Revly Consumer Health Data Privacy Policy

Effective date: 15 July 2026 Last updated: 15 July 2026

This Consumer Health Data Privacy Policy is a separate, supplemental policy that applies to residents of Washington State (under the My Health My Data Act, RCW 19.373), Nevada (under NRS Chapter 603A, as amended by SB 370), and Connecticut (under the Connecticut Data Privacy Act, as amended).

It explains how Revly handles data that those laws may treat as “consumer health data” (“CHD”). It supplements — and does not replace — our general Privacy Policy. Where this policy and the general Privacy Policy conflict for residents of those states, this policy controls with respect to CHD.

1. Who We Are

• Regulated entity / publishers: Gökdeniz Kaymaz and Suat Emir Atabey (joint controllers)
• App: Revly — a driving and ride-tracking journal and social application
• Contact email: support@joinrevly.com
• Address: Available on request via the contact email above

We are a small independent developer team. We do not operate a health service, and Revly is not a medical, fitness, or health application.

2. Why a Driving App Has This Policy

Revly is not a health app, and we do not set out to collect health information. However, the My Health My Data Act defines “consumer health data” very broadly — broadly enough that it can include precise location information and biometric or bodily-function data, because such data could, in theory, reveal something about a person’s health or their attempt to seek health services.

Because Revly records precise GPS location and motion-sensor telemetry while you record a drive, we take a cautious approach and treat the categories below as CHD for residents of the states listed above — even though this data is generated by driving, not by health care.

3. Categories of Consumer Health Data We Collect

We treat the following as CHD for the purposes of this policy:

We do not collect medical records, diagnoses, prescriptions, health-insurance information, genetic data, or biometric identifiers.

4. Sources of This Data

All CHD listed above comes from one source: you and the device you use Revly on — specifically, your device’s GPS, accelerometer, and gyroscope, and the content you choose to upload or enter.

We do not buy, license, or obtain CHD from data brokers, advertising networks, or any other third-party source.

5. How and Why We Use This Data

We process CHD only to operate the features you ask for:

We do not use CHD for advertising, profiling, cross-app or cross-site tracking, or any purpose unrelated to operating Revly. We do not ask for permission under Apple’s App Tracking Transparency framework because we do not track you across other companies’ apps and websites.

6. Who We Share It With

We share CHD only with processors who handle it on our behalf and under contract, and only as needed to run the app:

We have no affiliates with whom we share CHD.

We do not share CHD with advertising networks, data brokers, analytics resellers, or any party for their own independent purposes.

7. We Do Not Sell Consumer Health Data

We do not sell your consumer health data, and we have never done so. “Sale” here has the meaning given by the My Health My Data Act — an exchange of consumer health data for monetary or other valuable consideration.

Because we do not sell CHD, we do not collect the separate valid authorization that the law would require for a sale. If this ever changes, we will update this policy and obtain that separate authorization before any sale occurs.

8. Consent

We collect and process CHD only to provide the features you actively choose to use:

• Precise location and motion telemetry are collected only while you are recording a drive — an action you start.
• Live convoy location is shared only when you join a convoy and enable live sharing — and stops when you leave or the session ends.
• Coarse location is used only when you use exploration features.
• Photos and videos are processed only when you upload them.

iOS also requires you to grant location and photo permissions before we can access that data at all.

Withdrawing consent. You can withdraw consent at any time by:

• ending or not starting a ride recording;
• leaving a convoy or turning off live sharing;
• revoking Revly’s location or photo permissions in iOS Settings → Privacy & Security; or
• deleting your account in the app.

Withdrawing consent does not affect processing that already took place before you withdrew it.

9. Data Retention

• Ride data, routes, and ride metadata — retained while your account is active.
• Live convoy location — ephemeral. It exists only during an active convoy session and is removed when the session ends or you leave.
• Photos and videos — retained while your account is active or until you delete them.
• Diagnostic and analytics data — retained for limited periods per Firebase’s retention settings.

When you delete your account, we delete or anonymize your CHD from our cloud systems (Cloud Firestore, Cloud Storage, Realtime Database) and clear your on-device cache, except where we must retain limited records to comply with legal obligations, resolve disputes, or enforce our Terms. Backups are retained for a limited period and then expire.

10. Your Rights

If you are a resident of Washington, Nevada, or Connecticut, you have the right to:

• Confirm whether we collect, share, or sell your CHD;
• Access your CHD, including a list of all third parties with whom we have shared it (and, where applicable, contact information for those third parties);
• Withdraw consent to our collection and sharing of your CHD;
• Delete your CHD — including, where required, having us direct our processors to delete it;
• Not be discriminated against for exercising any of these rights.

The fastest way to delete your data is the in-app account deletion feature (Profile → Settings → Delete Account), which removes your cloud and local data as described above.

How to exercise your rights

Email support@joinrevly.com with your request. We may need to verify your identity — typically via the email address on your account — before we act. We will respond within the timeframes required by applicable law (generally 45 days under the My Health My Data Act, extendable by a further 45 days where permitted, with notice to you).

Appeals

If we deny your request, we will tell you why and how to appeal. To appeal, reply to our response or email support@joinrevly.com with the subject line “CHD Appeal.” We will respond to your appeal within 45 days. If we deny your appeal, we will provide you with a method to contact the Washington State Attorney General (or your state’s Attorney General) to submit a complaint.

11. No Geofencing Around Health Care Facilities

The My Health My Data Act prohibits geofences around entities that provide in-person health care services where the geofence is used to identify or track consumers, collect consumer health data, or send health-related advertisements.

Revly does not do this. We do not operate any geofence around health care facilities, we do not use location to infer health-service visits, and we do not send health-related advertising of any kind. Revly’s location processing exists solely to record the drive you choose to record and to power the convoy and exploration features you choose to use.

12. Changes to This Policy

If we make material changes to this policy, we will update the “Last updated” date above, post the revised policy at this URL, and — where the law requires — notify you and obtain any newly required consent before applying the change to previously collected CHD. We will not apply material changes retroactively to CHD collected before the change without your consent.

13. Contact Us

Questions, requests, or complaints about your consumer health data:

• Gökdeniz Kaymaz and Suat Emir Atabey
• Email: support@joinrevly.com
• Address: Available on request via the contact email above

Washington residents may also have a private right of action under the Washington Consumer Protection Act (RCW 19.86) for violations of the My Health My Data Act.