Consumer Health Data Privacy Policy

1. What This Policy Covers

"Consumer health data" means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. Because QuitBet helps people stop gambling, much of the recovery data you give us in the app is consumer health data.

This policy applies to consumer health data about people protected by these laws, such as Washington residents, people whose consumer health data is collected in Washington, and residents of Nevada and Connecticut.

2. Consumer Health Data We Collect

Depending on the features you use, we collect:

• your gambling behavior and patterns, such as the kinds of gambling you do and how often, from the trigger and gambling-pattern check;
• your triggers and the urges you log;
• your daily check-ins, including mood and notes;
• relapse and streak tracking, including streak resets;
• your quit plan, goals, and progress in guided programs and lessons;
• money-related recovery data, such as amounts you used to spend on gambling and money saved;
• messages you send to the AI coach, and its replies, which may reveal health information;
• posts and messages you share in the Community Forum or group chat, which may reveal health information;
• the fact that you use QuitBet, a recovery app, which may itself suggest you are dealing with gambling.

Our website does not ask for health information. If you include health information in a message you send through our contact form, we use it only to respond to you. Because a visit to a gambling recovery website could itself be seen as health-related, we load website analytics only if you accept analytics cookies, as described in our Cookie Policy.

3. Where We Get It

• From you, when you complete the pattern check, build your quit plan, log check-ins and urges, chat with the AI coach, or post in the community.
• From your use of the app, such as your streaks, progress, and the urge tools and exercises you use.

We do not buy consumer health data.

4. How We Use It

We collect and use consumer health data to provide the features you ask for:

• to build and personalize your quit plan;
• to record your check-ins, urges, and relapses, and show your progress, streaks, and money saved;
• to provide urge tools, guided programs, and lessons;
• to generate AI coach replies;
• to show your community posts to other users;
• to keep your data available in your account when you sign in;
• to keep the Service and your account secure, prevent abuse, and moderate the community;
• to respond to your requests and comply with the law.

We do not use consumer health data for advertising.

5. Your Consent

We collect consumer health data only as necessary to provide the features you request, such as check-ins, your quit plan, progress tracking, the AI coach, and the community. We will not collect it for any other purpose, or share it except as described in this policy, without first asking for your separate consent.

You can stop us from collecting and using it at any time by deleting your account in the app or by contacting us. Features that depend on this data will then stop working.

If we want to collect, use, or share consumer health data for a purpose not described in this policy, we will ask for your consent first.

6. Who We Share It With

We share consumer health data only with these categories of recipients:

• Cloud hosting and database providers, which store your account and recovery data on our behalf.
• AI model providers, which process the messages you send to the AI coach to generate replies on our behalf.
• Other QuitBet users, but only for content you choose to post in the Community Forum or group chat.
• Our website analytics provider, only if you accept analytics cookies on our website, for information about your visit.
• Authorities or others, when the law requires it, such as to comply with a valid court order.
• A buyer or successor, if we are part of a merger, acquisition, or sale of assets, as the law allows.

We do not share consumer health data with affiliates.

7. We Do Not Sell Consumer Health Data

We do not sell consumer health data.

8. Your Rights

Under these laws, you have the right to:

• Confirm and access. Confirm whether we collect, share, or sell your consumer health data, and get access to it.
• Know who received it. Get a list of all third parties and affiliates with whom we have shared your consumer health data, with an email address or other online way to contact them.
• Delete. Have your consumer health data deleted. When we delete it, we also tell our processors and any third parties we shared it with to delete it. Copies in backups are deleted within 90 days.
• Withdraw consent. Withdraw your consent to our collection and sharing of your consumer health data.
• Appeal. Appeal if we refuse to act on your request.

9. How to Exercise Your Rights

• In the app. Delete your account in Settings. This deletes your consumer health data as described in Section 8.
• By email. Email support@quitbet.co with the subject line "Consumer Health Data Request". Tell us which right you want to use and include the email address linked to your QuitBet account.

We may need to verify your identity, for example by confirming that you control the email address linked to your account. We use information you give us for verification only to verify your request. Requests are free of charge.

We respond within 45 days of receiving your request. If it is reasonably necessary, we may extend this once by another 45 days. If we do, we will tell you within the first 45 days and explain why.

10. Geofencing

We do not use geofencing around places that provide in-person health care services to identify or track people seeking those services, to collect consumer health data, or to send them notifications, messages, or ads.

11. Security and Access

We use reasonable administrative, technical, and physical safeguards to protect consumer health data. We limit access to it to the employees, contractors, and processors who need it to provide the Service or for the other purposes in this policy.

12. No Discrimination

We won't discriminate against you for exercising your rights. Some features need consumer health data to work, so if you delete that data or withdraw your consent, those features may no longer be available.

13. Changes to This Policy

We may update this policy. We'll post the updated version here and change the "Last updated" date. If we want to collect, use, or share consumer health data in a materially different way, we will ask for your consent first.

14. Contact Us

For questions or requests about consumer health data, email support@quitbet.co.