Consumer Health Data Privacy Policy

Stelr Labs, LLC (Orion)
Effective date: September 30, 2026
Last updated: September 30, 2026

This policy explains how Stelr Labs, LLC ("we," "us") collects, uses, shares and deletes "consumer health data," as the Washington My Health My Data Act (RCW 19.373) and Nevada law (NRS 603A.400 to 603A.550) define that term. It covers data collected through the Orion app for iPhone and Apple Watch, including the AI Coach. It applies to the consumer health data of Washington and Nevada residents, and of anyone whose consumer health data is collected or processed in Washington or Nevada. Because Stelr Labs is based in Washington, we honor the rights in this policy for all Orion users. This policy supplements our Privacy Policy (https://www.stelrlabs.com/privacy.html).

Contact: Stelr Labs, LLC, Spokane, Washington, privacy@stelrlabs.com.

Consumer health data we collect

• Apple Health data you allow Orion to read: workouts (including those recorded by other apps and devices), workout routes, heart rate, active energy, steps, running speed and body weight. For the AI Coach, Orion also reads heart-rate variability, resting heart rate, heart-rate recovery, VO2 max, exercise time, sleep and workout effort.
• Heart rate and calories recorded while you record a workout with Orion (for example, from your Apple Watch), and calorie estimates we calculate for gym workouts. These are shown in the app and saved to Apple Health. When you record an outdoor workout on your iPhone, the route saved to our servers also includes your heart rate at each point along it, taken from Apple Health readings during the workout. Calories are not uploaded to our servers.
• Workout data you log, record or import (for example, from another workout app's export file): workout names and captions, dates and times, workout type, exercises, sets, weights, reps, durations, distances, pace, active time, splits, steps, elevation, notes and effort ratings.
• Workout location. If you allow location access, we record one precise map coordinate for each workout you save, gym or outdoor, along with the city, region and country and any venue name you type. During outdoor workouts we record your GPS route, which is saved to your Orion account on our servers and, if Apple Health access is on, in Apple Health.
• AI Coach profile: injuries and injury notes, height, weight, date of birth, gender, goals, training experience, training days and session length.
• Workout photos you add, which may show your body.
• Information we derive:
  • recovery "readiness" ratings and their notes, which can include health values and are recorded in our AI Coach service logs;
  • training-consistency assessments;
  • AI Coach weekly plans and coach notes;
  • calorie estimates;
  • weekly workout counts and streaks.

How we use it

• To record, display and sync your workouts across your devices.
• To save workouts to, and read them from, Apple Health, and to estimate calories.
• To show where a workout happened.
• To show your workouts and weekly progress to the accountability groups you join, and to send group notifications.
• To create AI Coach training plans and coach notes.
• To operate, secure and fix the Services, including diagnosing crashes and bugs from reports that may show health information.
• To understand how Orion is used so we can improve it.

We don't use consumer health data for advertising. The only information Orion sends to an advertising company is described under "Third-party tracking" below. It doesn't include your workouts, Apple Health data, AI Coach information or workout location.

How we process it

We process consumer health data on your devices and on servers run by us and our service providers, mainly in the United States. For the AI Coach, Apple Health metrics are summarized on your device before anything is sent. Some service providers, including our AI model provider, may process data in other countries. We limit access to consumer health data to the people and service providers who need it to provide the Services.

Sources

• You, including files you import from other workout apps.
• Your iPhone's and Apple Watch's sensors, such as GPS, the heart-rate sensor, the step counter, motion sensors and the barometer.
• Apple Health.
• Apple's location services, which turn a workout's coordinate into a place name.
• Our own processing, including AI Coach assessments.

Consumer health data we share, and with whom

• Service providers that process it for us:
  • Cloud hosting, database and photo storage providers, which hold the consumer health data we keep on our servers.
  • Our analytics provider. It receives workout activity linked to your name, email address and Orion account, such as workout type, duration, distance, number of exercises, the names of custom exercises you create, and when you use the AI Coach or save a progress photo. It doesn't receive Apple Health values, workout locations, notes or photos.
  • Our bug-reporting provider. It receives crash and error reports and the reports you send. These include your name, your email address and a recent diagnostic log that may contain workout activity. Reports you send also include a screenshot, which may show health information.
  • A third-party AI model provider that creates AI Coach plans. It receives your goals, training experience, age (instead of your date of birth), gender, height, weight, and injuries and injury notes. It also receives your recent workouts, including notes, captions, effort ratings and each workout's location with its map coordinate, and a readiness assessment worked out from your Apple Health summary.
• Apple, which provides Apple Health on your device, looks up place names for workout locations, delivers push notifications (including your workout progress to group members), and provides iCloud storage for your progress photos.
• Other Orion users in accountability groups you join:
  • Members see workouts set to "My groups". This is the default for new workouts, including workouts imported from Apple Health. For each workout they see the workout name, caption, date and time; exercises, sets, weights, reps, durations and distances; for outdoor workouts, the type, distance, elevation, duration and a map of your route, which can show where you started and finished; workout photos; and where the workout happened, shown as a place name. They don't see the single map coordinate recorded for a workout, your notes, effort ratings, step counts, Apple Health metrics or AI Coach information.
  • Members also see your weekly workout count, which includes workouts set to "Only me", and may get notifications about your progress.
  • People you or other members send a group invite link to can see your weekly workout count before they join.
  • You can change each workout's visibility, and your default visibility, in Settings.
• Workouts imported from Apple Health. When "Show Apple Health Workouts" is on (the default), workouts that other apps saved to Apple Health are uploaded to your Orion account. Like your other workouts, they are visible to your groups unless you set them to "Only me" or change your default workout visibility. Turning the setting off hides them in the app but doesn't delete them from our servers or from group feeds. To remove one, delete it in the app.

We have no affiliates that receive consumer health data. We don't sell consumer health data.

Third-party tracking

Orion includes Meta's app software development kit (SDK). The SDK collects app-event information, such as app installs and opens and, possibly, in-app purchases, along with device information and identifiers. Meta may combine this with information from other apps and websites. We don't send Meta your workouts, Apple Health data, AI Coach information, workout location or other health measurements. Our analytics and bug-reporting providers process data only for us and don't track you across other apps or websites. For more detail, see "Meta (Facebook SDK)" in our Privacy Policy.

Your rights

You have the right to:

• confirm whether we collect, share or sell your consumer health data;
• access it, including a list of all third parties and affiliates we have shared it with and an email address or other online way to contact them;
• withdraw consent, and ask us to stop collecting and sharing your consumer health data;
• delete it.

Reviewing and changing your data. You can review and change your workouts, workout visibility and AI Coach answers in the app, and delete individual workouts and photos. To ask us to change anything you can't change in the app, email privacy@stelrlabs.com.

Withdrawing consent. You can withdraw consent at any time:

• set workouts to "Only me", or leave a group, to stop showing them to that group;
• turn off Settings > Auto-Generate Weekly Plan and stop requesting AI Coach plans;
• turn off Orion's access in iOS Settings > Privacy & Security > Health, or Location Services, to stop future collection.

For anything else, email privacy@stelrlabs.com. We'll stop the collection or sharing you ask about. Some of it can only be stopped by deleting your account.

How to make a request. Email privacy@stelrlabs.com, or delete your account in the app (Settings > Account > Delete). When you delete your account, or ask us to delete your consumer health data, we delete it from our systems and tell our service providers to delete it. Copies in backups and system logs are removed as they expire. Data in Apple Health and progress photos in your own iCloud stay under your control there.

We verify requests by confirming that you control the email address on your account. If you use Apple's "Hide My Email," tell us and we'll verify you another way. Requests are free unless they are clearly unfounded or excessive. We respond within the time required by law.

We won't discriminate against you for using these rights.

Appeals. If we decline your request, email privacy@stelrlabs.com with the subject "Health Data Appeal." We'll respond in writing within the time required by law. If you're not satisfied with our response, you can file a complaint:

• with the Washington Attorney General at https://www.atg.wa.gov/file-complaint, if you live in Washington or your data was collected there;
• with the Nevada Attorney General at https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/, if you live in Nevada or your data was collected there.

Changes

We'll post any change to this policy on this page and update the effective date. If a change is material, we'll notify you as required by applicable law, such as through the app or on our website. We'll ask for your consent before collecting new categories of consumer health data, using it for new purposes, or sharing it with new kinds of recipients.