection regarding their consumer health data. For further details on the types of consumer health data we have collected about you, the sources of that information, how we use the information (e.g., our business or commercial purposes for collecting, sharing or selling consumer health data), other individuals and business with whom we share Consumer Health Data, and the categories of Consumer Health Data that we have collected or shared about you, please visit the “**Consumer Health Data We Collect” And “Disclosing Your Consumer Health Data**” sections above.

For more information about your rights in Nevada, see the “**Additional Rights of Individuals in Washington and Nevada**” section above. Please note that the rights awarded to Nevada residents will not apply if the consumer health data QALO collects from you, or if all of the information we collect, is exempt from the statute (for example, Nevada’s Consumer Health Data Privacy Law does not protect information that is already protected by certain other privacy laws, and does not protect information that is already publicly available). Additionally, these Nevada specific privacy rights do not apply to QALO employees or subcontractors. 

To make a request regarding one of the aforementioned Nevada Consumer Health Data Privacy Law data rights, please follow the instructions below under the section titled “**How to Exercise Your Rights**” below. If you appeal a determination by QALO and your appeal is denied, we will provide you with information on how to contact the Nevada Attorney General to submit a complaint or you can go to the Nevada Attorney General’s website by clicking the following link to submit a complaint online: Nevada Attorney General Complaint Procedure.

Washington Consumer Health Data Rights

The Washington My Health My Data Act (“MHMDA”) is a law that is intended to provide consumers in the state of Washington with privacy rights and protection regarding their consumer health data. 

For further details on the types of consumer health data we have collected about you, the sources of that information, how we use the information (e.g., our business or commercial purposes for collecting, sharing or selling consumer health data), other individuals and business with whom we share consumer health data, and the categories of consumer health data that we have collected or shared about you, please visit the “**Consumer Health Data We Collect” And “Disclosing Your Consumer Health Data**” sections above.

For more information about your rights in Washington, see the “**Additional Rights of Individuals in Washington and Nevada**” section above. These rights will not apply, however, if QALO does not collect any consumer health data about you or if all of the information we collect is exempt from the statute (for example, the MHMDA does not protect information that is already protected by certain other privacy laws like HIPAA and does not protect information that is already publicly available).

To make a request regarding one of the aforementioned MHMDA data rights, please follow the instructions below under the section titled “**How to Exercise Your Rights**”.  In addition, in lieu of appealing a determination, you can go to the Washington Attorney General’s website by clicking the following link to submit a complaint online: Washington Attorney General Online Complaint.

How to Exercise Your Rights

You can exercise the rights mentioned in this Consumer Health Data Privacy Policy by submitting a verifiable consumer request by sending us an email at support@qalo.com or submitting a request webform, available at: [INSERT HYPERLINK TO WEBFORM]. 

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of and/or deletion of your personal information, we may require you to provide additional information to help us identify you.

Consumers may designate an authorized agent to make a request on their behalf. We will deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us. 

Modifications to this Consumer Health Data Privacy Policy

We may change, modify, add and/or delete all or portions of this Consumer Health Data Privacy Policy at any time, at our discretion, and modifications are effective upon being posted. If we decide to change this Consumer Health Data Privacy Policy, we will post those changes on the home page of our website and any other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You are responsible for reviewing this Consumer Health Data Privacy Policy periodically to ensure that you are aware of any changes to it. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by means of a notice on our website’s home page.

How to Contact Us

If you have any questions, concerns, or inquiries regarding this Privacy Policy or our privacy practices, please contact us at by email at support@qalo.com. 

We will respond to consumer health data privacy-related requests and inquiries within a reasonable timeframe. By using our website or providing personal information, you acknowledge that you have read and understood this Consumer Health Data Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

Thank you for entrusting the privacy of your personal information to QALO.