Nevada Consumer Health Data Privacy Addendum

Effective Date: November 3, 2026

Last updated: November 3, 2026

Entity: ORTHOREP LLC, Washington State

Introduction

This Nevada Consumer Health Data Privacy Addendum applies to consumers who reside in Nevada or whose consumer health data is collected in Nevada.

It supplements OrthoRep’s Privacy Policy and the Washington Consumer Health Data Privacy Notice, and describes how ORTHOREP LLC ("OrthoRep," "we," "our," or "us") collects, uses, shares, and otherwise processes consumer health data as defined by Nevada Senate Bill 370 (2023).

OrthoRep is a local-first app. Consumer health data you enter or that your devices measure is stored on your iPhone and Apple Watch and is not transmitted to OrthoRep servers. The only information that leaves your device is the anonymous usage analytics described below, which you can turn off.

Categories of Consumer Health Data We Collect and the Manner in Which It Will Be Used

1. Body measurements and fitness profile data

Examples: body weight, height, sex, birth year, experience level, training goal, and the equipment you train with.

Used on your device to set up and maintain your profile, calculate loads for bodyweight exercises, display progress, and tailor starting routines and suggestions.

2. Workout, exercise, and performance data

Examples: exercises performed, sets, reps, weight used, reps in reserve, workout duration, routines and templates, workout history, and personal records.

Used on your device to provide workout logging and history, detect personal records, show progress, and generate progression and weight suggestions.

3. Apple Health, Apple Watch, and connected device data

If you grant permission: heart rate, active energy, resting energy, and body weight read from Apple Health or Apple Watch sensors during workouts; completed workouts and active energy written to Apple Health; and heart rate read from a Bluetooth heart rate monitor you connect.

Used on your device to show live stats, save a workout’s average and maximum heart rate, keep your body weight current, and save workouts to Apple Health.

Examples: personal records, estimated one-rep maxes, progression suggestions, and weight suggestions calculated from the categories above.

Used on your device to display progress and suggest what to lift next.

5. Identifiers reasonably linkable to the categories above

The App does not collect your name, email, or account identifier. The anonymous usage analytics described below use a random identifier generated by the analytics SDK on your device, which is linkable only to the limited usage data sent with it.

Categories of Sources From Which Consumer Health Data Is Collected

Directly from you, when you enter body measurements, profile details, workouts, routines, or notes into OrthoRep.
From Apple Health and Apple Watch sensors, only when you grant permission.
From a Bluetooth heart rate monitor, only when you connect one during a workout.
From your use of the App, when the App derives records and suggestions from your history on your device.
From your paired device, when data moves between your iPhone and Apple Watch over Apple’s Watch Connectivity framework.

We do not purchase consumer health data from data brokers, advertising networks, or other third-party vendors.

Categories of Consumer Health Data That Are Shared

Consumer health data stored on your devices is not transmitted to us or to any processor. The only categories that may be disclosed, to a processor acting on our behalf and only to the extent necessary to provide the analytics we use to maintain and improve the App, are:

a limited subset of workout, exercise, and performance data: the number of sets in a workout, its duration, whether it was logged on iPhone or Apple Watch, the time from workout start to the first logged set, the catalog ID of a bundled library exercise when you add it (custom exercises are reported only as "custom"), the number of exercises and days per week in a routine, and the number of personal records in a workout you chose to share; and
a limited subset of fitness profile data: experience level, training goal, and an equipment category.

Weights lifted, reps, body weight, heart rate, Apple Health data, exercise names you type, and notes are never included. You can stop this sharing at any time in Profile › Data & Privacy.

If you turn on Apple Health, workouts you save are written to Apple Health on your device under Apple’s privacy terms. This is a disclosure you direct, not a disclosure by us.

Third parties for independent use: None.
Affiliates: None.

For transparency, the following category of processor may process the limited consumer health data described above on our behalf:

a product analytics provider, currently PostHog, Inc. (EU-hosted), which receives anonymous usage events from the iPhone app unless you turn analytics off. The Apple Watch app sends no analytics.

Apple provides the operating system services the App relies on (Apple Health, Watch Connectivity, and App Store purchases) and processes data on your devices and under your Apple ID according to Apple’s privacy policy. Apple does not receive your training data from us.

We require processors to handle consumer health data only on our instructions and for the purposes disclosed in this addendum.

to provide workout logging, history, routines, and records on your devices;
to display progress and provide progression and weight suggestions;
to enable the Apple Health, Apple Watch, and heart rate monitor integrations you choose to turn on;
to move your data between your iPhone and Apple Watch;
to maintain, troubleshoot, and improve the App through anonymous usage analytics; and
to comply with applicable law, enforce our terms, and protect the rights and safety of users and others.

The Manner in Which Consumer Health Data Will Be Processed

We process consumer health data by storing it on your iPhone and Apple Watch, moving it between those devices when they are paired, and using it on those devices to operate the features you request. The App reads from and writes to Apple Health only with your permission. A limited, anonymous subset of usage data is sent to our analytics processor over an encrypted connection unless you turn analytics off.

Data on your devices is protected by Apple’s iOS and watchOS Data Protection and your device passcode. We use contractual restrictions on our processor and encryption in transit for the analytics data we do send.

We collect consumer health data only:

with your affirmative, voluntary consent; or
to the extent reasonably necessary to provide a product or service that you request.

Logging workouts and entering profile details are services you request. Apple Health access and Bluetooth access each require your separate permission through iOS. Anonymous usage analytics can be turned off at any time in Settings.

Where consent is required for sharing consumer health data, that consent is separate from consent for collection.

Withdrawing consent stops future collection or sharing that depends on it. It does not undo prior processing and does not prevent the App from processing data on your device that is necessary for a feature you continue to use. To stop on-device processing of a category of data, stop using that feature or delete the data.

Procedure for Submitting a Consumer Request

You may submit a request at any time by:

using the controls in the App (Profile › Export Data; delete items in the App or delete the App; Profile › Data & Privacy; the Health app’s data access settings); or
emailing us at privacy@orthorep.app.

We may use secure and reliable methods to verify your identity before acting on a request and may ask for information reasonably necessary to authenticate you and your request.

Because we do not hold a copy of your training data and analytics are not linked to your name or contact details, we usually cannot locate analytics records that belong to a specific person. We will tell you if that is the case for your request.

Process to Review and Request Changes to Consumer Health Data

Your consumer health data is on your devices, where you can review and edit it directly in the App. If you believe we hold other consumer health data about you, contact privacy@orthorep.app to request review or correction. Where data cannot be corrected, you may request deletion.

Process for Notifying Consumers of Material Changes

If we make a material change to this addendum, we will update the Last updated date and post the revised addendum at orthorep.app. Where required by law, we will also provide notice in the App and obtain any consent required before applying the change to consumer health data already collected.

Whether a Third Party May Collect Consumer Health Data Over Time and Across Different Internet Websites or Online Services

We do not authorize any third party to collect consumer health data over time and across different websites or online services when you use OrthoRep. Our analytics processor receives data only from the OrthoRep iPhone app and only on our behalf, and is not authorized to use it for its own cross-site tracking. The App contains no advertising or tracking SDKs. The orthorep.app website sets no cookies and runs no analytics.

Consumer Rights

Subject to applicable law, you have the right to:

confirm whether we are collecting, sharing, or selling consumer health data concerning you;
obtain a list of all third parties with whom we have shared consumer health data concerning you or to whom we have sold it;
cease our collection, sharing, or sale of consumer health data concerning you; and
request deletion of consumer health data concerning you.

We do not sell consumer health data.

Response Timing, Deletion, and Appeals

We respond to requests without undue delay and within 45 days after authenticating the request. We may extend that once by up to 45 additional days when reasonably necessary, and we will tell you why within the initial response period.

Responses are free of charge at least twice each year and for additional requests that are not manifestly unfounded, excessive, or repetitive. Where permitted by law, we may charge a reasonable fee for manifestly unfounded, excessive, or repetitive requests.

If you request deletion of consumer health data we hold, we will:

delete it from our records and network within 30 days after authenticating the request;
notify any processor that received it; and
require that processor to delete it within the time permitted by law.

If data is in archived or backup systems, deletion may be delayed as necessary to restore and delete from those systems, but not for more than 2 years after the request is authenticated.

Data stored only on your devices is deleted by you, in the App or by deleting the App, and takes effect immediately.

If we decline to act on a request, you may appeal by emailing privacy@orthorep.app with the subject line Appeal. We will respond in writing within 45 days. If we deny your appeal, we will provide contact information for the Nevada Office of the Attorney General.

Precise Geolocation and Geofencing

OrthoRep does not collect precise geolocation. PostHog derives an approximate location (country, region and city) from the IP address of each analytics request. It is not linked to your name or any account, and we use it only for aggregate product analytics. The App never asks for or uses your device’s location services. We do not use geofencing around medical facilities, facilities for dependents, or other providers of in-person health care services or products.

Contact Us

Email: privacy@orthorep.app