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Consumer Health Data Privacy Notice

Effective: July 24, 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, LH-test, and pregnancy-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. One of those is the optional Safr Cycle Science Study: if you are 18 or older, sync a temperature wearable, and choose to join, your cycle logs are sent to our own research database under a random study ID that is never linked to your name or your device (see Section 2). 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:

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. The one exception is the optional research study described below: if you choose to join it, the logs listed there are sent to our own research database under a random study ID.

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

3. Where this data comes from (sources)

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, unless you join the research study described in Section 2, in which case your temperature readings are also included in what is sent to our research database.

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

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:

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.

Collecting consumer health data for the Safr Cycle Science Study happens only after you give your separate, opt-in consent in the app, and you can withdraw that consent at any time in Settings. Research is not a sale or a share: we receive nothing of value for it, and research data is never disclosed to advertising networks.

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:

How to use your rights, in the app

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.

If you join the research study: raw research data keyed to your study ID is kept for the duration of the Safr Cycle Science Study and for up to 5 years after it ends, then deleted or irreversibly anonymised. You can ask us to delete it sooner by emailing chenglin@growlabsllc.com.

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). The Safr Cycle Science Study is adults only: it is offered only to users who are 18 or older, whatever the local minimum age for using Safr, so a minor is never invited to join.

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.