Consumer Health Data Privacy Policy

Effective date: October 28, 2026

This policy explains how Works Pretty Good LLC ("Works Pretty Good LLC," "we," "us") handles consumer health data in Etona, a notes app for iPhone and iPad. It is the policy that Washington's My Health My Data Act and Nevada's consumer health data law require. Connecticut's privacy law protects consumer health data too. We follow this policy for everyone who uses Etona, in whichever state they live. Our Privacy Policy covers the other information Etona handles.

"Consumer health data" is personal information that identifies a person's past, present or future physical or mental health. It includes what is worked out or inferred about someone's health, as well as what is stated. In this policy, "your device" means an iPhone or iPad with Etona on it.

Contact for questions and requests: support@etona.app, or Works Pretty Good LLC, 2248 Broadway #2262, New York, NY 10024.

1. The consumer health data we collect, and how we use it

Etona does not ask for health information. It has no health questions, and it reads nothing from Apple Health or from sensors. You decide what goes into your notes. If you save something about health, we collect it, in these categories:

Health information in what you write and save. Anything about health in your notes' text and links, your photos, screenshots and videos, your voice memos, your files, the web pages you save, and the notes and conversations you import from other apps. Depending on what you save, this could be any kind of health information the laws list: conditions, symptoms and diagnoses; tests, treatment, procedures and medication; mental and behavioral health; reproductive or sexual health; gender-affirming care; measurements such as weight or sleep; and efforts to find or get health care.
What Etona works out from your notes. Etona reads your notes in order to organize them, and what it works out can reveal health information when your notes contain it. It works out the words in your photos, screenshots, files and saved pages, and a transcript of each voice memo. It finds the names of people, places and organizations, such as a doctor or a clinic. It gives each note a short subject, and finds to-dos and their due dates, such as an appointment. It groups notes into themes and names each one, and a theme could be named after a health condition you write about. With Etona Pro, it writes theme pages, Your week and answers in Ask from your notes. It also builds a search index.
Photos and voice recordings. Washington's law counts a picture of a face or a recording of a voice as biometric data, which is a kind of consumer health data, when an identifying template could be taken from it. Etona stores the photos, videos and voice memos you save. It does not take any such template from them, and it does not use them to identify anyone.
Approximate location, if you allow it. A position rounded to about a kilometer, with the city and country, saved with each note. It is not a precise location. Next to what a note says, it could suggest a visit to a health care provider.

Why we collect it, and how we use it. We collect and use consumer health data only to provide Etona to you:

to save your notes on your device, back them up to our cloud, and sync them to the devices you sign in to;
to read and organize them: search, names, to-dos and themes;
if you allow AI, to have Google's Gemini AI read their text, in order to find names, to-dos and themes and, with Etona Pro, to write theme pages, Your week and answers;
to show where you wrote a note, if you allow location;
to keep Etona secure, to answer you when you ask for help, and to comply with the law.

We do not sell consumer health data. We do not use it for advertising or marketing, to train AI models, or to make decisions about you.

How it is processed.

Every note saves on your device first. It is then stored in our cloud, which runs on Google Firebase in the United States. It is encrypted in transit and at rest. It is not end-to-end encrypted.
Etona analyzes your notes automatically, on your device. It does not upload the search index to our cloud, or the text it has read from your photos, recordings and PDFs.
If you allow AI, the text of your notes goes to Google's Gemini AI through our server, including the words read from your photos, recordings, files and saved pages. Our server stores neither what is sent nor what comes back.
No one at Works Pretty Good LLC looks at what your notes say, unless you ask us for help and agree to it, we need to investigate a security problem or misuse of Etona, or the law requires it.
We keep consumer health data until you delete it. A note you delete is erased 30 days later. Deleting your account erases everything in it from our cloud. Copies in Google's systems expire on their own: Gemini's abuse-monitoring log within 55 days, our server's error logs in about 30 days, and backups within 180 days.

2. Where it comes from

You: what you write, photograph, record, attach, save and import.
Other apps and services, when you import your notes or conversations from them, and websites, when you save their pages.
Your device: its location, if you allow it.
Etona itself: what it works out from all of the above.

We do not get health information about you from Apple Health, from wearables, from other apps on your device, or from data brokers.

3. What we share, and with whom

We do not sell consumer health data. We have no affiliates that receive it. It goes only to the following.

Companies that process it for us. They may use it only to provide their services to us.

Google, as our cloud provider (Firebase and Google Cloud). It stores and processes what section 1 lists: your notes and their files, what Etona works out from them, and the approximate location. It does not receive what Etona keeps only on your device.
Google, as our AI provider (the Gemini API), only if you allow AI. Etona asks for this permission on its own screen before anything is sent. It is separate from your agreement to our Terms of Use, and you can withdraw it in Settings, under AI. With your permission, Gemini receives the text of your notes, including the words read from your photos, recordings, files and saved pages, the names you use most, and your questions in Ask. It never receives your photos, recordings or files themselves, or your location. Google keeps what is sent for up to 55 days to check for abuse, and does not use it to improve its products.

Apple. If you allow location, your device sends the rounded position to Apple's location service to look up the city and country. Apple handles it under its own privacy policy.

Authorities, when the law requires it, such as under a court order.

A new owner. If Etona is sold or merged, your information may pass to the new owner, which must keep to this policy. We will tell you before that happens.

The categories shared. Our cloud provider receives every category in section 1, except what Etona keeps only on your device. Our AI provider, with your permission, receives the health information in the text of your notes and what Etona works out from them. Apple receives only the approximate location.

Tracking by other companies. No other company collects consumer health data about you over time and across different websites or online services when you use Etona or this website. Etona contains no advertising or analytics software from other companies.

4. Your rights, and how to use them

You have the right to:

Confirm and access. Ask whether we collect, share or sell your consumer health data, and get a copy of it. You can ask for a list of every third party and affiliate we have shared it with or sold it to, with a way to contact each one. In Etona, Settings › Export all notes gives you your notes, their files, your theme pages and your names.
Withdraw consent, and have us stop. Turn AI off in Settings, under AI, and nothing more goes to Gemini. Turn location off in your device's Settings, under Etona. To have us stop collecting or keeping health information altogether, delete the notes that hold it, or delete your account.
Delete. Delete a note in Etona, and it is erased from our cloud 30 days later. Settings › Delete account erases your account and everything in it from our cloud. You can also ask us to delete your consumer health data. Copies in Google's logs and backups can't be removed on request. They expire on the schedule in section 1.
Review and correct. You can read and edit your notes, your names and your themes in Etona at any time.

We will not treat you differently for using any of these rights.

How to make a request. The controls in Etona are the fastest way. You can also email support@etona.app, or write to Works Pretty Good LLC, 2248 Broadway #2262, New York, NY 10024. You don't need to create an account to make a request. To protect you, we confirm that a request comes from you, using the email address on your account.

When we answer. We answer within 45 days of receiving your request. If we need more time, the law allows one extension of 45 days, and we will tell you why within the first 45. We complete a deletion within 30 days of confirming that the request is yours. Requests are free.

Appeals. If we decline to act on your request, you can appeal by replying to our answer, or by emailing support@etona.app with the subject "Appeal." We will tell you in writing, within 45 days, what we decided and why. If your appeal is denied, you can complain to your state's attorney general. In Washington, that is at www.atg.wa.gov/file-complaint. In Nevada, it is at ag.nv.gov.

5. Changes to this policy

We update this policy when Etona changes. The effective date at the top shows when it last changed. If a change is material, we will tell you in the app or by email before it takes effect. Before we collect a new category of consumer health data, share it with someone this policy doesn't list, or use it for a new purpose, we will update this policy and ask for your consent first.

6. Contact

Works Pretty Good LLC
2248 Broadway #2262, New York, NY 10024
Email: support@etona.app