Your privacy matters. This policy explains what data Henry collects, why we collect it, how we protect it, and what rights you have. It is written in plain English.
The short version: We collect only what we need to coach you. We never sell your data. Your health data from Apple Health, Oura Ring, and WHOOP stays in your private account — it is never used to train AI models or shared with third parties for any commercial purpose.
This policy addresses your rights under the GDPR (EU/UK), CCPA/CPRA (California), COPPA (US children's privacy), and Apple's HealthKit Guidelines.
GDPR Art. 13(1)(a) Henry is a personal AI coaching application operated by Coach Henry ("we", "us", "our"). We are the data controller for all personal data described in this policy.
For any privacy questions, requests, or complaints:
We do not have a designated Data Protection Officer (DPO) as we do not meet the thresholds that make one mandatory under Article 37 GDPR. Privacy-related inquiries are handled directly by our team at the email above.
This policy applies to all personal data collected through:
It does not apply to third-party services you connect. Please review their own privacy policies for details on how they handle your data independently.
CCPA 1798.100 The table below summarises what we collect, the source, and why — as required by California law and GDPR transparency obligations.
With your explicit permission, Henry reads the following from Apple HealthKit. HealthKit Guidelines This data is never used for advertising, never sold, and never shared with data brokers.
You can revoke Apple Health access at any time via iOS Settings → Privacy & Security → Health → Henry.
If you choose to connect your Oura Ring, Henry requests the following data via OAuth 2.0:
Henry stores your Oura access token (encrypted) to retrieve data on your behalf. You can disconnect Oura at any time in Henry's Settings, which revokes access and permanently deletes your stored token. Oura Privacy Policy →
If you choose to connect your WHOOP strap, Henry requests the following data via OAuth 2.0:
Henry stores your WHOOP access and refresh tokens (encrypted) to retrieve data on your behalf. You can disconnect WHOOP at any time in Henry's Settings, which immediately revokes our access and permanently deletes your stored tokens. We do not write any data back to WHOOP and do not use your WHOOP data to train AI models. WHOOP Privacy Policy →
If you enable push notifications, we store your device push token to send you coaching nudges, check-in reminders, and workout prompts. You can disable notifications at any time in iOS Settings. We do not use notification tokens to track you or serve advertising.
GDPR Art. 6 & 9 For users in the EU and UK, every piece of data we process has a specific legal basis. Health data (including data from Apple Health, Oura, and WHOOP) is classified as "special category" data under Article 9 GDPR and requires explicit consent.
| Data Type | Legal Basis | GDPR Article |
|---|---|---|
| Account data (email, password, goals) | Performance of contract — necessary to provide the service | Art. 6(1)(b) |
| Health data (Apple Health, Oura, WHOOP) | Explicit consent — you actively connect each integration | Art. 6(1)(a) + Art. 9(2)(a) |
| Check-in photos | Explicit consent — you choose to upload each photo | Art. 6(1)(a) + Art. 9(2)(a) |
| Coaching messages | Performance of contract — the core service you signed up for | Art. 6(1)(b) |
| Technical & usage data | Legitimate interests — improving reliability and performance | Art. 6(1)(f) |
| Push notification token | Consent — you grant permission via iOS prompt | Art. 6(1)(a) |
Where we rely on legitimate interests (Art. 6(1)(f)), we have assessed that our interests do not override your fundamental rights and freedoms. You may object to such processing at any time (see Section 10).
Where we rely on your consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal. Withdrawal can be done by disconnecting the relevant integration in Settings or contacting us directly.
We use your data for one primary purpose: to give you better, more personalised coaching. Specifically:
Your health data is never used to train AI models. Data from Apple Health, Oura Ring, and WHOOP is used solely to generate your personal coaching responses in real time. It is never pooled, anonymised for model training, sold, or shared with any third party for commercial purposes.
GDPR Art. 22 CCPA ADMT 2026 Henry's coaching is powered by a large language model (LLM). Your health data, messages, and goals are sent to this model to generate personalised responses. This constitutes automated processing.
Important clarifications:
Under CCPA regulations taking effect in 2027, businesses must provide a pre-use notice for automated decision-making technology used in health-related contexts. We are committed to full compliance ahead of that deadline and will update this policy accordingly.
GDPR Art. 13(1)(e) CCPA 1798.110 We do not sell your data. The following trusted service providers have access to limited data to operate the app. Each is contractually bound to process your data only as instructed by us.
Supabase — database, authentication, and file storage. Your account data, health metrics, messages, and photos are stored on Supabase infrastructure (hosted on AWS, primarily in the US). Supabase is our primary data processor. Supabase Privacy Policy → Supabase DPA →
AI model provider (currently Anthropic) — Your coaching messages and relevant health context (metrics, goals, recent activity) are sent to a third-party large language model API to generate coaching responses. Our current provider is Anthropic. Anthropic does not use API-submitted data to train their models. If we change providers, we will update this policy before doing so. Anthropic Privacy Policy →
Oura Health — if connected, Henry communicates with the Oura API to read your ring data. Henry never writes data to Oura. Oura Privacy Policy →
WHOOP — if connected, Henry communicates with the WHOOP API to read your strap data. Henry never writes data to WHOOP. WHOOP Privacy Policy →
Apple — if you enable Apple Health integration, data flows from Apple's HealthKit framework on your device to Henry. Apple governs the HealthKit permission system; Henry reads only the data types you explicitly authorise. Apple Privacy Policy →
OneSignal — push notification delivery. If you enable notifications, your device token is shared with OneSignal to deliver coaching nudges and reminders. OneSignal does not receive your health data. OneSignal Privacy Policy →
No other third parties receive your personal or health data. We do not use advertising networks, analytics brokers, or data marketplaces.
GDPR Ch. V Henry is operated from the United States. If you are located in the EU, UK, or another jurisdiction with data transfer restrictions, your data may be transferred to and processed in the US when you use Henry.
We rely on the following transfer mechanisms:
For more information about the safeguards in place, email support@coachhenryapp.com.
Progress photos you upload are stored in a private, access-controlled storage bucket. They are:
You can delete individual photos from within the app at any time.
We apply industry-standard security practices to protect your data:
No system is completely immune to attack. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and relevant supervisory authorities as required by law (GDPR Art. 33–34) without undue delay and within 72 hours of becoming aware.
GDPR Art. 13(2)(a) We retain your data for as long as your account is active and for a short period afterwards to allow account recovery:
| Data Type | Retention Period |
|---|---|
| Account data & profile | Until account deletion + 30 days |
| Health metrics (Apple Health, Oura, WHOOP) | Until account deletion + 30 days, or until integration is disconnected |
| Coaching chat messages | Until account deletion + 30 days |
| Nutrition & weight logs | Until account deletion + 30 days |
| Check-in photos | Until deleted by you, or account deletion + 30 days |
| OAuth tokens (Oura, WHOOP) | Deleted immediately on disconnect, or account deletion |
| Push notification tokens | Until notifications disabled or account deletion |
| Crash logs & error data | 90 days from creation |
| Aggregated, anonymised usage stats | Indefinitely (cannot identify you) |
When you delete your account, we initiate permanent deletion of all personal data within 30 days. Aggregated statistics that cannot be linked back to you may be retained for product improvement purposes.
The Henry iOS app does not use browser cookies. The website coachhenryapp.com uses only essential cookies necessary for the site to function (e.g., authentication state). We do not use advertising cookies, tracking pixels, or third-party analytics cookies.
The app may use local device storage to cache your preferences and reduce server requests. This data stays on your device and is cleared when you uninstall the app.
Regardless of where you live, you have the right to:
GDPR Art. 15–22 If you are located in the European Economic Area (EEA), EU, or United Kingdom, you also have the right to:
We will respond to GDPR requests within one month of receipt. In complex cases, this may be extended by up to two additional months with prior notice.
CCPA/CPRA If you are a California resident, you have the following rights under the California Consumer Privacy Act (as amended by Proposition 24):
To submit a California privacy request, contact us via one of the two methods below. We will respond within 45 days. One free extension of 45 days may apply for complex requests, with notice to you. We do not charge a fee for reasonable requests.
To exercise any of your rights, use either of these two methods:
We may need to verify your identity before processing requests to protect against fraudulent submissions. We will ask you to confirm your email address at a minimum.
HealthKit Guidelines WA HB 1155 Henry makes the following firm commitments regarding health data from Apple Health, Oura Ring, and WHOOP:
These commitments apply permanently and are not subject to change by a future policy update. If we were ever to change any of these commitments, we would seek your explicit re-consent before doing so.
COPPA 15 U.S.C. § 6501 Henry is not directed at children. We do not knowingly collect personal information from anyone under the age of 17. Users must be at least 17 years of age to create an account and use the app.
If you are a parent or guardian and believe your child under 17 has created a Henry account, please contact us at support@coachhenryapp.com. We will delete the account and all associated data promptly upon verified request.
We do not knowingly collect the personal information of children under 13 as defined by COPPA (Children's Online Privacy Protection Act). If we become aware that a user is under 13, the account is immediately deleted.
GDPR Art. 77 If you are located in the EU or UK and believe we have processed your data unlawfully, you have the right to lodge a complaint with your local data protection supervisory authority. You may do this without first contacting us, though we encourage you to reach out to us first so we can try to resolve the issue directly.
Examples of relevant supervisory authorities:
This policy has been written to address the requirements of the following laws and guidelines. If you have questions about how we meet any specific requirement, please contact us.
| Law / Framework | Jurisdiction | Section(s) Addressed |
|---|---|---|
| GDPR (Regulation (EU) 2016/679) | EU & UK | §§ 1, 4, 6, 8, 10, 11, 13, 16 |
| CCPA / CPRA (Cal. Civil Code § 1798.100+) | California, USA | §§ 3, 7, 13.3, 13.4 |
| COPPA (15 U.S.C. § 6501) | United States | § 15 |
| Apple HealthKit Guidelines | App Store (global) | §§ 3.2, 7, 14 |
| Washington My Health MY Data Act (HB 1155) | Washington, USA | §§ 4, 13, 14 |
| CCPA ADMT Regulations (effective Jan 2027) | California, USA | § 6 |
We review this policy at least once every 12 months as required by California law. If we make material changes, we will:
Continued use of Henry after changes take effect constitutes acceptance of the revised policy. If you do not agree with a change, you may delete your account before it takes effect.
Questions, concerns, correction requests, or deletion requests — we take them all seriously.
Include "Privacy Request" in your subject line for fastest routing. We aim to acknowledge all privacy-related emails within 5 business days.