Consumer Health Data Privacy Policy

Effective Date: July 3, 2026 Last Updated: September 13, 2026

This Consumer Health Data Privacy Policy is provided by Devtegra, LLC (“Devtegra,” “we,” “us,” or “our”) under the Washington My Health My Data Act. It applies to consumer health data handled by our FitCreature mobile application.

1. Categories of Consumer Health Data We Collect, and Why

FitCreature collects the following categories of consumer health data. Except where stated, this data is processed and stored only on your device and is never transmitted to or stored on our servers.

• Exercise and physical activity data: workouts you log in the app (exercises, sets, repetitions, weights, durations, notes) and, with your permission, exercise sessions recorded by other apps. Purpose: to provide workout tracking, history, reports, and the in-app game features that respond to your training. Processed and stored on your device only.
• Health measurements read, with your permission, from Apple Health or Google Health Connect: sleep, steps, heart rate, active calories. Purpose: to show you reports and summaries, to check on your device whether you met in-game step and sleep goals, and to use the heart rate recorded during your workouts in computing the derived fitness scores described below. Processed and stored on your device only. Separately, and only if you turn it on, the app saves the workouts you log in FitCreature to Apple Health or Google Health Connect on your device, where other apps you have allowed can read them; the app never copies data from other apps back into Apple Health or Google Health Connect.
• Body measurements you choose to log or authorize: body weight, body-fat percentage, body measurements. Purpose: to let you track progress toward a goal you set, and to check on your device whether you met an in-game goal for logging them. Processed and stored on your device only.
• Progress photos you take or add in the app to see changes over time. Purpose: to let you compare your progress over time. Processed and stored on your device only. The photo image files are left out of device backups; each photo’s details (such as its date, pose, notes, and the body weight and training goal recorded with it) are saved with your other on-device data and are included in device backups.
• Daily calorie and protein targets you choose to set. Purpose: to let you track your targets. Stored on your device only.
• Derived fitness scores: your device computes eight game scores from your training, each a general rating between 0 and 1, plus an indication of which scores are active. These derived scores are transmitted to and stored on our servers. Purpose: to pair you with opponents and run battles in the game, and to rank Gym Zone leaderboards (regional, national, and worldwide) by one of these scores; other users in the same zone can see your rank. The scores cannot be turned back into your workouts, health measurements, or any other underlying health data.
• Derived progress signals: small values transmitted to our servers so the game can grant rewards and power social features: your training-streak length and the date of your most recent workout, which days included a workout, the number of workout entries you logged on a given day, the number of days you finished a workout while your creature is still an egg, dates bridged by a streak freeze, achievement unlocks, challenge progress (including whether you met a weekly sleep, step, or body-logging goal), reward claims, and milestone events shown to your in-app friends (for example, that you set a new personal record). Purpose: to operate streaks, workout XP, egg hatching, achievements, challenges, quests, and rewards, and to show your friends milestone events, your current streak, and the date of your most recent workout. These signals never include workout contents, exercise names, weights, or health or body measurements.
• Training goal: the goal you choose for your creature (such as build or cut). It is transmitted to and stored on our servers. Purpose: to restore it if you reinstall the app, to tailor in-game messages to it (such as the goal description on your profile), and to tailor reminders to it once that feature is available.
• Approximate location, only if you opt in: your device converts your location into a coarse area code covering an area roughly 5 kilometers across before anything leaves the device, and only that coarse code is transmitted and stored. Purpose: to place you in a regional Gym Zone and in the national Gym Zone for its country, to run Gym Zone leaderboards, and to choose which partner business cards you see by comparing partner locations with the center of your regional zone. Your precise location is never transmitted or stored. Regional Gym Zones are named from public U.S. Census Bureau place data stored in our own database. If you type a city or zip code to change your region, it is matched against the same data in our own database, converted into the same coarse area code, and not kept. No location, area code, or search text is sent to any outside mapping or geocoding service.

2. Categories of Sources

• You, when you log workouts or body measurements, or submit information in the app.
• Apple Health (HealthKit) or Google Health Connect, only with your permission.
• Your device’s sensors (location), only with your permission, and only as the coarse on-device conversion described above.

3. Categories of Consumer Health Data We Share

None. We do not share consumer health data with third parties or affiliates, and we do not sell consumer health data. We use service providers that process data on our behalf under contractual restrictions (our backend hosting provider holds the consumer health data described above that is stored on our servers); they are not permitted to use it for their own purposes.

Some of the derived values described in Section 1 are shown to other users of the app, and only with your consent given in the app: friends you add can see your training streak and your milestone events (a new personal record, training with a buddy, or reaching a new level) if you choose to show them, which is a separate choice from your training consent, and a friend can get a nudge when your streak is about to end; a battle opponent sees which of the rolled game scores you won and by roughly how much, never the scores themselves; and members of your Gym Zone see your rank on its leaderboard. They never see your workouts, exercise names, weights, or health or body measurements.

Partner businesses whose locations you add as a friend in the app do not receive any of the consumer health data listed in Section 1.

4. Third Parties and Affiliates With Whom We Share Consumer Health Data

None. There are no third parties and no affiliates with whom we share consumer health data.

5. Your Rights and How to Exercise Them

If you are a Washington consumer, you have the right to:

• Confirm whether we are collecting, sharing, or selling consumer health data about you, and to access that data, including a list of all third parties and affiliates with whom we have shared or to whom we have sold it and an active contact address for each (as stated above, there are none).
• Withdraw your consent to our collection and sharing of your consumer health data. In the app, open Settings, then Health & Data, then Health data consent, and choose Withdraw. The app stops collecting right away, including workouts, body measurements, and data from Apple Health or Google Health Connect; the derived scores, signals, and training goal we store are cleared when your device next connects; and you choose whether to keep or delete the data stored on your device. You can also turn off health access in your device’s health-permission settings and location in your device settings, or email us as described below.
• Delete your consumer health data. Deleting your account in the app (or requesting deletion at devtegra.com/data-deletion) deletes the consumer health data described above that is stored on our servers. Data stored only on your device is removed by choosing Delete health data from this phone in the app (Settings, then Health & Data, then Health data consent), by deleting your account in the app, or by deleting the app. Workouts the app wrote to Apple Health or Health Connect for you are kept by that service, not by FitCreature, and can stay there until you delete them there, and a file you exported or shared from the app stays wherever you saved or sent it. If your device’s backup (iCloud or Android backup) was made before then, the copy in that backup stays until the backup is replaced or you delete it. Deletion requests also extend to data held in our backups and archives, which are purged on our backup rotation schedule and in any event within six months, and we will notify any applicable third party (as stated above, there are none).

To exercise any of these rights, email contact.us@devtegra.com with the subject line “Consumer Health Data Request” from the email address associated with your account, or use the in-app deletion feature. We may need to verify your identity before acting on a request. We will respond within 45 days of receiving a verifiable request; where reasonably necessary, we may extend once by an additional 45 days and will tell you if that happens.

If we decline to act on your request, you may appeal by replying to our response or emailing contact.us@devtegra.com with the subject line “Consumer Health Data Appeal.” We will respond to an appeal within 45 days. If your appeal is denied, you may contact the Washington State Attorney General at www.atg.wa.gov/file-complaint.

6. Contact

Devtegra, LLC Texas, United States Email: contact.us@devtegra.com