Happy Charlie Consumer Health Data Notice

Version 2026-10-10.1 · Effective on publication after approval

Publication candidate. This version is now the application's legal source. Entity/contact fields and the publication conditions below remain pending; promotion does not approve unresolved legal or vendor issues or change historical consent.

1. Scope

This notice is available throughout the United States. Rights, consent requirements, response periods and other obligations apply to the extent required by the law governing the relevant person, information and processing, including applicable federal and state law. Availability of this notice does not extend a jurisdiction's statutory rights beyond its coverage. The Privacy Notice explains other personal information and platform practices.

2. Categories

Happy Charlie collects caregiver-entered care records, not a clinical medical record. Consumer health data is a separate legal category: information linked or reasonably linkable to a person that identifies their physical or mental health status under the applicable statute, which can include bodily functions, measurements, medication and qualifying inferences. A clinician need not have created it. Washington definition.

The categories below identify where such information can occur. A standalone food catalogue name, ordinary photo or generic technical identifier is not automatically consumer health data; linkage, content, use and the governing definition matter. Separately, Happy Charlie applies restricted-data protection to all care entries and free text as a precautionary product policy. That protective classification is not a claim that every item is a health record, or that it is HIPAA protected health information.

Relevant categories include:

• Feeding and foods: nursing/bottle records, pumping output, solid-food records and observations, family food names/types and optional pictures associated with those records.
• Sleep, elimination and activity: sleep intervals, diapers/observations, tummy time and their recorded times/durations.
• Measurements and health observations: weight, temperature, manually entered medicine/supplement details and associated notes.
• Milestones and retained history: caregiver-recorded/added milestones, measured milestones and retained legacy goal records, where present.
• Free text: care notes, support questions/replies and suggestions that contain health information.
• Derived information: totals, averages, intervals, trends and measured milestones calculated from the family's records.
• Linked identity: child name/nickname, birth date, optional profile photo, the U.S. state, district or territory the child lives in, relevant child/record identifiers and caregiver attribution when linked to health information. Pumping/support information can concern an adult as well as a baby.
• Optional integration information: relevant speech, Siri choices/replies, and linkable installation/delivery information to the extent it identifies or reasonably permits a health inference. A care-free wake-up payload alone does not decide that classification.

Properly de-identified information that cannot reasonably be linked to a person is handled under applicable de-identification conditions. We do not re-identify it.

3. Sources

Sources are caregivers' app/web entries, selected imported export files, support/suggestion submissions and email replies, selected speech/assistant services, and our own calculations. Chosen services also produce operational/integration information needed for the requested feature.

Import files are read on the phone or in the browser, not uploaded. Only confirmed supported entries are saved with their source; temporary app-controlled copies are removed after the step, or at the next start if a crash left one behind. We do not directly retrieve care histories from other tracker companies, buy health data, or receive care histories from brokers or advertising networks.

4. Purposes and processing

We store, organise, synchronise and display family records, preserve their correction/attribution history, calculate requested totals/trends, record milestones/foods and produce requested exports/summaries. We handle support information to answer the person's question and suggestions to consider product feedback. Limited operational processing protects and maintains the requested service or meets applicable legal obligations.

Optional speech transcribes an entry. Siri (on by default on iPhone, with a one-time notice; can be turned off) supplies timer/diaper/name choices and receives actions/replies. Optional push wake-ups help an enabled phone refresh its local lock-screen display. Their exchanges and separate provider practices are identified below.

We do not sell consumer health data or use it for advertising or audience building. We may use care records to train and evaluate AI models to improve the accuracy, reliability and functionality of Happy Charlie, only as permitted by applicable law. Where applicable law requires consent, we obtain it before using the information for training, including separate consent for sharing where required.

We do not make solely automated decisions with legal or similarly significant effects about people. Optional platform services can have separate improvement practices; their inclusion here does not approve an otherwise prohibited use under law, contract or Happy Charlie's vendor restrictions.

Where required by law, specific consent must precede collection or sharing; sharing consent is separate from collection consent where the law requires. The necessary-requested-service exceptions are assessed for each flow, not inferred from signing up or accepting Terms. A purpose that another provider independently chooses is not automatically necessary for the service the person requested.

5. Sharing categories and recipients

Hosting/support processors must be bound to reviewed instructions and permitted purposes. Optional platform services can perform separately governed processing. The Privacy Notice §5 explains the provider distinctions and links their practices. This notice does not promise that every platform service acts only on our instructions or has no independent use.

The table identifies recipient categories and material known providers; it is not the request-specific list of actual third parties/affiliates and active online contacts. We supply that list where applicable law requires it. Any affiliate receiving health data must be identified as required by applicable law; the actual affiliate list is [[AFFILIATE REGISTER — confirm none or name each]].

We do not embed advertising pixels, session replay or cross-context advertising tracking. Chosen providers' own technical/service practices must be reviewed separately; a broad promise about all third-party behavior across unrelated services is not made without that evidence.

6. Location and geofencing

Happy Charlie does not collect precise location or geofence hospitals, clinics, pharmacies or other health-care locations to identify, track, collect data about or message people. Platform services can have their own device/location settings and practices; Happy Charlie's prohibition is not a statement that Siri or a delivery provider receives no technical/location information.

Each child's profile records the U.S. state, district or territory the child lives in, chosen by a caregiver, so we know which state's law applies. When a child is added, the choice is pre-filled with a suggestion from the approximate region Cloudflare derives from the request's network (IP) address; our servers receive only the country and region for that request, not the address, and store neither. Only the state the caregiver saves is kept.

7. Retention and deletion

Shared care records remain for the family's requested history while that purpose continues and retention is lawful. Record/child/family deletion controls and statutory requests determine what is removed. Account closure alone does not automatically delete shared records or former-member display-name attribution.

We retain information for the disclosed purposes for as long as needed and permitted by applicable law. Production and backup deletion, including applicable deadlines and permitted exceptions, are assessed under that law. The retention criteria for shared records, replaced/removed images, support and suggestions are in Privacy Notice §6. Internal operating targets are not additional contractual or statutory deadlines.

Account closure does not itself erase Apple/Google histories. We perform the deletion, recipient notification and follow-up required by applicable law. Contractual and provider retention must satisfy applicable law; disclosures do not waive deletion rights.

8. Rights, consent withdrawal and requests

Depending on applicable law, rights may include confirmation/access, a portable copy, correction, deletion, withdrawal of consent, actual third-party/affiliate identities and online contacts, appeal, and sale/targeted-advertising/consequential automated-profiling opt-outs. We provide the rights required by the law governing the relevant person, information and processing. We do not currently engage in sale, targeted advertising or consequential automated profiling; ordinary family/provider disclosures are distinguished from advertising “sharing.”

You may act for yourself or through a lawful representative, including a child's verified parent/guardian. A current account or family administrator role is not required to submit a statutory request. Verification is limited to reasonably necessary identity/authority information. We do not deny a statutory right merely because another caregiver can see the record or the requester lost family access.

Request: email support@happy-charlie.com with the right sought and enough information to identify the relevant person/records. Do not send a full health history or unnecessary identity documents. We may request narrowly necessary verification through a secure channel; no new account is required.

Timing: we handle covered requests within the period required by applicable law, using only extensions and exceptions that law permits and providing required notices. Washington's normal health-request clock is 45 days from receipt; Nevada's begins after authentication. Verification does not restart Washington's clock. Where no legal right applies, we may consider a request without committing to a particular outcome or response period.

Appeal: where applicable law provides an appeal right, reply to the privacy contact saying you appeal. We provide the review, response, reasons and complaint route required by that law. Washington/Nevada require an appeal response within 45 days. Relevant regulator complaint routes include Washington AG, Nevada AG and Connecticut AG.

Required rights responses are free at the statutory frequency. Any excessive-request fee/refusal is limited to what applicable law allows, with required explanations. We do not unlawfully discriminate for exercising a right. Withdrawal can prevent processing necessary for the requested service; we provide any required explanation, and withdrawal does not waive a separate deletion right.

Withdraw optional off-device speech or Happy Charlie's Siri timer/name permission in Settings → Privacy; turn off lock-screen status in Settings → Lock screen. These stop the respective future app integration and do not disable the platform itself or erase its existing history. Other collection/sharing withdrawal requests can be sent to the privacy contact. The adequacy of the actual consent controls remains a publication condition.

Self-service account/child/family controls are explained before confirmation. Statutory requests can require a different result; we provide the explanations of retained categories and lawful reasons required by applicable law. Product administrator succession rules do not eliminate the last administrator's statutory rights.

9. Changes

A material change has a new version/effective date and legally required notice. Before a covered new category, use, purpose or recipient is introduced, we obtain affirmative consent where required. A generic provider category or an edited page does not automatically permit a new Nevada recipient or materially different processing. Existing acknowledgments do not become consent merely because this notice changes.

10. Contact

TMIC, Inc.
70 Hemlock Dr. Holland PA 18966

• Consumer health data requests and appeals: support@happy-charlie.com
• Security: support@happy-charlie.com

Publication conditions — internal, remove only after completion

1. Complete core sensitive/known-child and representative consent analysis, including Connecticut; do not use Terms acceptance or the first-entry acknowledgment as universal health-data consent.
2. Resolve Siri's vendor/spec conflict and Apple's contract restriction; confirm outgoing identifiers/replies and protected-data/no-passcode behavior. The existing local acknowledgment is not the full PR-3 evidence record.
3. Approve the actual speech provider, all health-data processors and platform roles; complete push metadata/inference/installation deletion review, affiliate register and active recipient contacts.
4. Staff rights/appeals and operational deletion, including non-account/representative requests and shared records; verify retention, provider deletion and backup obligations.
5. Complete entity/contact fields; keep this policy separate and prominently linked on the homepage. Final public copy must omit internal publication notes and have no extraneous content.
6. The app now uses this source and version. Reconcile remaining first-entry, Siri, push, deletion and minor-user gaps before release; promotion does not change those controls.
7. Before any AI-training activation, resolve NR-08, including law coverage, specific disclosures, required consent and existing notice/Terms commitments. Verify retention criteria and actual category-specific handling, including fixed intended periods where applicable law requires their disclosure; internal PR-5 targets are unchanged and are not new public deadlines.