Privacy Policy for RLS Coach

Effective Date: June 15, 2025

Welcome to RLS Coach (the “App”), developed by SaguaroBytes LLC (“we,” “us,” or “our”). We know how personal the data you log can be, and we’re dedicated to keeping it private. This Privacy Policy explains how we handle your information when you use our App.

Please read this Privacy Policy carefully.

1. Our Commitment to Your Privacy

Our main goal is to protect your privacy and give you control over your data.

• For Free Users (Those Not Using the AI Coach): If you only use the free parts of the App and don’t activate the personalized RLS Coach, all the information you log stays only on your device, unless synchronized to your personal iCloud (see Section 2.A.2). We do not collect, store, or see any of your personal or health data from your device in this mode. We also don’t use analytics, crash reporting, or send any data to our systems for these users.
• For AI Coach Users: If you choose to activate and use the personalized RLS Coach feature, some of your logged data will be securely sent from your device for analysis, as explained in Section 3. We’ll ask for your clear, explicit permission before this data is sent.

2. What Information We Handle (and When)

The type of information we handle depends on how you use the App:

A. Information on Your Device & iCloud (For All Users, including Free Users):

The App lets you record different details about your health and daily life. This information is primarily stored on your device and, if enabled, synchronized to your personal iCloud. We do not access this data unless you explicitly choose to activate the AI-powered RLS Coach feature (see Section 2.B). This information might include:

• Activities: What physical activities you do (like exercise type, how long, how intense).
• Food & Drinks: What you eat and drink.
• Supplements: Any supplements you take.
• Sleep Quality: Details about your sleep patterns and how well you sleep.
• RLS Symptoms: Records of your Restless Legs Syndrome (RLS) experiences (like how severe or often they happen).
• On-Device Reports: Any summaries or insights the App creates directly on your device based on your logged information.

A.1. Local Device Storage: All the information listed above is stored locally on your device in a secure database.

A.2. iCloud Sync: If you have iCloud enabled on your device, the RLS Diary Data you log in the App may be automatically synchronized to your private iCloud account via Apple’s service. This means your data is stored in your personal iCloud, managed by Apple, and can be accessed across your devices. We do not store or have access to this synchronized data on our systems. Apple’s privacy policy governs the data stored in your iCloud account.

B. Information Handled When You Use the RLS Coach AI Feature:

If you choose to activate and use the AI-powered RLS Coach feature, the following information is securely sent from your device and processed by us:

• Your RLS Diary Data (for AI Analysis): A package of your logged information from the last 30 days (your activities, food, drinks, supplements, sleep quality, and RLS symptoms) will be sent from your device to our secure systems. This information may contain health details.
• Anonymous ID: An anonymous, unique identifier (UID) is created by our system for your app’s internal use when you first use the RLS Coach. This ID helps us keep track of your session and link the RLS Coach’s responses to you, without revealing who you are personally. This ID is not directly tied to your real-world identity.
• RLS Coach Advice (AI Output): The recommendations, insights, next steps, and advice that the RLS Coach generates after analyzing your submitted RLS Diary Data.

3. How We Use and Process Information (When You Use the RLS Coach AI Feature)

The information described in Section 2.B is handled primarily to provide you with the personalized RLS Coach feature and its insights.

When you use the RLS Coach:

• Your RLS Diary Data (which may contain health information) is sent from your device to our secure backend systems. Our lawful basis for processing this sensitive health data for the RLS Coach feature is your explicit consent, which we obtain before you enable and submit data to this feature.
• Our systems use advanced technology to analyze your data and find connections and patterns related to your RLS symptoms and lifestyle.
• This technology then creates personalized recommendations, insights, and advice (“RLS Coach Advice”).
• This RLS Coach Advice (cleaned up to just show the important parts) is then saved temporarily on our systems, linked to your anonymous ID. Once your device successfully retrieves the report, this temporary copy is automatically deleted from our systems by your device. We do not save your original RLS Diary Data (the information you send for analysis) on our systems after the analysis is done; that original information stays only on your device.
• Improving the AI Coach: We may also use the RLS Coach Advice (the AI-generated insights, not your original logged diary data) in an anonymized and aggregated form for our internal analysis. This means we remove any information that could directly or indirectly identify you and combine it with data from many other users. This anonymized information helps us understand patterns, improve the App’s features, and refine the AI Coach’s performance. This anonymized data cannot be linked back to you.

Purpose of Handling: The only reasons we handle this information are to give you the personalized RLS Coach service, helping you understand possible triggers, improvements, and strategies for your RLS, and to improve the App itself for all users.

4. How We Share Information

We don’t sell your personal data. We don’t share your personal data with other companies for marketing or advertising.

When you use the RLS Coach, we share your RLS Diary Data and anonymous ID with trusted service providers who help us run our systems and provide the AI analysis. They are required to protect your information and only use it for the purposes we’ve authorized.

We ensure that these service providers are bound by strict data processing agreements that uphold your privacy and data security standards.

5. Data Security

We use strong technical and organizational measures to protect your information from accidental or unauthorized access, loss, changes, or disclosure. This includes:

• Secure Data Transfer: We encrypt data when it’s sent between your device and our systems, and when it’s sent to our analysis technology.
• Secure Temporary Storage: We use secure methods for the temporary storage of your RLS Coach Advice on our systems.
• Controlled Access: Only authorized personnel have access to our systems and your data.

Important Note: While we work hard to protect your data, no internet transmission or electronic storage method is 100% secure. So, we can’t guarantee its absolute safety.

6. Data Retention

• On-Device Data: Information you log on your device stays there until you delete the App, clear its data, or remove specific entries yourself.
• iCloud Data: Data synchronized to your personal iCloud account is retained according to your iCloud settings and Apple’s policies.
• RLS Coach Advice (on our systems, linked to your anonymous ID): The RLS Coach advice linked to your anonymous ID is stored temporarily on our systems until your device successfully pulls the report, which is immediately after the report has been produced.
• Anonymized Data for App Improvement: Anonymized and aggregated RLS Coach Advice, which cannot be linked back to you, may be retained for longer periods to help us continually improve the RLS Coach App.

7. Your Data Rights

Depending on where you live (e.g., in the European Union/EEA or California, USA), you might have certain rights regarding your personal data. These rights may include:

• Right to Access: You can ask to see the RLS Coach advice linked to your anonymous ID.
• Right to Correct: You can ask us to fix any incorrect data.
• Right to Delete (“Right to Be Forgotten”): You can ask us to delete any temporary RLS Coach advice stored on our systems before your device pulls it, and to delete your anonymous ID. Note that once data is truly anonymized, it cannot be linked back to you and therefore cannot be deleted or accessed as personal data.
• Right to Limit Processing: You can ask us to limit how we use your data.
• Right to Data Portability: You can ask to receive your data in a common, machine-readable format.
• Right to Object: You can object to us processing your personal data.

To use any of these rights for the RLS Coach advice handled by our systems or your anonymous ID, please contact us at support@saguarobytes.com. We may need you to provide your anonymous to fulfill your request.

8. Children’s Privacy

The App isn’t meant for children under 18. We don’t knowingly collect personal data from anyone under 18. If we find out we’ve accidentally received personal data from a user under 18 without a parent’s permission, we’ll remove that information from our records.

9. International Data Transfers

If you’re in the European Union or other regions with data protection laws, please know that when you use the RLS Coach feature, your data might be sent to, stored, and processed in the United States, where our service providers are located. Data protection laws in these countries might be different from yours. We ensure that proper safeguards, like standard contractual clauses, are in place with our service providers to protect your data as required by law.

10. Important Disclaimers (Not Medical Advice)

The RLS Coach App, including its personalized AI-powered RLS Coach feature, is for informational and educational purposes only. It is NOT meant to provide medical advice, diagnosis, or treatment. The insights, recommendations, and information given by the RLS Coach are created by AI and should not be used as a substitute for professional medical advice from a qualified healthcare provider.

Always talk to your doctor or another qualified health provider if you have any questions about a medical condition. Never ignore professional medical advice or delay getting help because of something you’ve read in this App.

11. Changes to This Privacy Policy

We might update this Privacy Policy from time to time to reflect changes in how we operate or for legal reasons. We’ll let you know about any big changes by posting the new Privacy Policy in the App and/or on our website https://rlscoach.health (if applicable). If you keep using the App after we make changes, it means you accept the updated Privacy Policy.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle data, please contact us at:

support@saguarobytes.com