Effective Date: October 14, 2026

This Washington Consumer Health Data Privacy Policy (“Policy”) supplements the Rootwell Privacy Policy and explains how Biokainos Corp., the operator of Rootwell (“Rootwell,” “we,” “us,” or “our”), collects, uses, and discloses consumer health data.

This Policy applies to Washington residents and individuals whose consumer health data is collected in Washington, when acting in an individual or household capacity. It covers information defined as “consumer health data” under the Washington My Health My Data Act (“Act”).

If this Policy conflicts with our general Privacy Policy concerning consumer health data covered by the Act, this Policy governs.

1. Categories of Consumer Health Data We Collect

Depending on the features you use and the information you provide, we may collect or process the following categories to the extent they qualify as consumer health data:

• Health and Profile Information: Age, sex, height, weight, activity level, and health or nutrition goals provided during onboarding or when updating your profile.

• Food and Dietary Information: Food photos, meal descriptions, scanned food products, meal logs, dietary preferences, dietary restrictions, and restaurant menu submissions associated with you.

• Nutrition Estimates and Insights: Estimated nutrient intake, fiber intake, plant diversity, food scores, and personalized nutrition insights generated from your submissions.

• Progress and History: Saved meal analyses, dietary patterns, and progress toward nutrition goals.

• Health-Related Inferences: Information derived from your profile, food logs, or analyses that may identify aspects of your health status or nutritional needs.

• Support Communications: Health-related information you voluntarily include when contacting us or providing feedback.

Information can qualify as consumer health data even when it is inferred or estimated rather than directly measured.

2. Sources of Consumer Health Data

We obtain consumer health data from:

• You: Information you enter, photograph, upload, scan, or otherwise submit through Rootwell or in communications with us.

• Your Use of Rootwell: Meal history, saved analyses, and progress information generated through your use of App features.

• Analysis Providers: Nutrition estimates and related insights returned by service providers that process your submissions, including OpenAI through its API.

Rootwell stores information locally on your device and sends relevant information to service providers when you request features that require external processing.

3. Purposes for Collecting and Using Consumer Health Data

We use consumer health data to:

• Provide food photo analysis, barcode scanning, restaurant menu analysis, and meal logging.

• Personalize nutrition insights using the information and goals you provide.

• Estimate nutritional content and generate food scores.

• Help you track dietary patterns, fiber intake, plant diversity, and progress.

• Respond to support requests and troubleshoot problems involving your submissions or results.

• Maintain the security and functionality of the services you request.

• Fulfill applicable legal obligations and respond to privacy requests.

We collect consumer health data with your consent or to the extent necessary to provide a product or service you request, as permitted by the Act. Where separate consent is required for sharing, we obtain it before sharing.

We will disclose additional categories or purposes and obtain affirmative consent before collecting, using, or sharing consumer health data in ways that require such consent under the Act. Using Rootwell or reading this Policy does not, by itself, constitute that consent.

4. Disclosure of Consumer Health Data

4.1 Categories of Data Disclosed

Depending on the service requested, we may disclose relevant portions of the categories listed in Section 1. For example:

• Food photos, meal descriptions, and menu submissions may be sent for AI-powered analysis.

• Profile information or nutrition goals may be included where needed to personalize the requested analysis.

• Relevant submissions, analysis results, or support messages may be processed to resolve a support issue.

4.2 Categories of Recipients

Consumer health data may be disclosed to:

• AI and Nutrition Analysis Providers: Including OpenAI through its API, to process submitted content and return nutrition estimates and insights.

• Technical and Support Providers: Providers supporting the transmission, processing, security, or troubleshooting of the requested service, to the extent they need the information for those functions.

• Recipients You Authorize: When you specifically request or consent to a disclosure.

• Legal Authorities: Where disclosure is required or permitted by applicable law.

• Business Successors: In a qualifying merger, acquisition, or similar transaction, subject to the Act and applicable privacy obligations.

Service providers acting as processors must process consumer health data under our instructions and applicable contractual requirements.

We do not sell consumer health data.

5. Your Washington Consumer Health Data Rights

Under the Act, you may:

• Confirm whether we collect, share, or sell your consumer health data and access that data.

• Obtain a list of third parties and affiliates receiving your data, with a way to contact them.

• Withdraw consent to collection and sharing.

• Request deletion, including notification to recipients required to honor your request.

Email info@rootwellapp.com with the subject “Washington Health Data Request.” We may reasonably verify your identity without requiring a new account.

We respond within 45 days of receipt, with one additional 45-day extension when permitted, explained within the initial period. Information is provided free up to twice annually, subject to statutory exceptions.

Deletion includes covered backups, although backup deletion may take up to six months after authentication where permitted. We will not unlawfully discriminate against you for exercising your rights.

6. How to Submit an Appeal

Email info@rootwellapp.com with “Washington Health Data Appeal” and reference the decision.

We will explain our appeal decision in writing within 45 days. If denied, you may submit a complaint to the Washington Attorney General.

7. Contact Us

For questions or requests regarding this Policy, contact:

Biokainos Corp.
Rootwell Privacy Team
Email: info@rootwellapp.com