Effective Date: August 31, 2026 Last Updated: August 31, 2026 Version: 1.0
This is a separate, standalone policy, required by the Washington My Health My Data Act (RCW 19.373) and Nevada SB 370. It exists on its own because those laws require a distinct consumer health data policy with its own link, not a section buried inside a general privacy policy.
It applies to residents of Washington and Nevada, and to anyone else who wants to know how Theo handles data that touches wellbeing. Theo is offered in the United States and 143 other territories; it is not offered in the EEA, the UK, or Switzerland. Our general Privacy Policy governs everything else, and where the two overlap, this one controls for consumer health data.
Washington defines "consumer health data" broadly — any information linkable to a consumer that identifies their past, present, or future physical or mental health status. Theo is a Bible study and focus app, not a health app, and we collect no diagnoses, medications, lab results, biometrics, genetic data, or reproductive health information.
We nonetheless treat the following as consumer health data, because a broad reading of the statute could reach them and we would rather over-protect than argue about it later:
| Data | Why it may qualify |
|---|---|
| Fasting session records | Start and end times of voluntary fasts you log — arguably bodily function or nutrition data |
| Focus session history | Patterns of attention and device use — arguably behavioural health data |
| Spiritual needs and obstacles | Free-text selections such as anxiety, loneliness, or discouragement |
| Conversations with Theo touching wellbeing | Messages you choose to send about emotional or mental state |
| Journal entries touching wellbeing | Reflections you write that mention how you are doing |
We do not collect: precise location, biometric identifiers, health-provider records, prescription data, reproductive or sexual health data, gender-affirming care data, or any information from a health care provider.
Only from you, and only because you entered it. We do not buy it, we do not infer it from third-party sources, and we do not obtain it from data brokers, advertising networks, or your other apps.
That is the entire list. We do not use consumer health data for advertising, marketing, profiling, scoring, research, or product analytics keyed to health signals.
We do not sell consumer health data. We have never sold it. Selling it would require your separate written authorisation under RCW 19.373.100, and we have never sought one and do not intend to.
We share it only with processors who run the service on our behalf, under contract, and only for the purposes above:
| Processor | What it receives | Why |
|---|---|---|
| Supabase | Journals, fasting and focus records, spiritual profile | Stores your account so it survives a new device |
| Anthropic | Message text and journal excerpts you opted in, when you use the AI assistant | Generates Theo's reply |
| OpenAI | Text of journals you opted into "Theo can read" | Generates the embedding that makes search work |
| Amazon Web Services | Summarised conversation memory | Gives Theo continuity between sessions |
Fasting records and focus history are never sent to any AI provider. Neither AI provider trains models on your data.
We will disclose consumer health data if legally compelled by valid process, and we will tell you unless we are barred from doing so.
We ask before we collect, and separately before we share:
Withdrawing consent is available at any time in Settings → Privacy. Withdrawal stops future collection and sharing. It does not undo what already happened, which is what deletion is for.
Washington and Nevada residents have the right to:
How to exercise them:
We respond within 45 days, extendable once by 45 days where reasonably necessary, and we will tell you if we extend and why. Verification is proportionate — writing from your registered email is normally enough. There is no charge.
On deletion, we delete from our active systems and notify every processor in Section 4 to do the same, as RCW 19.373.080 requires. Backups roll off within 30 days.
If we refuse, you may appeal by replying to our
decision. We will respond in writing within 45 days. If we still refuse,
you may complain to the Washington State Attorney
General at atg.wa.gov/file-complaint or the
Nevada Attorney General at ag.nv.gov.
Private right of action. Washington's Act is enforceable through the state Consumer Protection Act, which means a violation may give you a private claim. We would rather you told us first, but that right is yours regardless.
We do not use geofencing. Theo does not request, collect, or process precise location data at all. We operate no geofence around any health care facility, and we could not build one — the location permission is not in the app.
RCW 19.373.110 prohibits geofencing health care facilities to collect health data or send health-related advertising. We comply by not touching location in the first place.
| Data | Retention |
|---|---|
| Fasting and focus records (on device) | Until you delete them or remove the app |
| Fasting and focus records (account) | Life of the account; deleted within 30 days of a deletion request |
| Journals and spiritual profile | Life of the account; deleted within 30 days |
| Chat message text | Not retained — discarded once the reply is delivered |
| Conversation memories | 180 days, then automatically expired |
| Copies held by AI providers | Up to 30 days |
Material changes will be notified in the app before they take effect. Where a change concerns data we process on your consent, we will ask again rather than assume.
Landslide Studios LLC — tommy@landslidestudios.com Subject line: "Consumer Health Data Request"
Related documents: Privacy Policy · Terms of Service