Consumer Health Data Privacy Policy

Who we are

Keel Habit is operated by Swapnil Prakash Chaudhari, a sole proprietor based in India. Contact: [email protected].

What consumer health data we collect

"Consumer health data" is defined broadly in these laws and expressly includes substance-use-disorder information. The categories we collect are:

• The habit you are quitting — for substances such as nicotine or alcohol, this is substance-use data; for the others it is behavioural-health data. Either way we treat it as consumer health data.
• Craving logs, including the free-text notes you write in them — what you were feeling, where you were, what triggered it.
• Streak and relapse history — how long you have gone, and when you started over.
• Quit dates — when you decided to stop.
• AI coach conversation content — what you tell Mira and what she replies.
• Leaderboard entries, if you opt in — a handle you choose, shown next to a named habit and a streak. That combination reveals a recovery status to anyone who can see the board. This is the one feature that intentionally makes health data visible to other people, and it is entirely your choice.
• Check-ins, quit profiles, settings, and your recorded Anchor (a photo, voice note or video of your reason for quitting).

Where it comes from

All of it comes from you, entered directly in the app. We do not buy consumer health data, we do not receive it from data brokers, advertising networks, other apps, or any third-party source, and we do not infer it from anything outside the app. Keel does not connect to Apple Health or Health Connect and requests no health permissions.

What stays on your device

Most of the list above never leaves your phone. Craving logs and their notes, quit profiles, streak and relapse history, quit dates, check-ins, settings, your Anchor media, and your AI plan once it has been returned are stored only in on-device storage. There is no account. We cannot see this data and cannot produce it if asked.

What we actually collect, and why

Three things leave your device, and only these:

• The AI plan and coach. To generate your plan or a chat reply, we send the habit you are quitting, your questionnaire answers, and — for chat — your last 10 messages plus your days-clean and money-saved figures to Cloudflare Workers AI (Llama 3.3 70B) through our own Cloudflare Worker. The reply comes back to your device. We do not store these messages on our servers.
• Usage analytics — opt-in, off by default. If you turn it on, we collect a persistent pseudonymous 24-character install identifier, a session identifier, your platform and app version, screen names, how long you spent on a screen, funnel steps, the habit identifier, and an error signal carrying the type of exception that occurred. The habit identifier makes this consumer health data, which is why it is opt-in and off unless you choose it. Purpose: understanding where people get stuck so we can fix it.
• Leaderboard — opt-in. If you join, we collect a user identifier, a friend code, the habit identifier, the handle you chose, your streak length and your XP. Purpose: ranking the board you asked to be on.

The purposes for collecting consumer health data are therefore: providing the app's core function, generating your AI plan and coaching replies, running the optional leaderboard, and — if you opted in — product analytics. Nothing else. We do not use it for advertising or profiling, and we do not use it to train any model of our own.

Who we share it with

We share consumer health data with these categories of third party, and only for the purposes stated:

• Cloudflare, Inc. — as our processor/service provider. Cloudflare Workers runs our endpoints, Cloudflare Workers AI generates plan and chat responses, and Cloudflare D1 stores opt-in analytics and leaderboard rows. Cloudflare processes this on our instructions.
• RevenueCat, Inc. and Apple Inc. / Google LLC — for purchases and subscription entitlements. These parties receive purchase and receipt data, not your habit, craving notes or chats.

That is the complete list. No advertisers, no analytics SDKs, no data brokers, no ad networks. There are no third-party advertising SDKs in the app at all.

We do not sell consumer health data

We do not sell consumer health data, and we never have. We do not exchange it for money or for anything else of value, to anyone, for any purpose. Because we do not sell it, the signed-authorization process under RCW 19.373.070 does not apply — we do not ask you to sign one, because there is nothing to authorize. If this ever changes, we will obtain valid written authorization first, and this policy will say so before it happens.

How long we keep it

On-device data stays until you delete it, either in-app or by uninstalling. Opt-in analytics events are retained for 548 days (18 months) and then automatically purged. Leaderboard entries are kept while you are a member and removed when you leave or delete your data. AI coach messages are not persisted on our servers.

IP addresses

Our Cloudflare Workers read the connecting IP address (cf-connecting-ip) transiently to rate-limit abuse. It is used for that check and is not stored alongside your app data or used to identify you.

Washington — My Health My Data Act (RCW 19.373)

If you are a Washington resident, or your consumer health data is collected in Washington, you have the following rights under RCW 19.373.060:

• Right to confirm. You can ask us to confirm whether we collect, share or sell your consumer health data, and to access that data.
• Right to a list of third parties. You can ask for a list of all third parties and affiliates with whom we have shared or to whom we have sold your consumer health data, including an active email address or other online mechanism for contacting them.
• Right to withdraw consent. You can withdraw your consent to our collection and to our sharing of your consumer health data at any time. In the app: Settings, where you can turn off analytics and leave the leaderboard. Or email us.
• Right to delete. You can ask us to delete your consumer health data, and we will delete it from our live systems and tell our processors to do the same, as required by RCW 19.373.060(3). One honest caveat: our database provider takes automatic point-in-time backups that we cannot edit selectively. Deleted data expires from those backups on their normal rolling schedule, and we will never restore deleted data from a backup. We would rather tell you exactly how this works than promise something our infrastructure cannot do.

How to exercise these rights: email [email protected] from any address, describing what you want. You do not need an account. The app also gives you two immediate self-service options that need no request at all: Settings → "Delete my account and all data", which erases everything on your device and the limited data on our servers, and CSV export from Settings, which gives you a copy of your data.

Response window: we will respond within 45 days of receiving your request. Where reasonably necessary, we may extend once by a further 45 days, and we will tell you within the first 45 days if we do, with the reason.

Appeals. If we refuse a request, we will tell you why and how to appeal. To appeal, reply to our decision or email [email protected] with "Appeal" in the subject line. We will respond to an appeal in writing within 45 days, explaining the reasons for the decision. If we deny the appeal, we will give you a way to submit a complaint to the Washington State Attorney General.

Employees and contractors. Only the operator has access to the server-side data described above, and access is limited to what is needed to run the service and answer your requests.

Geofencing. Keel does not use geofencing. We do not collect your location at all.

Nevada — SB370 (NRS 603A.400 to 603A.360)

Nevada's consumer health data law imposes materially the same obligations as Washington's. Everything above applies to Nevada consumers: the same categories of data, the same sources, the same purposes, the same third parties, and the same statement that we do not sell consumer health data.

Nevada consumers have the right to confirm whether we are collecting their consumer health data, to access it, to a list of the third parties with whom we have shared it, and to have it deleted. Use the same mechanism — email [email protected] — and we will respond within 45 days, extendable once by 45 days where reasonably necessary. Appeals work exactly as described in the Washington section; if we deny an appeal you may submit a complaint to the Nevada Attorney General.

We do not use geofencing around any health care facility.

Connecticut — CTDPA

The Connecticut Data Privacy Act treats consumer health data as sensitive data, which we may not process without your opt-in consent. That is how Keel is built: nothing leaves your device until you agree on the first-launch consent screen, analytics is off unless you turn it on, and the leaderboard only exists if you join it. You can withdraw consent at any time in Settings, and we will stop processing within 15 days of withdrawal.

Connecticut consumers also have the rights to confirm and access, correct, delete, obtain a portable copy of, and opt out of targeted advertising, sale, and profiling with legal or similarly significant effects. We do not conduct targeted advertising, do not sell personal data, and do not profile you. Correction and portability are available directly in the app (edit anything, export CSV). For anything else, email [email protected]; we respond within 45 days, extendable once by 45 days. Appeals: same process as above, with a right to submit a complaint to the Connecticut Attorney General.

Changes to this policy

We will not collect, use or share consumer health data for a purpose not listed here without asking your consent first. If we make a material change to this policy, we will post the updated version here with a new date and notify users prominently in the app before it takes effect.

Contact

Email [email protected] for any request or question under this policy. The entity responsible is Swapnil Prakash Chaudhari, sole proprietor, trading as "Keel Habit".