Privacy Policy

Effective date: September 17, 2026

This Privacy Policy explains how Human Codex ("we," "us," or "our") collects, uses, shares, and protects information when you use our mobile app, website, and related services (the "Services").

1. Information We Collect

  • Account and contact data, including Sign in with Apple identifiers, email address, profile details, and support messages.
  • Health and wellness data you provide directly, including nutrition, water, supplements, medications, symptoms, habits, fasting records, vitals, notes, and lab biomarkers.
  • Data you authorize from Apple Health/HealthKit and connected services, such as heart rate, resting heart rate, heart rate variability, sleep, workouts, steps, body measurements, glucose, ketones, blood pressure, and other supported metrics.
  • Content you choose to submit for analysis or storage, such as chat messages, journal entries, uploaded lab reports, PDFs, meal photos, and other user-provided files.
  • Calendar or reminder data when you authorize the app to create Apple Calendar events or Apple Reminders items.
  • Voice and speech input if you use microphone or speech recognition features to interact with the app.
  • Location data if you grant permission for sun exposure or UV-related features.
  • Technical, diagnostic, and usage data, such as app version, device type, crash logs, telemetry, and product analytics.
  • Subscription and transaction metadata from Apple. We do not receive or store your full payment card details.

2. Permissions and Optional Integrations

Depending on the features you use, the app may request permission to access Apple Health/HealthKit, Camera, Photos, Microphone, Speech Recognition, Calendars, Reminders, Notifications, and Location. These permissions are optional unless directly required for the feature you choose to use, and you can manage them in iOS Settings or within applicable in-app controls.

3. On-Device Storage and Cloud Processing

Human Codex uses a privacy-oriented architecture. A significant portion of your health and profile data is stored locally on your device using Apple technologies such as SwiftData, Keychain, and the iOS security model. When you use the Agent, the data it needs to respond is sent to our AI providers, as described in Section 4.

Some features require secure cloud or third-party processing to work. When you use features such as Agent chat, lab report OCR and interpretation, the morning briefing, plan generation, food photo analysis, voice features, or other network-dependent tools, the data needed for that request is transmitted to service providers.

Because some functionality depends on cloud processing, we do not describe the Services as operating exclusively on-device.

4. AI Processing and Language Models

Human Codex uses artificial intelligence, including large language models, to generate health-related summaries, explanations, action ideas, and other decision-support outputs. Our current primary AI processing provider is Google through the Gemini API. We may change or add providers over time.

We also use Anthropic (Claude) as a fallback provider for lab report interpretation, and Google Document AI to extract the contents of lab reports you upload. Data sent to these providers is processed under their respective terms.

  • Data is sent to AI providers only for AI-powered features — such as Agent chat, lab report interpretation, the morning briefing, and plan generation — and, where applicable, after explicit consent.
  • Depending on the feature, data sent may include:
    • Profile details, such as your name, age, sex, height, weight, BMI, activity level, allergies, and notes you add.
    • Health goals and diet preferences.
    • Health conditions and medications.
    • Memories the Agent has saved and the name you gave it.
    • Apple Health readings and recent metrics, such as steps, heart rate, heart rate variability, VO2 max, sleep, weight, body fat, and workouts, including 90-day averages when interpreting lab reports.
    • Measurements you log, such as glucose, ketones, and blood pressure.
    • Food, water, caffeine, and fasting logs, and training sessions you record.
    • Family history and menstrual-cycle status, used to generate your plan.
    • Lab results, including reports you upload (parsed by Google Document AI).
    • Images or files you choose to share.
    • Your messages to the Agent.
  • Sign-in credentials, access tokens, and passwords are not intentionally sent to AI providers.
  • We configure AI processing for product functionality, not advertising. Where provider terms and controls offer a no-training or equivalent setting, we do not intentionally provide user data for third-party model training.
  • Provider handling and retention may vary depending on service configuration, provider terms, abuse-monitoring requirements, and law.
  • AI-generated content is informational only and does not constitute medical advice, diagnosis, treatment, or emergency guidance.

5. How We Use Information

  • Provide, maintain, and improve personalized health interpretation, AI assistance, and product functionality.
  • Process user requests, including chat responses, lab interpretation, OCR, food analysis, reminders, calendar events, and summaries.
  • Maintain security, reliability, performance, and abuse prevention.
  • Process subscriptions, restore purchases, customer support, and service communications, and send optional updates if you choose to receive them.
  • Comply with legal obligations and enforce our Terms of Service.
  • Analyze product usage using aggregated, de-identified, or otherwise privacy-protective measurements where appropriate.

6. Health Data and HealthKit Commitments

We treat health-related information as sensitive data. For data obtained through Apple Health/HealthKit or other health-related features:

  • The health data we may collect can include metrics such as heart rate, resting heart rate, heart rate variability, sleep, steps, workouts, body measurements, glucose, ketones, blood pressure, fasting information, nutrition logs, water logs, and lab-related entries where supported.
  • HealthKit and other health data are not used for advertising, marketing, ad targeting, or data brokerage.
  • We do not sell health data to third parties.
  • Health data is shared only when reasonably necessary to provide a feature you request, operate the Services, or comply with law, and where required only after obtaining explicit permission.
  • We do not write false, misleading, or clinically unsafe or inaccurate data into HealthKit.
  • You can disable Health access through iOS Settings > Privacy & Security > Health and through applicable in-app controls.

7. Analytics, Diagnostics, and Telemetry

We may use analytics, diagnostics, crash reporting, and telemetry tools to understand performance, reliability, and feature quality. Current services may include Firebase Analytics, Firebase Crashlytics, Google Analytics on the website, and internal or hosted telemetry infrastructure.

These systems may process device and app metadata, hashed or pseudonymous identifiers, crash data, and product interaction events. The values you log — nutrition, weight, glucose, fasting hours and similar readings — are not included in analytics or telemetry events: we record that something happened, not what it contained. Events collected before September 2026 may still contain some of those values, and they are kept for the periods described in Section 11. We do not use health data from HealthKit or similar sources for advertising or use-based data mining.

Advertising measurement. We run app-install ad campaigns with Meta and Google, and the app includes the Meta SDK and Google Analytics for Firebase to measure them. Because that measurement can use your device's advertising identifier, iOS asks for your permission through Apple's App Tracking Transparency prompt: new installs see it during setup, and people who installed earlier see it once after updating. You can change your answer at any time in iOS Settings > Privacy & Security > Tracking.

  • If you allow tracking: app events such as installs, launches and purchases are sent to Meta together with your device's advertising identifier (IDFA), and Google receives ad-measurement signals for the same kind of events. Google's ad personalization signal stays off in every case, and we do not use Meta app events to build remarketing audiences.
  • If you decline, or your device does not allow the request: no advertising identifier is shared with anyone, and Google receives no advertising signals. The Meta SDK keeps sending basic app events such as installs, launches and purchases, with no advertising identifier attached and flagged so that Meta restricts them to measurement rather than ad targeting. Until you answer, a new install sends Meta nothing at all; an app updated from an earlier version may already have sent those same basic events.
  • Either way, Apple's SKAdNetwork framework reports aggregated campaign results that do not identify you, and we have turned off collection of the device's vendor identifier (IDFV) in Google Analytics.

Health data is never sent to advertising partners and never used for advertising: your labs, meals, weight, fasting records and conversations with the Agent stay out of these events. Declining tracking changes nothing about how the app works.

Analytics identifiers and deletion. Analytics identifies your install with a random identifier, not with your name or email. When you delete your account, the app replaces that identifier with a new one, resets its Firebase Analytics data, and removes the Meta SDK's anonymous identifier, so activity recorded afterwards is not joined to activity recorded before. This resets identifiers going forward; it does not anonymize data already collected, which is retained as described in Section 11.

8. How We Share Information

We may share information with:

  • AI processing providers, currently including Google Gemini API, Google Document AI, and Anthropic (Claude), to fulfill AI-powered requests.
  • Evidence search services, currently NCBI PubMed and Tavily, which receive the search terms the Agent writes to find sources; these can name a health topic, condition, or marker.
  • Analytics and diagnostics providers, currently including Firebase Analytics, Firebase Crashlytics, and Google Analytics, for product measurement, reliability, and website traffic analysis.
  • Advertising measurement partners, currently Meta and Google. With your permission under App Tracking Transparency, their SDKs receive app events such as installs, launches and purchases together with your device's advertising identifier (IDFA). Without that permission, no advertising identifier is shared and Google receives no advertising signals; Meta still receives those basic app events, flagged so that they are restricted to measurement rather than ad targeting. Apple's SKAdNetwork reports aggregated campaign results either way. Health data is never shared with them and never used for advertising.
  • Apple, for Sign in with Apple, App Store subscription processing, billing metadata, and platform services you use through iOS.
  • Connected services you choose to enable when you direct the app to connect or manage content on your behalf.
  • Service providers acting on our instructions, such as infrastructure, security, support, or operational vendors, subject to contractual or operational data-protection obligations.
  • Professional advisors and auditors under confidentiality obligations.
  • Authorities where required by law, court order, or legal process.
  • Successors in a merger, acquisition, financing, or asset transfer, subject to this Policy and applicable law.

We require service providers acting on our instructions to protect personal data in a manner consistent with this Policy and applicable law.

9. Cookies and Website Analytics

Our website uses a small number of strictly necessary cookies required for it to function, which do not need consent. We also use Google Analytics (GA4), which sets measurement cookies (such as _ga and _ga_*) to understand traffic, measure site performance, and improve the user experience. Analytics cookies are not strictly necessary, so they are disabled by default and are only set after you give consent through our cookie banner. You can accept or reject analytics at any time using the “Cookie settings” link in the website footer. We do not use cookies for cross-site behavioral advertising or to build health-based advertising profiles.

10. Legal Bases and Consent

Depending on your jurisdiction, we may process information based on your consent, the performance of a contract, legitimate interests such as security and product improvement, and compliance with legal obligations. You can withdraw certain permissions and consents through iOS Settings or applicable in-app controls, subject to technical and legal limits.

11. Data Retention and Deletion

We retain personal data only for as long as necessary for the purposes described in this Policy, including legal, security, fraud-prevention, accounting, tax, and dispute-resolution needs. Our current retention targets are:

  • Account, profile, subscription, and core service records: retained while your account is active, and generally deleted or de-identified within 90 days after account deletion unless a longer period is required for legal, tax, security, or dispute-resolution reasons.
  • Health, wellness, journal, lab, chat, and uploaded content stored by the Services: retained while your account is active or until you delete the data or request deletion, subject to backup, legal, and provider-processing limitations.
  • Local app data stored on your device: retained on your device until you clear it, delete your account, or remove the app.
  • Product analytics and telemetry: event-level data is retained in pseudonymous form for up to 14 months in Google Analytics and its BigQuery export, then deleted or aggregated.
  • Crash logs and diagnostic logs: generally retained for up to 30 days unless needed longer to investigate reliability, abuse, security, or legal issues.
  • Support, billing, tax, fraud-prevention, and legal records: retained as long as reasonably necessary for the relevant operational, accounting, or legal purpose.

Cloud-processed or provider-handled data may have different retention periods depending on the feature, provider, and applicable law. The app may include in-app options to clear data or delete your account. You can also contact us at privacy@humancodex.app to request deletion or ask questions about retention.

12. Your Choices and Privacy Rights

Depending on your location, including California and other states with privacy laws, you may have rights to:

  • Access, correct, or delete personal data.
  • Obtain a portable copy of certain personal data.
  • Withdraw certain consents and revoke permissions.
  • Opt out of the sale or sharing of personal data where applicable. We do not sell personal data.
  • Appeal certain privacy decisions where local law provides that right.

If you reside in the European Economic Area, the United Kingdom, or Switzerland, you may have additional rights under the GDPR, UK GDPR, or similar laws, including the right to object to or restrict certain processing, request portability, withdraw consent, and lodge a complaint with your local supervisory authority.

If you reside in California, you may have additional rights under the California Consumer Privacy Act as amended by the CPRA, including the right to know, access, correct, delete, and obtain a copy of personal information, and to opt out of the sale or sharing of personal information where applicable. We do not sell health data or use it for cross-context behavioral advertising.

You can also manage permissions for Health, Photos, Camera, Microphone, Speech Recognition, Location, Calendars, Reminders, and Notifications through iOS Settings, change your tracking answer at any time under iOS Settings > Privacy & Security > Tracking, and disconnect optional connectors through in-app controls when available.

To exercise your rights, contact us at privacy@humancodex.app.

13. Security

We use administrative, technical, and organizational safeguards designed to protect personal data, including sensitive health information, against unauthorized access, disclosure, alteration, and destruction. No method of storage or transmission is completely secure, but we work to apply reasonable and appropriate safeguards.

14. U.S. Health Privacy Laws

  • HIPAA scope: Unless explicitly stated in a separate agreement, Human Codex does not act as a HIPAA covered entity or business associate. The Services are intended for consumer self-management, education, and wellness support.
  • Breach notifications: Where applicable, we follow U.S. breach-notification obligations, including the FTC Health Breach Notification Rule and applicable state laws.

15. Children

Our Services are not directed to children under 13, or under a higher age where local law requires it. We do not knowingly collect personal data from children without legally required consent. If you believe a child has provided personal data to us, contact us and we will review and delete the information where appropriate.

16. International Transfers

If information is processed across borders, including by AI, analytics, diagnostics, or infrastructure providers, we use contractual and operational safeguards designed to protect data in line with applicable law, including Standard Contractual Clauses where required.

17. Changes to This Policy

We may update this Policy from time to time. Material updates may be communicated through the app, website, or other appropriate channels. The effective date at the top reflects the latest version.

18. Contact

Privacy questions, data requests, or concerns: privacy@humancodex.app

Human Codex · San Juan, Puerto Rico