This policy applies to Washington and Nevada consumers — residents, and anyone whose consumer health data is collected in those states — and to Connecticut residents. It describes how Brontwell (Om Fund Operations sp. z o.o., [adres], Poland) collects, uses, and shares consumer health data. Our general Privacy Policy describes our overall practices.
1. Consumer health data we collect
With your consent, we collect the following categories of consumer health data, which you provide directly in the app:
- Dietary and health history — dietary patterns and preferences, health conditions you choose to record
- Allergy and intolerance information — allergens and intolerances you mark for yourself or for profiles you manage
- Supplement information you choose to record
- Laboratory or biomarker results you choose to share
- Basic body details you provide (age, sex, height, weight), used as context for your questions
- Meal photos and food questions you submit, and the AI-generated nutrition inferences derived from them
- Life-stage information relevant to nutrition (e.g. pregnancy, breastfeeding)
Source: you (or, for a child's profile, the parent or legal guardian managing it). We do not collect consumer health data from third parties, data brokers, or advertising networks.
2. Why we collect it (purposes)
- To generate personalised nutrition guidance you ask for — this is the core service
- To maintain the profiles you create and keep answers consistent over time
- To meet legal obligations (e.g. consent records, security, responding to your requests)
We collect only the health data needed to provide the service you request, and each AI query sends only the data relevant to that query.
3. How we disclose it
We do not "share" consumer health data as Washington and Nevada law define that term. We disclose it only to processors acting on our documented instructions under contracts restricting any other use:
| Category | Provider | Purpose |
|---|---|---|
| AI processing | OpenAI Ireland Ltd. (EU) | Generating the answer to your query |
| AI quality monitoring | Langfuse (EU) | Pseudonymised logs of your question, the answer, and your meal photo (location metadata removed) — without your profile or identity; retained 30 days; used to monitor and improve answer quality |
| Hosting | [provider] | Running the service |
We do not sell consumer health data. We do not share it for advertising. We do not use it for targeted advertising. Our analytics do not receive your health data or the content of your questions.
4. Your rights
If you are a resident of Washington, Nevada, or Connecticut, you may:
- Access your consumer health data, including a list of all third parties and affiliates with whom we shared it and an e-mail address or other online mechanism to contact them
- Withdraw consent to collection and sharing (Settings → Privacy — takes effect immediately)
- Delete your consumer health data — from our active systems without undue delay, from archived and backup systems within six months at the latest, and by instruction to our processors and anyone we shared it with
Exercise these rights in-app (Settings → Privacy / Account) or at privacy@brontwell.app. We respond within 45 days (one 45-day extension where reasonably necessary; we will tell you). If we refuse a request, you may appeal by replying to our decision; we respond to appeals within [45] days, and you may contact the [Washington / Nevada / Connecticut] Attorney General if the appeal is denied.
We will not discriminate against you for exercising these rights.
5. Consent
We ask for your affirmative, opt-in consent to collect the categories above before collection, in a dedicated in-app step separate from accepting our Terms of Service, and separately for sharing beyond our service providers (we currently do no such sharing). For a child's profile, the parent or legal guardian provides consent on the child's behalf. For another adult's profile, we require that adult's own agreement: the account holder confirms at profile creation that the person has reviewed our Family Member Notice and consents, and that person may exercise all rights in Section 4 directly, at any time, without the account holder's involvement.
6. Changes to this policy
We will notify you of material changes to this policy in-app and by e-mail at least 30 days before they take effect, and update the date above. Where a change would expand how we collect or share consumer health data, we will ask for your consent first.
7. Contact
Om Fund Operations sp. z o.o. · [adres] · privacy@brontwell.app