Welltory — All-in-One Wellness App.
Welltory — All-in-One Wellness App.
Last updated: April 23, 2026
This Community Privacy Addendum (“Addendum”) supplements Welltory’s Privacy Policy and applies to individuals who: (i) are evaluating whether to join a Welltory Health Community (including completing a Community interest questionnaire or enrollment flow); or (ii) are enrolled members of a Welltory Health Community — in each case to the extent relevant to their stage of participation. It describes what data Welltory Inc. (“Welltory”, “we”, “us” or “our”) collects in connection with Community Services, how Welltory uses it, who has access to it, and what rights you have. In the event of conflict between this Addendum and the main Privacy Policy, this Addendum prevails with respect to Community Services.
Capitalized terms not defined in this Addendum have the meanings given in the Community Terms of Service and Privacy Policy.
This Addendum applies to United States residents only, subject to the Washington State restriction described below. Community Services are not currently available to individuals who reside outside the United States.
Washington State Notice. Community Services are not currently available to residents of Washington State or to individuals accessing Community Services while physically located in Washington State (My Health MY Data Act, Chapter 19.373 RCW). This restriction applies to Community Services only — the core Welltory App remains available to Washington State users.
Enrollment verification. During enrollment, you will be asked to confirm that you are not a resident of Washington State and are not accessing Community Services while physically located in Washington State. By confirming this, you represent that the restriction does not apply to you. Welltory relies on this representation in good faith.
Change of residency. If you become a Washington State resident after enrollment, you must stop using Community Services immediately and notify us at [email protected]. Upon notification, we will close your Community membership and delete or anonymize your Community data, unless we have a legal obligation to retain it. Your core Welltory App data is not affected.
The data controller for personal data processed under this Addendum:
Welltory Inc.
541 Jefferson Avenue, Suite 100
Redwood City, CA 94063, USA
Email: [email protected]
“Community Data” means all personal data and information processed by Welltory in connection with your participation in Community Services. Community Data comprises the following categories, each described in detail below: Community Matching Data, Community Participation Data, Group Case Data, Patient-Reported Outcome (PRO) Data, and Research Data. Different categories are collected at different stages of your membership and are subject to different legal bases, as indicated in each section. Community Data does not include information you provide directly to the Community platform provider (currently Discord) outside of Welltory-operated features, which is governed by that provider’s own privacy policy. References to “Community Data” throughout this Addendum refer to all categories collectively or to the specific category or categories relevant to the context and purpose described.
To assess which Community best fits your health profile, Welltory processes:
Legal basis: Consent
During your Community membership, we process:
Legal basis: Contract performance (operating the Community you subscribed to) and legitimate interests (community safety and integrity).
Within the Community, Welltory may form group cases — de-identified analyses of patterns observed among members who voluntarily agree to participate. Before any specific case, we will ask for your explicit consent describing: what the case is about, which data will be used, and where results may be shared (for example, within the Community, on social media, or on a blog). You may decline any individual case without leaving the Community.
Sharing of group case results on academic preprint servers (such as medRxiv or bioRxiv) is conducted exclusively through Welltory’s IRB-overseen research track (see Research Data below) and is subject to a separate IRB-compliant informed consent. QI-track group cases are shared only within the Community, on Welltory’s blog, or on social media.
If you voluntarily consent to participate in a specific group case, we process the health metrics identified in that specific group case consent (e.g., HRV readings, sleep data for a specified date range), a de-identification record (transformation steps only — not the data itself), and your consent record for that case.
De-identification. Before our Group Health Educator or any third party sees group case data, Welltory removes identifying information and applies de-identification measures, including aggregation of data and removal of all direct identifiers, so that individual data cannot be recovered from the resulting group report.
Minimum group size thresholds vary by intended use, as set out in the table below. We will specify the applicable threshold in the per-case consent you receive.
| Use case | Minimum N |
|---|---|
| Internal review by Group Health Educator only | N ≥ 7 |
| Sharing within the Community | N ≥ 10 |
| External publication (preprint servers, social media, blog posts) | N ≥ 20 |
For external publication tracks, Welltory additionally applies removal of all 18 categories of direct identifiers prior to sharing.
Legal basis: Consent, obtained separately for each group case
Welltory may offer optional PRO questionnaires within the Community (e.g., symptom severity scales, quality-of-life measures). These are always voluntary and never required for continued membership. Data collected includes self-reported symptom scores, functional limitations, and energy levels, as specified per questionnaire.
Legal basis: Consent
Anonymized aggregate research. Welltory may use anonymized, aggregated Community data — from which no individual can be identified — for internal product improvement, scientific publications, and educational materials. This processing does not involve your personal data and does not require your consent.
IRB-regulated research. If Welltory initiates a formal research study subject to Institutional Review Board (IRB) oversight, you will receive a separate, full IRB-compliant consent form (Informed Consent Form) before any of your personal data is included. Participation in any such study is entirely voluntary and separate from your Community membership.
Legal basis: Legitimate interests (anonymized aggregate research — no personal data involved); explicit consent (IRB-regulated research involving personal data).
We use Community data for the following purposes:
Community matching and recommendation. We use your matching data to assess which Community best fits your health profile and to recommend a Community or place you on a waitlist.
Operating and improving Community Services. We use your Community participation data to operate the Community, including but not limited to delivering content, facilitating group Q&A sessions, and improving the Community experience.
Safety and moderation. We monitor Community channels to detect prohibited content and crisis signals, to protect the safety of all members, and to enforce Community Guidelines.
Group cases. Where you separately consent, we use your health data to generate anonymized, aggregated group case reports for educational purposes.
Research. With your separate consent, as described above, we may use your data for research and scientific publication.
Analytics. We share certain Community activity data with our service providers for analytics purposes, under Data Processing Agreements that prohibit those providers from using your data for their own purposes.
Use of anonymized and aggregated data. We may use anonymized, aggregated Community data — from which no individual can be identified — to improve Community Services and the Welltory App, to develop new features, and for scientific and educational publications. Where such use involves personal data prior to anonymization, it is subject to your explicit consent as described above.
All processing of your identifiable health data described above is based on your explicit consent, except where indicated otherwise. Processing of anonymized, aggregated data does not constitute processing of personal data and is not subject to consent requirements. You may withdraw your consent to the processing of your identifiable data at any time as described in the Your Data Privacy Rights section below.
We do not sell your Community data. We disclose it only as described below.
Welltory uses artificial intelligence to support two core functions within the Community: facilitation and moderation. Both functions are powered via the OpenAI API — OpenAI OpCo, LLC (Privacy Policy) and Claude API — Anthropic, PBC (Privacy Policy) — under Data Processing Agreements that prohibit OpenAI and Anthropic from using Community data to train or improve their models.
Moderation AI processes only the text content of messages posted to Community channels, together with minimal metadata (timestamp and channel identifier, but not member display names or profile data). No member’s individual App health data (such as HRV readings, sleep metrics, or activity data) is transmitted to AI providers for moderation purposes.
Facilitation AI receives only de-identified, aggregated group case data (e.g., population-level HRV distributions for N ≥ the applicable minimum threshold of consented participants). No individual member’s identifiable health data is transmitted to AI providers. AI providers do not retain Community data beyond the retention period specified in our Data Processing Agreements. The AI does not provide medical advice and does not make binding decisions autonomously — see Human Oversight below.
Community facilitation. Facilitation AI assists in forming anonymized group cases from confirmed member contributions (using only de-identified, aggregated data as described above), generating structured summaries for educational review by Welltory’s Group Health Educators.
Content moderation. Community channels are monitored in real-time by an AI moderation system that: detects crisis signals and automatically publishes crisis resource messages (988, 911, Crisis Text Line); detects and flags prohibited content for human review; and appends mandatory disclaimers to posts of Welltory’s Group Health Educators. Where AI-generated messages are published in channels — such as crisis resource prompts — they are clearly identifiable as automated responses, not communications from a human.
Human oversight. AI flags and moderation actions are reviewed by human moderators before any enforcement action is taken against a member. No member’s access to Community Services is restricted solely on the basis of an automated decision. If you believe a moderation action was taken in error, you may contact [email protected] to request a review.
Limitations. AI moderation is designed to support — not replace — human judgment. The system may occasionally miss content that should be flagged, or flag content incorrectly. Welltory does not guarantee that all harmful or prohibited content will be detected and removed.
Community Services are currently hosted on Discord (Discord Inc.). Discord processes your Community activity data as a data processor under a Data Processing Agreement with Welltory.
Discord also acts as an independent data controller for your Discord account generally. Welltory has limited control over processing performed by Discord in its capacity as an independent data controller. Discord’s privacy practices are described in Discord’s Privacy Policy.
Important: Community messages and files are stored on Discord’s servers, not Welltory’s servers. Do not post personally identifiable medical information in any Community channel — including medical records, insurance numbers, Social Security Numbers, prescription details, or identifying photos. Welltory recommends using a pseudonym as your Community display name. Contact [email protected] immediately if you accidentally share such information.
Deletion of Discord data. When your Community membership ends or you request deletion of your Community data, Welltory will remove your access to the Community Discord server. However, messages and files you have posted in Community channels are stored on Discord’s servers and subject to Discord’s data retention policies. To request deletion of your message history from Discord’s servers, you must contact Discord directly via channels specified in Discord’s Privacy Policy or use Discord’s own account deletion tools. Welltory cannot delete data held by Discord in its capacity as an independent data controller.
We share Community data with third-party service providers (such as analytics, infrastructure, and customer support providers) who process data on our behalf under Data Processing Agreements. These agreements prohibit service providers from using your data for their own commercial purposes.
We may disclose your data if required to do so by law, court order, or governmental authority; to protect the rights, property, or safety of Welltory, our members, or others; or in connection with a merger, acquisition, or sale of assets, in which case we will notify you of any material changes to data handling.
Welltory applies the technical and organizational security measures described in the main Privacy Policy to all Community data, including but not limited to encryption in transit and at rest, role-based access controls, vulnerability management, and annual external audits.
Community-specific considerations: messages and files shared in Community channels are transmitted to and stored on Discord’s servers, and are subject to Discord’s own security practices in addition to Welltory’s. Content processed by the OpenAI API and Claude API for moderation and facilitation purposes is transmitted over encrypted connections under contractual data protection obligations. Welltory does not store the outputs of AI moderation beyond what is necessary for safety and compliance purposes.
While we take these measures seriously, no system is entirely immune from security risks. We cannot guarantee that unauthorized access, disclosure, or loss will never occur. You can reduce risk on your end by using a strong, unique password, enabling two-factor authentication on your account, and not posting personally identifiable medical information in Community channels.
We retain your Community data for as long as your Community membership is active or as needed to provide you with Community Services, comply with our legal obligations, resolve disputes, and enforce our agreements with you. When Community data is no longer needed for these purposes, we delete or anonymize it.
If you complete the community matching process but do not subscribe, your matching data is deleted or anonymized within 90 days after your last interaction with the enrollment flow.
You may request deletion of your Community data at any time by contacting [email protected]. We will honor your request unless we have a legal basis or obligation to retain the data — for example, to comply with applicable law, to resolve a pending dispute, or to enforce our agreements. Note that anonymized group case reports cannot be recalled once finalized, as individual contributions are not recoverable from finalized reports.
Deletion of your Community data does not affect your Welltory App data.
You have the following rights in relation to your Community data, in addition to all rights described in Welltory’s main Privacy Policy. Additional rights may apply depending on your jurisdiction — see the jurisdiction-specific sections below.
Right to Access. You may request a copy of all personal data Welltory holds about you in connection with Community Services — including community matching data, Community participation data, group case consent records and contributions, PRO questionnaire responses, and research participation records, depending on your level of involvement.
Right to Correction. You may request correction of inaccurate Community data Welltory holds about you — including community matching data, PRO questionnaire responses, and participation records. You may update certain information directly through your Community profile; for other corrections, contact [email protected].
Right to Deletion. You may request deletion of your Community data. Note that anonymized group case reports cannot be recalled once finalized, and moderation logs may be retained for legal purposes. Deletion of Community data does not affect your core Welltory App data or Energy Profile.
Right to Data Portability. You may request a machine-readable export of your Community data.
Right to Withdraw Consent. You may withdraw any consent given in connection with Community Services at any time. Withdrawal does not affect processing already completed:
Right to Human Review of Automated Decisions. Where an AI moderation system has contributed to an enforcement action against you (such as content removal or access restriction), you have the right to request that the decision be reviewed by a human moderator. To exercise this right, contact [email protected] with a description of the action you wish to have reviewed.
California Residents (CCPA/CPRA). Community matching data, participation data, and group case data constitute Sensitive Personal Information under CCPA/CPRA, processed under your explicit consent. You have the right to limit Welltory’s use of your Sensitive Personal Information to purposes necessary to provide the Community Services you requested. To exercise your right to limit use of Sensitive Personal Information, submit a written request to [email protected] with the subject line “Limit SPI Use — Community.” Welltory will respond within 45 days of receiving your verifiable request, as required by CPRA. A preference center for managing these choices will be made available in a future update. Welltory does not sell or share your Community health data for cross-context behavioral advertising. For full details on your California privacy rights, see the California section of Welltory’s main Privacy Policy or contact [email protected].
Welltory may update this Addendum from time to time. We always indicate the date the last changes were published. If changes are significant, we will provide a more prominent notice as required by law, such as by emailing you or highlighting the changes within the Community.
If you have any questions, concerns, or complaints about this Addendum or the processing of your personal data in connection with Community Services, please contact us at [email protected].
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