Consumer Health Data Policy

Consumer Health Data Policy

Last updated: June 23, 2026.

This Consumer Health Data Privacy Policy describes how The Matter Company LLC ("Oja," "we," "us," or "our") collects, uses, shares, and protects "consumer health data" through the Oja mobile application and related services (the "Service"). It applies in addition to our general Privacy Policy and is provided to comply with the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Law (SB 370), the Connecticut Data Privacy Act, and similar laws. Where this policy applies to consumer health data, it controls.

"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.


Categories of Consumer Health Data We Collect

We may collect the following categories of consumer health data:

  • Symptom and digestive comfort information you log, such as bloating, heartburn, or related symptoms and their severity.

  • Bowel or stool information you choose to log.

  • Body measurements you choose to provide, such as weight.

  • The wellness goal or protocol track you select.

  • Health-related information you provide during onboarding, such as allergies, intolerances, foods you wish to avoid, dietary preferences, and a baseline description of how you feel.

  • Food and meal logs and food photographs, and the dietary and nutrient information derived from them, to the extent this information is used to identify your health status.

  • Insights, scores, and patterns that we derive from the information above.


Sources of Consumer Health Data

We collect consumer health data directly from you when you set up and use the Service and log information in the app. We also derive or infer consumer health data from the information you provide, such as deriving dietary and nutrient information from the food photos and entries you log.


How and Why We Use Consumer Health Data

We collect and use consumer health data to provide the features of the Service that you request, including identifying ingredients in your photos, generating insights, scores, and weekly reviews, building recipes and plans you request, and personalizing your experience based on the goals, preferences, and information you provide. We also use consumer health data to maintain, secure, and support the Service. We do not use consumer health data for purposes that are not described in this policy without first obtaining your consent.


Categories of Consumer Health Data We Share

We share consumer health data only with the service providers (processors) listed below, and only to the extent necessary to provide the Service you request. We do not share consumer health data with advertisers, we do not use it for targeted advertising, and we do not sell it.


Categories of Third Parties and Affiliates With Whom We Share Consumer Health Data

We share consumer health data with the following categories of service providers, who process it on our behalf under contract and only to provide services to us:

  • Cloud hosting and infrastructure providers that store and host the information in the Service. [Insert provider name, e.g., Amazon Web Services or Google Cloud.]

  • An artificial intelligence processing provider that analyzes food photographs and generates text such as insights and recipes. This provider processes the information to return results to us and does not use it to train its own general-purpose models. [Insert provider name, e.g., OpenAI.]

Our email delivery, analytics, and customer support providers are configured so that they do not receive your consumer health data.


Affiliates.
We do not have affiliates with whom we share consumer health data.

We may also disclose consumer health data if required to comply with applicable law or legal process, or in connection with a merger, acquisition, or sale of assets, in which case the recipient will remain bound by this policy.


Your Rights Regarding Consumer Health Data

You have the right to:

  • Confirm whether we collect, share, or sell your consumer health data, and access the consumer health data we have collected about you.

  • Obtain a list of the third parties and affiliates with whom we have shared or sold your consumer health data, along with contact information for those third parties.

  • Withdraw consent to our collection and sharing of your consumer health data.

  • Delete your consumer health data, and have us direct our service providers to delete it.

  • Appeal a decision we make regarding your request.


How to Exercise Your Rights

To exercise any of these rights, email us at support@ojacare.com or use the in-app settings. You may also delete much of your information directly in the app's settings. We will not require you to create a new account to exercise your rights, and we will not discriminate against you for exercising them.

We will authenticate your request using commercially reasonable methods and respond within 45 days. We may extend this period by an additional 45 days when reasonably necessary, and we will tell you if we do. If we deny your request, you may appeal, and we will respond to your appeal within 45 days. If we deny your appeal, you may contact the Attorney General of your state to submit a complaint.


Consent, Sale, and Geofencing

We collect and share consumer health data only as necessary to provide the Service you have requested, or with your consent. We do not sell consumer health data. We do not use geofencing technology to identify or track consumers, to collect consumer health data, or to send messages or advertisements related to consumer health data or health care services.


Data We Do Not Collect

We do not collect precise geolocation, biometric identifiers, or information about reproductive or sexual health or gender-affirming care.


Security and Retention

We maintain administrative, technical, and physical safeguards designed to protect consumer health data, including limiting access to those who need it to provide the Service. We retain consumer health data only as long as necessary to provide the Service and as required by law, and we delete or de-identify it when it is no longer needed.


Changes to This Policy

If we intend to collect, use, or share categories of consumer health data, share with third parties or affiliates, or use consumer health data for purposes that are not described in this policy, we will update this policy and obtain your consent where required before doing so.


Contact Us


Email:
support@ojacare.com
The Matter Company LLC