Consumer Health Data Privacy Notice
Posted separately from our general Privacy Policy, as required by the Washington My Health My Data Act and comparable laws
Operated by ClientValley OÜ (Estonia)
Last Updated: 14 September 2026 · Effective Date: 15 July 2026
EELO IS A SELF-HELP WELLNESS APP. IT IS NOT A HEALTHCARE PROVIDER, AND WE ARE NOT A COVERED ENTITY OR BUSINESS ASSOCIATE UNDER HIPAA. THE INFORMATION YOU ENTER IS NOT PROTECTED HEALTH INFORMATION UNDER HIPAA. IT IS, HOWEVER, SENSITIVE, AND WE TREAT IT AS CONSUMER HEALTH DATA UNDER APPLICABLE UNITED STATES STATE LAW.
This notice is the Consumer Health Data Privacy Policy of ClientValley OÜ for the product EELO. It is the same notice as Section 6 of our Privacy Policy. We post it here so it can be linked separately and conspicuously.
This notice applies to "consumer health data" as defined by the Washington My Health My Data Act, the Nevada consumer health data law, and comparable United States state laws. It applies to all users. Residents of Washington and Nevada have the additional rights described below.
1. What consumer health data we collect
The practice content described in Section 4.1 of our Privacy Policy, including the fears, triggers, habits, challenges, reflections, distress ratings, and completion records you enter, together with the fact that you use a mental wellness application at all, may constitute consumer health data because it can reveal information about your mental health status or your attempts to seek mental wellness support.
2. How we collect it
We collect consumer health data only when you voluntarily enter it into the Service, or when it is generated by your use of features you choose to use. We do not collect consumer health data from any third party, and we do not infer health data from data brokers or from external sources.
3. Why we collect it
- To provide the core functionality of the Service to you, that is, to store and display your own entries back to you and to track your own progress.
- To operate, secure, maintain, and troubleshoot the Service.
- For no other purpose, unless we obtain your separate, specific, informed consent first.
4. Who we share it with
WE DO NOT SELL CONSUMER HEALTH DATA. WE DO NOT SHARE CONSUMER HEALTH DATA FOR ADVERTISING, MARKETING, PROFILING, OR ANY CROSS-CONTEXT BEHAVIORAL ADVERTISING PURPOSE. WE DO NOT DISCLOSE IT TO DATA BROKERS.
The only parties that may process consumer health data are our infrastructure service providers, acting solely as processors under contract and solely to host and operate the Service on our behalf. They are listed in Section 8 of our Privacy Policy. Where end-to-end encryption is applied, those providers hold only encrypted data that they cannot read.
We may also disclose data where required by law, as described in Section 8.3 of the Privacy Policy.
We collect consumer health data when you voluntarily enter it after you have been given this notice (including by agreeing to our Privacy Policy). We will obtain a separate, specific authorization from you before any sale of consumer health data (we do not sell it). You have a private right of action under the Washington My Health My Data Act if we fail to comply.
5. Your consumer health data rights
You have the right to:
- Confirm whether we are collecting, sharing, or selling your consumer health data, and to access that data.
- Obtain a list of all third parties with whom we have shared your consumer health data.
- Withdraw your consent to the collection and sharing of your consumer health data.
- Have your consumer health data deleted, including from our archives and backups, subject to the backup limits described in Section 9 of our Privacy Policy and to any legal retention obligation.
To exercise these rights, contact us at the address below. We will not discriminate against you for exercising them. You may appeal a denial, and if your appeal is denied, you may contact your state Attorney General.
6. Contact
ClientValley OÜ, a private limited company registered in Estonia (registry code 14802223), Tallinn, Estonia.
Privacy and legal contact: eeloocd@gmail.com
The full Privacy Policy and Terms of Service also apply.