Privacy Policy

Privacy Policy

Update Date: Aug 4, 2025
Effective Date: Jul 1, 2025

We value your privacy highly. Please read the following to understand how we handle your personal information. By accessing or using our services in any way, you acknowledge and agree to the practices and policies described in this Privacy Policy and consent to our collection, use, and sharing of your information as described herein.

Please note that your use of our services is always subject to our Terms of Use, which incorporates this Privacy Policy. Any undefined terms used in this policy shall have the meanings given to them in the Terms of Use.

Contents of This Privacy Policy

Scope of This Privacy Policy
Personal Data
Categories of Personal Data We Collect
Categories of Sources of Personal Data
Business or Commercial Purposes for Collection or Disclosure
How We Disclose Your Personal Data
Tracking Tools, Advertising, and Opt-Out
Data Security
Children’s Personal Data
California Resident Rights
How to Exercise Your Rights under the California Consumer Privacy Act (CCPA)
Privacy Rights Under Other State Laws
EU and UK Data Subject Rights
Contact Information

Scope of This Privacy Policy
This Privacy Policy covers how we treat personal data that we gather when you access or use our services.
“Personal data” refers to any information that identifies or relates to a particular individual, including “personally identifiable information” or “personal information” as defined under applicable data privacy laws, regulations, or ordinances.
This Privacy Policy does not apply to the practices of companies we do not own or control, or to individuals we do not employ or manage.

Categories of Sources of Personal Data

We collect personal data about you through the following sources:

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties with Whom We Share Data
Account Information or Contact Data	Name, email address, phone number, password, and similar identifiers	Service Providers
Payment Data	Bank account details, payment card type, credit or debit card number, billing address, phone number, email address	Service Providers (including our payment processors: Stripe Inc. and Apple Inc.)
Commercial Data	Purchase records on Most Days	Service Providers
Device/IP Data	IP address, device ID, device/operating system/browser type used to access the service	Service Providers, Advertising Partners, Analytics Partners
Website Analytics Data	Page interactions, referral sources, service interaction statistics by device/browser	Service Providers
Demographic Data	Age/date of birth, gender	Service Providers
Geolocation Data	Location based on IP address	Service Providers, Advertising Partners, Analytics Partners
Health Data	Medical conditions, health/fitness tracking, psychological health status	Service Providers
Sensitive Data as Defined by California and Virginia Laws	Personal health-related information of consumers	Service Providers
Inferences from Other Personal Data	Inferences about user preferences, behavior, and abilities	Service Providers

Information You Provide Directly

When you voluntarily provide information to us;
When you create an account or use our interactive tools and services;
When you fill out forms, surveys, or questionnaires within the service;
When you email us or otherwise contact us;
When data is collected automatically during your use of our services;
Through cookies (see section "Tracking Tools, Advertising, and Opt-Out");
If you download our mobile application or use a location-enabled browser, we may receive your location and device information (as applicable).

Affiliates
Our subsidiaries and affiliates may provide us with personal data they hold about you.

Third Parties
We may also obtain personal data about you from third parties, including:

Service Providers: For example, we may use analytics providers to understand how you interact with the service, or third parties to help provide customer support;
Advertising Partners: We may receive information about your interactions with our websites, apps, products, advertisements, or communications from vendors who help us with marketing or promotional services;
Social Networks: If you log into the service through a third-party site or service (e.g., a social media account), or if you provide us with your social account information, some content or information may be transferred to your account on our platform;
Apple Health: If you explicitly authorize us to collect data from your Apple Health app, the authorized information will be transmitted to our application. We do not use Apple Health data for advertising or similar purposes, nor do we sell this data to advertising platforms, data brokers, or resellers. We use this data solely to personalize and deliver services to you.

Business or Commercial Purposes for Collection or Disclosure of Personal Data

We process your personal data to operate, optimize, understand, and personalize our services. Specific purposes include:

Fulfilling the purpose for which the information was provided;
Communicating with you about the service, including notices, updates, or promotional messages;
Providing support and assistance for the service;
Creating and managing your account or user profile;
Processing orders or other transactions;
Responding to user inquiries and fulfilling requests;
Improving and developing the service, including testing, research, and product development;
Marketing and selling our services;
Displaying advertisements to you, including interest-based ads;
Maintaining the security and integrity of the service and preventing fraud, illegal activity, or harmful behavior;
Complying with legal or contractual obligations, resolving disputes, and enforcing our Terms of Use;
Protecting the rights, property, or safety of you, our application, or others;
Responding to law enforcement requests and complying with legal processes, court orders, or government regulations;
And any other business purposes permitted under applicable laws such as the California Consumer Privacy Act (CCPA).

We will not collect additional categories of personal data or use personal data for materially different, unrelated, or incompatible purposes without providing notice.

As noted above, if you provide us with your contact information such as your email address, we may communicate with you regarding service updates or promotional content. For example, we may receive a confirmation when you open our emails, helping us improve our communications. If you prefer not to receive such emails, you may express your preferences by contacting us at: ws@letshealth.cn.

If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes defined in Section 7027(m) of the California Privacy Rights Act (CPRA).

How We Disclose Your Personal Data

We may disclose your personal data to service providers or other third parties for the following purposes (under some state laws, such disclosures may constitute a "sale"):

Auditing related to current interactions or transactions, such as counting ad impressions, verifying ad quality, or auditing for compliance;
Detecting security incidents and protecting against fraudulent, deceptive, or illegal activity;
Debugging to identify and repair errors that impair existing functionality;
Short-term, transient use, provided the information is not used by a third party to build a consumer profile;
Performing services on our behalf, such as account maintenance, customer service, order processing, payment processing, and analytics;
Internal research and development;
Verifying or maintaining the quality and safety of a product or device we own, manufacture, or control.

How We Handle Facial Data

Data Collected:

This app collects only facial image features used to estimate health indicators such as heart rate, stress distribution, and skin tone. It does not collect facial features used for identity recognition or any personally identifiable information.

Purpose of Use:

The collected data is used solely to generate health risk scores and trend estimations. It is not used for any form of identity recognition or storage, and all processing is anonymized.

Third-Party Sharing:

We do not share facial image data with any third parties. If DeepAffex® (NuraLogix) technology is used for facial analysis, the processing is performed entirely on-device. No facial images are uploaded to any server or external platform.

Data Storage Location:

Facial image data is processed locally in real time and immediately deleted afterward. It is neither uploaded nor stored. If data needs to be uploaded due to feature requirements, it is encrypted and handled only with explicit user consent.

Data Retention Period:

All facial image data is used only for real-time analysis and is retained for no longer than 24 hours before being automatically deleted.

Legal Obligations

We may share any personal data we collect with third parties under the following circumstances:

To comply with applicable laws and regulations;
To enforce our legal rights and terms;
To fulfill any of the activities described under the section "Business or Commercial Purposes for Collection or Disclosure of Personal Data".

Business Transfers

In the event of the following, we may transfer all personal data you have provided to a third party:

A merger;
Acquisition;
Bankruptcy;
Or any other transaction in which a third party assumes control of all or part of our business.

If such an event occurs, we will make reasonable efforts to notify you before your information is subjected to a different privacy and security policy.

Non-Personal Data

We may create aggregated, de-identified, or anonymized data from the personal data we collect. This includes removing information that can identify a specific user.

We may use such aggregated, de-identified, or anonymized data for lawful business purposes and share it with third parties, including:

Data analytics;
Service development and improvement;
Promoting our business.

We will not share such data in a way that could identify you.

Tracking Tools, Advertising, and Opt-Out

Our services use cookies and similar technologies (such as pixel tags, web beacons, clear GIFs, and JavaScript—collectively referred to as "Cookies") to:

Recognize your browser;
Understand when and how you use our services;
Analyze usage trends;
Understand user demographics;
Operate and optimize our services.

What Are Cookies?

Cookies are small data fragments, typically text files, that are stored on your device (such as a computer, tablet, or phone).

We may also combine the information we collect from you with data from third parties, some of whom may also place their own cookies on your device.

Note: Our services currently do not respond to browser “Do Not Track” signals due to our use of cookies.

Types of Cookies We Use

Essential Cookies

Provide you with core features or services (e.g., secure login areas).
Disabling these may render some services unavailable.

Functional Cookies

Remember your settings and preferences (e.g., language or region).
Help us recognize and load your preferences on return visits.

Performance/Analytical Cookies

Help us understand how visitors use the service.
Track metrics such as page views, time spent, and navigation behavior.
Measure ad performance and optimize content.
For example, we use Google Analytics:
You can opt out via Google Ads Settings or Google Analytics Opt-out Add-on.

Retargeting/Advertising Cookies

Track your online activities;
Analyze your interests;
Serve you relevant advertisements.

How to Manage Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to:

Disable cookies entirely;
Choose whether to accept new cookies;
Delete existing cookies.

Please note: If you clear cookies, you may need to manually reconfigure settings, and some features may no longer function properly.

You may also access cookie preferences through the [Cookie Settings link] within our service interface (placeholder).

To learn more about cookies and how to manage them, visit:http://www.allaboutcookies.org/

https://ico.org.uk/for-the-public/online/cookies/ (for EU users)

Data Security and Retention

We are committed to protecting your personal data through reasonable physical, technical, organizational, and administrative safeguards against unauthorized access, use, or disclosure.

For example, we use industry-standard SSL (Secure Socket Layer) technology to encrypt personal data you provide to us during transmission.

You are also responsible for taking measures to protect your data, including:

Choosing and securely managing your passwords or login credentials;
Limiting access to your devices and browsers;
Logging out of your account after use.

Please be aware that no method of transmission or storage over the internet is 100% secure. Unless required by law, we are not responsible for the theft, destruction, loss, or accidental disclosure of your information.

We retain your personal data for as long as your account remains active or as needed to provide our services. We may also retain data longer:

To comply with legal obligations;
To resolve disputes;
To collect outstanding payments;
Or in other circumstances permitted or required by law.

We may retain information in anonymized or aggregated form so that it can no longer be used to identify any individual.

Children’s Personal Data

As stated in our Terms of Use, we do not knowingly collect or solicit personal data from children under the age of 16.

If you are under 16, please do not attempt to register for an account or use the service, and do not provide us with any personal data.

If we learn that we have collected personal data from a child under 16, we will delete that information as quickly as possible.
If you believe a child under 16 has provided personal data to us, please contact us at [EMAIL PLACEHOLDER: ws@letshealth.cn].

California Resident Rights (CCPA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA).
For more details on how to act on these rights, see the next section titled “Exercising Your Rights.”
If other sections of this Privacy Policy conflict with this section, the more protective terms will apply.
If you have questions, please contact us at: [EMAIL PLACEHOLDER:ws@letshealth.cn]

Right to Know (Access)

You have the right to request information about the following regarding your personal data collected in the past 12 months:

Categories of personal data collected;
Categories of sources from which the data was collected;
Business or commercial purposes for collecting or selling the data;
Categories of third parties with whom we share the data;
Specific pieces of personal data we collected about you;
If disclosed for business purposes, which categories of third parties received which types of data;
If sold, which categories of purchasers received which types of personal data.

Right to Delete

You have the right to request that we delete the personal data we collected from you.

However, under the CCPA, this right is subject to certain exceptions, including but not limited to:

If the data is necessary to provide the service;
To complete transactions requested by you;
Other exceptions permitted by law.
If your request falls under an exception, we may deny your deletion request.

How to delete your account:

Log into the app;
Tap your profile icon in the top right → tap the gear icon → select “Account Settings”;
Scroll down and tap “Delete My Account”;
All personal data will be removed from the platform.

Note: Deleting your account does not automatically cancel any subscriptions.
You must manually cancel subscriptions via the Apple App Store or Google Play Store.

Right to Correct Inaccurate Information

You have the right to request that we correct inaccurate personal information we hold about you.

However, under the CCPA, we may deny your correction request if we reasonably determine that the data is already accurate.

Right to Opt-Out of Sale or Sharing of Cookies Data

Under the CCPA, some third-party cookies embedded on our website allow parties to collect browser or device data, which may be used for:

Interest-based advertising;
Cross-context behavioral advertising.
This may constitute a “sale” or “sharing” of your personal data.

We use cookies for the following sale/sharing purposes:

Promoting and selling our services;
Displaying interest-based or behavioral advertisements.

You may opt out by:

Enabling Global Privacy Control (GPC) or another legally recognized mechanism;
Note: GPC must be enabled per browser and device session.
GPC is distinct from “Do Not Track” signals.
Once opted out, we will not request re-authorization of cookie sales or sharing for at least 12 months.

We do not knowingly sell or share the personal data of minors under 16.

Data Security and Retention

We are committed to protecting your personal data through reasonable physical, technical, organizational, and administrative safeguards against unauthorized access, use, or disclosure.

For example, we use industry-standard SSL (Secure Socket Layer) technology to encrypt personal data you provide to us during transmission.

You are also responsible for taking measures to protect your data, including:

Choosing and securely managing your passwords or login credentials;
Limiting access to your devices and browsers;
Logging out of your account after use.

We retain your personal data for as long as your account remains active or as needed to provide our services. We may also retain data longer:

To comply with legal obligations;
To resolve disputes;
To collect outstanding payments;
Or in other circumstances permitted or required by law.

We may retain information in anonymized or aggregated form so that it can no longer be used to identify any individual.

Children’s Personal Data

As stated in our Terms of Use, we do not knowingly collect or solicit personal data from children under the age of 16.

If you are under 16, please do not attempt to register for an account or use the service, and do not provide us with any personal data.

California Resident Rights (CCPA)

Right to Know (Access)

You have the right to request information about the following regarding your personal data collected in the past 12 months:

Categories of personal data collected;
Categories of sources from which the data was collected;
Business or commercial purposes for collecting or selling the data;
Categories of third parties with whom we share the data;
Specific pieces of personal data we collected about you;
If disclosed for business purposes, which categories of third parties received which types of data;
If sold, which categories of purchasers received which types of personal data.

Right to Delete

You have the right to request that we delete the personal data we collected from you.

However, under the CCPA, this right is subject to certain exceptions, including but not limited to:

If the data is necessary to provide the service;
To complete transactions requested by you;
Other exceptions permitted by law.
If your request falls under an exception, we may deny your deletion request.

How to delete your account:

Log into the app;
Tap your profile icon in the top right → tap the gear icon → select “Account Settings”;
Scroll down and tap “Delete My Account”;
All personal data will be removed from the platform.

Note: Deleting your account does not automatically cancel any subscriptions.
You must manually cancel subscriptions via the Apple App Store or Google Play Store.

Right to Correct Inaccurate Information

You have the right to request that we correct inaccurate personal information we hold about you.

However, under the CCPA, we may deny your correction request if we reasonably determine that the data is already accurate.

Right to Opt-Out of Sale or Sharing of Cookies Data

Under the CCPA, some third-party cookies embedded on our website allow parties to collect browser or device data, which may be used for:

Interest-based advertising;
Cross-context behavioral advertising.
This may constitute a “sale” or “sharing” of your personal data.

We use cookies for the following sale/sharing purposes:

Promoting and selling our services;
Displaying interest-based or behavioral advertisements.

You may opt out by:

Enabling Global Privacy Control (GPC) or another legally recognized mechanism;
Note: GPC must be enabled per browser and device session.
GPC is distinct from “Do Not Track” signals.
Once opted out, we will not request re-authorization of cookie sales or sharing for at least 12 months.

We do not knowingly sell or share the personal data of minors under 16.

How to Exercise Your Rights

To exercise the rights described above, you must send us a request that:

Provides sufficient information to verify your identity; and

Clearly describes your request so we can understand, evaluate, and respond.

We treat requests that meet these criteria as “Valid Requests.”
We may not respond if a request does not meet these criteria.
We will only use personal data provided in a request to verify your identity or authority to make the request.

You do not need to have an account with us to submit a valid request.

We will respond to valid requests within 45 days of receipt.
We will not charge a fee to process your request unless:

The request is excessive, repetitive, or manifestly unfounded.
If a fee is necessary, we will inform you of the cost and rationale before proceeding.

To submit a valid request:

Email us at: [EMAIL PLACEHOLDER: ws@letshealth.cn]

Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA.

This means we will not:

Deny you access to our services;
Charge different prices or rates;
Provide a different level or quality of service.
However, where permitted by law, we may offer different service tiers or pricing based on the value of the personal data you voluntarily provide.

Other U.S. State Law Privacy Rights

California Civil Code §§ 1798.83–1798.84

You may request that we not disclose your personal information to third parties for their direct marketing purposes.
Please send your request to: ws@letshealth.cn

Nevada Resident Rights

Nevada residents have the right to opt out of the sale of their personal data to third parties.

To exercise this right, please contact us:

Email: ws@letshealth.cn
Subject: “Nevada Do Not Sell Request”
Include your name and account email.

Note: We currently do not sell data as defined by Nevada Revised Statutes Chapter 603A.

EU & UK Residents – GDPR Rights

If you reside in the:

European Union (EU),
United Kingdom (UK),
Liechtenstein,
Norway,
Iceland,
you have additional rights under the General Data Protection Regulation (GDPR).

Most Days is the data controller for your personal data when using our services.

Legal Bases for Processing

We collect and use personal data as described earlier under:

“Categories of Personal Data We Collect”
“How We Use Your Personal Data”

Our legal bases for processing include:

Contractual Necessity
We process the following data to fulfill our agreement with you:

Health-related data (certain features may not function if this data is not provided)

Legitimate Interests
We process the following for our or a third party’s legitimate interests:

Personal and contact information
Payment data
Device/IP data
Website analytics
Location data
Inferred data (e.g., behavioral preferences)
Purposes include:
Service operation and improvement
Customer support
Fraud prevention and security
Legal compliance
Business transactions

Consent
In specific cases (e.g., collecting Apple Health data), we process data based on your explicit consent.
Other Legal Bases
Including:

Legal obligations
Protection of vital interests
Tasks carried out in public interest

Your GDPR Rights

If you are an EU/UK data subject, you have the following rights (to exercise them, contact [EMAIL PLACEHOLDER: ws@letshealth.cn]):

Right of Access – Request a copy of your personal data we hold. You can also view some data by logging into your account.

Right to Rectification – Request correction or completion of inaccurate or incomplete data. You may update some info via your account.

Right to Erasure (“Right to Be Forgotten”) – Request deletion of all or part of your data from our systems.

Right to Withdraw Consent – If data processing is based on consent, you may withdraw consent at any time (you may need to re-authorize features).

Right to Data Portability – Request a machine-readable copy of your data or have it transferred to another controller (where technically feasible).

Right to Object – Object to specific uses of your data, such as direct marketing.

Right to Restrict Processing – Request restriction of processing under certain conditions.

Right to Lodge a Complaint – File a complaint with your local data protection authority.

EU authorities list: https://edpb.europa.eu/about-edpb/board/members_en

International Data Transfers

Our services are hosted and operated in the United States.

If you are located outside the U.S., by using the service, you:

Consent to the transfer of your personal data to the United States;
Consent to the storage and processing of your data in the U.S. and possibly other jurisdictions.
Some data transfers may be governed by a Data Processing Agreement based on Standard Contractual Clauses (SCCs).

Changes to This Privacy Policy

We may update this Privacy Policy from time to time based on changes to our services.

When we make changes, we will notify you by:

Posting a notice in the app;
Sending you an email;
Or through other reasonable methods.

If you’ve disabled legal notice emails, we will still consider you notified once the new version is posted.

Your continued use of the service constitutes acceptance of the updated Privacy Policy.

The use of information is subject to the Privacy Policy version in effect at the time of data collection.

Contact Information

If you have any questions about this Privacy Policy, our data practices, or your rights, you may contact us at:

Website: https://www.letshealth.cn/timeLeft/en/#/
Email: ws@letshealth.cn