Consumer Health Data Privacy Policy

Version 1 — effective July 5, 2026

Consumer Health Data Privacy Policy

Effective date: July 5, 2026

Givfi, Inc. ("Givfi," "we," "us") operates the Givmo app and is the entity that collects and controls the consumer health data described in this policy. Givmo Charitable Fund is an affiliate on whose domain this policy is hosted; Givfi, Inc. is the regulated entity that collects and controls your step data for Steps Competitions. This Consumer Health Data Privacy Policy describes how we handle the daily step totals we process when you join a Givmo Steps Competition.

What consumer health data we collect. Only your daily step totals for the dates of a competition you have joined, read from Apple Health (iOS) or Health Connect (Android) with your explicit permission, and only after you join a competition and consent. We do not collect step timestamps, individual step samples, GPS or location data, routes, heart rate, sleep, workouts, or any other health or fitness information. Steps you entered manually into Apple Health or Health Connect are excluded and do not count.

Categories of sources. We read daily step totals only from your device's health store (Apple Health or Health Connect), and only with your permission.

How and why we process it (manner and purposes of processing). We process your daily step totals solely to display the competition leaderboard and determine the winner, whose chosen charity receives the sponsoring company's prize donation. We store daily step totals on Givfi's servers for the duration of the competition and transmit them securely (encrypted in transit). Your visibility on a leaderboard reflects both your own setting (public or private) and the competition's setting (open to any signed-in Givmo user, or limited to your employer's participants); the more restrictive of the two always applies. If your participation is private, others see only an anonymous rank and step count — not your name, avatar, or chosen charity. One exception: if a private participant wins, the public celebration post names the sponsoring company and the winning charity — but never the winner's name, avatar, or identity. So if you keep your participation private and go on to win, your chosen charity may be named publicly while you remain unnamed.

Categories of consumer health data we share, and with whom. None. We do not sell your health data, do not share it with third parties, and do not use it for advertising, marketing, or analytics. (Your sponsoring employer's competition admins can view participant rows to run the competition; they are contractually bound as our processor, restricted to running the competition, with no export or download of individual step data and need-to-know access — this is not third-party sharing.)

Retention and deletion. We keep your step data only while it is needed to run a competition you have joined. If you withdraw, your row is removed immediately. If you delete your Givmo account, your individual step entries are deleted. Completed competitions may retain aggregate results (such as final standings) that do not require your individual daily step records.

Your rights and how to exercise them. You may at any time: withdraw your consent; confirm whether we hold your consumer health data and access it; and request deletion of your consumer health data, which we will also pass on to anyone we have shared it with (currently none). We will honor your request and respond within 45 days. When you request deletion, we delete your step data from our active systems and from any backup or archived systems the next time those systems are cycled (in all cases within six months). To exercise any of these rights, contact us at support@givmocharitable.org. On your device, you can revoke Givmo's access to Apple Health or Health Connect at any time in your system settings.

How we notify you of changes. If we make a material change to this Consumer Health Data Privacy Policy, we will notify you by updating the effective date above and posting notice in the Givmo app and/or by email.

Contact. Givfi, Inc. — consumer health data requests: support@givmocharitable.org.