Consumer Health Data Privacy Policy

Effective date: November 5, 2026

This policy applies to residents of Washington and Nevada, and to anyone whose consumer health data is collected in those states. It explains how Evolve Medical Systems, LLC ("We") handles consumer health data in SmartBP and on smartbp.app. It adds to Our Privacy Policy.

"Consumer health data" means personal information linked or reasonably linkable to You that identifies Your past, present or future physical or mental health status.

Consumer health data We collect

Measurements: blood pressure, pulse and heart rate, weight, height, BMI, and ECG data if You choose to sync it
Context for measurements: dates and times, tags and notes
Medications: names, doses, reminders, whether doses were taken, and medicine photos
Health background: Your blood pressure condition, smoking status, and answers to onboarding questions
Lifestyle: goals and check-ins
Data from other health apps, if You allow it: sleep, exercise and heart rate variability
Data about Your use of health features: for example, that You used medication tracking
Identifiers linked to this data: if You use SmartBP Cloud Sync or SmartBP Clinic, Your name, email, date of birth and sex

Why We collect and use it

To provide the features You ask for, such as tracking, charts, reports, reminders and on-device insights
To sync and back up Your data if You use SmartBP Cloud Sync
To share Your data with a clinic if You connect to one
To keep the Service secure and fix problems
To create aggregated, de-identified statistics that do not identify You, to understand the impact of SmartBP and improve it. We do not sell these statistics or use them for advertising or to target You.

We collect this data because it is necessary to provide the product You requested, or with Your consent.

How We process it

Health data is stored on Your device. It reaches Our servers only if You use SmartBP Cloud Sync or SmartBP Clinic, where it is encrypted in transit and at rest. Personalized insights are generated on Your device.

Where We get it

Directly from You
From Your device and the SmartBP app
From Bluetooth blood pressure monitors You connect
From Apple Health or Google Health Connect, if You allow it

Consumer health data We share

At Your direction:

Clinics You connect to: readings, tags and notes, medication and lifestyle information where applicable, and identifying profile information
Apple Health and Google Health Connect: data You choose to sync
Your Google Drive or Dropbox: files You choose to export
Researchers: only if You join a study and sign its Informed Consent

To service providers that process it for Us: Amazon Web Services (hosting and email).

Usage and device information sent to analytics and advertising companies: Google (Firebase, AdMob and Google Ads), Meta, Moloco and IronSource may receive device or advertising identifiers, IP address, and app or website activity. This may show that You use SmartBP, or that You used a health feature.

Affiliates: We do not share consumer health data with affiliates.

We do not sell consumer health data.

Third-party collection over time

Third parties may collect information over time and across different websites or services when You use smartbp.app or SmartBP. This happens through cookies, advertising identifiers and similar tools from Google and Meta. You can manage cookies through the website's consent banner, and ad tracking through Your device settings.

Your rights

You have the right to:

Confirm and access: find out whether We collect, share or sell Your consumer health data, get a copy of it, and get a list of the third parties and affiliates We have shared it with, including a way to contact them
Withdraw consent: withdraw Your consent to collection and sharing
Delete: have Your consumer health data deleted from Our active systems. Some older copies may remain in backups and system archives for longer. Where We can, We will tell the companies We shared it with
Review and change: You can review and correct Your data in the SmartBP app at any time

Exercising these rights is free up to twice a year.

How to make a request

In the app: delete Your data or account from the Smart Cloud screen
Use Our Privacy Request Form
Email support@evolvemedsys.com

We may need to verify Your identity. You don't need to create an account, though if You have one We may ask You to use it. We will respond within 45 days. If We need longer, We will tell You why within those 45 days, and We can extend by up to 45 more days.

How to appeal

If We decline Your request, You can appeal by emailing pranam@evolvemedsys.com with the subject "Health data appeal". We will respond in writing within 45 days and explain Our decision.

If Your appeal is denied, You can file a complaint with the attorney general of Your state:

Washington: www.atg.wa.gov/file-complaint
Nevada: ag.nv.gov

Changes to this policy

If We make a material change, We will post it here and tell You by email or by a prominent notice in the app or on Our website. We will not collect, use or share new categories of consumer health data, or use it for new purposes, without first disclosing them and getting Your consent.

Contact

Evolve Medical Systems, LLC, 2292 Faraday Ave, Suite 63, Carlsbad, CA 92008, USA
support@evolvemedsys.com