Consumer Health Data Privacy Policy

Scope

SoulHeal Technology operates DreamPhones headphones, the DreamPhones companion wellness ring, and the DreamApp mobile application. Because we collect health-related information, this Consumer Health Data Privacy Policy describes how we collect, use, share, and protect "consumer health data" under the Washington My Health My Data Act and similar consumer health privacy laws.

DreamPhones products are consumer wellness products, not medical devices. We do not use consumer health data to diagnose, treat, cure, or prevent disease.

Consumer Health Data We Collect

• Sleep data, sleep summaries, sleep stages, sleep timing, sleep duration, and sleep trends
• Heart rate, heart rate variability (HRV), blood oxygen saturation (SpO2), and stress indicators
• taVNS session data, such as session duration, intensity settings, stimulation status, and session history
• DreamPhones ring data, including ring-generated heart rate, HRV, SpO2, stress, and sleep metrics
• Health-related information you choose to share in conversations with Sophia, our AI wellness companion
• Data you authorize us to read from Apple Health
• Face videos from the optional camera-based wellness measurement, and the heart rate, HRV, and pupil-size estimates derived from them (full face data practices are in the "Face Data" section of our Privacy Policy)
• Support, troubleshooting, warranty, return, and privacy-request information that includes health-related information

Sources and Purposes

We collect consumer health data directly from you, from your DreamPhones headset and DreamPhones ring through the DreamApp, from Apple Health with your permission, and from messages or requests you choose to send to us.

We collect and use consumer health data only with your consent or to the extent necessary to provide a product or service you request. We use it to operate app features, personalize sessions, provide sleep and focus insights, show wellness dashboards and reports, operate Sophia, troubleshoot technical issues, maintain security, respond to your requests, and comply with law.

Consumer Health Data We Share

We do not sell consumer health data, and we will not sell it without the separate, signed authorization required by law. We do not send app health metrics, Sophia conversations, ring data, or session history to advertising networks or data brokers.

• Categories of consumer health data shared: account identifiers connected to app health data; headset, ring, session, sleep, and derived wellness metrics; Sophia chat messages that contain health-related information; support, privacy, and troubleshooting requests that include health-related information.
• Categories of third parties: cloud hosting, database, security, and infrastructure providers; contracted AI/model infrastructure providers that help operate Sophia; app platform and device-permission providers when you choose Apple Health; e-commerce, payment, customer-account, shipping, and support providers when purchase or support information may reveal your interest in a wellness product; professional advisors, compliance vendors, and government authorities when required by law.
• Specific affiliates: none currently. SoulHeal Technology does not currently share consumer health data with any affiliated company.

Named Service Providers and Recipients

• Microsoft Corporation (Azure): hosts DreamPhones app infrastructure and may process account, device, session, and wellness data needed to operate the app.
• Eleven Labs Inc.: provides the live conversational interface for Sophia and may process voice, text, conversation metadata, and transcripts. Contact: ElevenLabs Privacy Policy.
• OpenAI, L.L.C.: may process Sophia conversation text to generate requested summaries or wellness reports. Contact: OpenAI Privacy Policy.
• Alibaba Cloud: provides object storage and communications infrastructure and may process uploaded files, account contact information, and service logs. Contact: Alibaba Cloud Privacy Policy.
• Apple Inc. and Google LLC: provide app distribution, sign-in, and device permissions. Apple Inc. also provides the Apple Health integration when you enable it.
• Shopify Inc., Klaviyo, Inc., and Formspree, Inc.: process storefront purchases, customer accounts, email communications, or event lead forms. They do not receive Sophia conversations, ring metrics, or app session history from us.
• Google LLC and Meta Platforms, Inc.: may receive public-storefront events such as device identifiers, pages viewed, and purchase or conversion events. They do not receive Sophia conversations, ring metrics, Apple Health data, or app session history from us.

These providers act as processors or service providers for the purposes described above, except where they independently control data under their own terms. We require processors to use consumer health data only to provide contracted services. If we add a provider that will process a new category of consumer health data or use it for a new purpose, we will update this policy and obtain consent when required.

Sophia AI Processing

Sophia is an AI wellness companion, not a doctor or medical service. Sophia uses ElevenLabs for the live conversational interface. After a conversation, DreamPhones may retrieve and store a transcript and use OpenAI to generate a summary or wellness report requested through the service.

We do not use consumer health data or Sophia conversations to train our own general-purpose models. We configure or contract with our AI processors, where available, so that DreamPhones inputs are not used to train their general models. If that protection is unavailable for a feature, we will obtain separate consent before sending consumer health data for that feature.

Your Rights

• Right to know and access: confirm whether we collect, share, or sell your consumer health data and access that data, including a list of third parties and affiliates with whom we have shared it
• Right to withdraw consent: withdraw consent to our collection or sharing of your consumer health data
• Right to delete: request deletion of your consumer health data, including from backups and by service providers where required by law
• Right to appeal: appeal a refusal of your request by replying to our decision

To exercise these rights, email contact@dreamphones.ai or use our Delete My Data page. We will not discriminate against you for exercising these rights. If your appeal is denied and you live in Washington, you may raise a concern with the Washington State Attorney General at www.atg.wa.gov.

Retention

• Account data, session history, ring metrics, and derived wellness measurements: retained while your account is active to provide app features and deleted within 30 days after account deletion unless a longer period is required by law.
• Sophia messages: retained while your account is active to provide conversation continuity and deleted within 30 days after account deletion unless a longer period is required for security, legal compliance, or dispute resolution.
• Push notification tokens: retained while your account is active and notifications are enabled; removed when you disable notifications or delete your account.
• Face videos (optional camera measurement): retained on access-restricted servers only while your account is active, solely for measurement quality assurance and troubleshooting; permanently deleted within 30 days of account deletion or a face-data deletion request. Face videos are never shared with third parties other than our hosting provider acting as our processor.

We instruct processors that hold your consumer health data to delete it when we honor a verified deletion request. Data in backups is deleted or made inaccessible on the backup-rotation schedule and no later than six months after verification, unless the law requires longer retention. We may retain anonymized, aggregated data that cannot identify you for analytics and service improvement.

Contact

If you have questions about this Consumer Health Data Privacy Policy, contact us at contact@dreamphones.ai.