Consumer health data privacy policy
This policy explains how Sawary Trading LLC handles consumer health data, as required by Washington's My Health My Data Act and Nevada's SB 370. It applies to everyone, not only residents of those states.
Everything else we collect is covered by our privacy policy.
Last updated 1 August 2026.
What we treat as health data
The Life Portrait asks 84 questions about how your life is going. Some concern your mood, your sleep, your energy, your relationship with food, and your relationship with your body. From your answers we calculate scores and place each of the seven areas into one of three bands.
We treat all of the following as consumer health data:
- Your individual answers to the cards
- How long you spent on each one
- The scores and sub-scores calculated from them
- The band assigned to each of the seven areas
- The area you tap as loudest for you
- Which product we recommend, since it's derived from the above
The bands are not diagnoses and we don't treat them as clinical findings. We treat them as health data anyway, because they're inferences about your health and that's what the law covers.
Where it comes from
From you, directly, when you take the Life Portrait. We don't buy health data, and we don't obtain it from anyone else.
Why we collect it
- To build your portrait and show it to you. This is the whole purpose.
- To recommend one product — the area with the lowest score, or the area you tapped.
- To send you your results by email, and to keep them at your link.
- To make the test more accurate, using records with your name and email removed.
We do not use it to target advertising. We do not use it to set prices.
Your consent
We ask before you start, and we ask separately for two different things:
- Consent to collect. Required to take the test, because there's no test without it.
- Consent to share with our email provider. Optional. This lets us send your results to Klaviyo so your emails can reflect what your portrait actually said. Decline it and you still get your full results on screen and your link — the emails are just less specific.
You can withdraw either at any time by emailing empower@hervanguard.com. Withdrawing stops future processing. It doesn't undo what already happened.
Who we share it with
| Who | Why | What they receive |
|---|---|---|
| Supabase | Stores your portrait and serves your link | Answers, scores, bands |
| Vercel | Hosts the site that calculates and displays it | Data in transit only |
| Klaviyo | Sends result-specific email, only with your separate consent | Scores, bands, priority area, recommended product |
These are service providers acting on our instructions under contract. They can't use your health data for their own purposes.
We have no affiliates with access to your consumer health data.
We may disclose it if the law compels us, or to prevent serious harm to someone.
We do not sell it
We have never sold consumer health data and we will not. Selling it would require your written, signed authorization, and we won't ask for one.
We do not share it with advertisers
Google Analytics and Meta receive no health data. They are not sent your answers, your scores, your bands, or your results page address.
How long we keep it
Until you ask us to delete it, or 3 years after you last use your account, whichever comes first.
Anonymous research records are kept indefinitely. Your name and email are never written to them, and they can't be traced back to you.
Your rights
You can ask us to:
- Confirm whether we hold consumer health data about you.
- Show you what we hold, and the list of everyone we shared it with.
- Delete all of it, including from our service providers and our backups.
- Withdraw consent to collect it or to share it.
Email empower@hervanguard.com. We confirm within 2 working days and complete within 30 days, or 45 if a request is complex, in which case we'll tell you why.
There's no charge, and asking never affects your access to anything you've bought.
If we say no. You can appeal by replying to our decision. We'll review it and respond within 45 days with our reasoning. If we still say no, you can complain to the Washington Attorney General at atg.wa.gov/file-complaint.
Changes
We update this when what we do changes. The date at the top tells you when. If a change is significant, we'll ask for your consent again rather than assume it.
Sawary Trading LLC, 30 N Gould St Ste R, Sheridan, WY 82801. empower@hervanguard.com