Tovkin Consumer Health Data Privacy Policy
Draft — requires attorney review. Not legal advice. Prepared to meet the Washington My Health My Data Act (chapter 19.373 RCW (https://app.leg.wa.gov/RCW/default.aspx?cite=19.373)), which requires a distinct policy with a prominent link on the homepage, and to cover Nevada and similar state laws. Placeholders in [brackets]; [CONFIRM] items need the app builder.
Last updated: [date]. Version 0.1 (draft 2026-10-16).
This policy supplements the Tovkin Privacy Policy for "consumer health data": information that identifies your past, present or future physical or mental health status, including data we infer from other information. In Tovkin that means the health information you enter, the lab results and files you upload, your questions to the companion, your family health history, your checks and results, medications, and anything we infer about your health from them.
1. Categories we collect and why
| Category | Purpose |
|---|---|
| Health conditions, symptoms, family history you tell us | Personalize your checks and answers; prepare you for your clinician |
| Lab results, measurements (blood pressure, A1c, cholesterol, Lp(a), others), files you upload | Explain them; track trends; build your Tovkin Card |
| Medications and supplements you list | Answer questions; flag questions for your clinician or pharmacist |
| Conversations with the companion | Answer you in context |
| Appointments and requests you ask Tovkin to handle | Carry them out with your approval |
| What you choose to share with a plus-one | Share it with them |
| Inferences (for example, "you may be due for a blood-pressure check") | Show you your checks and next steps |
We collect consumer health data only with your consent for these purposes, or to the extent necessary to provide the service you requested. We do not collect it for other purposes without asking you first.
2. Sources
You (directly), people you ask Tovkin to request records from (when that feature exists), and your plus-one only for cheers or acceptance, not health data. We do not obtain consumer health data from brokers.
3. Who we share it with
| Recipient | Categories | Purpose |
|---|---|---|
| Processors under contract: [Supabase] (storage), [Vercel] (hosting), [Anthropic via Vercel AI Gateway] (AI processing), [Resend] (email notices only; no health data in email bodies [CONFIRM]) | As needed | Operate Tovkin for you |
| Your plus-one | Only items you switch on | Your choice |
| A clinic or provider | Only the minimum you approve for that request | Act on your request |
We do not sell consumer health data. We do not share it with third parties for their own purposes. If this ever changed we would ask separately, with a signed authorization as the Act requires (RCW 19.373.070).
4. Your rights
You can: confirm whether we collect, share or sell your data and get a list of third parties and affiliates it was shared with; access it; withdraw consent to collection or sharing; and ask us to delete it. We delete from all our systems including backups (backups within [30 days] and in no case more than six months), and tell processors to delete.
How: in the app (Settings → Privacy) or hello@tovkin.com. We answer within 45 days, and may extend once by 45 days if we tell you why. Two requests a year are free [we recommend: unlimited].
Appeal: if we refuse, reply to our answer with "appeal". We answer in writing within 45 days. If you remain unhappy you can contact the Washington Attorney General at atg.wa.gov (https://www.atg.wa.gov/file-complaint) [CONFIRM link] or your state's attorney general.
5. Consent
We ask for your consent in the app as a separate, clear action before we collect your health information, before we share it with a plus-one and before we use it to act for you. Acceptance of the Terms is not consent. You can withdraw consent in Settings at any time; the app will stop the related feature.
6. Security
Reasonable administrative, technical and physical safeguards, including encryption, access controls, row-level security so members can read only their own data, private file storage, and limited and logged staff access. See the Privacy Policy section 9.
7. Geofencing
We do not use geofencing around health care facilities.
8. Changes
We will tell you in the app and by email before material changes and ask for new consent for new categories or purposes.
9. Contact
hello@tovkin.com · [address]