Consumer Health Data Privacy Policy

Effective date: September 4th 2026



This policy applies to residents of Washington and Nevada, and to anyone whose consumer health data is collected in those states. It explains how BonTriage, Inc. ("we," "us") handles consumer health data in the Migraine Mentor app. It supplements our Privacy Policy; where the two differ as to consumer health data, this policy controls.



What consumer health data means

Washington and Nevada define consumer health data broadly. It covers information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status — including conditions and symptoms, treatments and medications, bodily functions and vital signs, use of health care services, and health information inferred from other data. It is broader than the information a doctor or hospital holds.

For Migraine Mentor, essentially everything you log in the app is consumer health data.



What we collect, and why

CategoryExamplesWhy we collect it
Migraine and symptom dataAttack dates, times, and duration; pain severity and location; aura; nausea; light and sound sensitivityTo build your headache history and show you patterns over time
Medication dataMedications you take, doses, timing, effectiveness, side effectsTo track what you have taken and provide reminders at your request
Trigger and lifestyle dataSleep, stress, meals, caffeine, alcohol, screen time, exercise, weather sensitivity, menstrual cycleTo help you identify what precedes your attacks
Health background you provideDiagnoses, other conditions, care you receiveTo tailor the app to your situation
Reports you generate or exportSummaries you create to share with a clinicianTo let you take your data to appointments
Health-related device dataHealthkit, Google FitTo help you better predict the onset and lifecycle of a headache
Account data linked to the aboveName, email, date of birth, account identifiersTo keep your health data attached to your account and secure
Support communicationsWhat you tell us when you contact supportTo answer your question
App usage and diagnostic data linked to health featuresWhich features you use, crash reportsTo keep the app working and improve it

We do not collect precise geolocation data.

We do not collect any category of consumer health data not listed above. If we want to collect a new category, or use what we already have for a new purpose, we will ask for your consent first.



Where the data comes from

  • Directly from you, when you log entries, complete your profile, or contact support.
  • From your device, when you grant permission: HealthKit, Health Connect.
  • Generated by us, when the app infers patterns from what you have logged (for example, identifying a possible trigger correlation). These inferences are also consumer health data.
  • Public weather sources, keyed to your general location (not precise enough for identification or geolocation), when available.

We do not buy consumer health data from data brokers or other third parties.



How we use it

We use consumer health data to:

  • provide the tracking, history, insight, and reporting features you asked for;
  • generate reports you choose to export or share;
  • send you reminders and notifications you have turned on;
  • provide customer support when you contact us;
  • keep the app secure and detect fraud, abuse, and security incidents;
  • diagnose and fix technical problems; and
  • comply with legal obligations.

We do not use consumer health data for advertising, marketing, or profiling for advertising purposes. With your separate permission, we de-identify your health data and use it to improve Migraine Mentor's insights. We do not attempt to re-identify it and require the same of anyone we share it with. You can decline or withdraw any time by emailing support@bontriage.com.



What we share, and with whom

We share consumer health data only in these circumstances:

What we shareWho receives itWhy
The categories in Section 2Amazon Web ServicesTo store and run the service
Reports you choose to shareThe recipient you selectBecause you asked us to
Any category, if legally compelledLaw enforcement, courts, regulatorsTo comply with a valid legal demand

Affiliates. We do not share consumer health data with any affiliate.

We do not share consumer health data with advertising networks, data brokers, or social media platforms.



We do not sell your consumer health data

We do not sell consumer health data, and we will not sell it without first obtaining your separate, signed written authorization that meets the requirements of Washington and Nevada law.



Your rights

If you are a Washington or Nevada resident, you have the right to:

  • Know and access — confirm whether we are collecting, sharing, or selling your consumer health data, and get a copy of it, including a list of all third parties and affiliates we have shared it with and how to contact them.
  • Delete — have your consumer health data deleted from our systems. Washington law provides this right without exception other than our inability to verify your identity. We will honor it.
  • Withdraw consent — withdraw your consent to our collection or sharing of your consumer health data at any time.
  • Appeal — appeal if we decline a request.

We will not discriminate against you, deny you the service, or charge you differently for exercising these rights.



How to exercise your rights

Submit a request by email to support@bontriage.com.

What happens next. We will verify your identity using a key on the app. We will respond within 45 days of receiving your request. If we need more time, we will tell you within that period and take up to 45 additional days.

For deletion requests. Once we verify your identity, we will delete your consumer health data from our active systems within 30 days. We will notify every service provider, affiliate, and third party we shared it with and instruct them to delete it as well. Data held in backups and archives will be deleted within six months, which is the outer limit permitted by Washington law. We will confirm to you when deletion is complete.

Where the law requires us to retain specific records, we will keep only those records, only for as long as required, and we will not use them for any other purpose. We will tell you if this applies to your request.

Appeals. If we decline your request, you may appeal by writing to support@bontriage.com. We will respond in writing within 45 days, explaining our reasoning. If we deny your appeal, we will give you a way to complain to the Washington Attorney General at https://www.atg.wa.gov/file-complaint or the Nevada Attorney General at https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/.

Requests are free. We may charge for or decline excessive requests beyond two in a 12-month period.



Security

We maintain administrative, technical, and physical safeguards for consumer health data that meet the standard of care in our industry, taking into account the volume and sensitivity of the data we hold. We restrict access to consumer health data to those employees and service providers who need it to do their jobs.



Geofencing

We do not use geofencing around any facility that provides in-person health care services. We do not use location to identify or track anyone seeking health care, or to send them advertising related to their health.



Changes

If we change this policy, we will post the updated version here and update the effective date. If we want to collect a new category of consumer health data, or use or share it for a purpose not described above, we will obtain your consent before doing so.



Contact

BonTriage, Inc., 3226 Playa Court, Oxnard, CA 93035, support@bontriage.com