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.
We collect the following categories of consumer health data, in every case only because you enter it or because a feature you use needs it. Before your first food log, and again before your first body-weight entry, the App asks you to allow that category, and records on your account the date and time you agreed; nothing in these categories is collected when you sign up:
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 infer anything about you beyond the calculations described above, and we do not collect location data or use geofencing.
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.
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 (Supabase) stores all of it; our notification and update provider (Expo) 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 (Sentry) and our purchase-management provider (RevenueCat) 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 workout count, and friends whose requests you accept can see your workout statistics, streak, rank, 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. 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 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.
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.
You have the right to:
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.
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.
Questions about this policy or our consumer health data practices: