PRIVACY POLICY

Effective Date: June 1, 2026Last Modified: June 1, 2026

Introduction

Lisah (“Lisah,” “we,” “us,” or “our”) is a consumer health information platform that helps women understand how hormonal changes influence mood, cognition, energy, sleep, and physical symptoms over time. We translate user-reported signals, optional wearable data, and scientific research into explanations, pattern recognition, near-term forecasting, and lifestyle-level guidance. Lisah is designed to make women’s biology legible – not to medicalize it. We support women across all lifestages, including puberty, cycling years, postpartum, perimenopause, and menopause. This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you access or use the Lisah mobile application and any related services (collectively, the “App”). This Privacy Policy is incorporated into and forms part of the Lisah Terms of Use (“Terms”).

IMPORTANT: LISAH IS A CONSUMER WELLNESS AND EDUCATION PLATFORM. IT IS NOT A MEDICAL DEVICE, DIAGNOSTIC TOOL, TREATMENT SYSTEM, OR EMERGENCY SERVICE. LISAH DOES NOT PROVIDE MEDICAL DIAGNOSES, PRESCRIBE MEDICATIONS, PERFORM CLINICAL RISK SCORING, OR PROVIDE EMERGENCY CARE. IF YOU ARE EXPERIENCING A MEDICAL OR MENTAL HEALTH EMERGENCY, PLEASE CALL 911, YOUR LOCAL EMERGENCY NUMBER, OR THE 988 SUICIDE & CRISIS LIFELINE IMMEDIATELY.

What Lisah Is and What Lisah Is Not

What Lisah Is

  • A consumer wellness and education platform
  • A personalized insight and forecasting tool that uses pattern recognition to help you understand your body
  • A decision-support system for daily life – not for clinical decisions

What Lisah Is Not

  • A medical device (as defined by the FDA or any comparable regulatory authority)
  • A diagnostic tool or treatment system
  • A fertility or pregnancy product
  • A replacement for a licensed clinician, physician, therapist, or other healthcare provider
  • An emergency service of any kind

Lisah Does Not:

  • Provide medical diagnoses of any condition or disease
  • Prescribe, recommend, or dispense medications
  • Perform clinical risk scoring or clinical decision support
  • Provide emergency care or crisis intervention
  • Integrate with electronic health records (EHRs) or clinical providers
  • Collect, store, or transmit Protected Health Information (PHI) as defined under HIPAA

All insights, forecasts, and guidance provided by Lisah are for informational and educational purposes only. They are not a substitute for professional medical advice, diagnosis, or treatment.

Our Health Privacy Principles

Lisah is built on four foundational privacy principles:

  • a) Data Minimization. We collect only the data necessary to deliver personalized insights. Accounts are anonymous or pseudonymous by default.
  • (b) On-Device Processing. Where technically feasible, data processing occurs on your device rather than on our servers.
  • (c) Transparency and Control. You control what data you share. All data inputs are optional. You can view, export, and delete your data at any time. Consent choices are granular, revocable, and clearly presented.
  • (d) Security by Design. We implement industry-standard encryption, access controls, and security practices. See Section 16 for details.

Data We Collect

Lisah collects data in the following manner. You choose what to share.

(a) User-Reported Signals and Data

You may voluntarily log the following signals through taps, short text entries, or voice input:

  • Mood (e.g., calm, anxious, irritable, content)
  • Energy level
  • Sleep quality and duration
  • Stress level
  • Pain (e.g., headache, cramps, joint pain)
  • Focus and cognitive clarity
  • Cycle-related observations (e.g., period start/end, flow intensity)
  • Other symptoms you choose to log

All user-reported signals are voluntarily provided. You may skip any input at any time.

(b) Wearable and Device Data

If you connect a compatible wearable, Lisah may receive:

  • Sleep metrics (duration, stages, restfulness)
  • Heart rate and heart rate variability
  • Skin temperature trends
  • Physical activity and step count
  • Other metrics supported by the connected device

Compatible platforms: Oura, Apple Health, Fitbit. Connections are optional and revocable.

(c) Scientific Knowledge Layer

Lisah uses peer-reviewed research and public medical guidelines. This is not personal data.

(d) Technical and Device Information

  • Device type, operating system, and app version
  • Randomized internal user identifier (not linked to real identity)
  • App usage events (with consent – see Section 9)
  • Crash logs and performance data

We do not collect IDFA or any advertising identifier. Apple ATT does not apply to Lisah.

Data We Do NOT Collect

We explicitly do not collect:

  • Legal names, first names, or surnames
  • Home or mailing addresses, physical location data
  • Phone numbers
  • Dates of birth or exact age
  • Social Security numbers or government IDs
  • Insurance information, policy numbers, or coverage details
  • Medical record numbers or patient identifiers
  • Clinical diagnoses, lab results, or test results
  • Prescriptions, medications, or dosage information
  • Physician notes, clinical assessments, or treatment plans
  • Electronic health records (EHRs) or clinical provider data
  • Payment card numbers (app store handles payments)

How We Use Your Data

  • (a) Personalized Insight Generation. To generate personalized explanations of how hormonal patterns influence mood, cognition, energy, sleep, and physical symptoms.
  • (b) Pattern Recognition. To identify trends, cycles, and recurring patterns in your data.
  • (c) Near-Term Forecasting. To generate short-term predictions about upcoming symptom patterns based on your historical data and scientific models.
  • (d) Lifestyle-Level Guidance. To provide actionable, non-clinical suggestions related to sleep, nutrition, exercise, and stress management.
  • (e) Product Improvement. To improve accuracy, functionality, and user experience.
  • (f) Anonymous Analytics (With Consent). With your explicit consent (Section 9), anonymized product-usage events. No health data in the analytics stream.
  • (g) Aggregate Model Learning (With Separate Consent). With separate consent (Section 10), de-identified symptom and cycle patterns to improve global prediction models. Personal insights work the same either way.

Consumer Health Personal Data – State Law Compliance

This section addresses compliance with various state privacy and medical health privacy laws, including, but not limited to:

  • Washington My Health My Data Act, Wash. Rev. Code § 19.373 et seq.
  • Nevada SB 370 (consumer health data privacy)
  • Maryland Online Data Privacy Act (MODPA), Md. Code Ann., Com. Law § 14-4601 et seq.
  • Connecticut Public Act No. 23-56 (health data provisions)
  • Comparable state consumer health data privacy statutes

(a) Categories of Consumer Health Data Collected

  • Self-reported symptom data: mood, energy, sleep, stress, pain, focus, cycle observations
  • Wearable-derived biometric data: sleep metrics, heart rate, HRV, skin temperature, activity (if connected)
  • Inferences: pattern recognition outputs, trend analyses, forecasts

(b) Sources

  • Directly from you (voluntary self-reporting)
  • Wearable devices you connect (Oura, Apple Health, Fitbit)
  • Generated internally by Lisah’s algorithms

(c) Purposes

  • Core App services: insights, pattern recognition, forecasting, guidance
  • Model improvement (only with separate consent per Section 10)
  • NOT used for advertising, third-party marketing, or sale to data brokers

(d) Disclosures

Lisah does not sell consumer health data. Shared only with:

  • Infrastructure service providers under strict contractual obligations
  • As required by law or valid legal process

(e) Your Rights

  • Confirm whether we collect/share your consumer health data
  • Access your consumer health data
  • Withdraw consent to collection or sharing
  • Delete your consumer health data
  • Receive notice and provide prior consent before any collection beyond this Policy

Contact: privacy@lisah.com or in-app settings.

California Consumer Privacy Act (CCPA) Compliance

This section provides the disclosures required under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), Cal. Civ. Code § 1798.100 et seq. The information below covers the preceding twelve (12) months. The following table describes the categories of personal information we collect, using the CCPA’s enumerated categories under § 1798.140(v), along with examples, sources, purposes, disclosure recipients, and whether each category is sold.

CategoryExamplesCollected?SourcesBusiness / Commercial PurposeDisclosed ToSold?
A. IdentifiersRandomized internal user ID; optional account-recovery email address; IP address; device identifiersYesFrom user (optional email at account setup); automatically (IP address, device ID)Account management; service delivery; security; analytics (with consent per §9)Infrastructure service providersNo
B. Customer Records (Cal. Civ. Code §1798.80(e))Name, address, SSN, insurance, payment card number, bank accountNoN/AN/AN/AN/A
C. Protected Classification CharacteristicsLife-stage selection (e.g., perimenopause, postpartum, cycling years); sex/gender (implied by platform focus on women’s health)Limited; voluntarily providedDirectly from user (life-stage selection during onboarding)Personalized, stage-appropriate insight generation and pattern recognitionNot disclosed to third partiesNo
D. Commercial InformationPurchase records, consuming historiesNo (app store handles purchases; Lisah does not receive payment data)N/AN/AN/AN/A
E. Biometric InformationHeart rate; heart rate variability (HRV); skin temperature trends; sleep stages and durationYes (optional; only if wearable connected)From wearable devices user connects (Oura, Apple Health, Fitbit)Pattern recognition; forecasting; insight generationInfrastructure service providersNo
F. Internet or Other Electronic Network ActivityApp usage events (screen usage, feature adoption, session duration); crash logs; performance dataYes (analytics require consent per §9)Automatically from the AppProduct improvement; quality assurance; performance monitoring; bug fixesInfrastructure service providersNo
G. Geolocation DataPrecise or approximate geographic locationNoN/AN/AN/AN/A
H. Audio, Electronic, Visual, or Similar InformationVoice input for symptom logging (only if user chooses voice entry method)Yes (optional; only if voice input used)Directly from user (voluntary voice logging)Natural language processing for symptom logging; insight generationInfrastructure service providers (for processing)No
I. Professional or Employment-Related InformationJob title, employment history, employerNoN/AN/AN/AN/A
J. Non-Public Education Information (per 20 U.S.C. §1232g; 34 C.F.R. Part 99)Education records, grades, transcriptsNoN/AN/AN/AN/A
K. Inferences Drawn from Personal InformationCycle trends; mood patterns; energy forecasts; symptom predictions; sleep pattern analysis; productivity/cognitive metricsYes (derived internally)Derived from Categories A, C, E, F, and H abovePersonalized insights; pattern recognition; near-term forecasting; lifestyle guidance; aggregate model learning (with separate consent per §10)Infrastructure service providersNo
L. Sensitive Personal InformationSelf-reported health symptoms (mood, energy, sleep, stress, pain, focus, menstrual cycle data); wearable health metrics (heart rate, HRV, temperature); optional account-recovery emailYesDirectly from user (voluntary self-reporting); wearable devices (if connected); user-provided email (optional)Core App services: insight generation; pattern recognition, forecasting, lifestyle guidanceInfrastructure service providersNo

(c) Sale of Personal Information

Lisah does not sell personal information as defined under CCPA § 1798.140(ad). No category of personal information listed above has been sold in the preceding twelve (12) months or at any time.

(d) Sharing for Cross-Context Behavioral Advertising

Lisah does not share personal information for cross-context behavioral advertising as defined under CCPA § 1798.140(ah). We do not use ad networks, retargeting pixels, or cross-app tracking technologies.

(e) “Do Not Sell or Share My Personal Information”

Because Lisah does not sell or share personal information for cross-context behavioral advertising, a “Do Not Sell or Share My Personal Information” link is not currently required. However, if our practices change in the future, we will: (i) update this Privacy Policy with at least thirty (30) days’ advance notice; (ii) place a conspicuous “Do Not Sell or Share My Personal Information” link in the footer of our Site and in the App settings; and (iii) honor all opt-out requests submitted through that link.

(f) Use of Sensitive Personal Information

Lisah collects sensitive personal information (Category L) solely as necessary to provide the core services of the App – personalized insights, pattern recognition, forecasting, and lifestyle guidance. We do not use sensitive personal information for purposes beyond what is necessary to provide these services. A “Limit the Use of My Sensitive Personal Information” link is available in the footer of our Site and in the App settings (Profile → Privacy). If you exercise this right, we will restrict our use of your sensitive personal information to the minimum necessary to provide the services you have requested.

(g) CCPA Rights Summary

California residents have the following rights under the CCPA. For detailed instructions on exercising these rights, see Section 20 (Your Privacy Rights):

  • Right to Know / Access (§ 1798.100, § 1798.110, § 1798.115)
  • Right to Delete (§ 1798.105)
  • Right to Correct (§ 1798.106)
  • Right to Opt Out of Sale or Sharing (§ 1798.120) – not currently applicable as Lisah does not sell or share PI
  • Right to Limit Use of Sensitive Personal Information (§ 1798.121)
  • Right to Non-Discrimination (§ 1798.125)

(h) Verification of Requests

To protect your privacy and security, we will verify your identity before fulfilling any consumer rights request. Verification may include confirming your account-recovery email address, randomized internal user ID, or other identifying details associated with your account. Because Lisah accounts are anonymous or pseudonymous, verification may be limited to confirming that the requestor controls the account in question.

(i) Authorized Agents

You may designate an authorized agent to submit a CCPA request on your behalf. The authorized agent must provide written permission signed by you and must verify their own identity with us. We may also require you to verify your identity directly and confirm the agent’s authorization.

(j) Response Timing

We will respond to verified consumer requests within forty-five (45) calendar days of receipt. If additional time is reasonably necessary, we will inform you of the reason and the extension period in writing. The response period may be extended by an additional forty-five (45) calendar days (for a total of ninety (90) days) with notice to you.

(k) Non-Discrimination

Lisah will not discriminate against you for exercising any CCPA right. We will not:

  • Deny you goods or services
  • Charge you different prices or rates, including through discounts, benefits, or penalties
  • Provide you a different level or quality of goods or services
  • Suggest that you will receive a different price, rate, or quality for exercising your rights

(l) Financial Incentives

Lisah does not offer financial incentives, price differences, or service differences in exchange for the retention or sale of personal information.

Anonymous Analytics Consent

Lisah collects anonymized, bucketed product-usage analytics to understand how the App is used and to improve the product experience. Analytics events include screen usage, onboarding completion, feature adoption, and session duration.

IMPORTANT: The analytics event stream does NOT contain health data. No mood, symptom, cycle, wearable, or any other health-related information is included.

Consent Mechanism

  • Dedicated onboarding step during initial App setup
  • Non-preselected binary option (NOT pre-toggled ON)
  • Clear, plain-language explanation of what is collected and why
  • Changeable at any time via Profile → Privacy
  • Does not affect App functionality

Regulatory Notes

  • HIPAA: Not applicable (no PHI in analytics)
  • Apple ATT: Not applicable (no IDFA/ad networks). App Store Privacy Nutrition Label discloses “Usage Data / Analytics”
  • GDPR (EU users): Explicit, informed, non-preselected choice per GDPR requirements for health-context apps

Aggregate Model Learning Consent

Lisah may use de-identified symptom and cycle patterns from consenting users to improve global prediction models. This is a separate, secondary use requiring its own consent, independent of analytics consent (Section 9) and general consent to use the App.

YOUR PERSONAL INSIGHTS ARE NOT AFFECTED BY THIS CHOICE. This consent only controls whether your de-identified patterns contribute to the shared model.

Consent Mechanism

  • Dedicated onboarding step, immediately after analytics consent
  • Non-preselected binary option (NOT pre-toggled ON)
  • Granular – separate from analytics consent and general App consent
  • Plain-language prompt: “Your patterns help improve predictions for everyone; your own predictions work either way”
  • Revocable at any time via Profile → Privacy; revocation excludes data from future model-retraining cycles
  • All consent events (grants and revocations) timestamped and logged

Data Handling

  • Only de-identified data used for model retraining
  • Data from non-consenting users never included
  • Pre-opt-in data not retroactively included

Accounts and Anonymity

Lisah accounts are anonymous or pseudonymous. We do not require your legal name, phone number, date of birth, or real-world identifier.

  • Each account uses a randomized internal identifier
  • Optional email for account recovery is stored separately from health data
  • You may use the App without providing any personally identifying information

Data Handling and De-Identification

(a) Data Minimization.

Only minimum data necessary for core functionality.

(b) Data Segregation.

Health data stored separately from account-recovery info. Not cross-linked.

(c) De-Identification.

Health data used for model learning (with consent per Section 10) is de-identified before entering the pipeline.

(d) No EHR Integration.

Lisah does not integrate with EHRs, clinical providers, health plans, or any healthcare entity.

Regulatory Positioning

(a) HIPAA

Lisah is not a HIPAA-covered entity. It does not operate as a healthcare provider, health plan, clearinghouse, or business associate. No PHI is collected or stored.

(b) FDA / Medical Device

Lisah is a consumer wellness platform, not a medical device (21 U.S.C. § 321(h)). It does not diagnose, treat, cure, mitigate, or prevent any disease. AI is used for pattern recognition and lifestyle-level explanations only.

(c) Apple ATT

Apple ATT does not apply. No IDFA, no ad networks, no third-party sharing. App Store Privacy Nutrition Label discloses “Usage Data / Analytics.”

Third-Party Data Sharing

Lisah does not sell personal information or consumer health data. No sharing with advertisers, data brokers, or marketing companies. Lisah may disclose data to certain parties as follows:

(a) Infrastructure Service Providers.

Cloud hosting under strict contractual obligations.

(b) Wearable Platform APIs.

Oura, Apple HealthKit, Fitbit. Data flows to Lisah only - not sent back.

(c) Legal and Safety Disclosures.

As required by law, regulation, or valid legal process.

(d) Business Transfers.

In connection with merger/acquisition, with advance notice to you.

Lisah has no ad-supported revenue model. No ad networks, retargeting pixels, or cross-app tracking.

Data Retention and Deletion

(a) Retention Periods

  • User-reported signals and wearable data: Duration of account; deleted on account deletion or request
  • Inferences and patterns: Duration of account; deleted on account deletion or request
  • Account-recovery email: Until removed or account deleted
  • Anonymized analytics (if consented): Aggregate, non-identifiable; not subject to individual deletion
  • De-identified model-learning data (if consented): De-identified; cannot be individually retrieved or deleted

(b) Your Right to Delete

Delete via Profile → Privacy → Delete My Data / Delete My Account.

  • Active data deleted within 30 days
  • Backups purged within 90 days
  • De-identified aggregate data cannot be individually extracted

(c) Effect of Deletion

Deletion removes all historical patterns, insights, and forecasts. A new account starts fresh.

Children’s Privacy

Lisah is for individuals 18+. We do not knowingly collect data from children under 18. Contact privacy@[domain] if you believe a child has provided data.

Note: While Lisah supports all life stages including puberty, the App is designed for adult users. Minors should use it only under parental/guardian supervision and consent.

International Data Transfers

Lisah is operated from the United States. Data may be transferred to and processed in the U.S. This App is not intended for users outside of the United States.

LISAH IS NOT FOR EMERGENCIES

⚠ WARNING: LISAH IS NOT AN EMERGENCY SERVICE. LISAH DOES NOT PROVIDE EMERGENCY CARE, CRISIS INTERVENTION, MEDICAL DIAGNOSES, OR CLINICAL TREATMENT OF ANY KIND.

IF YOU ARE EXPERIENCING A MEDICAL EMERGENCY including chest pain, difficulty breathing, severe bleeding, loss of consciousness, stroke symptoms, severe allergic reaction, or any life-threatening condition – CALL 911 (or your local emergency number) IMMEDIATELY.

IF YOU ARE EXPERIENCING A MENTAL HEALTH CRISIS including suicidal thoughts, self-harm urges, or severe emotional distress – CONTACT THE 988 SUICIDE & CRISIS LIFELINE BY CALLING OR TEXTING 988. You may also text HOME to 741741 (Crisis Text Line).

Nothing in the App constitutes medical advice, a diagnosis, or a treatment recommendation. By using Lisah, you acknowledge that: (i) Lisah is not a healthcare provider; (ii) you will not rely on Lisah for emergencies or clinical decisions; and (iii) you will seek professional care and call emergency services when needed.

Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

  • Right to Know / Access: Request categories and specific pieces of personal information collected
  • Right to Delete: Request deletion, subject to legal exceptions
  • Right to Correct: Request correction of inaccurate information
  • Right to Opt Out of Sale/Sharing: Not currently applicable (Lisah does not sell PI); opt-out mechanism will be provided if this changes
  • Right to Limit Sensitive PI: Limit use to what is necessary for core services
  • Right to Data Portability: Request data in structured, machine-readable format
  • Right to Withdraw Consent: Revoke analytics or model-learning consent at any time via Profile → Privacy
  • Right to Non-Discrimination: We will not deny services, change prices, or reduce quality for exercising rights

To exercise rights: privacy@lisah.co or in-app (Profile → Privacy). Response within 45 days, extendable 45 days with notice. Authorized agents accepted with verification.

Changes to This Privacy Policy

(a) Material Changes.

At least 30 days’ advance notice via in-app notification and email (if account-recovery email provided).

(b) Non-Material Changes.

Posted with updated “Last Modified” date. Effective upon posting.

(c) Continued Use.

Continued use after the effective date constitutes acceptance. Remedy: discontinue use and delete account.

Contact Information

If you have questions about this Privacy Policy:

  • Privacy Inquiries: privacy@lisah.co
  • General Support: support@lisah.co
  • Website:

We respond to all privacy inquiries within applicable legal timeframes. You may also lodge a complaint with a supervisory authority in your jurisdiction.

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