Consumer Health Data Privacy Policy

Effective October 9, 2026

This policy describes how Strudel Academy LLC (“we”, “us”, “our”) collects, uses, and shares consumer health data in the Fulminata Fitness mobile application (the “App”) and at fulminata.app. It provides the disclosures required by the Washington My Health My Data Act, Nevada’s consumer health data law (SB 370), and Connecticut’s consumer health data provisions, and it applies to every user of the App, wherever you live. Our Privacy Policy describes our data practices in full; this policy supplements it and controls for consumer health data.

“Consumer health data” means personal information that identifies your past, present, or future physical or mental health status, including body measurements, exercise, and diet information, and data we derive from it.

01 Consumer Health Data We Collect, and Why

We collect the following categories of consumer health data, in every case only because you enter it, because a feature you use needs it, or, for the app usage records, because you switched Usage analytics on. Before the App first collects a body measurement, and before it first saves nutrition data, it asks you to allow each and records on your account the date and time you agreed. We also keep a dated record of each time you allowed or stopped body metrics or nutrition data collection, for as long as your account exists, and both the current grant and that history are in your data export; your Fitness data answer stays on your device. After your first workout it asks separately whether the measurements in a completed workout may be used to improve the App, and keeps that answer on your device. The Nutrition data control in Settings → Privacy reads Not allowed until you allow it, and setting it back to Not allowed stops that collection. The app usage records are the one category no feature needs, so we collect them only while you have switched Usage analytics on in Settings → Privacy, and that switch is off until you do. No body measurements and no nutrition data are collected when you sign up:

  • Body measurements: body weight and your weigh-in history, and height.
  • Profile details used in calculations: gender and experience level, as you enter them.
  • Exercise and fitness data: workouts, exercises, sets, reps, weights, duration, distance, pace, machine resistance and incline, personal records, effort ratings, notes and mood ratings you add, streaks, program enrollment, and scheduled training days.
  • Nutrition data: foods and drinks you log with their portion, quantity, meal, date and time, calories, macronutrients, fiber, sugar, and sodium; custom foods, saved meals, and favorite foods.
  • Goals: calorie and macronutrient targets, goal direction and pace, goal weight, activity level, and the daily step band you select.
  • Derived data: an estimate of your maintenance calories, your weight trend, a projected date for reaching a goal weight, and the experience points, level, rank, and achievements the App derives from your workouts. The age you enter in the calorie calculator is used on your device and is not stored.
  • App usage and diagnostics: which features you open and use, the workouts you start and complete, and that you logged a meal, saved a calorie goal or created a custom food, with how long a workout ran and how many sets and exercises it held, kept for no more than 14 months. Each record holds counts, short labels, or the internal record numbers of your own programs and templates; it never holds food names, typed text, or barcodes. Food searches and barcode lookups are sent to our servers to return results; we do not keep the words you typed or the barcode you scanned, only that a search returned nothing or that a scan found no match. While Usage analytics is on, we also record where a food you picked sat in the results (first to tenth, or lower), what kind of result it was (one of the foods we curate, a general food, a branded product, or one of your favorites, recent foods or own foods), and whether a spelling correction found it. That record holds no food name and no words you typed, and is deleted after 90 days. The total weight you moved in a completed workout, and the exercise, type, and value of a personal record, are included only while the Fitness data control in Settings → Privacy reads Allowed; it reads Not allowed until you allow it, and your workout is saved either way. Crash reports carry sanitized error categories, stack traces, and app build metadata, not your entries, and are not linked to your account. Native crash reporting and performance/session tracking are disabled. The usage records are collected only if you ask for them: the Usage analytics switch in Settings → Privacy is off until you turn it on, that switch is both how you turn the collection on and how you withdraw it, and the Fitness data control governs the workout measurements inside those records. Turning Usage analytics off stops the collection and discards anything still waiting on your device; it deletes nothing we already hold, which Export my data and Delete account cover. Crash reports run the other way: they are on unless you turn the Crash reports switch off. Both switches are also offered during onboarding, on the Training step.

We use consumer health data to provide the tracking, statistics, and calculation features you use; to show your trends and progress; to show your workout activity to friends when you choose to use social features; to produce your data export on request; to answer support requests; to measure retention and improve the App; to diagnose technical issues and improve App stability; to keep the App secure and prevent abuse; and to comply with law. We do not use it for advertising or marketing, we do not use it to train large language models or any other artificial intelligence model, we do not use it to infer anything about you beyond the calculations described above, and we do not collect location data or use geofencing.

02 Where It Comes From

Consumer health data comes from you (what you type, select, or scan in the App), from your use of the App (which features you open and use), from your device (its time zone, used to place entries on the right day), and from calculations we perform on the data you entered. We do not obtain consumer health data from any other person or company, and we do not read data from Apple Health, Google Fit, or any other app.

03 How We Share It

We do not sell consumer health data, and we do not share it with any third party or affiliate for their own purposes. Selling it would require your separate, signed authorization under Washington and Nevada law, and we do not ask for one.

Service providers (processors) store or transmit data on our behalf under written contracts that limit them to our instructions: our hosting and database provider stores all of it; our notification and update provider receives only the text of each push notification in transit (for example, that a friend reacted to your personal record, or the name of a program a friend shared) and keeps nothing after delivery; our crash-reporting provider and our purchase-management provider receive no consumer health data. These providers may process data in the United States and other countries where they operate.

Other users see consumer health data only when you choose to use social features: while Findable by username is on in Settings → Privacy, any signed-in user can find your account and see your display name, username, profile image, and equipped cosmetics, and friends whose requests you accept can see your workout statistics, streak, rank, level, experience level, earned achievements and the dates you earned them, recent workouts (the workout name, duration, and total volume, and for any personal record the exercise and the weight, reps, duration, or pace of the record set), and whether you are training right now. The activity feed also shows them when you earn an achievement, reach a new realm or stage, or reach a streak or level milestone. Accepting a friend request is how you ask for this feature. Your accepted friends see the recent workouts listed above, including ones from before you became friends, and each workout you complete is shared with them, with no separate step per workout, until you remove that friend. If you send a friend a workout challenge, that friend also receives the full set list of that workout so they can repeat it. Someone you send a friend request to can view your profile statistics, experience level and earned achievements while deciding. Your nutrition data and body weight are never shown to other users. When Findable by username is off, only the friends you already have can find your account in search, and we refuse a friend request from anyone else.

If you choose Share on a workout, record, achievement or other card in the App, the App makes an image on your device and hands it to the iOS share sheet. We do not upload that image; whoever you send it to, or the service you post it on, receives it under their own terms.

We may also disclose consumer health data if required by law, court order, or governmental request, or to protect our rights, your safety, or the safety of others, and it may be transferred in a merger, acquisition, or sale of assets, in which case we will notify you.

04 Your Rights

You have the right to:

  • Confirm whether we are collecting, sharing, or selling consumer health data about you, and access it, including a list of the third parties and affiliates that have received it. We have no affiliates, we sell nothing, and nobody receives your consumer health data for their own purposes. The list is not always empty: it names the service providers in Section 3 that store or transmit data on our behalf, and, where you used a social feature, the friends you chose to show it to. Ask us and we will name them.
  • Withdraw consent to our collection and sharing of consumer health data. Settings → Privacy carries a control for each category: set Body metrics data, Nutrition data, or Fitness data to Not allowed and we stop collecting that category, without deleting anything you have already entered. Fitness data governs only whether the measurements in a completed workout are used to improve the App, and your answer to it is kept on your device rather than on your account. Because that answer is device-only, it resets to Not allowed on a new device or after you sign out, and you can turn it back on at any time in Settings → Privacy. Usage analytics works the other way round, as a grant rather than a withdrawal: it is off until you turn it on, and turning it off again stops the collection and drops anything still waiting on your device, without deleting what we already hold. You can also turn nutrition tracking off in Settings, and remove friends or leave social features; you can withdraw entirely by deleting the data or your account.
  • Have your consumer health data deleted, including from our backups as they rotate, within the time the law allows.

You can exercise these rights directly in the App: your profile, food entries, and goals can be changed there, weigh-ins can be removed, and any workout can be edited (to delete a workout or a goal entirely, delete your account or email us); Settings → Data & Account → Export my data produces a copy of your data; and Settings → Data & Account → Delete account deletes everything. You can also email support@strudelacademy.com with the subject line “Health Data Request”, from the email address on your account so that we can verify it is you. There is no fee, and we will not discriminate against you for exercising a right. We respond within 45 days, and if we need up to 45 more days we will tell you why before the first period ends.

Appeals. If we decline a request, you may appeal by replying to our response or by emailing support@strudelacademy.com with the subject line “Health Data Appeal”. We will decide the appeal in writing within 45 days. If we deny your appeal, you may contact your state attorney general: in Washington, the Office of the Attorney General at atg.wa.gov; in Nevada, the Office of the Attorney General at ag.nv.gov; in Connecticut, the Office of the Attorney General at portal.ct.gov/ag.

05 Additional Disclosures for Nevada Residents

  • How we process consumer health data: it is stored in our hosted database, encrypted in transit, and protected by access controls that limit each account to its own data.
  • How you can review or modify it: every entry that makes up your consumer health data can be viewed in the App; profile details, food entries, goals, and workouts can be edited there, weigh-ins and food entries removed, and everything deleted with your account or on request. Settings → Privacy shows whether Body metrics data, Nutrition data, and Fitness data are Allowed or Not allowed, and each can be changed at any time; it also shows whether Usage analytics is on, which it is not until you turn it on.
  • How we tell you about material changes: by notice in the App and by updating the effective date at the top of this policy.
  • Collection across other sites and apps: we do not collect consumer health data about you from other websites or apps, and we do not allow third parties to collect it through the App.
  • Requests and deletion: submit requests as described in Section 4; deletion requests are honored within 30 days.
  • Designated request address: support@strudelacademy.com is our designated request address for a verified consumer request under Chapter 603A of the Nevada Revised Statutes, including a request about consumer health data. It is the same address as in Section 7.

06 Changes

We may update this policy from time to time. When we do, we will revise the effective date at the top and notify you in the App before a material change takes effect.

07 Contact

Questions about this policy or our consumer health data practices:

Strudel Academy LLC
2800 E. Enterprise Ave STE 333, Appleton, WI 54913, USA
Telephone: +1 (715) 544-7830
Email: support@strudelacademy.com