Consumer Health Data Privacy Policy
Version 1.6.0 · Effective 2026-08-24
CLUBS HQ CONSUMER HEALTH DATA PRIVACY POLICY
Version 1.6.0 | Effective August 24, 2026
Why this is a separate document. Health and fitness data deserves its own plain statement rather than a clause buried in a general privacy policy. This document is reachable by its own link and applies to everyone, in every state — we do not maintain a lower standard for some members than others.
This policy explains how Clubs HQ LLC ("Clubs HQ," "we," "us") collects, uses, shares, and protects Consumer Health Data.
1. What We Treat as Consumer Health Data
We treat the following as Consumer Health Data, regardless of whether a particular law would require it:
| Category | Examples |
|---|---|
| Activity and performance | Workouts, distance, duration, pace, splits, cadence, stride, elevation gain, training load, personal records |
| Physiological measurements | Heart rate, resting heart rate, heart-rate variability, VO2 max estimates, calories, sleep data, respiration rate |
| Body measurements | Height, weight, age, sex, body composition — where you choose to provide them |
| Precise location | GPS route traces, start and end points, waypoints, and any location precise enough to identify where you were |
| Self-reported health information | Injuries, symptoms, recovery status, pregnancy status, medical notes you enter, dietary or medication notes |
| Interaction data | Questions you ask the AI Coach, messages to a coach about your health or injuries |
| Inferences | Fitness level, training readiness, injury risk, or health status that we or our features derive from the above |
Precise location is included deliberately. A running route reveals where you live, where you go, and can reveal visits to medical facilities, places of worship, or other sensitive locations. We treat it with the same care as heart rate data.
2. Where This Data Comes From
- Directly from you — manual workout entry, profile fields, injury notes, AI Coach prompts.
- From your device — GPS, accelerometer, and paired sensors, when you enable in-app activity recording.
- From device platforms you authorize — currently Garmin Connect and COROS. We receive only the data types you approve during that platform's connection flow, and only for as long as the connection remains authorized. Connecting Garmin also involves a transfer of data between Clubs HQ and Garmin under Garmin's own privacy policy, which we link at the moment you connect.
- From a coach or club, with your consent — for example, a coach recording a workout result on your behalf.
We do not purchase health data, and we do not obtain it from data brokers.
3. Why We Collect It, and How We Use It
We use Consumer Health Data only for these purposes:
- To show you your own data — dashboards, history, personal records, progress.
- To deliver features you requested — training plans, AI Coach responses, workout analysis, goal tracking.
- To display information you have chosen to share — with a coach you engaged, or on a leaderboard you opted into.
- To keep you safe — emergency contact access during an incident at a club activity.
- To operate and secure the service — debugging, preventing abuse, maintaining integrity.
- To comply with law — when legally required.
3.1 What We Never Do With Health Data
- We never use it for advertising or marketing, ours or anyone else's.
- We never use it for use-based data mining or profiling unrelated to the features you requested.
- We never sell it. Not for money, not for other valuable consideration.
- We never disclose it to data brokers.
- We never use it to train third-party artificial intelligence or machine-learning models.
- We never use geofencing around any healthcare facility, and we do not use location to identify, track, or message anyone based on health services they may be seeking.
- We never use minors' health or location data for advertising, profiling, or public display.
4. Consent
4.1 Separate, Opt-In Consent to Collect
We collect Consumer Health Data only after you give separate, affirmative, opt-in consent through the Health, Fitness and Location Data Consent. That consent is:
- Not bundled with our Terms of Service or general Privacy Policy;
- Presented on its own screen with a clear description of what is collected and why;
- Granular — you can consent to workout data without consenting to precise location, and to either without consenting to sharing;
- Never obtained through pre-checked boxes, scrolling, hovering, silence, or inactivity;
- Never a condition of using unrelated features of the Platform.
4.2 A Second, Separate Consent to Share
Consent to collect is not consent to share. Sharing your Consumer Health Data with anyone outside Clubs HQ and its service providers — including sharing with a coach, publishing to a leaderboard, or displaying a route publicly — requires an additional, separate consent describing who receives it, what they receive, and why.
4.3 Withdrawing Consent
You may withdraw any consent at any time in Account Settings → Health and Location Data, with no penalty to unrelated features. Withdrawal takes effect immediately going forward. On withdrawal we stop collecting that category, and you may separately request deletion of what we already hold (Section 8).
4.4 Sale Requires Written Authorization — and We Do Not Sell
We do not sell Consumer Health Data. If that ever changed, we would first obtain a separate written authorization from you, valid for no more than one year, identifying the specific data, the parties, and the purpose, stating that services are not conditioned on your signing it, and describing how to revoke it — and we would give you a copy. We would also give you advance notice and the ability to delete your data first.
5. Who Receives It
| Recipient category | What they receive | Basis |
|---|---|---|
| Cloud hosting and database providers | Encrypted storage and processing only | Service provider contract; no independent use permitted |
| Coaches you engage | Only the categories you approve, only while the coaching relationship is active | Your separate sharing consent; revocable |
| Clubs you join | Participation and attendance only — not heart rate, routes, or health notes, unless you separately consent | Your consent |
| Other users | Only what you publish (leaderboards, shared activities) | Your opt-in |
| Device platforms | Data you direct us to send back to a platform you connected, and the account linkage required to maintain that connection | Your direction |
| Law enforcement or courts | Only as legally compelled, and we will notify you unless prohibited | Legal obligation |
We do not disclose Consumer Health Data to advertisers, data brokers, analytics networks, or insurers. We do not disclose it in connection with a corporate transaction without giving you notice and an opportunity to delete it first.
Named categories of third parties and affiliates currently receiving Consumer Health Data are maintained and kept current at clubshq.us/legal/health-data-recipients.
6. Security
Consumer Health Data is encrypted in transit and at rest, segregated from general profile data, subject to least-privilege access controls, and accessible internally only to personnel with a documented operational need. Access is logged and audited. Our written information security program covers this data specifically, and we assess it at least annually.
7. Retention
We retain Consumer Health Data only as long as necessary for the purpose collected:
| Data | Retention |
|---|---|
| Workout and activity history | Life of your account, or until you delete it |
| Precise location / route traces | Kept until you delete them. No automatic expiry — deletion is always your choice, and is immediate when you make it |
| Health notes and injury records | Life of account, or until you delete it |
| AI Coach conversation history | 12 months, or until you delete it |
| Data from a disconnected integration | Kept. Disconnecting stops future syncing; already-synced activities remain yours until you delete them or ask us to |
| De-identified aggregates | Retained; cannot be re-identified and are not linked to you |
8. Your Rights Over Consumer Health Data
You have the right to:
- Know what Consumer Health Data we have collected, the purposes, the sources, and the specific third parties and affiliates who received it;
- Access a copy of that data;
- Correct inaccurate data;
- Withdraw consent to collection, sharing, or both;
- Delete your Consumer Health Data — and to have us notify our service providers and any recipient to delete it as well;
- Not be discriminated against for exercising any of these rights.
How: Account Settings → Health and Location Data, or email info@clubshq.us (subject: Health Data Request). Timing: We respond within 45 days, extendable once by 45 days with written notice. Deletion is completed within 30 days of a verified request. Appeals: If we deny a request, email info@clubshq.us (subject: Health Data Appeal). We respond in writing within 45 days. If we deny your appeal, you may complain to your state Attorney General.
9. Young Members
Members aged 13–17 have the same controls over Consumer Health Data as everyone else, and no additional parental or guardian consent is required. The commitments in this Policy — never used for advertising or profiling, never sold, never disclosed to data brokers — apply to every member regardless of age. A parent or guardian may request deletion of their child's Consumer Health Data at any time. See Age and Young Members.
10. Employees and Job Applicants
This policy does not apply to data we process about our own employees or applicants in that capacity.
11. Relationship to HIPAA
Clubs HQ is not a HIPAA covered entity or business associate, and the data described here is not protected health information under HIPAA. That means HIPAA's protections do not apply to it — which is precisely why the commitments in this policy exist. If we ever process data on behalf of a healthcare provider or health plan, that data will be governed by a separate business associate agreement.
12. Changes
Material changes to this policy will be posted with at least 30 days' notice, and any new category of collection, use, or sharing will require fresh opt-in consent rather than notice alone. Prior versions: clubshq.us/legal/archive.
13. Contact
Health data inquiries: info@clubshq.us (subject: Health Data Request) Appeals: info@clubshq.us (subject: Health Data Appeal) Postal: Clubs HQ LLC, 10820 Alico Pass, New Port Richey, Florida 34655