Habitcount Consumer Health Data Privacy Policy
Effective date: 24 September 2026
Last updated: 30 September 2026
This policy is for residents of Washington (under the My Health My Data Act, RCW 19.373) and
Nevada (under NRS 603A.400 to 603A.550, enacted as Senate Bill 370). It also applies to anyone whose consumer health data is collected in those states. Other states with similar rules, such as Connecticut, are covered as well. It explains how Intelligent Energy Solutions LLC, a company registered in the country of Georgia ("we", "us"), handles consumer health data in the Habitcount app.
It adds to our Privacy Policy, which covers all the information we handle. If the two conflict on consumer health data, this policy applies.
1. What "consumer health data" means here
"Consumer health data" is personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health status. In Habitcount,
we treat the following as consumer health data:
- counters and entries you sync that relate to health or health-related behaviour. For example: cigarettes or other tobacco, alcoholic drinks, pills or medication, calories, water, caffeine, exercise (such as push-ups or runs) and meditation. This includes each entry's date, time, time zone and amount, and any goal you set;
- notes you attach to those entries;
- statistics we calculate from them, such as daily totals and whether a goal was met;
- identifiers linked to that data, such as your email address, account ID and the app's random device ID.
We can't always know whether a counter is health-related, since you choose the name. So we apply this policy to all synced counters, entries, notes and statistics.
If you don't create an account, none of this leaves your device and we don't collect it.
2. Categories of consumer health data we collect, and why
| Category | Why we collect it and how we use it |
|---|---|
| Synced counters: name, emoji, type, unit, goals, optional price | To back up and sync your counters between your devices and show them to you |
| Synced entries: date and time, local day, time zone, amount, how the entry was made, optional note, optional price | To back up, sync and show your history |
| Derived statistics: daily totals, first and last time of day, goal met or not | To show your statistics and insights quickly on every device |
| Friend challenges, only if you use them: which counter a challenge link is for, the counters paired with a friend's, when a challenge started and stopped, and the name you chose for challenges | To show you and the friend you chose each other's daily totals for that counter |
| Linked identifiers: email address, account ID, random device ID | To link your data to your account, keep it secure and deliver it only to you |
| Usage statistics, only if you turn them on | Events such as "template selected" or "counter created" could indicate the kind of habit you track. They never contain names, amounts or notes. We use them only to understand and improve how the app is used, and we treat them as consumer health data |
We use consumer health data only to provide the Habitcount features you ask for. We do not use it for advertising or marketing. We do not build profiles or draw inferences about your health. We do not use location or geofencing of any kind.
3. Sources
We collect consumer health data directly from you, when you enter it in the app and choose to sync it, and from your device (time zone and app details). We also derive it, by calculating statistics from your entries. We do not get consumer health data from data brokers or other third parties. Sign in with Apple gives us only your account identifier and email address.
4. Consent
- Collection: we collect consumer health data only after you give separate, explicit consent in the app: "Store my counters on Habitcount's servers so they sync. They may include health-related habits." This consent is separate from accepting our Privacy Policy or Terms of Use. If you don't consent, you can keep using Habitcount on your device without sync.
- Usage statistics are off by default and are collected only if you turn them on.
- Sharing: we do not share consumer health data with third parties, except with the service providers (processors) listed in section 5 that we need to provide the service you asked for, and with a friend you choose through a friend challenge. A challenge shares only your chosen name and your daily totals for that one counter, from the day it started. The app asks for this separate consent, showing exactly what will be shared, before you start your first challenge and every time you accept one. You withdraw it by stopping the challenge in the counter's Stats. If we ever wanted to share it in any other way, we would first ask for your separate consent.
- Selling: we do not sell consumer health data, and we never will without the signed, valid authorisation that the law requires.
- Withdrawing consent: you can withdraw your consent at any time. Sign out and delete your account (You → Delete account) and we stop collecting and syncing. See section 7 for what happens to your data.
5. Categories of consumer health data we share, and with whom
We share consumer health data only with processors that handle it on our behalf, under contracts that limit them to our instructions:
| Processor | Consumer health data they handle | Why |
|---|---|---|
| 3hCloud, our server hosting provider | All synced consumer health data listed in section 2 | To run our server and database |
- Friends you challenge (only at your direction, see section 4): your chosen name and your daily totals for the challenged counter, from the day the challenge started. Never your entries, times, notes, prices or other counters.
- We share no consumer health data with affiliates.
- We do not share it with advertisers, data brokers, analytics companies or social networks.
- Our email provider, support mailbox provider and RevenueCat (subscriptions) do not receive your counters, entries or notes.
- We may disclose consumer health data if the law requires it, for example to comply with a valid court order. We will only do so where the law allows.
- No third-party tracking: no third party can collect consumer health data about you over time or across different websites or online services through Habitcount. The app contains no third-party analytics, advertising or tracking code.
6. Your rights
Subject to the law in your state, you have the right to:
- Confirm whether we collect, share or sell your consumer health data.
- Access your consumer health data. This includes a list of all third parties and affiliates we have shared it with or sold it to, with their contact details. (We don't sell it, and we share it only with the processors in section 5.)
- Withdraw consent to our collection and sharing, and ask us to stop collecting or sharing your consumer health data.
- Delete your consumer health data. When you ask us to delete it, we delete it from our systems and tell our processors to delete it too.
- Appeal if we refuse your request (section 8).
We will not discriminate against you for using these rights. That means no different prices or a worse service because you used them. Some features, such as sync, can't work without the data they need.
7. How to use your rights
- Delete: in the app, go to You → Delete account and type DELETE. Your account and all synced consumer health data are permanently deleted from our live database within 72 hours. We also ask our processors to delete it. Data in our backups is deleted when those backups expire, which is within 30 days and never later than six months after we confirm your request. Deleting your account does not delete the data stored on your phone. Delete the app to remove it.
- Access or get a copy: use You → Export my data in the app, or email us.
- Confirm, get the list of third parties, withdraw consent, or anything else: email ilia.kamyshev@iesllc.ge with the subject "Consumer health data request", or use You → Contact support.
Verification. To protect your data, we need to confirm the request comes from you. Usually we ask you to send it from the email address on your account, or to confirm it in the app while signed in. We only use the information you give us for verification to verify your request.
Timing and cost. We respond within 45 days of receiving your request. If we reasonably need more time, we may extend this once by another 45 days and will tell you why within the first 45 days. Requests are free, at least twice in any 12-month period.
8. Appeals
If we refuse all or part of your request, we will explain why. You can appeal by replying to our decision or emailing ilia.kamyshev@iesllc.ge with the subject "Consumer health data appeal". We will tell you in writing within 45 days what we decided and why. If we deny your appeal, you can contact:
- Washington residents: the Washington State Attorney General, at www.atg.wa.gov/file-complaint
- Nevada residents: the Nevada Attorney General, at ag.nv.gov
9. How we protect consumer health data
Only the people who need to run and support Habitcount can access consumer health data, and they use it only for that purpose. All traffic between the app and our server is encrypted. Each account can only reach its own data. Local backups are accessible only to the server administrator; off-site copies are encrypted before upload to Cloudflare R2 in the European Union. The decryption key is kept separately from the server and Cloudflare. See section 8 of our Privacy Policy for more details.
10. Changes to this policy
If we make a material change to this policy, we will tell you in the app and update the "Last updated" date before the change takes effect. If a change would let us collect, use or share consumer health data in a new way, we will first ask for your consent. You can review this policy at any time at https://apps.iesllc.ge/app-e7f4e392/legal/health, and in the app under
You → Privacy.
11. Contact us
Intelligent Energy Solutions LLC (identification number 445839816) 58 St. Andrew the First-Called Highway, Apartment 605, Block III, Batumi, Georgia Email: ilia.kamyshev@iesllc.ge Support: You → Contact support in the app