Consumer Health Data Privacy Policy

Effective date: July 11, 2026  ·  Last updated: August 27, 2026

This policy applies to consumer health data as defined by the Washington My Health My Data Act, Nevada SB 370, and similar state laws. It supplements our Privacy Policy, which continues to describe everything else we collect. Where the two overlap, this document controls for consumer health data.

Raretell is operated by Redoubtable LLC, a Virginia limited liability company ("we," "us," "our").

1. What Raretell is, in one paragraph

Raretell watches for ordinary signs that your phone's owner is up and about. If those signs stop for an unusually long time and you do not answer a check-in, it notifies emergency contacts you chose in advance. It is not a medical device, it diagnoses nothing, and it forms no view about your health. That matters here because it explains why the data below is collected: as evidence of movement, not as a measure of health.

2. The categories of consumer health data we collect

Only two categories, and both are collected only from your own device:

• Step activity. Recent step counts, and a flag for whether step data is available at all. Read through Apple HealthKit and the device's motion co-processor (Core Motion).
• Precise or approximate location. A single most-recent location fix — latitude, longitude, and its accuracy — taken from the position iOS has already cached. Precise or approximate depending on your iOS "Precise Location" setting.

We collect no other health data: no heart rate, no sleep, no medications, no diagnoses, no symptoms, no reproductive or sexual health information, no gender-affirming care information, no biometric identifiers, no health-care records, and nothing about any health service you have sought, received, or paid for.

3. Where it comes from

Only from the device the App is installed on, and only through APIs you have granted permission to: step activity from Apple HealthKit and Core Motion, and location from the fix iOS has already cached.

We do not buy, license, or receive consumer health data from data brokers, advertising networks, health-care providers, insurers, or any other third party. We do not derive it from your browsing, your purchases, or your search history.

4. Why we collect it, and how it is used

Each category has exactly one purpose:

• Step activity tells us the phone's owner is moving, so we can stay quiet. Its entire job is to prevent an alert. This is what lets Raretell work without asking you to check in every day.
• Location does three things and nothing else: it helps wake the App when you move; it gives your chosen emergency contacts a last-known location during an active alert, so they know where help might be sent; and it helps us tell "about to lose signal" apart from "something is wrong," so that driving through a dead zone does not read as an emergency.

We also use both, internally, to improve how reliably the App distinguishes a real silence from a coverage gap. That work is our own engineering on our own service.

We do not use consumer health data to infer anything about your health, to advertise, to market, to build profiles, to score or rank you, to train models we share with anyone, or for any automated decision producing legal or similarly significant effects.

5. Consent

We ask before we collect, on a screen of its own. Step access is requested during onboarding on a dedicated screen that explains what the data is for and offers a plain "Not now." Location is requested the same way, on its own screen. Neither is bundled with accepting our Terms of Service, and neither is a condition of using the App — Raretell runs in a reduced mode without them and tells you it is doing so.

You can withdraw either consent at any time in iOS Settings → Privacy & Security (Health, Motion & Fitness, or Location Services), or by deleting the App or your account. Withdrawal stops further collection; it does not undo processing already carried out. If you withdraw, the App keeps running on whatever signals remain and says so on its home screen rather than continuing to imply you are covered.

We do not use dark patterns. Declining is presented as plainly as accepting, and no screen is designed to make refusal harder than agreement.

6. Who we share it with

We have never sold consumer health data, and we will not. We do not offer it, and we do not have a "valid authorization" mechanism because we do not intend to be in a position to need one.

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

• The emergency contacts you chose — during an active alert only: your last-known location and its age, if you have not turned that off in the App. This is the purpose of the product.
• Cloudflare, Inc. (processor) — stored account data, including step and location values, as our hosting and database provider.
• Apple Inc. (processor) — push notification payloads for check-in prompts and alerts.

We do not share consumer health data with advertisers, ad networks, data brokers, analytics providers, insurers, employers, or law enforcement except where a law compels us. Observers — people you share a status link with — never see your location or your step data; they see only a coarse "all's well / away / trying to reach them."

7. How long we keep it

• Step activity is part of the activity record and has a 90-day retention target, after which it is deleted by an automated daily job.
• Location is kept as one latest fix, overwritten in place each time a newer one arrives. There is no location history and no movement trail on our servers. If your phone has been offline, the beats it saved up each carry the fix that was current when they were taken; when they arrive together we keep only the newest and discard the rest. Those saved-up beats are held on your own phone for at most seven days, not by us. The one fix we hold is deleted with your account.

Section 8 of the Privacy Policy describes the deletion mechanism honestly, including why we state a retention target rather than a guaranteed moment of erasure.

8. Your rights

• Confirm whether we are collecting, sharing, or selling your consumer health data (we do not sell it), and access what we hold.
• Withdraw consent to our collection and sharing — see Section 5.
• Delete your consumer health data. On request we delete it from our live database, and nothing can serve or read it again. You can also delete everything yourself, immediately, using the account-deletion control in the App.  ⚠ What we will not claim. An earlier version of this document said we delete it “including from backups” and that we “notify any processor” to do the same. Neither was true, and we would rather correct it than defend it. Our database provider automatically keeps point-in-time restore points for up to 30 days; a single record cannot be removed from them, because the mechanism restores a whole database to a past moment rather than editing the past. They expire on their own. We do not query them in normal operation and would use one only to recover from a failure. Section 8 of the Privacy Policy describes this in full.
• Not be discriminated against for exercising any of these rights. Raretell's free safety net does not change because you made a request.

To exercise a right, email privacy@raretell.com from the address you want us to act on, or use the in-App deletion control. Because Raretell accounts are pseudonymous — keyed to a random identifier generated on your device, not to your name or email — we usually cannot verify a request except from the device that holds the account. We will tell you if that is the case rather than silently doing nothing, and we will respond within the period the applicable law requires.

You may appeal a refusal by replying to our response. If we deny the appeal we will explain why, and Washington residents may complain to the Washington State Attorney General at atg.wa.gov.

9. Geofencing

Raretell contains no geofences. We do not, and the App technically cannot, place a virtual boundary around any health-care facility, pharmacy, clinic, or any other location in order to identify, track, or collect data from anyone near it, or to send anyone advertising or notifications based on being near one.

The App's only location trigger is iOS's significant-location-change service, which wakes the App after the phone has moved a substantial distance — it knows nothing about what is at either end of that movement.

10. Where this applies

We honor this policy for everyone, everywhere we operate, not only for residents of states that require it. Washington and Nevada residents have the specific statutory rights described above.

11. Changes

If we materially change how we handle consumer health data, we will update this document and its "Last updated" date, and — because these statutes require consent for new purposes — we will ask again rather than relying on a consent you gave for something else.

12. Contact

Redoubtable LLC
Attn: Privacy
8401 Mayland Dr # 10767
Richmond, VA 23294
Email: privacy@raretell.com