EverWell Privacy Policy

Last updated: October 13, 2026

Our privacy promise, in brief

• EverWell is built so that your health data never reaches our servers. What you take, your food, your lab results, your Apple Health data, your routine, your chats, and EverWell's memory of you are stored only on your iPhone. EverWell does not sync them to iCloud, and EverAssistant cannot see them. You can save an encrypted backup file wherever you choose.
• Encrypted Cloud Backup (paid plan, when available): Your health data stays on your iPhone. If you turn on Encrypted Cloud Backup (Family + Export), we store an encrypted copy that only your passphrase or recovery key can unlock. We can't read it, and if you lose both, we can't recover it. You can delete it at any time. The encrypted copy is stored by Cloudflare in the United States (Section 8).
• EverWell's AI is provided by Apple Intelligence, on your iPhone or, only if you turn it on, through Apple Private Cloud Compute, under Apple's privacy terms. We do not use any third-party cloud AI.
• You don't need an account. If you create one, we keep only your email address, your plan, your privacy choices, and a few dates.
• Anonymous usage statistics are on by default. They never include health data or anything you type, are not linked to your account, and you can turn them off at any time in Settings.
• No ads. No tracking. We never sell or share your personal information for advertising, and we never use Apple Health data for advertising or marketing.
• You are in control. You can export all your data, delete your health data, and delete your account, right in the app.

If you live in Washington, Nevada, or another US state with a consumer health data law, please also read our Consumer Health Data Privacy Policy.

The table below shows what goes where.

Medicines, supplements, food, doses and routine

• Where it is kept: Only on your iPhone (and in your own device backups and encrypted backup files, if you make them)
• Does EverAssistant receive it? No

Lab results, photos, documents, voice notes

• Where it is kept: Only on your iPhone (and in your own device backups and encrypted backup files, if you make them)
• Does EverAssistant receive it? No

Apple Health (HealthKit) data and summaries

• Where it is kept: Only on your iPhone (EverWell reads it again from Apple Health on a new device; not included in EverWell's backup file or device backups)
• Does EverAssistant receive it? No

Chat history, alerts, and EverWell's on-device memory

• Where it is kept: Only on your iPhone (and in your own device backups and encrypted backup files, if you make them; the memory index is rebuilt on a new device)
• Does EverAssistant receive it? No

Encrypted backup file (only if you create one)

• Where it is kept: Wherever you choose to save it (for example On My iPhone, iCloud Drive, Google Drive, OneDrive, Dropbox, or a computer; a cloud provider's own terms then apply); locked with your passphrase or recovery key
• Does EverAssistant receive it? No

Encrypted cloud backup (paid plan, when available; only if you turn it on; never Apple Health data)

• Where it is kept: Encrypted on your iPhone with your passphrase or recovery key, then stored by Cloudflare, Inc. in Cloudflare R2, in a storage location restricted to the United States
• Does EverAssistant receive it? We store the encrypted file, but we cannot read it and never have your key

Questions sent to Apple Private Cloud Compute (only if you turn it on)

• Where it is kept: Processed by Apple under Apple's privacy terms
• Does EverAssistant receive it? No

Account email, plan, privacy choices, dates (only if you create an account)

• Where it is kept: Supabase, hosted in Canada
• Does EverAssistant receive it? Yes

Waitlist email (only if you sign up on our website)

• Where it is kept: Supabase, hosted in Canada
• Does EverAssistant receive it? Yes

Emails we send you

• Where it is kept: Resend, in the United States (kept 30 days)
• Does EverAssistant receive it? Yes

Anonymous usage statistics (on by default; you can turn them off)

• Where it is kept: TelemetryDeck, in the European Union
• Does EverAssistant receive it? Yes, anonymously

Card and payment details

• Where it is kept: Apple
• Does EverAssistant receive it? No

1. About this policy

EverAssistant Inc. ("EverAssistant", "we", "us" or "our") makes EverWell, a personal health information app for iPhone. This privacy policy (the "Policy") explains how we collect, use, disclose, and protect personal information in connection with the EverWell app (the "App"), the EverWell web pages and waitlist on https://everassistant.io, and related emails and support (together, the "Service").

This Policy applies only to EverWell. Any other EverAssistant product or service has its own privacy policy. Please read this Policy together with the EverWell Terms of Use.

EverWell is offered in the United States and in Canada, except the Province of Quebec, where we plan to offer it once a French version is available. EverWell is for adults 18 and older.

EverAssistant Inc. is responsible for the personal information under its control. Everyone who works for us is bound by confidentiality obligations and must follow this Policy.

2. Key terms

• Personal information means information about an identifiable individual. It includes "personal data" and "personal information" as defined in the privacy laws that apply to you.
• Health data means information about a person's physical or mental health, including the medicines, supplements, and food you add to EverWell, lab results, symptoms, routine, Apple Health data, and anything EverWell infers from them. It includes "personal health information", "consumer health data", "sensitive personal information", and similar terms used in privacy laws.
• Your device means the iPhone (or other Apple device) on which you use EverWell.
• Device backup means the backup or transfer of your iPhone that you make with Apple's tools (iCloud Backup, a computer backup, or Quick Start). It is provided by Apple under your agreement with Apple, not by EverAssistant.
• Encrypted cloud backup means the optional backup in the EverWell Family + Export plan (when available) that the App encrypts on your device with your passphrase or recovery key and then uploads to Cloudflare R2 in a storage location restricted to the United States. We never receive the key and cannot read the backup.
• Encrypted backup file means a file you choose to create in EverWell, containing your EverWell data (except data read from Apple Health), encrypted on your device with a passphrase or recovery key that only you have, and saved wherever you choose.
• Account data means the limited information we keep if you create an optional EverWell account (see Section 5.1).
• Service provider means a company that processes personal information on our behalf, under a written contract, only to help us provide the Service.

3. Our commitments

• EverWell is built so that your health data never reaches our servers. If you turn on Encrypted Cloud Backup, we store only an encrypted copy that we cannot read (Section 4.1 and Section 8). Our code keeps health features separate from account and analytics features, and we test before every release that no health data leaves your device except, if you turn it on, requests to Apple Private Cloud Compute, and, if you turn on encrypted cloud backup, a backup file that is already encrypted on your device with a key we never receive. Device backups and backup files you choose to make are under your control.
• We never sell, rent, or trade personal information, and never share it for targeted or cross-context behavioural advertising.
• There are no ads in EverWell, and no advertising or cross-app tracking tools. EverWell does not use your device's advertising identifier (IDFA).
• We never use Apple Health (HealthKit) data for advertising, marketing, or data mining, never sell it, never disclose it to third parties, and handle it according to Apple's HealthKit rules.
• Optional data sharing is off by default, except anonymous usage statistics, which are on by default and contain no health data. You choose whether to create an account, whether to keep usage statistics on, whether to use Apple Private Cloud Compute, and whether to receive product emails.
• We collect only what we need, keep it only as long as we need it, and protect it with reasonable physical, administrative, and technical safeguards.
• We follow Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and the other privacy laws that apply to us, and we offer the privacy rights in Section 15 to every EverWell user, wherever they live.

4. Your health data stays with you

4.1 Where your health data is stored. Everything you add to EverWell, or that EverWell reads from Apple Health with your permission, is stored only on your device, in encrypted form. EverWell does not sync health data to iCloud, CloudKit, or any other cloud service, and EverWell has no iCloud feature of its own.

Your profile details. During setup, EverWell asks for your name (so EverWell can greet you), your birthday and your sex, and your race or ethnicity (so EverWell can tailor health information, such as reference ranges and health risks that differ by age, sex or group). Sex and race or ethnicity are optional, and you can choose "Prefer not to say". Your race or ethnicity is sensitive information. Like your health data, these details are stored only on your device, never go on our servers, are not part of your account or usage statistics, and are used only to personalize EverWell for you. You can change or delete them at any time in Settings. They are included in your encrypted backup file if you make one.

Moving to a new iPhone and backups. Your EverWell data can come back on a new or restored iPhone in three ways:

• Your device backup or transfer. The information you added yourself can be included when you back up or transfer your iPhone with Apple's tools (iCloud Backup, a computer backup, or Quick Start). Data read from Apple Health and EverWell's search index are kept out of these backups where iOS allows, because they can be rebuilt. Device backups are made and stored by Apple or on your computer under your own settings and agreement with Apple; iCloud Backup is end-to-end encrypted only if you have turned on Apple's Advanced Data Protection.
• Apple Health. Apple Health keeps its own data, and EverWell can read it again on a new device with your permission.
• An encrypted backup file. You can create a backup file in EverWell at any time. It is encrypted on your device with a passphrase or a recovery key that only you have, and you choose where to save it using your iPhone's Files app (for example On My iPhone, iCloud Drive, Google Drive, OneDrive, Dropbox, a computer, or AirDrop). EverAssistant never receives the file or the key, and EverWell does not connect to your cloud storage account. If you save it to a cloud storage service (for example iCloud Drive, Google Drive, OneDrive or Dropbox), that provider stores the encrypted file under its own terms and privacy policy; it cannot read the file without your passphrase or recovery key. If you turn on automatic backups, EverWell saves new encrypted backup files to the folder you chose when your data changes and on the schedule you pick, and removes older backup files it created there. If you lose the passphrase or recovery key, the file cannot be opened by anyone, including us.
• Encrypted cloud backup (paid plan, when available). If you turn on Encrypted Cloud Backup, your backup is stored by our service provider Cloudflare, Inc. in Cloudflare R2, in a storage location restricted to the United States. Your backup is encrypted on your device before it is uploaded, using a key made from your passphrase or recovery key, which we never receive, so neither we nor Cloudflare can read it. Because it is stored in the United States, your encrypted backup may be subject to US law, including lawful access requests by US authorities, even if you live in Canada or elsewhere. The backup does not include data read from Apple Health. Along with the encrypted file we keep only what we need to operate it: your account identifier, the backup date and size, and a format version. We keep at most your newest 2 backups and up to 2 GB per account. If you lose your passphrase or recovery key, we cannot recover your backup, and the App will tell you this clearly before you turn it on. You can delete your cloud backups at any time in the App. They are also deleted when you turn cloud backup off, when you delete your account, and 90 days after your subscription ends (restore-only during that window, with reminders; Section 13). Cloud backup is off unless you turn it on, needs its own consent, and is not available in the first version of EverWell.

4.2 Your consent. Before EverWell processes any health information, the App asks for your express consent on a separate screen that explains what EverWell does with it on your device. You can withdraw that consent at any time by deleting your health data in the App or deleting the App. Connecting Apple Health, turning on Apple Private Cloud Compute, and turning on encrypted cloud backup each need a separate choice by you.

4.3 How EverWell processes it. Reading photos and documents, transcribing voice, building EverWell's private memory (search index), and running interaction, daily-amount, and timing checks all happen on your device. EverWell's AI runs in one of three ways:

• Basic mode: templated answers, on your device.
• On-device Apple Intelligence: on supported devices, on your device.
• Apple Private Cloud Compute (opt-in): only if you turn it on, your question and the information needed to answer it may be processed by Apple's Private Cloud Compute, under Apple's terms and privacy policy. It does not go to EverAssistant. You can turn this off at any time in Settings.

4.4 What this means for you. Because we do not receive your health data in readable form (and, unless you turn on Encrypted Cloud Backup, we do not receive it at all):

• we cannot read it, use it, analyze it, train AI models on it, or disclose it to anyone;
• we cannot give you access to it, correct it, or delete it for you, but you can do all of these yourself in the App at any time (see Section 14); and
• we cannot recover it if it is lost, and we cannot open an encrypted cloud backup without your key. Please keep a recent device backup, encrypted backup file, or cloud backup (Section 4.1), and keep your passphrase or recovery key safe.

4.5 Apple Health (HealthKit). EverWell reads only the Apple Health categories you allow, only to provide EverWell's features to you, and never writes to Apple Health. Depending on what you allow, this can include activity, sleep, heart, vital signs and body measurements, nutrition and water, and medications. HealthKit data, including medicines that EverWell first suggested from Apple Health even after you confirm them, is never sent to EverAssistant, our service providers, or our analytics, and is not included in EverWell's encrypted backup file. You can change EverWell's access at any time in your iPhone's Settings > Health > Data Access & Devices, and you can remove everything EverWell imported from Apple Health in the App.

4.6 Exports you create. If you create an export or summary to share with your doctor, pharmacist, or someone else, the file is created on your device and you decide where it goes. Once you share it, the recipient's handling of it is up to them and the laws that apply to them.

4.7 Reminders. Reminders and wellness notes are created on your device and shown as local notifications. They do not pass through our servers.

5. Information we collect

We collect only the information described below. We do not collect your name, date of birth, phone number, mailing address, country or province of residence, health card number, location, contacts, or payment card information.

5.1 If you create an optional EverWell account

Your email address, which may be an Apple private relay address if you use "Hide My Email"

• Why: To create and secure your account, send sign-in links and service messages, and provide support

A sign-in identifier from Apple (if you use Sign in with Apple) and an internal account ID

• Why: To sign you in and keep your account separate from others

Subscription status received from Apple: product, status (for example, active, expired, refunded), whether it is purchased or family-shared, renewal or expiry date, and Apple's transaction ID

• Why: To unlock paid features on your devices and help with support

Consent choices: whether you accepted the Terms and this Policy, and your choices for anonymous usage statistics and product emails, each with the document version and date

• Why: To respect your choices and keep the records of consent the law requires

Account created date and last sign-in date

• Why: To manage your account and apply our inactive-account deletion rule (Section 13)

We do not ask for your name. EverWell requests only your email address from Sign in with Apple, not your name.

5.2 If you join the waitlist on our website

Your email address, the page where you signed up, the version of the consent text you saw, whether you agreed to receive emails, and the dates you signed up and confirmed. We use double opt-in: you are added only after you click the link in our confirmation email. Our sign-up form uses Cloudflare Turnstile to block spam, which processes technical information about your browser to check that you are not a bot.

5.3 Anonymous usage statistics

Usage statistics are on by default, and you can turn them off at any time in Settings. While they are on, the App sends anonymous events about actions taken in the App, sent to our analytics provider, TelemetryDeck. Events are fixed names only: screens viewed and onboarding steps, whether Apple Health access was allowed or denied, the kind of item added (for example "supplement"), that a chat message was sent, and that the AI was unavailable. They also carry the standard technical details our analytics provider's software adds (such as app version, iOS version, device model, and language and region settings).

Usage statistics never include: the names or amounts of any medicine, supplement, or food; lab results; Apple Health data; your routine; symptoms; the type, severity, or content of any alert; anything you type or say; your email; or your location. They also never include your name, device identifiers, or advertising identifier (IDFA), and are never used for tracking. Events are tied to a random install identifier that TelemetryDeck hashes. It is not linked to your account or email and is replaced when you turn statistics off. TelemetryDeck states that it does not store IP addresses. We do not use these statistics to identify you, build a profile of you, or make decisions about you, we will not try to re-identify anyone from them, and our contract with TelemetryDeck requires it not to either.

You can turn usage statistics on or off at any time in Settings. When they are off, nothing is sent and any events waiting to be sent are discarded. Because the statistics are anonymous and not linked to you, we cannot find or delete the events of a particular person after they are sent.

5.4 When you contact us

If you email us, we receive your email address and whatever you include in your message. Please do not include health information in messages to us; we will never ask you for it. If a message does include health information, we use it only to answer you and delete it as soon as we no longer need it.

5.5 Technical information

Like any internet service, our servers and service providers receive technical information when the App or your browser connects to them, such as your IP address, device or browser type, and the date and time of the request. For example, when the App downloads updates to EverWell's reference data (the drug and supplement information EverWell uses for its checks), the request includes only the App version and the data version, plus the technical information needed to deliver it. We use this information only to deliver, secure, and troubleshoot the Service, and we keep it only for a short time (see Section 13).

5.6 Information from Apple

Apple processes App Store purchases, and Apple, not EverAssistant, receives your payment details. Apple sends us subscription status information (see Section 5.1). If you choose in your iPhone settings to share analytics and crash reports with app developers, Apple may provide us with aggregated statistics and crash reports, which do not include your health data. The App does not send its own crash or diagnostic reports.

5.7 Our website

The EverWell pages on our website do not use analytics, advertising, or tracking cookies or tools. Our hosting provider, Cloudflare, may use strictly necessary security technology to protect the site and the waitlist form.

6. How we use information, and your consent

We use the information in Section 5 only to:

• provide, maintain, and secure your account, and send sign-in links;
• unlock and manage paid features and provide support;
• record and respect your consent choices;
• send service messages (for example, about your account, subscription, security, or changes to our Terms or privacy policies);
• send product or launch emails, only if you have opted in;
• understand, in aggregate, how EverWell is used so we can improve it, unless you have turned off usage statistics;
• deliver signed reference-data updates to the App;
• detect, prevent, and respond to fraud, abuse, security incidents, and illegal activity; and
• comply with the law and enforce our Terms.

Consent. Because EverWell is a health app, we ask for your express consent at the time we collect your information: for example, when you create an account, join the waitlist, or agree to product emails. We explain the purpose at that moment and link to this Policy. Each optional choice is separate and off by default, except anonymous usage statistics, which are on by default and can be turned off in Settings, and none of them is required to use the free app. You can withdraw your consent at any time, subject to legal or contractual limits, in the App's Settings or by emailing us; if you withdraw consent needed for a feature (for example, deleting your account), that feature will stop working. We will not use personal information for a new purpose without telling you and asking for your consent, unless the law allows it.

We do not make decisions about you based solely on automated processing of your personal information. EverWell's checks and alerts are generated on your device to inform you; EverAssistant does not see them.

7. What we never do

• We never receive or store your health data in readable form. Unless you turn on Encrypted Cloud Backup (when available), we do not receive it at all; if you turn it on, we store only an encrypted copy that we cannot read (Section 4.1).
• We never sell, rent, or trade personal information, and never "share" it for cross-context behavioural advertising (as those terms are used in US state laws).
• We never show ads, and never use advertising, data broker, or cross-app tracking tools.
• We never use your data, health or otherwise, to train AI models.
• We never use HealthKit data for advertising, marketing, or data mining, and never send it to any AI service off your device.
• We never send your health data to a third-party AI provider.

8. Service providers and where information is stored

We use a small number of service providers to run the Service. They may use personal information only to provide services to us, under written agreements that require them to protect it at least as well as this Policy does.

Supabase (Supabase, Inc., United States)

• What it does for us: Account sign-in, account data, consent records, subscription status, waitlist
• Information involved: Account data, waitlist data, technical information
• Where: Stored in Canada (Amazon Web Services Canada Central region, Montreal)

TelemetryDeck (TelemetryDeck GmbH, Germany)

• What it does for us: Anonymous usage statistics, on by default (you can turn them off)
• Information involved: Anonymous action events and a random identifier
• Where: European Union (TelemetryDeck states its data is hosted only in the EU, currently in Helsinki, Finland)

Cloudflare (Cloudflare, Inc., United States)

• What it does for us: Delivers reference-data updates; hosts our website and waitlist form; spam protection (Turnstile); small server tasks such as processing Apple subscription notifications; when available, stores Encrypted Cloud Backup ciphertext in Cloudflare R2
• Information involved: Technical information; waitlist email and subscription status in transit; encrypted backup files that neither we nor Cloudflare can read; account identifier, backup date, size, and format version
• Where: Global network for Workers and website (may be processed in the United States and other countries). Encrypted Cloud Backup objects are stored in Cloudflare R2 in a storage location restricted to the United States

Resend (Resend, Inc., United States)

• What it does for us: Sends sign-in links, confirmation emails, and other emails
• Information involved: Email address, email content, and delivery records
• Where: United States

Apple. Apple provides the App Store, payments, Sign in with Apple, device backups (iCloud Backup), HealthKit, Apple Intelligence, and Private Cloud Compute. You use these services under your own agreement with Apple, and Apple's privacy policy applies to them.

Information stored or processed outside your province or country. Our account data is stored in Canada, but Supabase, Cloudflare, and Resend are US companies, and TelemetryDeck stores data in the European Union. If you turn on Encrypted Cloud Backup, your encrypted backup is stored in the United States (Cloudflare R2, us jurisdiction), so it is subject to US law, including lawful access requests by US authorities, even if you live in Canada or elsewhere; neither we nor Cloudflare can read it without your passphrase or recovery key. Personal information handled by these providers may be processed in the United States, the European Union, or other countries, where it is subject to the laws of those places and may be accessed by their courts, law enforcement, and national security authorities. Under Canada's PIPEDA, we disclose these cross-border transfers and choose providers that protect information to a standard comparable to this Policy, bound by contract to do so.

9. Other situations in which we may disclose information

We may disclose the limited personal information we hold (never health data, which we do not have):

• To comply with the law: when required by law, a court order, a subpoena, or other legal process, or to respond to a lawful request from a government authority. Where the law allows, we will try to tell you first.
• To protect people and the Service: when we reasonably believe it is necessary to protect someone's life, health, or safety, to investigate or prevent fraud or a security incident, or to establish, exercise, or defend legal claims.
• In a business transaction: if we are involved in a merger, acquisition, financing, reorganization, or sale of all or part of our business, we may disclose personal information to the parties involved, only as needed for the transaction and under confidentiality obligations. Any successor must continue to protect it under this Policy, and we will tell you before your information becomes subject to a different privacy policy.
• With your consent: for any other purpose, only with your consent.

10. Emails

Service emails. If you have an account or join the waitlist, we send emails you need, such as sign-in links, confirmation emails, account and subscription notices, account-deletion confirmations, and notices of important changes to our Terms or privacy policies.

Product and launch emails. We send these only with your express consent, for example when you confirm your waitlist sign-up or tick the product-email box. Every product email identifies EverAssistant Inc., includes our mailing address and email address, and has a one-click unsubscribe link that keeps working for at least 60 days after we send the email. We act on unsubscribe requests right away, and always within 10 business days. After you unsubscribe, we keep your email address on a suppression list only so that we do not email you again.

11. Family plan and information about other people

With the EverWell Family + Export plan (when available), you can keep separate profiles for other adults you care for. Their information is stored exactly like yours: only on your device (and in your own device backups and backup files), never with EverAssistant. Profiles are for adults (18 or older) only. Please add someone else's information only with their agreement or if you have the legal authority to manage it (for example, as their attorney for personal care, guardian, or substitute decision-maker), and keep it private. Each profile is kept separate in the App.

12. Children

EverWell is for adults aged 18 and older and is not directed to children. We do not knowingly collect personal information from anyone under 18, and the App does not allow profiles for people under 18. If you believe someone under 18 has created an EverWell account or joined the waitlist, please contact us and we will delete it.

13. How long we keep information

We keep personal information only as long as we need it for the purposes in this Policy or as the law requires, and then we delete it or make it anonymous.

Account data

• How long we keep it: Until you delete your account. When you delete it, we remove it within 30 days (usually right away)

Inactive accounts

• How long we keep it: If you have not signed in for 24 months, we email you a reminder and delete the account 30 days later unless you sign in

Consent records

• How long we keep it: While your account exists. After you delete your account or withdraw a consent, we keep a minimal record (a one-way coded version of your email, which consent, the version, and the dates) for 3 years to show that we respected your choices, then delete it

Account-deletion record

• How long we keep it: A one-way coded record that a deletion happened, with no email, kept for 3 years

Subscription status

• How long we keep it: While your account exists

Unconfirmed waitlist sign-ups

• How long we keep it: Deleted after 30 days

Confirmed waitlist sign-ups

• How long we keep it: Until you unsubscribe or ask us to delete them, and no later than 12 months after the App's public launch (unless you create an account)

Unsubscribe (suppression) list

• How long we keep it: As long as we send product emails, so that we don't email you again

Emails held by our email provider (Resend)

• How long we keep it: 30 days

Support emails

• How long we keep it: 24 months after your issue is resolved (health information in them is deleted sooner, as described in Section 5.4)

Server and security logs

• How long we keep it: Up to 30 days (most are deleted after 7 days); up to 90 days if needed to investigate a specific security incident, or longer if the law requires it

Records of security breaches

• How long we keep it: At least 24 months, as Canadian law requires

Anonymous usage statistics

• How long we keep it: Kept by TelemetryDeck under its own retention practices, which currently have no fixed deletion date. They are anonymous and cannot be linked to you

Health data

• How long we keep it: Never held by us in readable form. It stays on your device (and in any device backups or backup files you make) until you delete it

Encrypted cloud backups (paid plan, when available)

• How long we keep it: Newest 2 backups and up to 2 GB per account. Until you delete them or turn cloud backup off; deleted within 30 days when you delete your account; restore-only for 90 days after your subscription ends (we remind you at lapse, 30 days and 7 days before deletion so you can restore or save a backup file), then deleted. How long Cloudflare keeps deleted objects in its own internal backups is an open item (residual-risks.md)

14. Your choices and controls in the App

• Export everything: Settings lets you export all of your EverWell data, including health data, in an open format, for free, at any time. The export is created on your device.
• Back up to a file: Settings lets you save an encrypted backup file and restore it on a new iPhone (Section 4.1).
• Encrypted cloud backup (paid plan, when available): turn it on or off, restore from it, and delete any or all cloud backups at any time.
• Delete your health data: you can delete individual items, remove everything imported from Apple Health, delete what EverWell "remembers", or delete all your data on your device. You can also delete the App. Device backups and backup files you saved are under your control; delete them through Apple's settings or wherever you saved them.
• Export your account data: if you have an account, you can download your account data (email, plan, consent history, dates) from Settings.
• Delete your account: Settings > Account > Delete account. This deletes your account data and any encrypted cloud backups from our systems, removes your waitlist entry, and revokes the Sign in with Apple link. It does not delete the health data on your device; the App offers that as a separate choice. It also does not cancel an App Store subscription; the App shows you how to cancel with Apple.
• Change your privacy choices: turn usage statistics, product emails, Apple Private Cloud Compute, encrypted cloud backup, and Apple Health access on or off at any time.

15. Your privacy rights

We offer the rights below to every EverWell user, wherever you live, for the personal information we hold. Your local law may give you additional rights.

• Access and portability: ask what personal information we hold about you, how we have used it, and to whom we have disclosed it, and get a copy in a commonly used format.
• Correction: ask us to correct inaccurate or incomplete information.
• Deletion: ask us to delete your personal information.
• Withdraw consent: withdraw any consent you have given, subject to legal or contractual limits.
• No selling, sharing, or targeted advertising: we don't do these, so there is nothing to opt out of; we also treat a Global Privacy Control signal as an opt-out request.
• Equal treatment: we will not treat you differently for using your rights.
• Complain: contact us, or a privacy regulator (see Section 19).

How to make a request. You can do most of this yourself in the App (Section 14). You can also email our Privacy Officer at [email protected]. We may need to confirm your identity, for example by asking you to reply from your account email. You may use an authorized representative where the law allows; we may ask for proof of their authority. Requests are free. We respond within 30 days. If we need more time, we will tell you why within that period, and we will respond within the longest extension the law allows (for example, 30 more days under PIPEDA, or 45 more days under some US state laws).

If we say no. If we refuse a request, we will explain why and how to challenge our decision. You can appeal by replying to our decision; we will respond to an appeal within 45 days. You can also complain to the regulators listed in Section 19, including your state Attorney General in the US.

Because we do not have your health data, we cannot fulfil requests for it ourselves. Instead, you can export, correct, or delete it in the App at any time.

Quebec. EverWell is not offered in Quebec yet. If you live in Quebec and use EverWell, you also have the rights given by Quebec's privacy law, and you may complain to the Commission d'accès à l'information du Québec.

16. Consumer health data

Some US state laws, such as Washington's My Health My Data Act and Nevada's consumer health data law, give special protection to "consumer health data". Our separate Consumer Health Data Privacy Policy explains how those laws apply to EverWell and how to use your rights under them.

17. Security and breach response

Health data. Your health data is protected by your device's encryption, EverWell's encrypted storage, an optional Face ID or passcode lock in the App, and, for backup files and cloud backups you create, encryption on your device with a passphrase or recovery key that only you have. Its security also depends on you: please use a device passcode and keep your Apple Account secure.

Information we hold. We protect account and waitlist information, and encrypted cloud backups, with safeguards appropriate to their sensitivity, including:

• Data minimization: our systems accept only a fixed list of account, consent, and subscription fields, and automated tests check before every release that no health data can leave the device in readable form, except, if you opt in, requests to Apple Private Cloud Compute; the cloud backup service accepts only files encrypted on the device;
• Encryption in transit and at rest;
• Access controls: each account can access only its own record; server keys are never shipped in the App; vendor accounts use multi-factor authentication; and access is limited to people who need it;
• Signed updates: reference-data updates are digitally signed and checked by the App before use;
• Testing: an independent security review of the App and our systems before public launch; and
• People and policies: written privacy and security procedures, privacy training, and confidentiality obligations for everyone who works for us.

If something goes wrong. No system is perfectly secure. If a breach of security safeguards involving personal information under our control creates a real risk of significant harm, we will report it to the Office of the Privacy Commissioner of Canada and any provincial commissioner that requires it, notify you as soon as feasible, and notify any organization that can help reduce the harm. We keep a record of every breach, whatever its size, for at least 24 months. If you live in the US, we will also notify you, and the authorities, as US state breach laws require.

Encrypted cloud backups. If someone gained unauthorized access to stored cloud backups, the backups should stay unreadable, because they are encrypted with keys we never have. We would still treat it as a security incident: we would investigate, secure the systems, and notify you and the authorities wherever the law requires, including if we could not rule out that a backup or its key had been exposed.

Although we do not hold readable health data, EverWell is a health app. If there were ever an unauthorized acquisition or disclosure of health information from the App or from cloud backups in readable form (for example, if a software error sent health information somewhere it should not go, or uploaded a backup without encrypting it), we would notify affected users, the US Federal Trade Commission, and, where required, the media, as the FTC's Health Breach Notification Rule requires: without unreasonable delay and no later than 60 calendar days after we discover it. Our notice would explain what happened, what information was involved, who received it, what we are doing about it, and what you can do.

18. Changes to this Policy

We may update this Policy, for example if we add features or change service providers. We will post the updated Policy in the App and on our website and update the "Last updated" date. If we make a material change, we will tell you in the App, and by email if you have an account, at least 30 days before it takes effect and, where required, ask for your consent. We will never start collecting your health data, or use personal information in a materially different way, without your express consent.

19. Contact us, our Privacy Officer, and complaints

Our Privacy Officer is accountable for our compliance with this Policy and with privacy law, including handling requests and complaints.

Our Privacy Officer EverAssistant Inc. Email: [email protected] Website: https://everassistant.io

If you think we have not followed this Policy or privacy law, please contact our Privacy Officer first. We will investigate, respond, and fix any problem we find. If we cannot resolve your concern, you can contact:

• the Office of the Privacy Commissioner of Canada (priv.gc.ca);
• the privacy commissioner in your province or territory, where applicable (for example, in Alberta or British Columbia);
• the Commission d'accès à l'information du Québec (cai.gouv.qc.ca), if you live in Quebec; or
• your state Attorney General or consumer protection agency, if you live in the United States.

Ontario health privacy law (PHIPA). Ontario's Personal Health Information Protection Act applies to health information custodians, such as doctors, pharmacies, and hospitals, and to those who act for them. EverWell is a consumer app that you use for yourself, and we do not receive your health information, so EverAssistant is not a health information custodian, or an agent or electronic service provider of one, for EverWell. If you share an EverWell export with your doctor or pharmacist, it becomes part of their records under the laws that apply to them.