FROMM FORM CONSUMER HEALTH DATA PRIVACY POLICY
This Consumer Health Data Privacy Policy explains how Wesley Fromm, doing business as FROMM FORM (“FROMM FORM,” “we,” “us,” or “our”) collects, uses, and discloses consumer health data through FROMM FORM and NAVPOINT by FROMM FORM (“NAVPOINT”).
This policy is separate from our general Privacy Policy.
It is intended to describe consumer health data practices clearly, including practices addressed by laws such as the Washington My Health My Data Act where those laws apply.
1. What We Mean by Consumer Health Data
For purposes of this policy, “consumer health data” means personal information that identifies or can reasonably be linked to a consumer and that relates to or reveals the consumer’s physical or mental health status, fitness, nutrition, bodily functions, health-related conditions, or similar wellness information where applicable law treats that information as consumer health data.
FROMM FORM provides fitness and nutrition coaching, not medical diagnosis or treatment.
2. Categories of Consumer Health Data We Collect
Depending on what you provide and which coaching features you use, we may collect the following categories.
Fitness, exercise, and performance information
Examples include:
- training history;
- strength and conditioning experience;
- exercises and workouts;
- workout completion;
- sets, repetitions, load, intensity, and performance;
- cardio activity;
- equipment availability;
- movement or exercise feedback.
Purpose:
- create individualized programming;
- track execution;
- review progress;
- adjust future programming;
- support coaching decisions.
Body and progress information
Examples include:
- body weight;
- body measurements if provided;
- body-composition information if provided;
- progress photographs;
- physical-performance trends.
Purpose:
- monitor progress toward client-selected goals;
- inform coaching adjustments;
- maintain progress history.
Nutrition information
Examples include:
- protein, carbohydrate, and fat intake;
- food logs;
- nutrition adherence;
- food preferences;
- dietary restrictions;
- allergies you choose to disclose;
- nutrition-related goals and habits.
Purpose:
- establish and adjust individualized macro targets;
- evaluate adherence;
- provide nonmedical nutrition coaching;
- support sustainable behavior change.
Recovery and wellness information
Examples include:
- recovery;
- fatigue;
- soreness;
- sleep information you choose to provide;
- stress information you choose to provide;
- perceived exertion;
- schedule or lifestyle factors affecting coaching.
Purpose:
- assess training tolerance;
- adjust workload;
- support safe and realistic programming;
- inform weekly coaching decisions.
Pain, injury, limitations, and health context
Examples include:
- pain or discomfort;
- injuries;
- physical limitations;
- clinician-provided restrictions you choose to tell us about;
- medical conditions, medications, pregnancy-related information, or other health context you voluntarily disclose because it affects exercise or nutrition.
Purpose:
- understand coaching limitations;
- avoid knowingly prescribing work inconsistent with disclosed restrictions;
- determine when coaching should be modified, paused, or referred outside FROMM FORM’s professional scope.
FROMM FORM does not use this information to diagnose or treat a medical condition.
Coaching reports and derived coaching information
Examples include:
- weekly FITREPs;
- evidence snapshots;
- adherence summaries;
- coaching recommendations;
- Coach Decisions;
- client-facing Orders;
- progress assessments derived from the information above.
Purpose:
- operate NAVPOINT’s weekly coaching cycle;
- synthesize what happened;
- make and document coaching decisions;
- communicate the next plan.
3. Sources of Consumer Health Data
We collect consumer health data from categories of sources including:
- you directly;
- information you submit through the FROMM FORM application process;
- information you enter into NAVPOINT;
- FITREPs and coaching communications;
- workout, cardio, nutrition, body-weight, and progress logs you provide;
- progress photographs you upload;
- information you communicate during coaching calls;
- coach observations and coaching records created as part of providing the service.
FROMM FORM does not currently require you to connect an electronic medical record, wearable, Apple Health account, or other third-party health-data account in order to receive coaching.
If a future product begins collecting new categories of consumer health data or data from new sources that require additional disclosure or consent, the applicable policy/consent must be updated before that collection begins.
4. Why We Collect and Use Consumer Health Data
FROMM FORM collects and uses consumer health data primarily because it is necessary to provide the fitness and nutrition coaching service the client requested.
Purposes include:
- understanding goals and baseline;
- creating individualized programming;
- setting and adjusting macronutrient targets;
- reviewing workout/cardio/nutrition execution;
- evaluating recovery and adherence;
- reviewing the weekly FITREP;
- producing factual coaching evidence/snapshots;
- generating advisory recommendations;
- supporting the human Coach Decision;
- issuing client-facing Orders;
- adjusting the next Prescription;
- monitoring progress;
- responding to client questions;
- addressing disclosed safety concerns or limitations;
- providing and administering the coaching relationship.
FROMM FORM does not use consumer health data to create unrelated advertising profiles.
5. Categories of Consumer Health Data We Disclose
We disclose only the consumer health data reasonably necessary for the requested service or another purpose permitted by law.
Depending on the service and context, disclosed categories may include:
- identity/contact information associated with coaching;
- application/intake information;
- limited fitness, goals, barriers, training, or real-life context;
- scheduling-related coaching context;
- coaching communications or records where necessary to operate the service.
We do not sell consumer health data.
We do not disclose consumer health data to advertising networks, data brokers, or social-media platforms for targeted advertising.
6. Categories of Recipients
Consumer health data may be processed or made available to categories of service providers that help FROMM FORM provide the service requested.
These may include:
Database and application infrastructure providers
Examples include Supabase and other infrastructure that stores or processes NAVPOINT data.
Hosting and deployment providers
Examples include Vercel and other providers necessary to operate the web application.
Google Workspace
Google Workspace supports coaching-related business email, Google Calendar, scheduling, Google Meet, and business-owned meeting artifacts.
For an applicant who has booked an intro call, a limited derived copy of application context may be placed in the assigned coach’s exact Google Calendar event so the coach can prepare for the requested call.
Professional advisers and service providers
Attorneys, accountants, insurers, security professionals, or contractors may receive limited information when reasonably necessary to provide services to FROMM FORM and subject to applicable confidentiality/legal obligations.
Authorities or legal recipients
Information may be disclosed when required by law or reasonably necessary to establish, exercise, or defend legal claims or protect safety.
7. Affiliates
As of this version of the policy, FROMM FORM does not have affiliates with which it shares consumer health data.
If that changes, this policy will be updated as required before health data is used or disclosed for a new purpose requiring additional notice or consent.
8. Sale of Consumer Health Data
FROMM FORM does not sell consumer health data.
FROMM FORM does not receive money or other consideration in exchange for providing identifiable client health/wellness information to data brokers, advertisers, or similar third parties.
If this practice ever changes, it would require a new legal/privacy analysis and any authorization required by applicable law. It is not authorized by this policy.
9. Targeted Advertising
FROMM FORM does not use private coaching or consumer health data for unrelated targeted advertising.
Consumer health data should not be placed into advertising pixels, advertising audiences, data-broker systems, or social-media advertising profiles merely because a person uses FROMM FORM or NAVPOINT.
10. Consumer Rights
Where applicable law provides consumer health data rights, those rights may include the ability to:
- confirm whether FROMM FORM is collecting, sharing, or selling your consumer health data;
- access your consumer health data;
- obtain information about third parties or affiliates to whom consumer health data has been shared or sold where required;
- withdraw consent to future collection or sharing when the collection or sharing is based on consent;
- request deletion of consumer health data;
- appeal a refusal to act on an eligible request.
You may submit a request by emailing:
You do not have to create a new account solely to submit a privacy request.
FROMM FORM may request information reasonably necessary to authenticate your identity and the request.
Where the Washington My Health My Data Act applies, FROMM FORM will respond without undue delay and generally within 45 days, subject to an additional 45-day extension where legally permitted and reasonably necessary.
If deletion obligations apply to archived or backup systems, deletion from those systems may occur on the timeline permitted by applicable law.
11. Appeals
If FROMM FORM refuses to take action on a consumer-health-data request for which applicable law provides an appeal right, you may appeal by replying to the decision or emailing:
with the subject:
Consumer Health Data Privacy Appeal
FROMM FORM will respond to an eligible appeal within the period required by applicable law.
If an appeal is denied and applicable law requires it, FROMM FORM will provide information about how to submit a complaint to the appropriate regulator.
12. Withdrawal and the Coaching Service
Some consumer health data is necessary to provide individualized fitness and nutrition coaching.
If you withdraw permission for processing that is necessary to provide a requested coaching service, FROMM FORM may no longer be able to provide some or all of that service.
Withdrawal does not require FROMM FORM to erase information that applicable law permits or requires us to retain.
13. Security
FROMM FORM uses administrative, technical, and organizational measures intended to protect consumer health data appropriate to the information and the service.
Access should be limited to the people and service providers who reasonably need the information to provide or operate the requested service.
No connected system can guarantee absolute security.
If a breach triggers consumer-health-data notification requirements under applicable law, FROMM FORM will provide required notifications.
14. Geofencing
FROMM FORM does not use geofencing around healthcare facilities to identify, track, collect, or infer consumer health data.
15. New Categories or Purposes
FROMM FORM will not intentionally begin collecting, using, or disclosing additional categories of consumer health data for materially new purposes without first updating the required disclosures and obtaining affirmative consent where applicable law requires it.
16. Changes to This Policy
Each published Consumer Health Data Privacy Policy version has its own effective date.
A new version will not silently rewrite the historical version associated with an earlier Enrollment Legal Acceptance.
17. Contact
Questions, requests, or appeals concerning consumer health data may be sent to:
FROMM FORM
Wesley Fromm
Email: wes@frommform.com