Consumer Health Data Privacy Policy

About this policy

This Consumer Health Data Privacy Policy applies to the Nimbo app (Nimbo: Your Child's Diary) and the website nimbodiary.com. It is written to meet:

Washington's My Health My Data Act (RCW 19.373);
Nevada's consumer health data law (NRS Chapter 603A, as amended by SB 370 of 2023);
the consumer health data rules of the Connecticut Data Privacy Act (as amended in 2023 and 2025).

We apply it to everyone who uses Nimbo, wherever you live. It adds to our Privacy Policy; if they differ about consumer health data, this policy applies.

Nimbo is run by one person, an independent developer based in Brazil: Jailton Rocha Cardoso, Rua Tomé de Souza, 07, Alto Buenos Ayres, Caetité, BA 46401-534, Brazil. Nimbo has no affiliates. Contact: contato@nimbodiary.com.

Whose data is this? Most of the health data in Nimbo is about a child, and it is entered by the child's parent or caregiver. Children do not use Nimbo. Some data can also be about you, for example a question about how you're coping. We treat both you and your child as the people this policy protects. As the parent or legal guardian, you can give consent and use the rights below for yourself and for your child.

Most of this data never leaves your phone, and we can't see it. We apply this policy to it anyway.

Consumer health data we handle

These are the categories of consumer health data Nimbo handles. Most of it is stored only on your phone; the last column shows what leaves it, and when.

Category	Examples	What leaves your phone
Conditions and age	The conditions you choose to track, such as autism, ADHD, Down syndrome or speech delay; your child's age	Sent with “Organize the day” and “Ask Nimbo”
Therapies and care	Types of therapy, sessions and appointments, professionals' names, roles and phone numbers	Therapy types with both AI features; titles and dates of upcoming appointments with “Ask Nimbo.” Professionals' phone numbers stay on your phone, unless you text them a summary
Medications	Names, doses, times, doses given, supply, prescription expiration	Sent with “Ask Nimbo,” and in a diary entry if you mention them
Behavior and wellbeing	Mood, hard moments (what happened, possible triggers, how they ended), calming strategies, wins	In diary entries you organize; a 7-day summary with “Ask Nimbo”
Sleep and eating	Sleep quality and hours, eating and feeding notes	In diary entries you organize; a 7-day summary with “Ask Nimbo”
Development and school	Goals and their levels, school notes	Goals with both AI features; school notes in diary entries
Voice recordings and text	What you say or type in the diary, which may include any of the above, and your child's name if you say it	Sent when you tap “Organize the day.” The app deletes the recordings from your phone when you leave that screen
Chat	Your questions in “Ask Nimbo” and the answers (up to 100 messages on your phone)	Your question and up to 16 recent messages, with your child's name replaced
Documents and emergency card	Photos and PDFs of evaluations, prescriptions, IEP and 504 plans, insurance or Medicaid cards; allergies, how your child communicates	Nothing, unless you send or show them to someone
Results created at your request	The organized day (summary, mood score, sleep quality), goal suggestions, chat answers	Created by the AI providers and stored only on your phone
Signs that you use Nimbo	Subscription status, an anonymous app ID, the IP address of a connection	RevenueCat (subscriptions) and our server provider. No diary content. Because using a health app can suggest a health interest, we treat this as consumer health data too
Messages to us	Emails you send us, which may include health details	Only what you choose to email us

We do not collect precise location, biometric data or data from wearables. We do not create voiceprints from your recordings.

Where it comes from

From you, the parent or caregiver: what you type, say, select or save in the app, and what you email us.
From your phone: files you choose to save, and calculations the app makes on your device (for example, when a medication will run out).
From our AI providers, only at your request: the organized day and the chat answers.
From the App Store or Google Play, through RevenueCat: whether your subscription is active.

We do not collect health data from your child directly, and we do not buy or receive it from data brokers, other apps or other websites.

Why we use it

We use consumer health data only to provide the features you ask for:

transcribe your recordings and organize your diary entries (with your consent);
answer your questions in “Ask Nimbo” with your child in mind (with your consent);
show summaries, progress and reports, built on your phone;
schedule medication and appointment reminders on your phone;
show the emergency card you create;
manage your subscription, answer your requests, keep the service secure and comply with the law.

We do not use it for advertising, marketing profiles or training AI models, and we do not sell it. We will not use it for any other purpose without telling you first and asking for your consent.

Your rights

You have the right to:

Confirm and access: know whether we collect, share or sell your consumer health data, get access to it, and get a list of all third parties and affiliates we have shared it with, with their contact information. (We have no affiliates and don't share it with third parties; our processors are listed above.)
Delete: have your consumer health data deleted, including by our processors.
Withdraw consent: stop the collection and sharing of your consumer health data, as described in section 6.
Correct and port: fix inaccurate data and get a copy in a portable format.
Not be discriminated against for using any of these rights.

Most of this is already in your hands: your data is on your phone, where you can see it, correct it, export it (My profile → Backup) and delete it (My profile → Delete all my data, which also deletes your saved documents). Our server stores no diary content, so we usually hold nothing of yours besides your subscription record and any emails you sent us.

Deletion at our AI providers. We send OpenAI and Anthropic no name, account or device ID, so neither we nor they can find one person's requests. Instead, they delete them on a fixed schedule: OpenAI doesn't keep audio sent for transcription and deletes chat request logs within 30 days; Anthropic deletes requests within 30 days (or up to 2 years if its safety systems flag one). See section 12. When you ask us to delete your data, we delete what we hold and ask RevenueCat to delete your subscription record.

How to use your rights and appeal

In the app: see, edit, export or delete your data, and withdraw your AI permission, in My profile.
By email: write to contato@nimbodiary.com with the subject “Consumer health data request.” Tell us your state and what you want. You don't need an account.

Verification: to find the few records we may hold, we may ask for the email address you wrote from or the order ID of your App Store or Google Play purchase. We won't ask for more health information than we need.
For your child: as the parent or legal guardian, you can make requests about your child's data. You can also use an authorized agent; we may ask for proof of their authority.
Timing: we will respond within 45 days. If we need more time, we may extend once by up to 45 more days, and we will tell you why within the first 45 days. When you ask us to delete data, we delete what we hold within 30 days after we confirm the request.
Cost: requests are free of charge.

Appeal

If we decline your request, in whole or in part, you can appeal by replying to our answer with the word “Appeal” within 60 days. We will tell you in writing what we decided, and why, within 45 days of receiving your appeal. If we deny the appeal, you can contact your state attorney general:

Washington: Washington State Office of the Attorney General, file a complaint
Nevada: Nevada Office of the Attorney General, consumer complaint
Connecticut: Connecticut Office of the Attorney General
Other states: your state attorney general's consumer protection office.

We don't sell consumer health data

Nimbo does not sell consumer health data, and does not share it for advertising. The app and our website have no advertising pixels or trackers. Because we don't sell it, we have no “authorization to sell” form. If that ever changed, we would first get your valid, signed authorization, as the law requires, and you could revoke it at any time.

No geofencing

Nimbo does not use geofencing. We don't set virtual boundaries around health care facilities, or anywhere else, to identify or track people, collect consumer health data, or send notifications or ads. The app does not collect your location at all.

Security and who can access it

Data sent to the AI features travels over encrypted connections (HTTPS).
Our server processes it in memory and does not save it. Its logs record only technical details, never what you said or wrote.
The keys to the AI providers stay on the server, never inside the app.
Only the person who runs Nimbo can access the server configuration. Anyone who is ever given access to consumer health data will be bound by a duty of confidentiality.
On your phone, the data is protected by your device's own security. Use a passcode or biometrics.

If someone gets your consumer health data without your permission because of a problem on our side or at one of our processors, we will tell you within 60 days of finding out, in the app and on this website, and notify the FTC and other authorities when the law requires it. Nimbo is not covered by HIPAA (it is not a health care provider or health plan); the FTC Health Breach Notification Rule and the state laws above apply instead. See our Privacy Policy.

How long it is kept

On your phone: until you delete it or uninstall the app. Recordings are deleted when you leave the “Tell me about the day” screen.
Our server: not stored; only in memory while your request is processed. Supabase keeps technical logs (no content) for up to 7 days.
OpenAI: audio sent for transcription is not kept. Chat requests may be kept in abuse-monitoring logs for up to 30 days. OpenAI does not use API data to train its models.
Anthropic: deleted within 30 days, or up to 2 years if its safety systems flag a request. Anthropic does not train models on our requests.
Both AI providers: longer only if a law or court order requires it. We don't have a zero data retention agreement with either today.
RevenueCat: while your subscription exists and afterwards as needed for accounting and legal purposes, or until you ask us to delete it.
Emails you send us: as long as needed to answer you, and then up to 24 months after our last message, so we have a record of requests. Then we delete them.

Changes to this policy

We will update this policy before we collect new categories of consumer health data, share it with new kinds of recipients or use it for new purposes, and we will ask for your consent when the law requires it. We will also tell you in the app. The date of the last update is at the top of this page.