Staminabar Privacy Policy

Effective date: October 17, 2026
Last updated: October 23, 2026

Staminabar turns the health and fitness readings on your phone into nine game attributes, and lets games you choose read those attributes. Because that starts with health data, we hold ourselves to one strict standard everywhere: we ask before we collect it, we ask again before any game can see anything derived from it, and we never sell it or use it for advertising.

This policy explains what we collect, why, who receives it, how long we keep it, and what you can do about it. If you live in Washington, Nevada or Connecticut, or anywhere else, please also read our separate Consumer Health Data Privacy Policy at https://staminabar.io/consumer-health-data, which focuses only on health data.

Summary

Contents

1. Who we are
2. What this policy covers
3. Information we collect
4. Where our information comes from
5. How we use information
6. Legal bases for processing (EEA, UK and Switzerland)
7. Consent for health data
8. What games receive
9. Service providers and other disclosures
10. Research and modelling
11. How long we keep information
12. Deleting your data and disconnecting
13. Your rights and choices
14. US state privacy rights
15. Notice to California residents
16. Additional information for the EEA, UK and Switzerland
17. International transfers
18. Security
19. Breach notification
20. HIPAA and medical use
21. Android and Health Connect
22. Children
23. Cookies, Do Not Track and Global Privacy Control
24. Changes to this policy
25. Contact us

1. Who we are

Staminabar is operated by Lynn Allen Holdings, LLC, a Georgia limited liability company doing business as Staminabar ("Staminabar", "we", "us", "our"). We are the controller of the personal data described in this policy.

• Mailing address: 5450 Glenridge Drive, Apt 251, Atlanta, GA 30342
• Privacy questions and rights requests: privacy@staminabar.io
• Help with the app: support@staminabar.io
• Security reports: security@staminabar.io

2. What this policy covers

This policy applies to the following, which together we call the "Service":

• The Staminabar iPhone app. It reads data from Apple Health.
• The Staminabar Android app. It reads data from Android Health Connect. It is available through Google Play.
• Our website, staminabar.io, including the early-access waitlist form.
• Our APIs and servers, which store your account and health data, work out your attributes, and handle game connections.
• Games that connect to Staminabar, to the extent described in section 8. Third-party games and studios have their own privacy policies for anything else they collect.
• Staminabar mods, which are game modifications we make, such as Staminabar for Skyrim, and the files they keep on your computer.
• Staminabar-operated game servers, which are servers we run so our mods can connect to Staminabar.
• Emails and support conversations with us.

This policy does not cover Apple Health itself, the Apple App Store, Health Connect, Google Play, your game platform (for example Steam), mod tools you install separately (for example SKSE or SkyUI), or any third-party game's own data practices. Those are governed by their own terms and privacy policies.

3. Information we collect

3.1 Account information

• Email address. You enter it to create an account and to sign in. We store it in lowercase. We use it to send one-time sign-in links and messages about your account.
• User ID. A random identifier we create for your account.
• Verification status and dates. Whether your email has been confirmed, and when your account was created and last updated.

Staminabar has no passwords. You sign in with a one-time link we email to you, which works once and expires after 1 hour. If you never confirm your email, the unconfirmed account is removed automatically after 24 hours.

3.2 Device and sign-in information

When you sign in on your phone, the app creates a sign-in key and we keep a record of that device:

• Device ID. A random identifier the app creates and keeps in your phone's Keychain. It is not Apple's advertising identifier and not the "identifier for vendor". On Android, the app creates a random identifier and keeps it in the app's private storage. It is not Google's advertising ID and not the Android ID.
• Public key. Your phone creates a key pair. The private key never leaves your phone; it stays in the iOS Keychain, is available only while your phone is unlocked, and is not included in backups. We store only the public half and its key ID. On Android, the private key is created and kept inside the Android Keystore. It cannot be exported and is never sent to us.
• Platform: "ios" or "android".
• Device name, as reported by your phone (on current iPhones this is usually a generic name such as "iPhone"). On Android, this is the name set in the phone's settings (Settings > About phone), or the phone model if no name is set. People sometimes put their own name in the device name.
• Status and dates: when the device was enrolled, last seen and last updated.
• Sessions and sign-in challenges. Short-lived records that keep you signed in (sessions last 1 hour; challenges last 5 minutes). We store only a scrambled digest of each session secret, never the secret itself.

3.3 Apple Health and Health Connect data

With your permission, the app reads data from Apple Health and sends it to our servers. Specifically:

• Read only. The app never writes to Apple Health.
• You choose. Apple's Health permission screen lets you allow or deny each type. You can change this at any time in the Health app or in iOS Settings.
• How it syncs. The first sync sends your last 14 days of readings. After that, the app sends new readings about once a day, including in the background using Apple's background delivery, and whenever you tap Sync now.
• What each reading contains. The reading's type, value, unit, start and end time, Apple's random sample ID, a sleep stage where relevant, and your phone's time zone offset from UTC at the time of the reading. We also record that the source is Apple Health. We do not receive the name of the app or device that recorded the reading.
• Time zone offset. The offset (for example "UTC minus 5 hours") lets us put readings on the right day. It is not a location, but over time it can show which time zone you were in.
• No clinical records. The app does not request Apple's clinical health records, workout routes, or "characteristics" such as date of birth, sex or blood type.
• Never in iCloud. We do not store health data in iCloud or CloudKit.

The app can read up to 58 types. Nine of them exist only on iOS 18 or later, so on iOS 17 the app reads at most 49.

If you delete a reading in Apple Health after it has synced, it is not removed from Staminabar automatically. It is removed when it reaches the end of its 90-day retention period or when you delete your account.

3.3.1 Health Connect (Android)

With your permission, the Android app reads data from Health Connect and sends it to our servers.

• Read only. The app never writes to Health Connect.
• You choose. Health Connect's permission screen lets you allow or deny each type. You can change this at any time in the Health Connect settings on your phone.
• How it syncs. The first sync sends your last 14 days of readings. After that, the app sends new readings about once a day, including when the app is closed, and whenever you tap Sync now.
• Background reading. The app asks for Health Connect's "access data in the background" permission so the daily sync can run when the app is not open. If you do not allow it, the app syncs only while it is open.
• Past data. The app asks for Health Connect's "access past data" permission, which lets it read readings from before you first gave access. It only reads the last 14 days.
• What each reading contains. The reading's type, value, unit, start and end time, Health Connect's record ID, a sleep stage where relevant, and your phone's time zone offset from UTC at the time of the reading. We record that the source is Health Connect. We do not receive the name of the app or device that recorded the reading.
• Worked-out values. Some readings are worked out on your phone from Health Connect records before they are sent. Distance is split by sport using your exercise sessions (for example, distance during a cycling session counts as cycling distance). Exercise minutes come from the length of your exercise sessions. Body mass index is worked out from your weight and height.
• Never in a cloud backup. The app turns off Android cloud backup, so its data is not copied to Google Drive.

The Android app can read up to 33 types:

These are the Health Connect permissions the app asks for: steps, distance, active calories burned, basal metabolic rate, floors climbed, exercise, heart rate, resting heart rate, respiratory rate, oxygen saturation, sleep, VO2 max, power, speed, wheelchair pushes, weight, height, body fat, lean body mass, access data in the background, and access past data.

The Android app does not read heart rate variability, heart rate recovery, skin or wrist temperature, swimming strokes, cross-country skiing, stand or move minutes, physical effort, walking gait measures (step length, asymmetry, double support time, steadiness), stair speed, six-minute walk, running form measures (stride length, vertical oscillation, ground contact time), cycling functional threshold power, underwater depth, water temperature, or waist circumference. It does not request Health Connect's medical records, nutrition, hydration, cycle tracking, blood pressure, blood glucose, or exercise routes.

If you delete a reading in Health Connect after it has synced, it is not removed from Staminabar automatically. It is removed when it reaches the end of its 90-day retention period or when you delete your account.

3.4 Data we derive from your readings

• Daily summaries. For each day, we combine your readings into one summary. It can include: readiness and sleep quality figures; resting heart rate, heart rate variability, respiratory rate, wrist temperature change, and blood oxygen; sleep start and end, duration, stages and whether it was a nap; daily activity totals; fitness and movement measures; body measurements; the number of readings; the time zone offset used; and when the summary was calculated. If both an iPhone and an Android phone send data for one account, we score from the one that uploaded most recently.

• Nine attributes. From your last 90 days of daily summaries, we work out nine game attributes: readiness, rest, exertion, discipline (updated daily) and stamina, power, mobility, balance, constitution (updated slowly). Each attribute has:

  • a score from 0 to 100, or empty if there is not enough data;
  • a tier (peak, good, baseline, low or depleted);
  • a state (scored, pending or unscorable);
  • a trend (improving, declining, stable or not enough data);
  • delta from mean, which is how far today's score is from your own usual score;
  • a cadence (daily or slow).

  The set also carries an as of date and a stale flag, which is true when your newest scored day is more than 2 days old.

Attributes compare you only with your own history, not with other people. They are worked out each time they are requested and are not stored as a separate record. They are game attributes, not health advice or a medical measurement.

3.5 Game connection records

When you connect a game, we keep a record of the connection: the game and its publisher, the permission granted ("Your stamina scores"), when you allowed it, whether it is still active, and the public half of a connection key that the game's server created for that connection. We never hold the game server's private key. Connection keys expire after 30 days and are renewed automatically while the connection stays active. While a connection is being set up, we also keep a pairing record for up to 5 minutes and a one-time pairing code that stops working after 5 wrong attempts.

3.6 Logs and technical data

When your phone, a game server or a browser calls our servers, our servers record:

• your IP address;
• your user ID or account context, if you are signed in;
• the request method, address path, status code, time taken, size, and a request ID.

We use logs to run the Service, fix problems, enforce rate limits and stop abuse. Logs are kept for 14 days. Logs never contain your health values, sign-in codes, tokens or keys; the sensitive parts of sign-in addresses are removed before logging.

3.7 Camera

The app asks for camera access only to scan a game's QR code when you connect a game. The camera view is used live to read the code; the app does not take photos or video, and no images are stored or sent to us. You can type the code instead if you prefer not to allow camera access. The Android app works the same way.

3.8 Information kept on your phone

The app keeps some information only on your phone: your private sign-in key, session and device ID (in the Keychain); and app settings such as an email address you are confirming, sync progress markers for each Apple Health type, and which introduction screens you have seen. We do not receive these settings. The device ID stays in your phone's Keychain even after you sign out or delete your account, so that the phone is recognized consistently; it is not linked to you on our side once your account is deleted. On Android, the private sign-in key is kept in the Android Keystore. Your session, user ID and device ID are kept in the app's private storage, each encrypted with a key held in the Android Keystore. App settings and sync progress markers for each Health Connect type are also kept in the app's private storage. Other apps cannot read it, it is not backed up or moved to a new phone, and uninstalling the app removes it.

3.9 Communications

If you email us, we receive your email address, the content of your message and any attachments, and our replies. Sign-in emails we send to you contain a one-time link and QR code.

3.10 Website and early-access waitlist

• Waitlist form. If you join the early-access waitlist at staminabar.io:

  • as a player, we collect your email, name, phone platform (iPhone, Android or both), the games and wearables you use, and any notes you add;
  • as a developer, we collect your email, name, studio, role, team size, the game engines you use, and a description of your project.

  We use this only to reply to you and to tell you about access to Staminabar. Waitlist entries are stored with Supabase, our database provider for the website.

• Site statistics. Our website is hosted by Lovable, whose platform scripts record basic visit statistics such as pages viewed, referring site, device and browser type, and approximate country. We use these only to understand how the site is used. They are not used for advertising.

• Cloudflare. The site is delivered through Cloudflare's network, which sets a short-lived security cookie (__cf_bm) to tell people from bots. See section 23.

• Browser storage. The waitlist form's database library may store technical values in your browser's local storage. The website has no user login.

3.11 Staminabar mods on your computer

When you install a Staminabar mod, such as Staminabar for Skyrim (a Skyrim Script Extender plugin), it stores files on your computer:

• a settings file, which includes the mod's connection token sealed with Windows Data Protection (DPAPI) for your Windows user account, so the token cannot be used if the file is copied to another computer;
• a log file, which never contains the token, pairing links or scores received;
• scores in your save games. The mod records the attribute scores applied each in-game day inside your save's co-save file, so your saves stay consistent. These are scores only, never the token;
• the game's logo image.

The mod connects to one address only: the Staminabar-operated game server for that game. Its requests identify the mod version and game runtime version. The mod has no analytics, advertising or other telemetry. While you are pairing, it shows a QR code in the game that contains only a one-time session ID and code.

3.12 Staminabar-operated game servers

Our mods do not talk to our main servers directly. They go through a game server that we run for each game. A Staminabar-operated game server stores:

• Pairing records: a scrambled (hashed) install token and display token, a sealed temporary pairing secret and connection key, the pairing state and times. Completed, denied or expired pairing records are purged after 24 hours.
• Connection records: the hashed install token, connection and key IDs, the connection's private key encrypted with AES-256-GCM, when the key expires, and when the connection was created or revoked. When you remove access, the private key is deleted. A revoked connection record keeps only random IDs and dates; it contains no key, scores or details that name you.
• Logs: your computer's IP address, the route, status, time taken and a request ID, kept for 14 days. Tokens are removed before logging.

The game server keeps your nine-attribute scores in memory for up to 60 seconds so it does not ask us repeatedly. It does not store your name, email, Staminabar user ID, game account or platform IDs, or any health readings.

3.13 What we do not collect

We do not collect your name (except if you choose to give it on the website waitlist or in an email), date of birth, age, sex, home address, phone number, precise or approximate location, contacts, photos, advertising identifiers (Apple's or Google's), or payment information. The app contains no third-party analytics, advertising, crash-reporting or attribution software, and it does not send push notifications. The Android app does not send push notifications either.

4. Where our information comes from

We do not buy data about you or receive it from data brokers.

5. How we use information

We use information to:

1. Provide the Service: create your account, sign you in, sync your Apple Health or Health Connect readings, build daily summaries and work out your nine attributes, and show them to you in the app.
2. Let games you approve read your attributes, and stop them when you remove access.
3. Keep the Service and your account secure: verify sign-ins, detect and stop abuse, enforce rate limits, and prevent replayed requests.
4. Run, maintain and fix the Service, using logs and error information.
5. Communicate with you: send sign-in links, answer support and privacy requests, and tell you about important changes such as updates to this policy.
6. Run the waitlist: reply to you and tell you about access.
7. Comply with law and enforce our Terms of Service.

We never use health data, or attributes derived from it, for advertising, marketing, data mining, profiling for sale, or decisions about employment, insurance, credit, housing or eligibility for any benefit. We do not use any personal data for targeted advertising.

Automated processing. Working out your attributes is automated profiling of your own data. It has no legal effect and no similarly significant effect on you; it only changes in-game bonuses in games you choose to connect.

6. Legal bases for processing (EEA, UK and Switzerland)

If the GDPR or UK GDPR applies to you, we rely on these legal bases:

You can withdraw consent at any time (section 13). Withdrawing does not affect processing that happened before.

7. Consent for health data

We use one standard for everyone, wherever you live:

• Separate consent to collect. Before the app reads any Apple Health data, it explains what it reads and why, and asks you to allow Apple Health. Apple then asks you to choose each type. If you choose "Not now", nothing is read. On Android, the app explains what it reads and why, then opens Health Connect's permission screen, where you choose each type.
• Separate consent to share, game by game. No game receives anything until you scan its code, review its verified name and publisher and what it will see, and tap Allow. Each game needs its own Allow.
• Easy to withdraw. You can stop collection (Connectors tab > Apple Health > Disconnect, or in iOS Settings) and remove any game (Games tab > Remove access) at any time. On Android, also in Settings > Security and privacy > Privacy > Health Connect > App permissions > Staminabar (the menu names vary a little between phone makers).
• No sale, ever. We do not sell health data. Washington law would require your signed authorization to do so; we do not ask for one because we do not sell.

Our Consumer Health Data Privacy Policy describes these consents in more detail.

8. What games receive

8.1 The attribute payload

When you connect a game, its server can request your current attributes. It receives exactly:

• the nine attributes (readiness, rest, exertion, discipline, stamina, power, mobility, balance, constitution), each with its score, tier, state, trend, delta from mean and cadence;
• the as of date and the stale flag.

A game never receives your raw readings (such as heart rate, heart rate variability, sleep times or stages, weight or distance), any reading's time, any clinical value, your name, your email, or your Staminabar user ID. The game's server receives only a connection ID and a key ID, which are random and different for every connection. Our automated tests check that nothing else is sent.

8.2 How connecting works

1. The game shows a QR code (or a code to type) that contains only a one-time session ID and code.
2. You scan it in the app. The app shows the game's name, publisher and logo from our own records, marked "Verified by Staminabar", and what it will be able to see.
3. You tap Allow or Deny. The request expires after 5 minutes.

8.3 Removing a game

Open the Games tab and tap Remove access. The game stops being able to read your attributes within about 60 seconds, its connection key is cancelled, and we notify the game's server that the connection has ended. A Staminabar mod then removes all Staminabar effects from the game. Anything a third-party game already received before you removed it is governed by that game's own privacy policy and the Staminabar Developer Terms (https://staminabar.io/developer-terms).

8.4 Who the games are

• Staminabar's own mods. Today, the only game that can connect is Staminabar for Skyrim, which we make and whose game server we run. Others, such as Minecraft and Fallout 4 integrations, appear in the app as "coming soon" and cannot connect yet.
• Third-party studios. In the future, outside game studios may connect. Before one can, it must be verified by us and agree to the Staminabar Developer Terms, which allow attributes to be used only for in-game features and forbid advertising, sale, onward sharing, profiling, decisions about employment, insurance or credit, training AI models, attempts to identify players or work out raw health data, and linking players across games. The consent screen always names the game and publisher before you decide.

9. Service providers and other disclosures

9.1 Service providers

We use these companies to run the Service. They process data on our behalf, under contract, only to provide their services to us.

We do not use advertising networks, data brokers, analytics or crash-reporting companies in the app.

9.2 Other disclosures

We disclose personal data only:

• To games you approve, limited to the payload in section 8.
• To comply with law, such as a valid subpoena or court order, and to protect the safety, rights or property of our users, the public or Staminabar. Where the law allows, we will tell you before disclosing your data in response to legal process.
• In a business transfer, such as a merger, acquisition or sale of assets. Any successor must honor this policy for data collected under it, and we will ask for your consent before any new use of your health data.
• With your consent in any other case.

We do not share personal data in any other way.

10. Research and modelling

We are developing models to spot cheating (for example, data that could not have come from a real person) and to make attributes fairer across different people and devices.

• Today, these models use only the data of one of our founders, who has agreed to it. His historical readings are kept for this purpose outside the normal 90-day limit.
• We do not use your data to train models, and we will not, unless you give separate, opt-in consent in the app for that specific purpose. That consent will never be a condition of using Staminabar, and you will be able to withdraw it at any time.
• Working out your own attributes from your own history (section 3.4) is part of providing the Service to you. It is not model training.

11. How long we keep information

Expired records are removed by an automatic sweep, normally within 48 hours of their expiry time. The founder's research data described in section 10 is the only exception to the 90-day health data limit.

12. Deleting your data and disconnecting

12.1 Delete your account in the app

Open Settings and tap Delete account, then confirm. Deletion is immediate and cannot be undone. In this order, we:

1. revoke every game connection and tell each game's server that the connection has ended;
2. delete your Apple Health and Health Connect readings, daily summaries and connected health sources;
3. delete your sessions, devices and keys;
4. delete your account record and email address.

The app then stops syncing and removes your sign-in key from your phone. You do not need to contact us. You can later sign up again with the same email as a new account.

What remains for a short time. Copies may remain in our 14-day server logs (which contain IP addresses and user IDs, but no health values) and in database backups, which age out within 35 days. Short-lived sign-in and pairing records expire on their own within hours. Anything a game already received before deletion is described in section 8.3.

You can also ask us to delete your account by emailing privacy@staminabar.io from your account's email address.

12.2 Stop Apple Health syncing

• In the app: Connectors tab > Apple Health > Disconnect. Syncing stops right away. Readings already sent stay until their 90-day period ends or you delete your account.
• In iOS: Settings > Health > Data Access & Devices > Staminabar (or the Health app's Sharing tab), where you can turn off any or all types.

12.2.1 Stop Health Connect syncing

• In the app: Connectors tab > Health Connect > Disconnect.
• On the phone: open Health Connect (Settings > Security and privacy > Privacy > Health Connect), choose App permissions > Staminabar, and turn off any or all types, or remove all access.

12.3 Remove a game

Games tab > Remove access. See section 8.3.

12.4 Remove a mod's data from your computer

Disconnect the mod in the game (this tells the game server to end the connection), then uninstall the mod. To remove everything it stored, delete its settings file (Data/SKSE/Plugins/Staminabar.json), its log (Staminabar.log in your SKSE log folder) and its folder in Data/SKSE/Plugins. Scores recorded in your save games remain in those saves until you delete the saves. We cannot reach these files ourselves.

12.5 Website waitlist

Email privacy@staminabar.io to have your waitlist entry deleted.

13. Your rights and choices

Wherever you live, you can ask us to:

• Access your data: confirm whether we process it and get a copy, including a list of every third party we have shared it with;
• Delete your data;
• Correct inaccurate data;
• Export your data in a portable, machine-readable format;
• Withdraw consent to collecting health data or sharing it with any game;
• Object to or restrict certain processing, where the law gives you that right.

How to make a request. Most choices are in the app (sections 12.1 to 12.3). For access, export, correction or anything else, email privacy@staminabar.io. We will confirm the request comes from you by checking it was sent from your account's email address or by sending a confirmation link to it. We respond within 45 days. If we need more time, we will tell you why, and take up to 45 more days where the law allows. Where the GDPR applies, we respond within one month, extendable by two months for complex requests.

Correction. Your health readings come from Apple Health. To correct them, correct them in Apple Health; corrected readings sync as new data, and earlier readings expire after 90 days. On Android, correct them in Health Connect or in the app that recorded them. You can also ask us to delete specific readings.

Free of charge. Requests are free. We may refuse or charge a reasonable fee for requests that are clearly unfounded or excessive, where the law allows, and we will explain why.

14. US state privacy rights

Residents of many US states, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia and Washington, have rights under state privacy laws. We give these rights to all US users, whether or not a law requires it.

• Your rights: access, correction, deletion, portability, and opting out of targeted advertising, sale of personal data and profiling with legal or similarly significant effects. We do not do any of those, so there is nothing to opt out of, but you may still ask.
• Sensitive data. We process health data only with your opt-in consent.
• Appeals. If we decline your request, in whole or in part, you can appeal. Email privacy@staminabar.io with the subject line "Privacy appeal" and explain what you disagree with. Someone who did not make the original decision will review it and respond in writing within 45 days, explaining the outcome and reasons. If you are not satisfied, you may contact your state Attorney General.
• Authorized agents. You may use an authorized agent. We will ask the agent for your signed permission, and we may ask you to confirm your identity with us directly, unless the agent holds a valid power of attorney.
• Non-discrimination. We will not deny you the Service, charge you a different price, or give you a different quality of service for exercising your rights. Note that if you withdraw consent to health data collection, the app cannot work out attributes, because that is what it does.
• Nevada. We do not sell covered information as defined by Nevada law. Nevada residents may still send an opt-out request to privacy@staminabar.io. See also our Consumer Health Data Privacy Policy.
• Washington, Nevada and Connecticut consumer health data. See our Consumer Health Data Privacy Policy at https://staminabar.io/consumer-health-data.

15. Notice to California residents

This section is our notice at collection and privacy policy under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. It covers the past 12 months and the present.

15.1 Categories of personal information

We do not collect geolocation, biometric identifiers used to identify you, government IDs, financial account information, or account log-in credentials such as passwords.

15.2 Sale and sharing

We do not sell or share personal information, as "sell" and "share" are defined in the CCPA, and we have not done so in the past 12 months. We have no actual knowledge of selling or sharing the personal information of consumers under 16. When you direct us to connect a game, we disclose attributes to it at your direction, and we do not receive anything of value from the game for it.

15.3 Sensitive personal information and "Limit the Use"

We use sensitive personal information only for purposes the CCPA permits without offering a right to limit, namely to provide the Service you request, to keep it secure, and for related permitted purposes. We do not use it to infer characteristics about you beyond working out your attributes for you. Because of this, we do not offer a "Limit the Use of My Sensitive Personal Information" link. If that changes, we will add one and ask for your consent first.

15.4 Your California rights

You have the right to know, access, delete, correct and port your personal information, the right to opt out of sale and sharing, the right to limit use of sensitive personal information, and the right not to be discriminated against for exercising these rights. See sections 13 and 14 for how to make a request, use an authorized agent, and appeal.

15.5 Shine the Light

We do not disclose personal information to third parties for their own direct marketing.

16. Additional information for the EEA, UK and Switzerland

• Controller: Lynn Allen Holdings, LLC, 5450 Glenridge Drive, Apt 251, Atlanta, GA 30342, privacy@staminabar.io.
• Representative: We are based in the United States and have no office in the EEA, UK or Switzerland. Please contact us directly at privacy@staminabar.io about any data protection matter.
• Your rights: access, rectification, erasure, restriction, portability, objection (including to processing based on legitimate interests), and withdrawal of consent at any time. You also have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects; we make no such decisions.
• Complaints: You may lodge a complaint with your local data protection authority, the UK Information Commissioner's Office, or the Swiss Federal Data Protection and Information Commissioner. We would appreciate the chance to address your concern first.
• Required data: Your email is required to create an account. Health data is optional, but the app cannot work out attributes without it.

17. International transfers

We store and process data in the United States, using Amazon Web Services in the us-east-1 region (Northern Virginia). If you use Staminabar from outside the United States, your data is transferred to the United States, where privacy laws may differ from yours. Where the GDPR, UK GDPR or Swiss law applies, we rely on the European Commission's Standard Contractual Clauses (with the UK Addendum and Swiss amendments where relevant) and, for health data, your explicit consent. Our service providers that receive personal data from the EEA, UK or Switzerland do so under their own Standard Contractual Clauses or other approved safeguards. You can ask for a copy of the relevant safeguards at privacy@staminabar.io.

18. Security

We protect data with measures that are actually in place today:

• Encryption in transit over the internet. Connections between the app, game servers, browsers and our servers use TLS. Our main API requires TLS 1.3, and plain HTTP is redirected to HTTPS. Calls between our own services stay inside a private AWS network that cannot be reached from the internet; encrypting that internal traffic as well is planned work.
• Encryption at rest. Our database, file storage and game server storage are encrypted at rest using encryption provided by AWS. Key material, such as sealed connection secrets and keys, is additionally protected with AWS Key Management Service (KMS) or AES-256-GCM encryption.
• No passwords. You sign in with a one-time emailed link and a device key. The private key stays in your phone's Keychain and is never sent to us or backed up.
• Signed requests. Game servers sign every request with a key unique to each connection. Each request carries a timestamp that must be within 5 minutes and a one-time value that we remember for 10 minutes, so captured requests cannot be replayed.
• Rate limits on sign-in, pairing, attribute requests and account deletion, plus identical error messages so nobody can tell whether an email has an account.
• Least privilege. Internal service routes are on separate listeners that the internet cannot reach. Secrets are kept in AWS Secrets Manager. Our services run with minimal permissions.
• Minimal logging. Logs never contain health values, sign-in codes, tokens or keys.

No system is perfectly secure, and we cannot guarantee absolute security. More detail is on our Security page (Trust Center) at https://staminabar.io/trust-center. Please report security concerns to security@staminabar.io.

19. Breach notification

If we discover a breach of security involving your health data or other personal data, including any unauthorized disclosure, we will notify you without unreasonable delay. For health data covered by the US Federal Trade Commission's Health Breach Notification Rule, we will notify affected people and the Federal Trade Commission no later than 60 calendar days after we discover the breach, and the media where the Rule requires it. We will also notify regulators and affected people as required by state law and, where it applies, the GDPR (generally within 72 hours to the relevant authority). Notices will describe what happened, what data was involved, what we are doing, and what you can do.

20. HIPAA and medical use

Staminabar is not a health care provider, health plan or health care clearinghouse, and we are not a business associate of one. The Health Insurance Portability and Accountability Act (HIPAA) does not apply to Staminabar or to the data you share with us. We protect your data under this policy, the Federal Trade Commission Act, the FTC Health Breach Notification Rule, and state consumer health data and privacy laws.

Staminabar is not a medical device and does not diagnose, treat or prevent any condition. Attributes are game mechanics, not health advice.

21. Android and Health Connect

The Staminabar Android app reads data from Health Connect with your permission. Everything in this policy about Apple Health applies to Health Connect in the same way: read only, you choose each type, 90-day retention, the same limits on what games receive, and never for advertising. Section 3.3.1 lists the Health Connect data types the app reads.

Health Connect Limited Use. Staminabar's use of information received from Health Connect, and its transfer of that information to any other app, adheres to the Health Connect Permissions policy, including the Limited Use requirements. We use Health Connect data only to work out and show your attributes and to provide the features described in this policy. We do not use it for advertising, we do not sell it, and we do not let people read it except with your consent, for security, to comply with law, or where data is aggregated and anonymised for running the Service.

22. Children

Staminabar is only for people 18 and older. We do not knowingly collect personal data from anyone under 18, and we do not direct the Service to children. If we learn that someone under 18 has an account or has given us personal data, we will delete the account and the data. If you believe this has happened, email privacy@staminabar.io.

23. Cookies, Do Not Track and Global Privacy Control

• App. The app uses no cookies, advertising identifiers or tracking, on iPhone or Android.
• Website. Cloudflare sets the __cf_bm cookie, which lasts about 30 minutes and is used only to distinguish people from bots. The website's hosting platform (Lovable) records the visit statistics described in section 3.10. The waitlist form may use your browser's local storage. We do not use advertising cookies, social media pixels or cross-site tracking.
• Do Not Track. Because we do not track you across sites, our website does not change its behavior in response to Do Not Track signals.
• Global Privacy Control. We honor Global Privacy Control (GPC). If your browser sends a GPC signal, we treat it as a valid request to opt out of the sale and sharing of your personal information, and of targeted advertising, for that browser. We do not do any of those, so the practical effect is that we confirm that nothing is sold or shared.

24. Changes to this policy

We may update this policy. We will change the "Last updated" date and post the new version at https://staminabar.io/privacy. If a change is material, we will tell you in the app or by email before it takes effect. If we ever want to use or share your health data in a materially different way, we will ask for your consent first, and we will not apply the change to you without it.

25. Contact us

Lynn Allen Holdings, LLC, d/b/a Staminabar
5450 Glenridge Drive, Apt 251, Atlanta, GA 30342

• Privacy and rights requests: privacy@staminabar.io
• Support: support@staminabar.io
• Security: security@staminabar.io

Consumer Health Data Privacy Policy: https://staminabar.io/consumer-health-data