Consumer Health Data Privacy Notice — Washington, Nevada, and Connecticut residents
Kinfara Labs LLC · 300 Delaware Ave, Ste 210 #250, Wilmington, DE 19801 · privacy@kinfara.com Effective: 2026-10-11. This notice applies to any data we handle that may be consumer health data under the state laws named next - for example precise location that could indicate a visit to a health-care provider - whether or not Kinfara can read it. Your location is end-to-end encrypted and unreadable to Kinfara, and Kinfara makes no health inference; encryption does not limit any right these laws give you. It supplements our Privacy Policy for residents of Washington (My Health My Data Act, RCW 19.373), Nevada (Consumer Health Data Privacy Act, SB 370, codified at NRS 603A.400–603A.550; enforced by the Attorney General, no private right of action), and Connecticut (consumer-health-data provisions of the CTDPA, Conn. Gen. Stat. §42-515 (definitions) and §42-526 (consumer health data)).
1. Why a family-safety app publishes a health-data notice
Kinfara does not collect health information. It has no fields for conditions, diagnoses, symptoms, medications, or disability. We publish this notice because Washington's law defines "consumer health data" broadly to include "precise location information that could reasonably indicate a consumer's attempt to acquire or receive health services or supplies" and data "derived or extrapolated from nonhealth information … including … algorithms" (RCW 19.373.010). A location-sharing service could, in principle, reveal a visit to a clinic. We want to state plainly what we can and cannot do with that. Nevada and Connecticut define consumer health data comparably — Nevada ties it to data used to identify a consumer's health status, and Connecticut (§42-526) includes gender-affirming and reproductive or sexual-health data.
2. What we collect that could be consumer health data
| Category | What it is | Could it indicate health? | Can Kinfara read it? |
|---|---|---|---|
| Precise location of a protected person | Live position shared with the family | In principle — a position near a clinic, pharmacy, or hospital | No. Encrypted on the phone; only the family's own devices can decrypt it. We store ciphertext and hold no usable key (Privacy Policy §5B(a)). |
| Place alerts (arrive/leave a zone) | Zones the parent defines on the parent's phone | Only if a parent defines such a zone | No — zones are evaluated on the parent's phone (Privacy Policy §5). |
| Safety alerts (SOS) | The fact that an SOS fired, and when | A distress alert could in principle be read as a health-related event | We see the alert kind, time, and a codename — not the location. |
We do not infer, classify, tag, or derive anything about health from any of the above (Privacy Policy §8). We keep no list of sensitive places, and we do not know which places your family visits.
3. Where the data comes from
The protected person's own phone (location, alerts) and the parent (zones). No data broker, no third-party app, no purchase, no other source.
4. Why we collect it
Solely to show a family member's location to the family members they chose, and to deliver safety alerts (Privacy Policy §5). Circle membership decides who receives the location: members join with an invite code and there is no approval step — whoever is in the circle receives a member's location. The member — or, for a child under 13, the verified parent — consents to sharing. Never for advertising, profiling, research, sale, or any secondary purpose.
5. With whom it is shared
| Recipient | What | Why |
|---|---|---|
| The family members the protected person and parent chose | Decrypted location, on their own devices | The service |
| Supabase (hosting) | Encrypted location it cannot read; alert rows with a codename | Runs the service |
| Google FCM / Apple APNs | The alert text with a codename or "your child" | Delivers the alert to the parent's phone |
| TomTom | The map area a circle member is viewing, and that phone's IP address — only if that member chose a real map (this happens on that member's own phone, and any circle member who chose a real map sends these requests, not only a parent) | Draws the map. The position-only mode sends nothing (Privacy Policy §15) |
We do not sell consumer health data, and we do not share it for advertising. No affiliate exists. (See Privacy Policy §6.)
6. No geofencing around health facilities
Washington's My Health My Data Act prohibits implementing a geofence around an in-person health-care facility to identify or track consumers, collect their consumer health data, or send them health-related messages (RCW 19.373.080). The 2,000-foot figure appears in the Act's definition of "geofence" (RCW 19.373.010); the .080 ban itself sets no radius. Kinfara implements no geofence around any health facility. The only zones in the app are the ones a parent draws for their own family (e.g., "Home," "School"); they are created and evaluated on the parent's phone, and Kinfara neither suggests nor builds any zone based on a health location (Privacy Policy §5, §8).
7. Two separate consents — collection and sharing
Washington requires consent to collect consumer health data and a "separate and distinct" consent to share it. Kinfara's design keeps them apart: The person whose location is shared gives both consents for themselves — the account holder does not consent on another adult's behalf. For a child under 13, the verified parent consents at the $1 step, where we clearly disclose that everyone in the circle will see the child.
| Consent | Who gives it | Where | Evidence |
|---|---|---|---|
| Collection | The person whose location is shared, by turning on their own "Share my location" switch — OFF until they do. For a child under 13, the verified parent's consent at the $1 step. | The Kinfara app, on the protected person's own phone | In-app sharing-consent flow |
| Sharing within the circle | The person whose location is shared, when they share it with the circle they joined. For a child under 13, the verified parent at the $1 consent step, where we clearly disclose that everyone in the circle will see the child. | The Kinfara app, when a circle is created or joined and at the child's consent | The recorded consent; you control who sees whom by circle membership |
Either can be withdrawn at any time: the protected person turns the switch off or leaves the circle (Settings → Leave this circle); a circle admin can remove the member from the circle.
8. Your rights
Washington, Nevada, and Connecticut residents may: (a) confirm whether we collect, share, or sell consumer health data about them and access it, including a list of the third parties with whom we shared it; (b) withdraw consent; (c) have their consumer health data deleted — on the deletion windows, and subject to the surviving records, set out in the Privacy Policy (Section 13, and the retention table in Section 9); and (d) appeal a refusal.
How to exercise them: email privacy@kinfara.com from the email on the account, or use the in-app controls (Settings → Account & Subscriptions: Download my data and Delete my account; a member's own Settings → Leave this circle). We respond within 45 days, extendable once by a further 45 days where reasonably necessary, and we tell you if we extend. Appeals: reply to our decision with "Appeal" in the subject line; a different reviewer answers within the statutory window, and if we still deny it we give you the contact for your state Attorney General.
No retaliation. We will not retaliate against you, or degrade your family's service, for exercising any of these rights.
9. How to reach us
privacy@kinfara.com · Kinfara Labs LLC, 300 Delaware Ave, Ste 210 #250, Wilmington, DE 19801.
Kinfara Labs LLC · 300 Delaware Ave, Ste 210 #250, Wilmington, DE 19801, USA · privacy@kinfara.com · Effective: 2026-10-11 · Privacy Policy · Terms of Use · Consumer Health Data Notice · Children’s Privacy