This Consumer Health Data Privacy Policy is provided in compliance with the Washington My Health My Data Act (RCW 19.373) and similar state consumer health data laws. It describes how XtrkR handles consumer health data in connection with the app’s local-storage architecture and limited optional features. This policy supplements, and does not replace, the general Privacy Policy.
XtrkR is operated by De Nihil LLC, a Wyoming limited liability company. In this policy, “I” and “my” refer to De Nihil LLC.
XtrkR is built so that the consumer health data you enter in the app is stored locally on your iPhone, not on servers I operate. I do not maintain a server-side copy of that data, and I do not have technical access to the health records you store in XtrkR. The categories of health data you may enter into XtrkR on your own device include:
This data is entered by you and is designed to remain on your device unless you choose to use an optional feature described in Section 3 or you choose to export, back up, or share information yourself.
XtrkR is built so that consumer health data you enter in the app is processed locally on your device, not on servers I operate. That local processing supports app functions such as insights, reminders, charts, and similar features. I do not use your consumer health data for advertising, analytics, profiling, or other commercial purposes outside the app’s local functionality.
I do not share your consumer health data for advertising, profiling, or other commercial purposes.
Two Apple services may process limited, non-health data when you use specific features:
| Service | What is processed | Is health data shared? | Your control |
|---|---|---|---|
| Apple StoreKit | Purchase transaction for paid feature unlock (Core or XtrkR+ subscription) | No | Triggered only when you make a purchase |
| Apple MapKit | GPS coordinates for reverse-geocoding (city name lookup) | No — the MapKit request is for location lookup only, not to share your health records with me | Triggered only when you add a location to an encounter; you can skip this entirely |
If you choose to enable the optional encrypted backup feature, your data is encrypted on your device with a password you set, and the encrypted backup file is stored in your personal iCloud Drive. I cannot decrypt or access that file. Apple’s iCloud terms apply to storage of the encrypted backup file.
All consumer health data in XtrkR comes from one source: you. You manually enter all data. XtrkR does not obtain health data from any other source — no health systems, no data brokers, no APIs, no partners, no public records.
Because of XtrkR’s on-device architecture, the records you enter are available to you directly in the app and on your device.
If you have questions about this policy, contact me at: hello@xtrkrapp.com
By using XtrkR, you consent to the handling of consumer health data as described in this policy, which in practice means local processing on your device for the app’s features and functions.
For optional features that may involve Apple services or storage outside the app’s local environment:
I do not sell your consumer health data or provide it to third parties for advertising or analytics purposes.
I do not use geofencing technology. XtrkR does not track your real-time location, monitor your proximity to any location, or identify when you enter or leave any area — including health care facilities.
The optional encounter location feature allows you to manually tag an encounter with a location. This is user-initiated, user-controlled, and stored only on your device.
XtrkR carries a 17+ rating on the Apple App Store. To use XtrkR, you must be at least 18 years old — on first launch, the app prompts for your date of birth and will not unlock until you reach 18. I do not knowingly process consumer health data from anyone under 18.
If I materially change how consumer health data is handled, I will update this policy and notify users via in-app notification before the change takes effect.
Ed — Solo Founder
XtrkR
De Nihil LLC
Email: hello@xtrkrapp.com
Website: xtrkrapp.com