This is the consumer health data notice for Trackd Co Pty Ltd (ACN 698 405 462, ABN 35 698 405 462), trading as Trakabl, covering the Trakabl application and the website at trackdco.app. It is published separately so that you can find it easily, and the same text appears as Section 16 of our Privacy Policy. Read it alongside the full Privacy Policy, which describes everything else we do with your information.
Some US states have consumer-health-data laws, including Washington's My Health My Data Act, Nevada's SB 370, and the Connecticut Data Privacy Act. Where one of those laws applies to you, this notice is our consumer health data privacy policy.
What consumer health data we collect. Everything you enter about your own health and your own protocols:
- the compounds you record, your doses, injection sites, cycles, and schedules;
- images of bloodwork you upload, and the draw date and notes you add to them;
- body metrics such as bodyweight;
- journal entries, the photos you attach to them, and the markers you record, including side-effect markers;
- progress photos; and
- your date of birth, sex, and goals, from your onboarding answers.
Where it comes from. Directly from you, and from the files you choose to upload. We do not buy consumer health data, obtain it from data brokers, or infer it from anything else.
Why we collect it. Only to provide the Service to you: to record, organise, compute, and display your own data back to you, and to send the reminders you turn on. We do not read or interpret your bloodwork, we do not assess your protocol, and no one at Trakabl reviews what you log.
How it is shared. We do not sell your consumer health data. We do not share it for advertising, and we show no advertising in the Service. We disclose it only to the service providers who help us operate the Service, listed in Section 5 of the Privacy Policy, and where we are required to by law (Section 6 of the Privacy Policy). Our payment processor does not receive it, and we do not use an analytics provider.
Who can see it. Our systems are built so that your protocol, bloodwork, journal, body-metric, and photo data is readable only by you. Neither founder can read it through the app. In an emergency, or where the law requires it, we may need direct database access to fix a fault or comply with a legal obligation.
The legal basis. We collect and process your consumer health data on the basis of the explicit consent you give when you create your account, through a separate consent step distinct from accepting our Terms of Service. We do not collect or share it beyond what is necessary to provide the Service to you without asking you separately.
Your rights. You have the right to:
- confirm whether we are processing your consumer health data, access it, and receive a list of everyone we have disclosed it to (the service providers in Section 5 of the Privacy Policy);
- withdraw your consent to our collection and processing of it; and
- have it deleted.
To exercise any of these, use the in-app "Delete my account" control or contact us at support@trackdco.app. Deleting your account removes your account data and your uploaded files immediately. Our service providers do not hold separate copies of your health data, and residual copies age out of our encrypted backups on their normal cycle. Records we must keep by law are listed, with reasons, in Section 8 of the Privacy Policy; none of them contain your health data.
Withdrawing your consent means closing your account, because the Service cannot operate without processing this information. We will explain that to you before acting on your request.
You will never be charged a different price, or given a worse service, for exercising any of these rights.
How to reach us, and how to complain. Email support@trackdco.app. We aim to acknowledge complaints within 5 business days and to resolve them within 30 days. If we refuse a request, we will tell you why, and you can ask us to look at it again. If you are still not satisfied, you can complain to your state Attorney General; in Australia, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au.