Effective date: September 8, 2026
Last updated: September 8, 2026

What this policy is

Some laws — including Washington State's My Health My Data Act — treat information about your physical or mental health, including inferences about it, as "consumer health data" requiring its own, separate disclosure. This policy is that disclosure. It applies regardless of where you live, because Fresh Start doesn't currently vary its practices by location.

Categories of consumer health data we collect

• Information you share about how you're feeling, your emotional state, and factors contributing to it (job loss circumstances, family situation, financial runway as ranges).
• Direct disclosures about thoughts of self-harm, when you choose to share them or when our safety check-in asks and you respond.
• Patterns Fresh Start infers from the above over time (for example, a sustained low mood across several weeks). We can tell you whether we hold inferences like this about you, and deleting your account deletes them too — but because they're derived, not something you directly gave us, they aren't included in the data-export file described in the Privacy Policy, Section 9.
• A minimal record of any safety/crisis flag: when it occurred, its severity tier, and what happened next — not a transcript.

Where this data comes from

Directly from you — what you type into the product during signup, daily check-ins, and conversation. Fresh Start does not buy or receive consumer health data about you from any outside source.

Why we collect and use it

• To provide the coaching and companionship service itself, including remembering your situation across sessions.
• To notice patterns relevant to your coaching over time.
• To detect possible safety concerns and connect you to real human help — see the Privacy Policy, Section 6, for the full description.
• To meet a legal reporting obligation that requires only an aggregate count of crisis referrals issued, with no individual identifiers.
• To respond to a payment dispute, using only account and billing metadata — never this data.

We do not use consumer health data for advertising, and we do not sell it, under any circumstance.

Who we share it with

• The vendors that process it on our behalf to run the product — the AI coaching model, the separate safety-classifier system, and the database host — each under contract for no-retention-beyond-service-need, no use of your data to train their own models, and no secondary use. Pending — none of the three is under contract yet; see [Privacy Policy](/policy/privacy) Section 8. This section will name each vendor once its contract is signed.
• Tzvika Besor, who currently operates Fresh Start, who may read relevant conversation content when our automated safety system flags a possible crisis — described fully in the Privacy Policy, Section 6. Ordinary account support (billing, login issues) never involves reading this data.
• Emergency services or law enforcement, only after human review finds an imminent threat of serious physical harm to you or an identifiable other person.
• If legally required to disclose something, we will, and we'll tell you unless the law forbids it.

We do not share consumer health data with any affiliate, advertiser, or data broker. Fresh Start currently has no corporate affiliates to share data with.

How long we keep it

90 days after your last activity, on the same schedule described in the Privacy Policy, Section 7.

Your rights

• Confirm whether we're processing your consumer health data — ask, and we'll tell you.
• Access the consumer health data we hold about you, by downloading your data (Privacy Policy, Section 9).
• Withdraw consent and have this data deleted, by deleting your account (Privacy Policy, Sections 4 and 9). There is no partial-withdrawal option, consistent with how the product is built.
• Appeal a denial of any of the above — write to the contact below and we'll respond.

To exercise any of these rights, contact us by mail at: 62 Krinitzi St., Ramat Gan, Israel. We will not charge a fee for a reasonable request, and we will respond within 45 days — extending once, by another 45 days if we reasonably need to, telling you before the original deadline if we do.

Changes to this policy

If what we collect, how we use it, or who we share it with changes, we'll tell you before the change takes effect.