FitLoad Consumer Health Data Policy

Effective date: October 28, 2026 · Version 2.0

About this Policy

This Consumer Health Data Policy (“Policy”) supplements the FitLoad Privacy Policy and applies in circumstances where information Scaling Reason LLC (“FitLoad,” “us,” “our,” or “we”) processes may be considered “Consumer Health Data” subject to the Washington My Health My Data Act, Nevada Senate Bill 370 (2023) (Chapter 603A of the Nevada Revised Statutes), the consumer health data provisions of the Connecticut Data Privacy Act, or other applicable U.S. state laws on consumer health privacy (“Applicable State Laws”).

When we say “Consumer Health Data,” we mean personal information that is linked or reasonably could be linked to you and that identifies your past, present, or future physical or mental health status, as defined by Applicable State Laws. Capitalized terms not defined in this Policy have the meanings given to them in our Privacy Policy.

Categories of Consumer Health Data We May Collect

At FitLoad, we help individuals develop personalized training plans for triathlon and other endurance sports; and to record, measure, improve, and (when they choose to do so) share their athletic performance. Much of the information we collect is Consumer Health Data, and we treat all of it as Consumer Health Data. The categories are:

• heart rate, heart-rate variability and resting heart rate, including heart rate recorded in your workouts;
• sleep;
• body weight;
• daily check-ins (readiness, tiredness, illness, pain level and where it hurts, and weekly stress), injury and illness reports, and reasons for missed sessions that describe your health;
• your messages to the AI coach and files you attach, to the extent they describe your health; and
• estimates and metrics we derive from the above, such as training load, fatigue, fitness and readiness estimates and heart-rate zones.

Categories of Sources We May Collect Consumer Health Data From

We may collect such information from:

• You, depending on how you engage with our Services and on your preferences. For example, when you enter a daily check-in, an injury or illness report, or upload a workout file that contains heart rate.

• Third-party apps, services, and devices, to the extent you permit third parties to share such information with us. For example, once you connect Intervals.icu or Apple Health, the heart rate, heart-rate variability, sleep, weight and other health data they hold arrive automatically, without further action by you.

Why We May Collect, Use, and Disclose Consumer Health Data

As necessary to provide you with the products and services you have requested, we may collect, use, and disclose Consumer Health Data. This may include creating personalized training plans for you, offering insights into your workouts and activities; providing, improving, and personalizing our platform and Services; and promoting safety, integrity, and security on our platform. We may also collect, use, and disclose Consumer Health Data for other purposes with your consent or authorization, or as the law otherwise permits.

Categories of Parties Consumer Health Data May Be Shared With

We do not sell Consumer Health Data. And, except as this section notes, we do not share it with third parties. We only disclose it to our service providers (including our AI provider(s)) and third parties you choose to share it with (such as third-party integrations). The AI providers we use are listed in our list of subprocessors.

We may also disclose Consumer Health Data to parties in a corporate transaction (such as new owners if there is a change of ownership or control of all or part of our business, products, or services), and to law enforcement or other third parties in connection with valid legal process, to comply with applicable law, or to prevent harm.

How to Exercise Your Privacy Rights Concerning Your Consumer Health Data

You have certain rights with respect to your Consumer Health Data, including to:

• Access your Consumer Health Data.

• Delete your Consumer Health Data.

• Withdraw your consent for the collection and sharing of your Consumer Health Data.

• Ask us to confirm whether we are collecting or disclosing your Consumer Health Data, and with whom.

If you would like to exercise your rights, review or request changes to your Consumer Health Data, or ask any questions, please see the FitLoad Privacy Policy and/or contact us through legal@fitload.ai.

If we deny a request to exercise a right, you may appeal that decision by contacting legal@fitload.ai. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint, with the Nevada State Attorney General at https://ag.nv.gov/, with the Connecticut Attorney General at https://portal.ct.gov/ag, or other regulatory authority as applicable.

Changes to This Policy

FitLoad reserves the right to change this Policy at any time. If we change this Policy, we will post the revised policy, together with its effective date, on our website. If we make changes that we consider material, we will give prominent, advance notice. If you object to any change to this Policy, you should stop using the Services and delete your account.