Consumer Health Data Privacy Policy

Last Updated: October 26, 2026

Version 1.2

1. Introduction and Scope

This Consumer Health Data Privacy Policy (“CHD Policy”) is published by Mirri Diabetes LLC (“Mirri,” “we,” “us,” or “our”) and provides the specific disclosures required for “consumer health data” under the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Law, the Connecticut Data Privacy Act, and similar state laws, as they relate to Mirri Cloud.

Mirri Cloud is the service that keeps the health record a person creates in MIRRI One, Mirri’s mobile app, in sync between that person’s own devices and shares it with the people they choose, together with the Mirri Cloud website at cloud.mirridiabetes.com, where people read and analyze their own record and records shared with them. This CHD Policy supplements, and should be read together with, the Mirri Cloud Privacy Policy and the Mirri Cloud Terms of Service. If anything here conflicts with the Mirri Cloud Privacy Policy regarding consumer health data, this CHD Policy controls as to that data, except that our U.S. State Health Privacy Notice controls for residents of the states it names.

“Consumer health data” means personal information that identifies a consumer’s past, present, or future physical or mental health status — here, the diabetes and related health information described below.

Mirri is not a HIPAA covered entity or business associate, and Mirri Cloud is not offered to covered entities or business associates for protected health information. This CHD Policy addresses consumer-health-privacy laws, not HIPAA.

2. How Mirri Cloud Holds Consumer Health Data

MIRRI One seals each health entry on the person’s phone before it is uploaded. Our servers store the entry in sealed form and are designed to hold no key that can open it, and entries are opened only on the person’s own approved devices and those of the Followers they choose. We still treat sealed entries as consumer health data. We also treat as consumer health data the routing information our servers can read about sealed entries, and the account, device, and Follower details described in Sections 3 and 4 of the Mirri Cloud Privacy Policy, because they can show that a person keeps a diabetes record and how often they add to it. Routing information is designed so that our servers cannot tell what a person recorded, which kinds of information they record, when within a two-week period the things they recorded happened, or what they changed or deleted. MIRRI One seals cycle and other reproductive-health information on the phone like every other kind, and Mirri Cloud stores it only in that sealed form; because the slot number is assigned at random for each record, our servers cannot tell which entries are cycle entries.

Our servers also keep service-wide daily totals, such as how many accounts exist, how many requests failed, and how much storage the database uses, and the name of any check that finds a problem, described in Section 4(l) of the Mirri Cloud Privacy Policy. They are kept for the service as a whole, never for a person, account, or record. When few people use Mirri Cloud, a day’s total can come close to one person’s activity that day, so we handle these totals as deidentified data under the Washington My Health My Data Act (RCW 19.373.010) and the similar laws of Nevada (NRS Chapter 603A) and Connecticut (Conn. Gen. Stat. § 42-515): we keep them only in that service-wide form, we take reasonable measures so that they cannot be associated with any person, we commit publicly here not to try to reidentify anyone from them, and we bind the service providers that process them for us to use them only to provide services to us.

3. Categories of Consumer Health Data

Kept in Mirri Cloud in sealed form. Once the person turns Mirri Cloud on in MIRRI One, MIRRI One keeps their record (shown in the apps as their data) there, whether or not anyone follows it yet. Depending on the version of MIRRI One and what the person records, a record can hold:

• glucose readings, including meter readings;
• insulin doses, mealtime and long-acting;
• carbohydrates, foods and meals with their nutrients, and saved meals;
• workouts and activity, steps, and sleep;
• cycle days, with flow and the first day of each period (no symptoms, no notes);
• therapy settings recorded in MIRRI One, such as ratios and target ranges;
• medicines on the person’s list, and when they were taken;
• supplies, such as sensor, infusion-set, and pen changes, and injection or wear sites;
• Playbook plays.

Readable by Mirri. For each sealed entry: the record it belongs to, its slot number (which does not tell us its kind), the two-week period it falls in, its size rounded up to one of five fixed sizes, the version of the record’s keys it was sealed under, the device that wrote it, and when we received it. About each record: the account that holds it and that account’s email address; its devices, with their public keys and a platform word such as “iPhone”; who follows it, and since when; how many entries arrive, when, and in which slots; which slot paces wake-ups when background refresh pings are on, and the cadence the phone declares; when its keys change; which two-week periods have entries; and its deletion, closure, consent, and security records. Apple and Google, which deliver our wake-ups, can see when each wake-up is sent to a device.

Never sent to Mirri Cloud. The person’s notes, photos, and conversations with Iris (MIRRI One’s in-app assistant).

Offline Sharing. Offline Sharing goes from the QR code on the person’s phone screen to a browser tab in person, and can carry information a record does not, such as workout distance and heart rate and the names of the apps the data came from. It is never sent to Mirri, and we do not collect it.

We do not collect precise location, and we do not use location to infer health conditions.

4. Sources of Consumer Health Data

Consumer health data reaches Mirri Cloud only from MIRRI One on the record holder’s phone: information the person enters in MIRRI One, and information MIRRI One reads, with the person’s permission, from Apple Health or Android Health Connect, which may include information other apps wrote there. The Mirri Cloud website does not collect consumer health data from anyone; it opens what MIRRI One sealed, in the reader’s own browser.

5. Purposes for Using Consumer Health Data

• To keep a person’s record in sync between their own devices.
• To make it available to the Followers and devices the person approves.
• To operate, secure, and support Mirri Cloud, including checking, with the service-wide totals described in Section 2, that it is working and within its hosting plan, and to carry out the person’s requests, including deletion.

We do not use consumer health data for advertising or data mining, and we do not use it for research or any other secondary purpose except with the person’s separate, explicit permission. We cannot use the content of entries for any purpose, because we cannot open them.

6. How We Share Consumer Health Data

We share consumer health data only:

• With the Followers the person chooses. The person confirms each Follower, chooses the kinds of information that Follower may read (every kind is off until the person chooses it), and can change or end that access at any time in MIRRI One. Every Follower’s devices receive the record’s sealed entries and can open only the kinds the person chose for them. Cycle and other reproductive-health information is sealed like every other kind, and a Follower receives it only if the person turns on the Cycle category for that Follower, which is off by default and asks for its own confirmation. Followers are chosen by the person and are not vetted, controlled, or supervised by Mirri.
• With our service providers, who process data on our behalf under contracts that require them to protect it and use it only to provide services to us: Supabase, our database host in the United States, which stores sealed entries and the readable information described in Section 3; Cloudflare, which carries requests to our servers, including sealed entries and routing information, as the network in front of our hosting provider; Resend, Inc., which sends our sign-in and account emails, delivers them through Amazon Web Services’ email infrastructure, and receives an email address and the content of those emails, with no health information; and Apple and Google, which deliver notices to MIRRI One that carry no health information.

We do not share consumer health data with any other third parties, we have no affiliates that receive it, and we do not sell consumer health data. We do not allow third parties to collect consumer health data about your online activities over time and across different websites or online services through Mirri Cloud, and we use no analytics, advertising, or tracking tools; the service-wide totals described in Section 2 are our own operating counts and identify no one.

7. Consent and Authorization

Consent to collect. Mirri Cloud is off by default in MIRRI One, and nothing is uploaded until the person turns it on. Before anything is uploaded, MIRRI One shows a screen titled “Turn on Mirri Cloud.” In labeled lines, it states what goes (the kinds of information that version of MIRRI One sends, which include cycle days, sealed on the phone before they leave it, and that notes, photos, and Iris chats stay on the phone); where it goes (Mirri’s servers in the United States); why (to keep the record in sync between the person’s devices and to let the Followers they choose see what they allow); who can read it (the person, the devices they approve, and each Follower they confirm, for the kinds they allow); and how to change their mind (by deleting the record or closing the account at any time in Mirri Cloud settings). Beneath those lines, the screen links this CHD Policy, the Mirri Cloud Privacy Policy, and the Mirri Cloud Terms of Service, and says that turning on Mirri Cloud accepts those Terms. Tapping “Agree and turn on” is the person’s affirmative, opt-in consent to the collection described on that screen; the consent rests on those disclosures, not on accepting the Terms. MIRRI One records the version and time of the consent on the phone and sends our servers a consent record that contains no health information. A person who set up Mirri Cloud before this screen existed is shown the same disclosures, and their phone does not upload until they agree. The service providers in Section 6 hold the data only in sealed form, apart from the readable information in Section 3.

Consent to share. Sharing with each Follower is a separate choice. On the screen where the person chooses what a Follower sees, every kind of information is off until the person turns it on, and the screen names the device or account the person is authorizing as it appears on the screen, states which kinds that Follower will be able to read (the kinds the person ticks) so that the Follower can follow their data, and says that this lasts until the person ends it; the person confirms by tapping “Start sharing,” and that tap is recorded as their signature. That tap is the person’s separate consent to the sharing and their authorization of it, and MIRRI One keeps a sealed copy of what was granted that only the person’s own devices can open. Cycle information has its own Cycle switch for each Follower, which is off by default and asks for its own confirmation before it turns on; that confirmation is the person’s separate consent to disclose it to that Follower. A person starts sharing by scanning the code the Follower’s screen shows, or, when they are apart, by sending a link that the Follower opens. A Follower can read the earlier entries of each kind the person allows, as well as new ones, not only entries made after the sharing starts. Before following by a link, the Follower is told that they will read what the person chooses to show them, that their phone keeps a copy for up to 72 hours, that they should treat it as the person’s own and not share it on, and that the person can stop the sharing at any time; the Follower taps “Follow,” and that acceptance is also recorded without any health information.

Withdrawing consent. A person may withdraw consent at any time by ending a Follower’s access, deleting their record, or closing their account. When a Follower’s access ends, the Follower can no longer read the record, and the person’s phone changes the record’s keys; we cannot recall what a Follower has already opened.

We do not sell consumer health data, and we would not do so without first obtaining a separate, valid written authorization containing all elements required by applicable law.

8. No Geofencing

We do not use a geofence to identify or track consumers seeking health-care services, to collect consumer health data, or to send notifications, messages, or advertisements based on a consumer’s proximity to any health-care facility, provider, or other location that could indicate an attempt to receive health-care services.

9. Your Rights

Subject to applicable law, you have the right to: confirm whether we are collecting, sharing, or selling your consumer health data, and access it, including a list of all third parties and affiliates with which we have shared or sold it, with an email address or other online way to contact each of them; withdraw consent to our collection and sharing; have your consumer health data deleted (and have us notify the service providers that received it to delete it); and appeal a decision we make about a request. We do not discriminate against you for exercising these rights.

The list of third parties. When you ask for it, we give you the service providers in Section 6, with a way to contact each, and each Follower who has had access to your record, by the email address of their account. We have no affiliates and sell to no one, so there is nothing else to list.

Entries we cannot open. Because Mirri Cloud is designed so that we cannot open your entries, we cannot produce a readable copy of them. We can tell you the readable information we hold, and you can read your entries in MIRRI One or on the Mirri Cloud website on your own approved devices.

How to exercise them. Delete a record or close your account in MIRRI One (open the Menu, then Mirri Cloud, then Settings, then Delete & close account; after you ask to close your account and log in again, “Delete now” closes it at once) or at cloud.mirridiabetes.com/delete-my-data, or contact us at support@mirridiabetes.com. We will confirm receipt within 10 days and respond within 45 days (extendable once by an additional 45 days with notice), and we take reasonable steps to verify identity before acting. If we deny a request, you may appeal by replying to our decision or contacting support@mirridiabetes.com; if the appeal is denied, you may contact your state Attorney General.

State-specific disclosures. Our U.S. State Health Privacy Notice gives the additional disclosures for Washington, Nevada, Connecticut, and other states, including when deletion is complete (a Mirri Cloud deletion you start yourself usually runs 24 hours after you ask, or at once when you close your account without waiting; a request is always completed within 30 days of verifying it), and the Attorneys General you may contact if we deny an appeal.

10. Retention of Consumer Health Data

We keep consumer health data only while the record exists. When a record is deleted, the deletion runs 24 hours after the request unless it is cancelled, destroys the record’s keys, and removes its entries and Followers’ access; copies in our hosting provider’s routine backups keep the entries sealed and expire, with everything else they hold, within 30 days. When an account is closed, the records only that account holds are deleted the same way (at once, when the account is closed without waiting), and the sign-in account, with its email address, its sessions, and its sign-in log, is erased within about an hour after closing runs. After a deletion we keep a record that it was requested and carried out, with its times and the identifiers needed to show it, such as the record’s identifier, and nothing about the contents of any entry, its name, or what kinds of information it held; consent records are kept with it. The service-wide totals described in Section 2 are not kept for any record and are kept for up to 90 days. The Mirri Cloud Privacy Policy, Section 9, gives the full retention schedule. Information a Follower has already opened on their own device is outside our control.

11. Security

We use administrative, technical, and physical safeguards designed to protect consumer health data. The main one is sealing entries on the person’s phone, which is designed so that our servers, our staff, and our service providers cannot open them; others are the access controls and logging described in the Mirri Cloud Privacy Policy. No method of transmission or storage is completely secure, and we do not guarantee that our safeguards will prevent every incident. If a breach affecting health information occurs, we will provide notice as required by law, including the FTC Health Breach Notification Rule and applicable state laws.

12. Changes to This CHD Policy

We may update this CHD Policy from time to time. We will revise the “Last Updated” date and, for material changes affecting how we handle consumer health data, obtain any consent required by law before the change applies.

13. Legal Process and Government Requests

Legal process and government requests. We disclose information only when valid legal process (such as a subpoena, court order, or search warrant) requires it, or when the law otherwise requires us to. We cannot produce the contents of your entries, because Mirri Cloud is designed so that we hold no key that opens them. Our servers are designed not to hold which kinds of information you record, when within a two-week period the things you recorded happened, your time zone, or what you changed or deleted, so we cannot produce those either; what we could be required to produce is limited to the information our servers can read, described in Section 3. We review every request for scope and validity, we object to requests that are overbroad or that seek more than the law requires, and we provide only what the request lawfully requires. Unless we are legally prohibited from doing so, we tell you about a request for your information before we respond, so that you can object. We do not voluntarily disclose information to any government body, and we treat requests concerning reproductive or sexual health exactly as we treat every other request; Cycle and other reproductive-health information is held, like every other kind, only in sealed form that we cannot open, and our servers cannot tell which entries are cycle entries, so we have no readable reproductive-health information to produce. We keep a record of each request we receive and how we answered it.

14. Contact Us

For questions about this Consumer Health Data Privacy Policy, or to exercise your rights, contact us at:

Mirri Diabetes LLC

300 Main St., Ste. 900

Lafayette, IN 47901, United States

support@mirridiabetes.com