Consumer Health Data Privacy Policy

A standalone policy for the health data ProAct collects -- separate from our general Privacy Policy, as required by Washington's My Health My Data Act and similar state laws.

Last updated: October 10, 2026

Privacy at a GlanceProAct uses analytics only to improve the app.
Analytics never include your health values. This is true from app version 1.4.8; older versions sent some, as the note below explains.
ProAct does not sell your data. It shares your trial start and first payment with Meta only if you saw ProAct's explanation and then allowed tracking in Apple's prompt, and never your health data.
Privacy at a glance: who receives data from ProAct, why, and for how longWhoWhat is sharedWhyHealth data?How long it is kept
ProAct servers (database hosted by Supabase)What you log (attacks, check-ins, routine records), your latest risk estimate, weekly and monthly summaries, device ID, timezone, push token, subscription records, and security logs with your IP address.To run the app: show your history, build insights, and send notifications.YesUntil you delete it or delete your account. Security logs and subscription event records are kept without the link to your device.
Anthropic (AI provider)Summaries of your Apple Health data, attack history, check-in answers, and cycle timing if you opted in. No name, email, or device ID.To generate your risk outlook and weekly and monthly summaries.YesKept by Anthropic for a limited period under its API data retention policy. Not used to train its models.
PostHog (product analytics)Which screens and features you use, onboarding steps, subscription events, and the type of notification sent, tied to your device ID. Website page views and clicks.To improve the app. Never for advertising.No health values, from app version 1.4.8 (older versions sent some; see the note below). It records the type of notification sent, such as a risk alert or an attack follow-up.Under our PostHog account settings. Ask us to delete it.
Sentry (error tracking)Error reports and performance data with your device ID. Masked website session replays. Feedback form messages and the email you enter.To find and fix bugs, and to reply to feedback.Request bodies, cookies, query strings, and login tokens are removed first. Health fields are removed by name; free-text error messages are checked for login tokens but not for health content. No app screenshots from 1.4.8.Under our Sentry account settings. Ask us to delete it.
RevenueCat (subscriptions)Purchase and subscription events, your device ID, IP address, and device identifiers (the advertising identifier only if you allow tracking).To manage your subscription and free trial.NoBy RevenueCat under its policies. Ask us to delete it.
Apple Health (on your iPhone)Your raw Apple Health data stays on your iPhone. Only summaries leave it, when the app builds an outlook.To build your outlook.Raw Health data: no. Summaries: yes, via ProAct servers and Anthropic.Raw data never leaves your iPhone. Summaries are kept as described for ProAct servers and Anthropic.
Apple SKAdNetwork (ad measurement)Apple tells ad networks, without saying who you are, whether an install from an ad led to a first launch, a paywall view, a free trial, or a purchase. Apple sends these signals, not us.To measure whether our ads work.NoHandled by Apple under its policies.
Meta (ad measurement, only if you allowed tracking after ProAct's explanation)Only if you saw ProAct's explanation and then allowed tracking in Apple's prompt: when you start a free trial and when you make your first payment, with its price (never renewals), your device's advertising identifier, and your iPhone model and iOS version, sent by ProAct's server with Meta's Limited Data Use mode. If you decline, ProAct sends Meta nothing about you.To measure which ads work.No health data and no IP address.By Meta under its policies. Turn this off anytime in iOS Settings > Privacy & Security > Tracking. ProAct learns of the change the next time you open the app; a trial turning into a paid subscription before then may still be shared once.
Apple Push Notification serviceYour push token and the notification text.To deliver notifications you turned on.Notification text can mention your risk level or attack loggingBy Apple under its policies.
Vercel (hosting)Requests between the app or website and our servers pass through it. Website page view counts.To host our servers and website.Passes through in transit onlyBy Vercel under its policies.
Upstash (rate limiting)The IP address of each device registration request.To limit abuse.NoShort-lived counters that expire after about 2 hours.

Privacy at a glance: who receives data from ProAct, why, and for how long
Who	What is shared	Why	Health data?	How long it is kept
ProAct servers (database hosted by Supabase)	What you log (attacks, check-ins, routine records), your latest risk estimate, weekly and monthly summaries, device ID, timezone, push token, subscription records, and security logs with your IP address.	To run the app: show your history, build insights, and send notifications.	Yes	Until you delete it or delete your account. Security logs and subscription event records are kept without the link to your device.
Anthropic (AI provider)	Summaries of your Apple Health data, attack history, check-in answers, and cycle timing if you opted in. No name, email, or device ID.	To generate your risk outlook and weekly and monthly summaries.	Yes	Kept by Anthropic for a limited period under its API data retention policy. Not used to train its models.
PostHog (product analytics)	Which screens and features you use, onboarding steps, subscription events, and the type of notification sent, tied to your device ID. Website page views and clicks.	To improve the app. Never for advertising.	No health values, from app version 1.4.8 (older versions sent some; see the note below). It records the type of notification sent, such as a risk alert or an attack follow-up.	Under our PostHog account settings. Ask us to delete it.
Sentry (error tracking)	Error reports and performance data with your device ID. Masked website session replays. Feedback form messages and the email you enter.	To find and fix bugs, and to reply to feedback.	Request bodies, cookies, query strings, and login tokens are removed first. Health fields are removed by name; free-text error messages are checked for login tokens but not for health content. No app screenshots from 1.4.8.	Under our Sentry account settings. Ask us to delete it.
RevenueCat (subscriptions)	Purchase and subscription events, your device ID, IP address, and device identifiers (the advertising identifier only if you allow tracking).	To manage your subscription and free trial.	No	By RevenueCat under its policies. Ask us to delete it.
Apple Health (on your iPhone)	Your raw Apple Health data stays on your iPhone. Only summaries leave it, when the app builds an outlook.	To build your outlook.	Raw Health data: no. Summaries: yes, via ProAct servers and Anthropic.	Raw data never leaves your iPhone. Summaries are kept as described for ProAct servers and Anthropic.
Apple SKAdNetwork (ad measurement)	Apple tells ad networks, without saying who you are, whether an install from an ad led to a first launch, a paywall view, a free trial, or a purchase. Apple sends these signals, not us.	To measure whether our ads work.	No	Handled by Apple under its policies.
Meta (ad measurement, only if you allowed tracking after ProAct's explanation)	Only if you saw ProAct's explanation and then allowed tracking in Apple's prompt: when you start a free trial and when you make your first payment, with its price (never renewals), your device's advertising identifier, and your iPhone model and iOS version, sent by ProAct's server with Meta's Limited Data Use mode. If you decline, ProAct sends Meta nothing about you.	To measure which ads work.	No health data and no IP address.	By Meta under its policies. Turn this off anytime in iOS Settings > Privacy & Security > Tracking. ProAct learns of the change the next time you open the app; a trial turning into a paid subscription before then may still be shared once.
Apple Push Notification service	Your push token and the notification text.	To deliver notifications you turned on.	Notification text can mention your risk level or attack logging	By Apple under its policies.
Vercel (hosting)	Requests between the app or website and our servers pass through it. Website page view counts.	To host our servers and website.	Passes through in transit only	By Vercel under its policies.
Upstash (rate limiting)	The IP address of each device registration request.	To limit abuse.	No	Short-lived counters that expire after about 2 hours.

Who This Policy Covers

This policy is published by ColetonCodes LLC ("we," "us") for the ProAct iOS app and proactmigraine.com. It describes only our practices around consumer health data -- the category of sensitive data regulated by Washington's My Health My Data Act (RCW 19.373) and comparable laws such as Nevada's SB 370. Our general Privacy Policy covers everything else (device data, subscription data, and how the site as a whole works); this page is the detailed, health-specific companion to it.

Although this policy is written to satisfy Washington and Nevada-style consumer-health laws specifically, we apply the same practices to all users, in every US state, as a matter of policy -- not just where a specific statute requires it.

Consumer Health Data We Collect

We collect the following categories of consumer health data, directly from you or from Apple HealthKit with your device permission:

Direct entryAttack Logs

Timestamps, pain intensity, and pain character (e.g., throbbing, sharp)
Pain locations, symptoms, medications taken, and identified triggers
Relief methods used and your notes

Direct entryGuided-Routine Execution Records

When you complete a guided relief routine: pain intensity before and after, how much of the routine you completed (adherence), and your rating of it

Direct entryWellness Check-Ins

Sleep quality, stress level, hydration, activity level, and energy level

From Apple Health, not storedHealth Summaries

Summaries of heart rate variability (HRV), resting heart rate, and sleep duration and quality, with your permission through the iOS Health prompt
Days since your last period started, only if you choose to include cycle tracking

Raw samples never leave your phone. We never receive your raw Apple Health readings, only the summaries above. They are sent to build your outlook and we do not save them in our database.

Generated by our AIRisk Estimates and Summaries

Your latest risk estimate: a risk level (low, moderate, elevated, or high), a short explanation, the factors behind it, and suggestions. Each new estimate replaces the previous one.
Weekly and monthly summaries of your attacks and triggers

Sources of This Data

You: everything you type or select in the app -- attack logs, routine ratings, notes
Apple Health: heart rate and sleep summaries, and cycle timing if you opt in, only after you grant the iOS Health permission prompt

We do not purchase, license, or otherwise obtain consumer health data from any other source.

Why We Collect and Use It

Risk Estimates

Generate your migraine risk estimate, up to 48 hours ahead.

Pattern Reports

Identify patterns in your triggers, symptoms, and what relief methods help you.

Guided Routines

Recommend and track relief routines and how well they work for you.

The App, and Nothing Else

We use consumer health data only to provide the features you asked for. We do not use it for advertising, and we do not build advertising or marketing profiles from it.

We do not sell consumer health data. We never have, and we never will -- not for money, and not for any other kind of valuable consideration.

Who We Share It With

We share consumer health data only with the service providers strictly necessary to run ProAct, and only for the purpose of providing our service to you -- never for their own purposes, and never for advertising.

SupabaseDatabase hostingStores attack logs, routine records, and risk estimates on our behalf

Anthropic (Claude)AI risk estimates and weekly and monthly summariesHealth summaries, attack history (counts, average severity, recent triggers), your known triggers, check-in answers, and days since your last period started only if you opt in to cycle tracking. For weekly and monthly summaries: attack counts, average severity and duration, and your most common triggers. No name, email, or device ID. Anthropic does not use the data to train its models and keeps requests only for a limited period under its API data retention policy.

VercelApplication hostingInfrastructure provider for our servers; data passes through it

PostHogUsage analyticsProduct events tied to your device ID. PostHog receives no health values from our server. From app version 1.4.8, the app does not send PostHog your symptoms, triggers, mood, sleep, pain, or severity values, your medications or notes, or your answer to the cycle question.

SentryError trackingError reports with your device ID. Our server and website remove request bodies, cookies, query strings, and login tokens before sending. Health fields are removed by name; free-text error messages are checked for login tokens but not for health content. From app version 1.4.8, the app sends no screenshots or screen contents with error reports.

ApplePush notificationsNotification text, which can mention your risk level or attack logging

UpstashRate limitingThe IP address of each device registration request, used to limit abuse. Upstash keeps it only in short-lived rate-limit counters that expire after about 2 hours. No health data.

Note about older app versions (added October 10, 2026): older versions of the app (before 1.4.8) sent PostHog some health values, such as symptom and trigger names, mood and sleep ratings, attack severity, and your cycle question answer, and could attach a screenshot of the screen in use when the app reported an error to Sentry. Updating to version 1.4.8 or later stops this.

Advertising: Only if you saw ProAct's explanation and then allowed tracking in Apple's prompt, ProAct's server tells Meta when you start a free trial and when you make your first payment (with its price), using your device's advertising identifier and Meta's Limited Data Use mode. Renewals are never shared. Each event also includes your iPhone model and iOS version, which Meta requires. ProAct never shares your health data with Meta, and these events never include your IP address. If you decline, ProAct sends Meta nothing about you. Apple may still tell Meta, without identifying you, how many installs and subscriptions each ad campaign produced. You can turn this off anytime in iOS Settings > Privacy & Security > Tracking. ProAct learns of the change the next time you open the app. Until then, if your free trial turns into a paid subscription, that one payment may still be shared. ProAct has turned off RevenueCat's own Meta integration, so our subscription provider, RevenueCat, sends nothing to Meta itself. The app has no Meta or Facebook SDK. We measure ad results through Apple's SKAdNetwork, which shares no personal information with ProAct or Meta. With SKAdNetwork, Apple, not us, tells the ad network whether an install from an ad led to a first launch, a paywall view, a free trial, or a purchase, without your device ID, identity, or any health data.

We do not otherwise disclose consumer health data to any third party, and we do not disclose it to any affiliate for a purpose unrelated to providing ProAct to you.

Your Rights

Access: in Profile > Privacy & Data > Export Your Data. You get a ZIP file with your attack logs, wellness entries, routine records, weekly and monthly summaries, and the rest of your account data. The export does not include your latest risk estimate, routine recommendations, notification history, or engagement events; email us and we will send those.
Deletion: in Profile > Privacy & Data > Delete Account. If you have an active subscription or free trial, you need to cancel your subscription or trial in iOS Settings first; the app will not accept the request until then. After a 7-day waiting period, during which you can cancel the request, we permanently delete your attack logs, wellness entries, routine records, risk estimates, and summaries from our database. A deleted account leaves no health data or health summaries behind in our database, anonymized or otherwise. The only records we keep are security log entries and subscription event records, with the link to your device removed (see our Privacy Policy). Deleting in the app does not delete data held by PostHog, Sentry, or RevenueCat; email us if you want us to ask them to delete it.
Withdraw consent: revoke ProAct's Health permission at any time in iOS Settings > Privacy & Security > Health, change your answer under Profile > Settings > Cycle tracking, turn off analytics in Profile > Privacy & Data, or simply stop entering data in the app. Withdrawing consent does not affect data we already processed before you withdrew it.
Appeal: if we deny a request you've made under this policy, you can appeal (see below).

How to Exercise These Rights

Access and deletion are self-service in the app (Profile > Privacy & Data). For anything else, or if the in-app flow does not work for you, email support@proactmigraine.com. We will respond within 30 days.

Appeals

If we deny a request, we will tell you why and how to appeal. To appeal, email support@proactmigraine.com with "Appeal" in the subject line. We are a small, solo-operated team, so we cannot promise a decision by a different individual within a separate team -- but every appeal gets a genuine second look, with fresh eyes, from someone reviewing the original decision again rather than simply restating it. We will respond in writing within 30 days of receiving your appeal. If we still deny your request, we will tell you that you may contact the Washington State Attorney General's office to file a complaint.

Which Laws This Policy Is Written For

This policy is written to meet the standalone-policy and content requirements of Washington's My Health My Data Act (RCW 19.373) and similar consumer-health-data laws in other states, such as Nevada's SB 370. As noted above, we extend the same practices to every ProAct user in the United States, regardless of which state's law would otherwise apply to you.

Changes to This Policy

We may update this policy as our service evolves. For material changes, we'll notify you through the app before they take effect. Your continued use after changes means you accept the updated policy.

Contact Us

Email: support@proactmigraine.com
Response time: within 30 days for data requests and appeals
General privacy questions: see our Privacy Policy

Change Log

October 2026

Updated October 10, 2026: only if you saw ProAct's explanation and then allowed tracking in Apple's prompt, ProAct's server now tells Meta when you start a free trial and when you make your first payment (never renewals), using your device's advertising identifier and Meta's Limited Data Use mode. It never sends your health data or your IP address. If you decline, ProAct sends Meta nothing about you. Apple may still tell Meta, without identifying you, how many installs and subscriptions each ad campaign produced. This replaces the earlier change below.
We stopped sending data to Meta from our servers. Ads are measured only through Apple's SKAdNetwork.
From app version 1.4.8, analytics no longer include your health values such as symptoms, triggers, mood, sleep, pain, severity, or your cycle answer.
Error reports sent to Sentry now have request bodies, cookies, query strings, and login tokens removed. Health fields are removed by name; free-text error messages are checked for login tokens but not for health content. From app version 1.4.8, the app sends no screenshots with error reports.
From app version 1.4.8, the app asks your permission before it sends data to our AI provider.
We turned off longer-term logging in Upstash, our rate-limiting service. It now keeps your IP address only in counters that expire after about 2 hours.
We corrected this policy to describe what we store, how deletion and export work, and which services receive data.