Consumer Health Data Privacy Notice

Effective: June 18, 2026

In short This notice covers your consumer health data under the Washington My Health My Data Act and Nevada SB370. Almost all of your cycle and health data, like your period, intercourse, mucus, symptom, Plan B, and LH-test logs, stays on your device and is never sent to us. A few features send specific data off your device only when you choose to use them. We do not sell your consumer health data, and we will not share or sell it without your separate, valid authorization. You can access, delete, and withdraw consent right inside the app.

This Consumer Health Data Privacy Notice explains how Grow Labs LLC (“Grow Labs,” “we,” “us,” or “our”) collects, uses, and discloses “consumer health data” in connection with the Safr app. It is provided under the Washington My Health My Data Act (MHMDA) and Nevada SB370, and it supplements our main Privacy Policy and our US State Privacy Law Notice. If anything here conflicts with the main Privacy Policy on the subject of consumer health data, this notice controls.

1. What we mean by consumer health data

“Consumer health data” means personal information that identifies your past, present, or future physical or mental health status. For Safr, this includes information about your menstrual cycle, reproductive health, sexual activity, and use of emergency contraception. Most of this data never leaves your device.

The categories of consumer health data Safr handles are:

Cycle and period data: your period logs, cycle length, period length, cycle history, and last period start.
Sexual activity: intercourse logs, including whether activity was protected or unprotected.
Emergency contraception: Plan B and emergency-contraception logs.
Fertility and ovulation signals: cervical-mucus and discharge logs, LH (ovulation) test logs and results, and, if you choose to connect Oura, overnight body-temperature readings.
Symptoms: symptom logs you record.
In-app risk estimates: the pregnancy-risk values Safr calculates from your logs.
Reproductive intent: your stated goal for using Safr (for example, avoiding pregnancy versus checking for pregnancy) and related onboarding answers.
Photos you choose to analyze: cervical-mucus or LH-test strip photos, only if you use optional photo analysis.
AI chat content: messages you send to the in-app AI assistant and the summary of your Safr data attached to them, only if you use AI chat.

2. On-device versus off-device

Your detailed health logs stay on your device. Your period, intercourse, mucus and discharge, symptom, Plan B, and LH-test logs, your cycle and period length, your cycle history, and your in-app pregnancy-risk values are stored locally in Safr's private app storage and are not sent to our servers during normal use. We never send these detailed logs to our analytics provider and never share them with advertising networks.

A small number of clearly labeled features send specific consumer health data off your device, and only when you choose to use them:

AI chat and optional photo analysis. If you use the AI assistant, your message and a summary of your Safr data (such as your cycle dates, logged symptoms, intercourse and Plan B entries, recent cervical-mucus and LH results, and your in-app risk estimate) are sent through our backend to OpenAI so the assistant can answer you. If you use optional photo analysis, the cervical-mucus or LH-test photo you choose is sent the same way. The first time you use either feature, Safr asks for your explicit agreement before anything is sent. If you do not agree, nothing is sent.
Oura (only if you connect it). If you connect Oura, Safr imports overnight body-temperature data from the Oura cloud API and holds it on your device with your other health data. See Section 4.
Reproductive intent for adults, only if you opt in to analytics. If you turn on “Share usage data” at onboarding (shown as “Usage analytics” in Settings), Safr sends a single coarse label of your stated goal (birth control versus pregnancy test) to our analytics provider, PostHog, to understand retention by goal. For users under 16 in any market, and for users under 18 in the UK and EU/EEA, this label is sent as “unknown,” so a minor's goal is never profiled. No other health data is sent to analytics. See Section 6 of this notice and our Privacy Policy.

3. Where this data comes from (sources)

You: the cycle, intercourse, mucus, symptom, Plan B, and LH data you log; your onboarding answers and reproductive goal; and any photos or chat messages you choose to send.
Your device: calculations Safr performs on your device, such as your in-app pregnancy-risk estimate, derived from what you log.
Oura: if you connect it, overnight body-temperature data imported from the Oura cloud API.
Apple Health: if you grant access, temperature data you already have in Apple Health, used for the same cycle insights. This stays on your device.

4. Connecting Oura

Connecting Oura is optional. If you choose to connect it, you authorize Safr, through Oura's secure OAuth sign-in, to import overnight body-temperature data from the Oura cloud API so Safr can detect the temperature shift around ovulation. The token exchange is handled through our backend, and your Oura access and refresh tokens are stored in your device's secure keystore. Imported temperature is held on your device with your other health data.

You can disconnect at any time using the Disconnect Oura Ring control in Settings. Disconnecting clears the stored Oura tokens from your device, so Safr can no longer import new Oura data. The “Delete all my data” control also erases your Oura tokens. To fully revoke the grant on Oura's side as well, you can remove Safr's access from your Oura account at cloud.ouraring.com. Ōura Health Oy is based in the EU.

5. How we use consumer health data

To provide Safr's core features on your device, including interpreting your logged cycle history and any temperature data to estimate fertile and non-fertile windows and produce daily insights.
To power AI chat and optional photo analysis when you choose to use them.
To understand, in coarse and pseudonymous form, retention by goal (adults only, only if you opt in to analytics), so we can improve the app.
To respond to you when you contact support, and to comply with legal obligations.

We do not use your consumer health data for advertising, and we never share your health data with advertising networks.

6. Who receives consumer health data, and what they receive

We disclose consumer health data only to the service providers (processors) below, acting on our behalf, and only as described:

OpenAI: receives your AI chat message and the attached summary of your Safr data, and any cervical-mucus or LH-test photo you submit for analysis, through our backend, only when you use these features and after you agree. Used to generate your answer or analysis. Not used for advertising and not sold.
PostHog (product analytics): receives, only if you opt in to “Share usage data” (shown as “Usage analytics” in Settings), a coarse onboarding_intent label (birth control versus pregnancy test). For users under 16 in any market, and for users under 18 in the UK and EU/EEA, this is sent as “unknown.” PostHog does not receive your detailed cycle, intercourse, mucus, symptom, Plan B, LH, risk-value, chat, or photo data.
Oura Health Oy: the source of imported body-temperature data you authorize, not a recipient of your other health data.
Our cloud hosting and backend: passes AI chat and photo content to OpenAI, handles the Oura token exchange, and records data-deletion requests. The backend does not store your detailed on-device health logs, and it does not retain your AI chat or photo content after the request is answered.

Our advertising-measurement partner, Singular, and the ad networks it forwards to (including TikTok and Meta), never receive your consumer health data. They receive only non-health commercial and identifier data for ad measurement, as described in our US State Privacy Law Notice.

7. We do not sell your consumer health data

We do not sell your consumer health data, and we will not sell or share it without your separate, valid authorization. "Sell" and "share" here have the meanings given in the Washington My Health My Data Act and Nevada SB370. We do not offer your consumer health data to any third party in exchange for money or other valuable consideration, and we do not collect, use, or share consumer health data for any purpose beyond what is described in this notice without first obtaining the consent the law requires.

8. Your rights

If you are a Washington or Nevada consumer (and many of these controls are available to everyone), you have the right to:

Confirm and access: confirm whether we are collecting, sharing, or selling your consumer health data, and access that data. Safr also lets you export a structured JSON copy of what it stores on your device, in Settings.
Delete: request deletion of your consumer health data.
Withdraw consent: withdraw consent to the collection or sharing of your consumer health data, including disconnecting Oura and turning off optional analytics.
Appeal: appeal a decision we make about your request.

How to use your rights, in the app

Access and export: Settings, under “Your data,” use Export my data for a JSON copy of what Safr stores on your device.
Delete: Settings, use Delete all my data. This wipes your on-device data, opts out and resets your analytics identifier, detaches advertising attribution, erases your Oura tokens, and sends a deletion request to our backend to erase the analytics record keyed to your device identifier. The same action also clears the consent that gates AI chat and photo analysis.
Withdraw consent: use Disconnect Oura Ring, or turn off Usage analytics or Share data with ad partners, in Settings.

You can also exercise any of these rights, or ask us a question, by emailing our privacy contact at chenglin@growlabsllc.com. Safr has no account or login. We identify you by your device or install and may follow up by email to confirm a request and protect your data. We respond within the time the law requires. If we cannot act on a request, we will explain why.

Right to appeal

If we decline to act on your request, you may appeal by replying to our decision or by emailing chenglin@growlabsllc.com with the subject line “Consumer Health Data Appeal.” We will respond to your appeal in writing within the time the law allows and explain the reasons for our decision. If your appeal is denied, you may contact your state attorney general: in Washington, the Office of the Attorney General; in Nevada, the Office of the Nevada Attorney General.

9. Data retention

On your device: your consumer health data stays until you delete it in the app or remove the app. If you opt in to analytics: the coarse, pseudonymous fields described above are retained for up to 2 years, or sooner on request. When you delete your data in the app, we erase it locally, reset your analytics identifier, and request erasure of the analytics record keyed to your device identifier. We keep limited records only where the law requires.

10. Children

Safr applies a region-aware minimum age, checked at onboarding, and does not knowingly collect consumer health data from anyone below the applicable age. Reproductive-intent labeling is, for users under 16 anywhere and users under 18 in the UK and EU/EEA, sent to analytics only as “unknown,” and advertising attribution is disabled below the ad-tracking age for the region (18 in the UK and EU, 16 in the US, Canada, and Australia).

11. Changes to this notice

We may update this notice from time to time. When changes are material, we will update the “Effective” date above and, where appropriate, notify you in the app.

12. Contact us

Grow Labs LLC
8 The Green, Suite A, Dover, DE 19901
Privacy contact: chenglin@growlabsllc.com

Health disclaimer: Safr is an education and cycle-tracking app. It is not a contraceptive and does not prevent pregnancy. Never rely on it to avoid pregnancy. For contraception or medical advice, talk to a healthcare professional.