Consumer Health Data Privacy Policy

Effective: October 22, 2026 · Updated: October 28, 2026. Comads OÜ (ELYND), Ahtri St. 12, 15551 Tallinn, Estonia · [email protected]

This policy is for people in the United States. It explains how ELYND handles “consumer health data”, as Washington’s My Health My Data Act and Nevada’s consumer health data law call it. It covers the ELYND app, elynd.app and any other place where we offer ELYND. Our Privacy Policy has everything else.

What we collect and why

• In the ELYND app: what you write, say or choose about how you feel, your goals, photos you add and the short description we make of them, and your meditation history. We use them to write, voice and personalise your meditations and to show your progress. If what you share sounds very hard, we write your meditation more gently. If you use My voice, we use your voice recording only to speak your meditations in your voice.
• The meditations we make for you, because they can reflect what you shared, and the fact that you use ELYND, for example that you started a meditation and how long it is.
• On elynd.app: only while website analytics is on for you, the pages you visit, which can include articles about topics such as sleep or anxiety (see our Cookie Policy). When we can tell from your connection that you are in Washington or Nevada, website analytics stays off until you switch it on.

Where it comes from

• From you: what you type, say or choose in the app, and your microphone or photos when you use those features.
• From the app and the website, which note what you use, as described under “Who receives it”.

Who receives it

• Service providers that work for us under contract to provide ELYND: the AI services that write and voice meditations, our hosting and storage, and error reporting, and, only if you turn on personal worlds, Meta’s AI models, which receive the written meditation to choose or paint a picture for it. The list is at elynd.app/subprocessors.
• App analytics (Firebase Analytics, by Google): which screens you use and what you tap there, for example that you started a meditation and how long it is, on Android together with your device’s advertising ID. Never what you write or say, your mood or your goals. You can switch this off in the app under Profile › Share usage analytics.
• Meta (measuring and improving our app ads): that you installed and opened the app, created an account and started a meditation (with its length), and, if Meta’s software records it automatically, that you subscribed. On Android, together with your device’s advertising ID. For this, never what you write or say, your mood or your goals. The same switch stops this, with two exceptions: the first install signal, which goes out when the app opens for the very first time, before the switch can apply; and, on iPhone, an anonymous signal that Apple may pass on to Meta or another ad network, without saying who you are, about how far an install from one of its ads got (for example to a first meditation). From app version 1.1.23, the app does not start the Meta SDK in the US (as far as we can tell from your internet connection) and sends Meta none of this; only Apple’s anonymous signal above can still reach Meta for this.
• Google (on elynd.app): the pages you visit, for website analytics and, while Marketing is on, to measure our own Google ads. Only while these are on for you (see our Cookie Policy).
• Over time and across apps and websites: Meta (through the app) and Google (Firebase in the app; Google Analytics and Google Ads measurement on elynd.app, while they are on for you) may collect information about your use of ELYND over time and across other apps and websites.
• People and apps you choose: if you send a meditation to a friend in the app, it goes to the person you choose. If you turn on Apple Health or Health Connect, the app writes your meditation minutes to it on your device.
• Others, only in two cases: authorities, when the law requires it, and a buyer of our business, under this policy.
• What we never do: we never sell what you write, say or choose about how you feel, and we never sell any of your data for money. We have no affiliates.

Your rights

What you can ask:

• to confirm whether we collect or share your consumer health data, and to see it, with the list of companies we shared it with and how to reach them;
• to delete it;
• to withdraw your consent.

How:

• In the ELYND app, under Profile: “Download my data” gives you a copy, My voice lets you delete your voice recording, “Share usage analytics” switches app analytics and Meta measurement off, and “Delete Account” deletes your account.
• Or write to [email protected] from your account email.

When you delete: we delete or anonymise your data within 30 days (Privacy Policy §§ 7 and 8). Copies in our database backups are deleted when those backups expire, at the latest two years after each backup was made. We use backups only to recover from a failure.

Our answer:

• We reply within one month, at no cost (up to twice a year). We may ask for details to confirm that the request is yours.
• If we decline, reply with “Appeal”. We answer in writing within 45 days.
• If we still decline, you can complain to the Washington Attorney General (atg.wa.gov/file-complaint) or the Nevada Attorney General (ag.nv.gov).
• Using these rights never changes how we treat you.

People in other US states with a privacy law: see § 8.1 of our Privacy Policy.

Changes

• When we change this policy, we update the date above.
• We never collect or use consumer health data for anything new without asking you first.

Contact