Privacy Policy

Who we are and what this covers

This Privacy Policy is issued by Gini Health (“Gini,” “we,” “us”) and covers:

• Available now The website gini.health, including the waitlist and founding-membership checkout.
• Available now The Gini app (the member portal, today at gini-userportal.vercel.app, and the same experience in the Gini iOS and Android apps when they release): your account, dashboard, cycle and symptom logs, journal, lab results, AI advisor, Privacy & Compliance controls, and connected wearables.
• Coming soon Health Records import from health systems, insurers and Medicare, and Gini Care (AI chat, Symptom Radar, clinician handoff). These are described here so you know how data will be handled from the first day they are offered. Until a feature is on in your account, we do not collect the data it describes.
• Coming soon The Gini blood test: kits, samples and laboratory results, from our launch.

Throughout this policy, “Available now” means the feature is live today; “Coming soon” means it is built and described here but not yet offered; “Awaiting partner approval” means a connection that turns on as each device maker approves Gini’s integration. We keep these labels current so nothing here overstates what we do.

Gini is designed for adults. If you are under 18, please do not use Gini or give us any information.

What we collect

Information you give us

• Account: name, email, password (stored only as a salted hash), optional phone, and two-factor authentication secret if you turn MFA on.
• Waitlist: first name, email, optional phone, and the reasons you select for joining. A referral code if a friend sent you.
• Founding membership: name, email, date of birth, US shipping address, whether you were assigned female at birth, pregnancy and pregnancy-planning answers, optional health concerns, and your agreement to our policies. Payment goes to Stripe; we see payment status, not card numbers.
• Health information you enter: cycle dates, symptoms, journal entries, supplements, goals, intake answers, and files or results you upload.
• Gini Care: legal name, preferred name, date of birth, US state, the questions you ask, and messages with clinicians.
• Messages you send to hello@, support@ or privacy@gini.health.

Information from sources you connect

Only with your explicit authorisation at the source, and only for the categories you approve there: wearable and device data, Apple Health and Health Connect data, clinical records and claims from your health system, insurer or Medicare. The table below lists each source.

Information created by the service

• Laboratory results from the lab that processes your Gini sample.
• Derived insights shown to you: cycle-phase estimates, recovery and symptom-pattern flags (Symptom Radar), trend summaries, and AI advisor and Gini Care replies.
• Clinical records created by a Gini Care clinician: notes, lab recommendations, prescription records.
• Consent and audit records: which purposes you have consented to and when, and a tamper-evident log of who accessed your health data (metadata only — never message text).

Information collected automatically

• Website: device and browser type, IP address, referring page and referral parameters, pages viewed, and product events (for example “waitlist form opened”) through PostHog; a page view and a “signup happened” conversion event through the Meta Pixel; video playback events through Mux for the hero video. None of these receive your health answers.
• App: sign-in events, session tokens, device type, IP address, and server logs limited to status codes and timing. The Gini app contains no advertising pixels or trackers.

Where it comes from

• You, through forms, logs, uploads and chat.
• Wearables and health platforms you connect (Oura, WHOOP, Fitbit, Garmin, Withings, Polar, Dexcom, Strava, Apple Health, Health Connect).
• Your health system, insurer or Medicare, when you sign in there and direct them to send your records to Gini. This is your legal right of access; Gini receives the data on your behalf and as your chosen app.
• Laboratories that analyse your Gini sample.
• Clinicians who care for you through Gini Care.
• Payment and email providers: payment status from Stripe; delivery status from our email provider.

We do not buy personal information, and we do not collect health data from data brokers or advertising networks.

Connected sources, one by one

Every connection is opt-in, scoped to what you approve at the source, and reversible. For each source we store an access credential (encrypted, see Security) and the synced measurements. We request only the scopes the feature needs. If a source lets you untick categories at sign-in, we honour that choice and never widen it without asking again. Names and logos belong to their owners; none of these companies endorses Gini.

Limits we accept from partners. Fitbit and Google data are used only to provide and improve Gini’s user-facing features, in line with the Google API Services User Data Policy, including its Limited Use requirements; they are never used for advertising, credit-worthiness or lending, and no human at Gini reads them except with your consent, for security, or to comply with law. Apple Health and Health Connect data are never used for advertising or marketing, never sold, and never shared with a third party without your explicit consent, and are used only for the health and fitness features you chose. Strava data are used only for training volume and never to infer a medical or health condition. Oura data are deleted within 72 hours of your deletion request; in practice, disconnecting deletes them immediately. Medicare and payer data are not re-disclosed to anyone without your consent, and you can revoke Gini’s access at any time in Gini or at Medicare.gov or your plan.

How we use it

• To run Gini for you: create your account, show your dashboard, return and explain lab results, chart cycle and symptoms against your wearable data, import and organise your records, and answer your questions.
• To personalise, only when you allow it: the AI advisor and Gini Care use your connected data only if the “personalise with my data” toggle is on, and health-record categories only when you switch each one on.
• To provide clinician care when you ask for a clinician through Gini Care.
• To keep you safe: deterministic emergency screening in chat (which returns a 911/988 message and never calls the AI), fraud prevention, and account security.
• To communicate: service emails (verification, password reset, “your clinician replied” without the message body), launch and access updates for the waitlist, and marketing email you can opt out of with one click.
• To run the business: fulfil memberships, take payment, estimate tax, ship kits, and keep records the law requires.
• To improve Gini: we may use your data to improve our services — for example to check that a reference range, a cycle-phase insight or a Symptom Radar pattern actually holds for members like you, to fix bugs, and to measure whether a feature helps. This work happens inside Gini, under the same access controls, and is logged like any other access.
• To do research on de-identified data: we may conduct research — including to develop Gini’s own women’s-health model — on data from which your name, contact details, dates of birth, device identifiers and other direct identifiers have been removed under the HIPAA de-identification standard (45 CFR 164.514). De-identified data cannot reasonably be linked back to you; we will not try to re-identify it and we forbid anyone we work with from trying. Research on data that still identifies you happens only with your separate, explicit consent.

We do not use your health data to target advertising, to train general-purpose AI models, to decide your eligibility for insurance, credit, employment or housing, or to profile you for anyone but you.

You can see who has looked. Every time someone other than you reads your data — a member of Gini staff, a clinician you work with, Gini’s AI when it prepares guidance from your records, or an automated sync job — one line is added to an access log you can view, filter and export in full under Account → Who has accessed my data. When a member of staff or a clinician accesses your data, we also notify you (a daily summary by default, or immediately if you prefer; you can turn the notices off). Automated syncs and your own activity do not trigger notices. The log records who, when, why and which categories of data — never the data itself.

AI in Gini

Gini’s AI advisor and Gini Care chat are powered by large language models from Anthropic, accessed through its business API under commercial terms that prohibit training on your content and restrict its use to generating a reply for Gini. The provider may hold conversation content briefly for security and abuse monitoring under those terms. Before clinician services launch we will hold a business associate agreement with the provider covering PHI.

• What is sent: your question, the prior turns of that conversation, and — only if the personalisation toggle is on — a compact summary of the data you allowed (for example, last night’s HRV, recent labs, the record categories you switched on). Your name is limited to a first name.
• What comes back is informational, not a diagnosis. It does not replace a clinician and is not medical advice. If you need medical advice, add a clinician. In an emergency call 911 (or 988 for a mental-health crisis).
• Clinicians may read AI conversations when you request a clinician, so they have context. Gini staff do not read them otherwise, except with your consent, for security investigation, or as the law requires.
• You can turn personalisation off at any time; the AI then knows only your first name and your earlier conversations. You can withdraw the AI consent entirely, which switches the feature off.

How we share it

We never sell your personal information or health data and never share it for cross-context behavioural advertising. We do not sell aggregate or de-identified data either. We share it only as follows.

Processors working for us

They act only on our written instructions, must protect the data, and may not use it for their own purposes:

• Hosting and database: Vercel (application hosting, serverless functions) and Neon (Postgres database) in the United States.
• AI model provider: Anthropic (see AI in Gini).
• Email: Resend, for account and service email from support@gini.health.
• Payments: Stripe. Stripe receives what it needs to charge you (name, email, amount, billing address) and acts under its own privacy policy for card data. It does not receive health answers.
• Laboratories that process your Gini sample, from launch. They receive the sample, the identifiers needed to match it to you, and the biological sex and date of birth needed to run and interpret the panel.
• Operations store: a restricted Google Workspace spreadsheet holds waitlist and founding-member records so we can fulfil memberships.
• Website analytics and video: PostHog (product analytics, error tracking) and Mux (video delivery) for gini.health only.

Clinicians you add

When you ask for a clinician in Gini Care, the clinician you are matched with sees your intake, the conversation, and the data you chose to share. Clinicians are bound by professional confidentiality and HIPAA.

People and services you choose

If you export your data, share a physician summary, or turn on the separate “share with a third party” consent, we send only what you selected, to whom you selected. That consent is off by default.

Advertising platforms

On gini.health, Meta may receive a page-view and a “signup happened” conversion event. It does not receive your email, phone, eligibility answers or health concerns. No health data from the Gini app is ever sent to any advertising platform.

Legal and corporate

We may disclose information when required by law or valid legal process, to protect the rights, safety or property of you, Gini or others, or to a successor if Gini is involved in a merger, acquisition or sale of assets. Any successor would be bound by this policy for the data it receives, and we would tell you before your data became subject to a different policy.

We may publish or share aggregated or de-identified statistics and research findings (for example, “40% of members report brain fog in the luteal phase”) that cannot reasonably identify you, for instance in a scientific paper or a public report. We never charge for aggregate or de-identified data, we will not try to re-identify de-identified data, and we contractually forbid recipients from doing so.

Your choices and rights

Everyone who uses Gini, wherever they live, can:

• Connect and disconnect any source in Wearables or Health Records. Disconnecting revokes our credential at the source (where the source supports it) and deletes the history we synced from it.
• Revoke at the provider too: every source lets you remove Gini in its own settings (see the table). We stop syncing the moment our credential stops working, and we delete the synced data when you disconnect in Gini or ask us to.
• Turn purposes on and off in Privacy & Compliance: storing your health data, AI personalisation, Gini Care AI, sharing with a clinician, sharing with a third party. Each has a plain description and a full history.
• Export a complete machine-readable copy of your data, including consent history and your access log, from Privacy & Compliance.
• See who has accessed your data under Account → Who has accessed my data: a complete, filterable record of every read by staff, clinicians, Gini’s AI and automated jobs, exportable as CSV or JSON. Choose daily or immediate access notifications for staff and clinician access, or turn them off. The log is append-only, kept for at least six years, and survives account deletion.
• Delete your account from Privacy & Compliance. This permanently removes your account and data from our systems and ends your sessions. See Retention for the narrow records the law makes us keep.
• Correct your information in the app or by emailing us.
• Opt out of marketing email with the unsubscribe link in any message. Service emails (security, receipts, clinician replies) continue while you have an account.
• Ask us anything at privacy@gini.health. We may verify your identity first. We do not discriminate against anyone for exercising a privacy right.

State and regional privacy rights

California (CCPA/CPRA and CMIA)

You have the right to know what personal information we collect, use and disclose; to access it; to correct it; to delete it; to opt out of “sale” or “sharing” (we do neither); and to limit the use of sensitive personal information. Health data, precise location, account credentials and sex-life or sexual-orientation information are sensitive personal information. We use sensitive personal information only to provide the services you request and for the security and legal purposes California law permits, so there is nothing further to limit; if that changes we will add a “Limit the Use of My Sensitive Personal Information” link. We do not use or disclose your medical information in violation of the California Confidentiality of Medical Information Act. To exercise rights, email privacy@gini.health. You may designate an authorised agent. The categories of personal information we have collected in the past 12 months, their sources, purposes and recipients are those listed in What we collect, Where it comes from, How we use it and How we share it. We do not knowingly sell or share the personal information of consumers under 16. We have not sold or shared personal information in the preceding 12 months.

Washington, Nevada and Connecticut (consumer health data)

See the Consumer Health Data Privacy Policy below. It lists categories collected, sources, purposes, categories shared, the third parties we share with, and how to exercise the rights to confirm, access, withdraw consent, delete and appeal.

Colorado, Virginia, Connecticut, Texas, Oregon, and other US states

Residents of states with comprehensive privacy laws may access, correct, delete and obtain a portable copy of personal data, opt out of targeted advertising, sale and profiling with legal or similarly significant effects (we do none of these), and appeal a refused request by emailing privacy@gini.health with “Appeal” in the subject. We treat health data as sensitive data and collect it only with your consent.

Outside the United States (GDPR and UK GDPR)

Gini is built for people in the United States and our kits ship only to US addresses, but the website is reachable worldwide. If you are in the EEA, UK or Switzerland, Gini Health is the controller of your data. Our legal bases are: performance of a contract (running the service you asked for), your explicit consent for health data and for connecting sources, legitimate interests (security, fraud prevention, improving the site) and legal obligations. You may access, rectify, erase, restrict, port and object, withdraw consent at any time without affecting prior processing, and complain to your local supervisory authority. Data is stored in the United States; transfers rely on standard contractual clauses or your explicit consent.

Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy applies to “consumer health data” as defined by state laws such as Washington’s My Health My Data Act, Nevada SB 370 and the Connecticut Data Privacy Act. It is part of our Privacy Policy; where the two differ for consumer health data, this policy controls to the extent state law requires. It is also reachable on its own at gini.health/privacy/health.

Consumer health data we collect, and why

Precise location is not collected. We do not use geofences around healthcare facilities to identify, track, or message you.

Where it comes from

• You, when you fill in forms, log data, upload files, or chat.
• Devices and services you connect (wearables, Apple Health, Health Connect), only for the categories you approve.
• Health systems, insurers and Medicare, only after you sign in there and authorise the transfer.
• Laboratories that process your Gini sample.
• Clinicians who care for you through Gini Care.

We do not buy consumer health data and do not collect it from data brokers.

Consumer health data we share, and with whom

We do not sell consumer health data and do not share it for advertising. We share it only:

• With processors that act on our written instructions and may not use it for their own purposes: cloud hosting and database (Vercel, Neon), transactional email (Resend), the AI model provider that generates advisor and Gini Care replies (Anthropic), laboratories that analyse your sample, and our restricted operations store for waitlist and founding-member records (Google Workspace).
• With clinicians you add through Gini Care, to the extent you share it with them.
• With a third party you choose, only after you turn on a separate sharing consent in Privacy & Compliance. It is off by default.
• When required by law, to protect life or safety, or to a successor if Gini is acquired, still under this policy.

We do not share consumer health data with affiliates for their own use. Stripe (payments) and Meta (a signup-happened conversion event) receive no eligibility answers, symptoms, or other consumer health data.

Consent

We ask for your consent before collecting consumer health data (when you fill in a form, connect a source, or turn on a feature) and, separately, before sharing it with any third party other than our processors. You can withdraw either consent at any time in Privacy & Compliance in your account or by emailing privacy@gini.health. Withdrawing collection consent for a feature turns that feature off and we stop collecting for it; withdrawing sharing consent stops the sharing. Selling consumer health data would require your separate, signed authorisation. We have never asked for one and have no plans to.

Your rights

• Confirm and access: learn whether we collect, share, or sell your consumer health data, get a copy, and see the list of third parties it was shared with.
• Withdraw consent for collection or sharing.
• Delete your consumer health data. Deleting your account removes it from our systems, and we pass the deletion request to processors holding a copy. Disconnecting a source deletes the data synced from it.
• Appeal if we decline a request. Email privacy@gini.health with “Appeal” in the subject; we respond within 45 days. Washington residents may also contact the Washington Attorney General; Nevada and Connecticut residents may contact their Attorney General.

We answer within 45 days (extendable once by 45 days with notice), may verify your identity first, and will never charge you a different price or reduce service because you exercised a right, except where the data is required to provide what you asked for (for example, eligibility answers are needed to purchase a blood test).

Contact for consumer health data: privacy@gini.health, or support@gini.health.

HIPAA and Gini Care

HIPAA covers health care providers, health plans and their business associates. For most of what Gini does, Gini is a consumer health app, not a HIPAA covered entity:

• When you connect a wearable, or direct your hospital, doctor, insurer or Medicare to send your records to Gini, you are exercising your own right of access. The sender is the covered entity; Gini receives the data as the app you chose, on your behalf. Once it is in Gini, it is protected by this policy, by the Federal Trade Commission Act and Health Breach Notification Rule, and by state consumer health data laws — not by HIPAA. Your health system and Medicare will tell you the same thing on their consent screens.
• When a licensed clinician treats you through Gini Care, that care is health care. The clinician and the practice are HIPAA covered entities and Gini is their business associate (or, where we operate the practice, a covered entity ourselves). Your clinical record is protected health information and the Notice of Privacy Practices below applies to it.
• The Gini blood test involves clinician-ordered lab work. To the extent that makes Gini or its physician partners a covered entity for your results, the Notice of Privacy Practices applies to those results as well.

We hold everyone’s data to the same technical standard regardless of which law applies (Security). We sign business associate agreements with vendors that handle protected health information for us, and apply the minimum-necessary principle to all staff access.

Notice of Privacy Practices

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Who this notice covers

When a licensed clinician provides care to you through Gini Care, the clinician (and the medical practice through which they are engaged) is a health care provider under HIPAA, and Gini Health acts as the technology platform supporting that care. The information created in that care — your intake, messages with the clinician, clinical notes, lab recommendations and prescription records — is protected health information (PHI). Gini Health, the clinician and the practice follow this notice for PHI, and Gini Health signs business associate agreements with any vendor that handles PHI for us (hosting, database, email delivery, and the AI model provider).

Information you bring to Gini yourself, from your wearables, or from your health records is not PHI in Gini’s hands merely because it came from a doctor or a plan. It is protected by the rest of our Privacy Policy and by state consumer health data laws, and by this notice only once a clinician uses it in your care.

How we may use and disclose PHI

• Treatment. To provide care to you, and to coordinate with other clinicians you ask us to involve (for example, sending a summary to your primary care physician at your request).
• Payment. To bill you for clinician visits. Gini Care does not currently bill insurers.
• Health care operations. Quality review, clinician supervision, training, and running the service. We apply the minimum necessary standard: staff see only what they need. Console operators who are not clinicians see queue counts and status, never names or transcripts.
• Required by law, public health reporting, abuse or neglect reporting, health oversight, court orders, law enforcement within HIPAA’s limits, to avert a serious threat to health or safety, and other disclosures HIPAA permits without authorisation.
• Business associates, under written agreements that require them to protect PHI and use it only for the work we contract.

Uses that need your written authorisation: marketing, sale of PHI (which we do not do), sharing psychotherapy notes, and any other use not described here. You may revoke an authorisation in writing at any time, except to the extent we already relied on it.

AI in Gini Care. The AI assistant drafts informational replies grounded in the data you allow it to see, using a third-party model provider under a business associate agreement. The provider may not train on your data or use it for anything but returning a reply to Gini. Clinicians may review AI conversations when you ask for a clinician. AI replies are informational and are not a diagnosis; a clinician’s reply is medical advice from that clinician.

Your rights over PHI

• Access and copies. Inspect or get a copy of your record, including an electronic copy. Your account’s data export includes your Gini Care record. We respond within 30 days.
• Amend. Ask us to correct your record; we may decline in limited cases and will explain why in writing.
• Accounting of disclosures. A list of disclosures we made other than for treatment, payment, operations, or with your authorisation, for the prior six years.
• Restrictions. Ask us to limit uses or disclosures; we are not always required to agree, but we must agree not to tell your health plan about a service you paid for in full out of pocket.
• Confidential communications. Ask to be contacted in a specific way or place.
• Paper copy of this notice, on request.
• Breach notification. We will tell you if a breach compromises the privacy or security of your PHI.

Telehealth consent

Gini Care clinician services are delivered by asynchronous messaging (telehealth). Before your first clinician conversation you will be asked to read and accept a separate Telehealth Informed Consent covering how messaging care works, its limits and risks, your responsibility to keep a primary care relationship, payment, lab partners, communications, how to complain, and any state-specific medical board notices. Clinicians hold a licence in the state you tell us you are in at the time of care; if none of our clinicians is licensed there, you keep the AI assistant and we tell you so.

Our duties and changes

We are required by law to keep PHI private, give you this notice, and follow the notice currently in effect. We may change it; the new notice will apply to PHI we already hold and will be posted at gini.health/privacy-practices with a new effective date.

Questions and complaints

Privacy Officer, Gini Health — privacy@gini.health. You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights (200 Independence Avenue SW, Washington, DC 20201; 1-877-696-6775; hhs.gov/ocr/complaints). We will not retaliate against you for filing a complaint.

Security

• In transit: all connections use HTTPS/TLS. Webhooks from device makers are signature-verified.
• At rest: our database is encrypted at rest by our hosting provider. On top of that, the credentials that let Gini read from your connected accounts (wearable and health-record tokens) are sealed with AES-256-GCM using a key that lives only on our servers, never in the browser or app.
• Passwords are stored as salted PBKDF2 hashes. You can turn on two-factor authentication (TOTP). Password reset links expire.
• Access controls: role-based access; console operators who are not clinicians see counts and status, not names or transcripts; server logs record status codes and timing only.
• Audit trail: every read, write, export, share, login and deletion involving health data is appended to a hash-chained audit log you can view and verify in Privacy & Compliance. It stores metadata, never message text.
• Access log and notifications: each read of your data by someone other than you is also written to your own append-only access log (Account → Who has accessed my data), with the actor, purpose, data categories and a request id, and staff or clinician reads notify you. Neither the log nor the notices contain health values.
• Data minimisation: we request the narrowest scopes each feature needs, and clinician notification emails contain no message content.
• Vendors are bound by contract to confidentiality and security obligations; those handling PHI sign business associate agreements.

No system is perfectly secure. Protect your password, turn on MFA, and tell us at privacy@gini.health if you see anything wrong.

If something goes wrong

If unsecured identifiable health information is acquired without authorisation, we will notify affected people without unreasonable delay and no later than 60 calendar days after discovery, notify the Federal Trade Commission as the Health Breach Notification Rule requires (and prominent media where 500 or more residents of a state are affected), and notify state authorities and individuals as state breach laws require. Where HIPAA applies we follow the HIPAA Breach Notification Rule as well. Our notice will say what happened, what information was involved, what we are doing, and what you can do.

Retention

• Account and health data you enter: kept while your account is active; deleted when you delete your account.
• Connected-source data: kept while the source is connected; deleted when you disconnect it or delete your account. Credentials are deleted and revoked at the same time. Access tokens from health systems are short-lived (typically one hour) and refreshed only while you stay connected.
• Gini Care clinical records (intake, clinician messages, notes, prescription records): medical-record retention laws require the practice to keep these — generally at least six years from the last visit, longer in some states. After you delete your account they are removed from your Gini profile and kept only in the restricted clinical archive for that period.
• Laboratory results are kept while your account is active; the laboratory keeps its own records under CLIA and state rules.
• Waitlist and founding records: until you ask us to delete them or we no longer need them to fulfil membership, tax and legal duties.
• Payment records follow Stripe’s and tax retention rules (typically seven years).
• Audit-log metadata, your access log and consent history are kept for at least six years for accountability, without content, including after you delete your account.
• Website analytics are retained by PostHog under our project settings and by Meta under its policy; we do not tie them to your account.
• Backups roll off within 30 days of deletion.

Cookies and analytics

gini.health uses first-party cookies and local storage for the site to work (variant, referral code), PostHog cookies for product analytics and error tracking (proxied through gini.health so PostHog does not see a separate third-party request), the Meta Pixel for advertising measurement, and Mux for video playback. You can block cookies in your browser; the site still works. We do not currently respond to “Do Not Track” signals, and because we do not sell or share personal information there is no sale to opt out of.

The Gini app uses only the session token needed to keep you signed in. It contains no advertising or analytics trackers.

Children

Gini is for adults 18 and over. We do not knowingly collect information from anyone under 18, and Gini Care will not treat minors. If you believe a minor has given us information, email privacy@gini.health and we will delete it.

Outside the United States

Gini operates from the United States and stores data there. Kits ship to US addresses only, and Gini Care clinicians serve US states where they are licensed. If you use the website from elsewhere, your information will be transferred to and processed in the United States, and the rights described under GDPR and UK GDPR apply to you.

Changes to this policy

We will update this page when our practices change and revise the version and date above. For material changes — a new category of data, a new purpose, or a new kind of recipient — we will notify you in the app or by email before the change takes effect and, where the law requires, ask for your consent again. We will never widen how we use data we already hold without telling you first. Earlier versions are listed under Version history.

Contact

Privacy Officer / Data Protection contact: privacy@gini.health
Support: support@gini.health
Post: Gini Health, Attn: Privacy, [LEGAL ENTITY NAME AND MAILING ADDRESS]

Version history

• Version 2.1 — September 17, 2026. “How we use it” now states plainly that Gini may use data to improve its services and may conduct research on de-identified data (HIPAA de-identification standard), and that identifiable research needs separate consent. Added that we do not sell aggregate or de-identified data, and that we never charge for the aggregated statistics we publish. Added the member-facing access log (Account → Who has accessed my data) with CSV/JSON export and access notifications for staff and clinician reads, under Your choices, Security and Retention. Answers given on Epic’s Data Use Questionnaire match this version.
• Version 2.0 — September 17, 2026. Extended the policy from the website and waitlist to the Gini app: connected wearables (per-source table), Apple Health and Health Connect, Health Records import, Gini Care and AI disclosures, HIPAA posture and Notice of Privacy Practices, FTC Health Breach Notification Rule, consumer health data policy for Washington, Nevada and Connecticut, expanded California and international rights, security and retention detail, cookies and analytics.
• Version 1.0 — August 31, 2026. First policy, covering gini.health, the waitlist and founding membership.