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

How we use 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

Consumer health data we share, and with whom

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:

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:

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:

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.