US State Privacy Law Notice
Effective: June 18, 2026
This US State Privacy Law Notice supplements our main Privacy Policy and applies to residents of US states with comprehensive consumer privacy laws, including California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and similar laws in other states. It is provided by Grow Labs LLC ("Grow Labs," "we," "us," or "our"), the business responsible for the Safr mobile application. If you live in Washington or Nevada, also see our Consumer Health Data Notice, which covers the specific rights those laws give you over health data.
1. A note on how Safr is built
Safr has no login and no account. We do not ask for your name, email, or phone number to use the app. Instead, your install is identified by a random device identifier (an "install id") that is not tied to your real-world identity. The detailed cycle and health information you log, your period, intercourse, cervical-mucus, symptom, Plan B / emergency-contraception, and LH-test entries, your cycle and period lengths, and the in-app risk estimates Safr calculates, all stay on your device and are not collected by us. Specific, clearly labeled features (optional analytics, advertising measurement, AI chat and photo analysis, and connecting Oura) are the exceptions, and they are described below.
2. Categories of personal information we collect
Under the CCPA/CPRA, the following describes the categories of personal information we may collect, the sources, and why we collect it. We collect most of these only when you opt in to a feature, so many users generate none of them. We do not collect Social Security numbers, driver's license numbers, financial account numbers, precise geolocation, biometric identifiers, or contents of your mail, email, or messages.
| CCPA category | Examples in Safr | Source | Purpose |
|---|---|---|---|
| Identifiers | Random install id; pseudonymous device identifier used to group analytics events. In the US, your device advertising identifier (IDFA) only if you meet the US minimum advertising age (16) and grant Apple's App Tracking Transparency (ATT) prompt. | Generated on your device; ATT identifier from Apple if you grant it. | Run the app, group analytics from the same install, and (with consent) measure advertising. |
| Characteristics / protected classifications (approximate age) | Your birth year, used only to estimate an approximate age. In the UK and EU/EEA, age is not attached to the analytics profile of a known minor; elsewhere it is attached for opted-in users aged 16 or older. | You, during onboarding (only sent to analytics if you opt in). | Understand the age mix of our users and apply age-based protections. |
| Commercial information | Subscription status, the product purchased, plan tier, whether a purchase is a free trial, and the transaction amount and currency. | Apple App Store and our subscription tools; sent to analytics only if you opt in. | Provide and manage subscriptions, prevent fraud, and understand which plans people choose. |
| Internet or other electronic network activity | Which screens you open, which features you use (not their contents), notification interactions, permission outcomes (such as notifications and the ATT prompt), onboarding-step progress, build channel (whether the install is from the App Store or is internal/test), app version, and platform. | Your use of the app (collected only if you opt in to analytics). | Understand usage, debug, and improve the app. |
| Sensitive personal information | Your reproductive-health goal for using Safr (birth control vs pregnancy test) is sent to analytics for adults, and for users 16 or older outside the UK and EU/EEA; under-16s anywhere, and all under-18s in the UK and EU/EEA, send "unknown." Body-temperature data from Oura (if you connect it) and the health entries you log are reproductive and health information. See Section 6 on sensitive PI. | You (onboarding answer, on opt-in) and Oura (if you connect it). Your detailed health logs stay on your device. | Understand retention by goal, power cycle insights, and (for AI features you choose to use) answer your questions. |
We do not send your detailed cycle, intercourse, cervical-mucus, symptom, Plan B, or LH-test logs, your cycle or period lengths, your in-app risk estimates, your name or email, or your chat content or uploaded photos to our analytics or advertising partners. Those either stay on your device or are sent only to the AI provider, and only when you use AI features (Section 4).
3. Where personal information goes (service providers and recipients)
We disclose personal information to the vendors below so they can perform services for us. Except for the advertising-measurement sharing described in Section 5, these are "service providers" or "processors" that are contractually limited to using the data for us. We do not sell personal information for money.
| Recipient | Categories disclosed | Purpose |
|---|---|---|
| PostHog (product analytics, only if you opt in to "Share usage data") | Identifiers (install id); approximate age and reproductive-health goal (under-16s anywhere, and under-18s in the UK and EU/EEA, send "unknown"); internet/usage activity; commercial information (subscription, plan, trial flag, amount, currency); app version, platform, and build channel. | Pseudonymous product analytics to understand usage and improve the app. No detailed health logs are sent. |
| Singular, our mobile measurement partner, which forwards conversions to ad networks including TikTok and Meta (only if ad tracking is active and you meet the age and ATT conditions in Section 5) | Identifiers (and, for a US user who meets the minimum advertising age and grants ATT, the device advertising identifier); commercial information for a subscription event (product, plan, amount, currency). No health data. | Measure which advertising campaigns lead people to install and subscribe. |
| OpenAI (only if you use AI chat or photo analysis) | Your chat message and a summary of your Safr data (cycle dates, symptoms, intercourse and Plan B entries, recent cervical-mucus and LH results, and your in-app risk estimate); for photo analysis, the photo you choose. | Generate a personalized AI answer or analyze the photo. Not used for advertising and not sold. |
| Apple App Store | Commercial information (subscription transactions). | Process and manage subscription payments. We receive subscription status, not your full card details. |
| Superwall | Identifiers and subscription/paywall interaction data. | Present paywalls and process subscription state. |
| Oura (Ōura Health Oy, EU-based) | Source of overnight body-temperature data you authorize. OAuth tokens are stored in your device's secure keychain; the token exchange is proxied through our backend. | Import temperature to inform your on-device cycle insights, only if you connect Oura. |
| Our cloud hosting / backend | Whatever a given feature requires: the AI request, the Oura token exchange, and your install-id-keyed deletion request. | Operate the AI proxy, the Oura token exchange, and deletion requests. |
4. AI chat and photo analysis
If you use Safr's AI chat, 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 (for example, cervical-mucus or LH-test photos), the photo you choose is sent the same way. Safr asks for your explicit agreement before anything is sent the first time, and if you do not agree, nothing is sent. We do not use these features for advertising and do not sell this data. [CONFIRM: our backend does not retain your chat messages or photos beyond what is needed to process the request; confirm OpenAI's enterprise/data-use terms for the API key in use.]
5. "Sale" and "share" of personal information, and your opt-out
We do not sell your personal information for money, and we never share your health, cycle, or reproductive data with advertising networks.
We do work with Singular, a mobile measurement partner, to understand which advertising campaigns bring people to Safr. When this is active, Singular receives device and subscription identifiers and forwards conversion signals to ad networks including TikTok and Meta. Two signals can be forwarded: a pre-paywall "registration" conversion when you finish onboarding, and a subscription conversion (carrying the product, plan, amount, and currency, but no health data). Because this involves disclosing device and commercial identifiers to advertising partners, it may count as a "sale" or a "share" for cross-context behavioral advertising under the CCPA/CPRA and similar state laws. For that reason we treat it as a share you can opt out of, and we do not claim that we never share.
This advertising measurement is a separate choice from product analytics. In the United States it is on by default for users who meet the minimum advertising age (16 in the US), and you can turn it off in Settings at any time. It runs only if all of the following are true: ad tracking is on (it is on by default in the US unless you turn it off), you meet your market's minimum advertising age (16 in the US), and, in the US, you have granted Apple's App Tracking Transparency (ATT) prompt. In the UK, the EU/EEA, and Canada, this ad measurement is instead off by default and runs only if you opt in. Today the app uses Apple's privacy-preserving SKAdNetwork and only accesses your device advertising identifier (IDFA) if a US user who meets the minimum advertising age grants ATT.
6. Sensitive personal information and your right to limit
Some information Safr handles is "sensitive personal information," including health and reproductive data and your reproductive-health goal for using Safr. We use sensitive personal information only to provide the features you ask for (such as cycle insights, AI answers you request, and, for adults who opt in to analytics, understanding retention by goal). We do not use or disclose sensitive personal information to infer characteristics about you, and we do not use it for advertising. Because we limit our use of sensitive personal information to these permitted purposes, there is generally nothing further to restrict, but you can still email us to ask us to limit its use, and you can withdraw the relevant consents in the app (turn off analytics, or disconnect Oura).
7. Your rights
Depending on your state, you may have the right to:
- Know and access the categories and specific pieces of personal information we have, the sources, the purposes, and the categories of recipients.
- Delete the personal information we hold about you.
- Correct inaccurate personal information.
- Opt out of any sale or share of your personal information for cross-context behavioral advertising (see Section 5).
- Limit the use of sensitive personal information to permitted purposes (see Section 6).
- Non-discrimination: we will not deny you service, charge a different price, or give you a lesser experience for exercising these rights.
- Appeal a decision we make on your request (Section 9).
8. How to exercise your rights, and how we verify you
You have direct, in-app controls, which are usually the fastest way to exercise your rights:
- Access / data portability: Settings, then "Export my data," gives you a structured JSON copy of your on-device data plus the identifiers and consent records that link to any server-side copy.
- Delete: Settings, then "Delete all my data," wipes the data on your device, opts out and resets your analytics identifier, detaches advertising attribution, erases your Oura tokens, and sends a deletion request keyed to your install id so we can erase the related server-side analytics record.
- Opt out of sale/share: Settings, then turn off advertising attribution / ad tracking.
- Withdraw consent: turn off analytics, turn off ad tracking, or use "Disconnect Oura" in Settings.
You can also email chenglin@growlabsllc.com to make any request. Because Safr has no account and we do not hold your name, the simplest way for you to exercise these rights is the in-app controls, which act on your own device and install. For requests by email, we verify you to the extent we can by matching the install id associated with your data (which the app can show or send) and corresponding with you at the email you use to contact us. If we cannot verify a request to the standard the law requires, we may not be able to act on it, and we will tell you why.
Authorized agents. You may use an authorized agent to submit a request. We may ask the agent for proof that you gave them written permission to act for you, and we may ask you to verify your own identity or confirm the agent's authority directly with us.
9. Right to appeal
If we decline to act on your request, you may appeal by emailing chenglin@growlabsllc.com with the subject line "Privacy appeal." We will respond to your appeal in writing within the time your state's law allows and explain our decision. If your appeal is denied, you may contact your state attorney general.
10. Minors
Safr applies a region-aware age gate at onboarding (a minimum age of 13 in the US, consistent with COPPA). Advertising attribution is disabled for anyone under the advertising age for their region (16 in the US, Canada, and Australia; 18 in the UK and EU/EEA). In the UK and EU/EEA, we do not attach an approximate age or a reproductive-health goal to the analytics profile of a known minor; their goal is sent as "unknown." Elsewhere, a user aged 16 or older who opted in has these recorded; we never record this for anyone under 16. We do not sell or share the personal information of consumers we know to be under 16.
11. Retention
- On your device: your logs and settings stay until you delete them in the app or remove the app.
- Analytics and advertising measurement: retained for up to 2 years, or sooner if you ask us to delete your data.
- Subscriptions: kept while your subscription is active, plus limited records we are legally required to keep.
12. Contact us
Grow Labs LLC
8 The Green, Suite A, Dover, DE 19901
Privacy contact: chenglin@growlabsllc.com