Legal

Privacy Policy

Last updated: 21 October 2026 · Effective on the date Phasly is made publicly available.
Plain-English summary: Phasly is a health app, so we handle some of the most sensitive data there is. We collect only what we need to personalise your training, we keep your intimate data in a separate private space, and your data is encrypted in transit and at rest. It is never sold, never used for ads and not used to train AI models. You can export your data, and you can delete your data any time. The full detail is below.
Important. Not a medical device. Phasly is a wellbeing tool, not a regulated medical device. We do not provide medical advice or diagnosis, and we do not use cycle data for contraception decision-making. If something feels off, like heavy bleeding, severe pain or missed periods, please consult a clinician (ACOG Committee Opinion 651).
1. Who we are
2. What we collect
3. How we use your data
4. Legal bases & consent
5. Who we share data with
6. How we protect your data
7. How long we keep it
8. Your rights & choices
9. Children
10. International transfers
11. Changes to this policy
12. Contact us

1. Who we are

Phasly LLC, a California limited liability company ("Phasly", "we", "us" or "our"), provides a cycle-aware fitness and wellbeing application that personalises training to your menstrual cycle and to how you feel each day. This Privacy Policy explains what personal information we collect, how we use and protect it, and the choices you have. It applies to our website, our mobile apps and any related services (together, the "Service").

For the purposes of data protection law, Phasly LLC is the data controller of the personal information described here. Our registered address is:

Phasly LLC
Northwest Registered Agent, Inc.
2108 N St, Ste N
Sacramento, CA 95816
United States
+1 424-540-2333

2. What we collect

Information you give us

Information we collect automatically

We do not use your health or intimate data for advertising, and we do not allow advertisers to target you based on it.

3. How we use your data

Where the GDPR or similar laws apply, we rely on the following legal bases: your consent (especially for health and intimate data, which are special-category data), performance of a contract (to provide the Service you sign up for), legitimate interests (to secure and improve the Service, balanced against your rights), and legal obligation where required.

Before you enter any health information, the app asks for your explicit consent in two separate checkboxes. One covers processing your health and cycle data to personalise your plan. The other covers sending your messages and relevant cycle context to Anthropic, our AI provider, so Phoebe can reply. We record when you gave each one.

You can withdraw your consent at any time by editing or deleting the relevant data or your account. Withdrawing consent doesn't affect processing that already happened.

5. Who we share data with

We do not sell your personal information. We share it only with service providers ("processors") who help us run the app, under contracts that require them to protect it and use it only on our instructions. These currently include:

We may also disclose data if required by law, to protect our rights or users' safety, or in connection with a merger or acquisition (in which case we'll notify you).

5a. Consumer Health Data Privacy Policy

This section is our consumer health data privacy policy under the Washington My Health My Data Act, Nevada SB 370 and similar state laws, and it sets the special rules we hold ourselves to. Your cycle, symptom, body measurement, pregnancy, contraception and intimate data are special-category health data. On top of everything above, these rules apply specifically to them:

6. How we protect your data

We use industry-standard safeguards, including encryption in transit (HTTPS/TLS) and at rest (AES-256), access controls and database row-level security so each user can only reach their own data, and secure storage of authentication tokens on your device. No system is perfectly secure, but we work hard to protect your information and to limit who can access it internally.

7. How long we keep it

We keep your personal data for as long as your account is active or as needed to provide the Service. If you delete specific entries, they are removed from your account. If you delete your account, your data is removed from our live database immediately. Encrypted database backups roll off on our provider's schedule. Our processors keep limited records, such as email logs, crash reports and purchase records, for their own retention periods. We keep limited records only where the law requires it.

8. Your rights & choices

Depending on where you live, you may have the right to:

You can exercise most of these rights directly in the app (Profile Settings → Delete account removes everything), through the deletion request form if you no longer have the app installed, or by emailing us at privacy@phasly.app. We won't discriminate against you for exercising your rights.

California (CCPA/CPRA). California residents have the right to know what personal information we collect and how it's used, to access and correct it, to delete it, and to opt out of "sale" or "sharing" of personal information. Phasly does not sell your personal information and does not share it for cross-context behavioural advertising. To exercise these rights, use the in-app controls or email privacy@phasly.app. we will verify and respond within the statutory window.

EU/EEA and UK (GDPR). The rights above (access, rectification, erasure, restriction, objection, portability, withdrawal of consent) apply in full, and you may lodge a complaint with your supervisory authority. Health and intimate data are processed on the basis of your explicit consent.

9. Children

Phasly is not directed to children. You must be at least 18 years old to use the Service. We do not knowingly collect data from anyone under 18. If you believe someone under 18 has provided us data, contact us and we will delete it.

10. International transfers

Your data may be processed in countries other than your own, including where our service providers operate. Where required, we use appropriate safeguards (such as Standard Contractual Clauses) to protect your data when it is transferred internationally.

11. Changes to this policy

We may update this Privacy Policy as the Service evolves. If we make material changes, we'll update the "Last updated" date and, where appropriate, notify you in the app or by email. Continued use of the Service after changes take effect means you accept the updated policy.

12. Contact us

Questions, requests or concerns about your privacy? Email us at privacy@phasly.app. We read every message.

Or write to the data controller:

Phasly LLC
Northwest Registered Agent, Inc.
2108 N St, Ste N
Sacramento, CA 95816
United States
+1 424-540-2333