Troi
These policies are drafts pending legal review and may change before launch.

Troi Consumer Health Data Privacy Policy

Effective date: 2026-07-09 · Version: 1.0 · Last updated: 2026-07-09

DRAFT — pending attorney review. This is a usable draft implementing Kanah LLC's documented decisions for consumer health data. It is not a substitute for licensed-counsel sign-off and should not be published as final until reviewed.

The short version (plain-language summary)

  • This policy covers consumer health data in Troi Life — the wellness information you choose to track: mood/journal, workouts, sleep, nutrition, and cycle/reproductive data, among others.
  • We collect this data only after you opt in, and only for the category you turn on. Nothing sensitive is collected until you say yes.
  • We do not sell or share your health data, and we would never do so without a separate, explicit authorization from you (which we don't seek).
  • You can withdraw consent anytime, which deletes that category of data.
  • We do not use geofencing around health facilities.
  • Troi Life is consumer wellness, not healthcare — not a medical provider, not HIPAA-covered, not a medical device, and not medical advice.
  • This policy is written to meet Washington's My Health My Data Act (MHMDA) and Nevada's and Connecticut's consumer-health-data laws.

1. Purpose and scope

This Consumer Health Data Privacy Policy is required by the Washington My Health My Data Act (MHMDA) and parallel laws in Nevada (SB 370) and Connecticut. It explains how Kanah LLC ("we", "us", "Kanah") — operator of Troi Life — collects, uses, shares, and protects your consumer health data, and the rights you have over it. It supplements our general Privacy Policy; where this policy is more specific about health data, it controls for that data.

Kanah LLC · 1603 Capitol Avenue, Suite 413A, #2280, Cheyenne, WY 82001, USA · info@kanah.app · +1 (424) 291-5470.

2. What "consumer health data" means here

We define consumer health data broadly, consistent with the MHMDA. In Troi Life it includes information you choose to track that relates to your physical or mental health, such as:

  • Mental health and journal data — mood, energy, reflections, and journal entries.
  • Fitness and activity — workouts and exercise.
  • Sleep — sleep tracking and patterns.
  • Nutrition — food, diet, and related logs.
  • Reproductive and cycle data — menstrual cycle and reproductive health.
  • Other health data — health conditions, labs, prescriptions, visits, and related wellness information you enter.

This is "special-category" data under the GDPR and "sensitive" data under US state law. We treat all of it as consumer health data for the purposes of this policy.

3. We collect health data only with your prior opt-in consent

We collect each category of consumer health data only after you give prior, affirmative, opt-in consent for that category. Consent is:

  • Per-category and granular — turning on journaling doesn't turn on cycle tracking; each is a separate choice.
  • Requested before collection — the first time you use a sensitive Life surface, we ask; the Service will not store that data until you've consented.
  • Recorded — we keep a record of your consent (category, version, time, and IP) so we can honor and prove it.

We use your consumer health data only to provide the wellness feature you enabled — to store, display, organize, and sync your own entries for you. We do not use it for advertising or profiling.

4. We do not sell or share your health data

We do not sell your consumer health data, and we do not share it for anyone else's purposes. Under the MHMDA, any "sale" of consumer health data would require a separate, specific written authorization from you — distinct from the consent above. We do not seek such authorization and we do not sell health data. If that ever changed, we would ask for a valid, standalone authorization first and you could decline.

5. Who we share health data with (processors)

To run Troi Life we use a limited set of service providers ("processors") who act only on our instructions and only to deliver the Service:

  • Microsoft Azure — hosting and storage of your data.
  • AI / media providers (Anthropic, OpenAI, ElevenLabs, and others as a feature requires) — on a zero-retention, no-training tier, only when you use an AI feature. They do not train models on your data.
  • Other infrastructure providers as listed on our Sub-Processor List (/legal/subprocessors).

These providers are bound by contract to protect your data and not to use it for their own purposes. This sharing to process data on our behalf is not a "sale" or "share" and does not require separate authorization.

6. Withdrawing consent and deleting your data

  • Withdraw consent anytime. You can turn off any consented category in Settings → Account & Privacy (the Privacy & consent section). Withdrawing consent stops further collection for that category.
  • Deletion on withdrawal. When you withdraw consent, we delete the consumer health data in that category. Sensitive Life data is our shortest-hold class: it is deleted on account deletion and immediately on consent revocation.
  • Right to delete. You can also request deletion of your consumer health data at any time without deleting your whole account.
  • Backups. Deleted data may persist in encrypted backups for up to 35 days before those backups rotate and are purged.

7. Your rights

Under the MHMDA and similar laws, you have the right to:

  • Access — confirm whether we are collecting your consumer health data and get a copy, including a list of the third parties (processors) with whom we share it.
  • Delete — have your consumer health data deleted.
  • Withdraw consent — for any category, at any time (Section 6).
  • Not be discriminated against for exercising these rights.

How to exercise them. Use the in-app controls, or email info@kanah.app. We respond within 30 days (extendable where the law allows, with notice). We may need to verify your identity to protect your data.

If we deny a request, you may appeal by replying to our decision; you may also contact the Washington State Attorney General (Consumer Protection Division) to file a complaint.

8. Retention

We keep consumer health data only while you keep the feature enabled. It is deleted on account deletion and immediately on consent revocation. See the Privacy Policy for the full retention schedule.

9. No geofencing

We do not use geofencing, and we do not create, use, or sell any virtual boundary around health-care facilities (or any other location) to identify, track, or send you messages based on your presence near such a place. The MHMDA prohibits this, and we don't do it.

10. Security

We protect consumer health data with technical and organizational safeguards, including encryption in transit and at rest and default-deny access controls that prevent AI agents from reading your sensitive Life data unless you explicitly opt in per category. See the Privacy Policy for more on our security measures.

11. Troi Life is consumer wellness, not healthcare

Troi Life is a consumer wellness and self-tracking tool. It is not:

  • a healthcare provider, covered entity, or HIPAA business associate (we offer no BAA, and HIPAA does not apply);
  • a medical device; or
  • a source of medical, mental-health, or professional advice.

The information in Troi Life — including anything generated by AI — is for your own organization and information only, may be inaccurate, and is not a substitute for professional medical care. Always consult a qualified professional for medical decisions, and call your local emergency number in an emergency.

12. Washington-specific contact and details

This policy is provided to meet the Washington MHMDA's requirement for a consumer-health-data privacy policy. Washington residents (and residents of Nevada and Connecticut) may exercise the rights in Section 7 using the contacts below.

  • Consumer health data requests: info@kanah.app
  • Kanah LLC: 1603 Capitol Avenue, Suite 413A, #2280, Cheyenne, WY 82001, USA · +1 (424) 291-5470
  • Data Protection Officer: not currently appointed

13. Changes to this policy

We'll update this policy as the Service and the law evolve, changing the version and last-updated date at the top and giving notice of material changes. Where a change affects data we collect with your consent, we'll seek fresh consent as required.

Related documents: Privacy Policy · Cookie Policy · Terms of Service · Sub-Processor List (/legal/subprocessors).