Prameya Privacy

OmniRx Consumer Health Data Privacy Policy

Effective date: 7 October 2026
App: OmniRx for iPhone and iPad, with its Apple Watch app, its Apple TV app, and its Mac and Apple Vision Pro versions — bundle ID legal.prameya.OmniRx
Publisher: Prameya LLC ("Prameya", "we", "us"), a US limited liability company
Contact: admin@prameya.legal

This is a separate policy, required by Washington's My Health My Data Act (RCW chapter 19.373) and
by Nevada's SB 370 (NRS chapter 603A). It deals only with consumer health data in OmniRx.

The main policy is here: OmniRx Privacy Policy.
All Prameya app policies: prameyallc.github.io/privacy.


The short version

OmniRx stores what you log about your medicines and how you feel on your own device. Prameya runs
no server that receives it. We do not share it. We do not sell it. Nobody at Prameya can see it. Your
medication records, journal entries and the list of medicines you follow do not go to iCloud.

A few things do leave the device, and all of them go to places tied to your own Apple Account, not
to us:

If you choose the optional on-device Ask model, the app downloads it from Hugging Face. That download
carries no consumer health data: it names the app and the model files, and nothing you typed or logged
(see About Hugging Face).

You can delete what you have logged yourself, from inside the app: More → "Delete all my data". It also
removes those iCloud values, cancels the daily reminder, deletes a downloaded Ask model and resets your
settings. Read the right to delete for what it does not reach.

We still treat all of this as consumer health data and still give you the rights below, because
Washington and Nevada define "collect" broadly enough to reach data that is processed on your device —
not only data that is sent somewhere.


Why you are reading a second policy

Washington's My Health My Data Act requires a business that handles consumer health data to publish a
distinct consumer health data privacy policy, linked separately, that says specific things.
Nevada's SB 370 requires substantially the same. This document says those things.

We publish it even though a fair argument exists that OmniRx's data never reaches us at all. The
question of whether "collect" is triggered when a developer never receives the data has not been
settled by the Washington Attorney General or by any court. We do not want your rights to depend on how
that argument comes out.


What counts as consumer health data in OmniRx

Consumer health data is personal information that identifies your past, present or future physical or
mental health status. In OmniRx that means the things you log about your medicines and your body, and
the things the app keeps that could reveal which medicines you take, or which medicines and conditions
you read about.

Categories collected, and why

Category What it is Why the app has it How it is used, and where it goes
Medicines you follow The names you type in "as on the bottle", and the names of medicines you have stopped following So the daily check and the reminder know what to mark Shown back to you. Kept in the app's settings storage on the device. Sent to your Apple Watch only if you turn on "Show medicine names on Apple Watch". Whether you follow any medicine (not which) is written to your own iCloud key-value storage for the Home Screen widget, which can show it wherever you place the OmniRx widget on a device signed in to your Apple Account
Medication records The date, the medicine name, and whether you marked it Taken or Skipped So you can see your own pattern Shown back to you; used to compute your percentage and streak. On the device only
Barriers to taking medicine "Forgot", "Cost", "Side effect concern", "Regimen complexity", "Ran out", "Other" So you can see what actually gets in the way Shown back to you and counted in the summary export. If you save a mood and energy at the same time, selecting "Side effect concern" is also stored as a side-effect entry on that journal entry. On the device only
Free-text notes Anything you type in the notes field Your own record Stored with the medication record and, if you save a mood and energy, the journal entry. On the device only
Wellness journal Mood (1–5) and energy (1–5), saved when you set both Habit and wellness tracking Averaged over the last 30 days and shown back to you. On the device only
Habit records Whether the dose was taken — written from your Taken or Skipped choice, not asked separately General wellness tracking Stored on the device; contributes to streaks
Profile record A record the app creates on first launch holding two default goals Personalizing your own view of your own record Stored on the device
Label and topic pages you opened The ID of the topic or medicine-label page you had open last, on iPhone, iPad, Mac, Apple Vision Pro, Apple Watch or Apple TV, including one you opened from the You tab (which links to the label for each medicine you follow); a label page's ID names the medicine, and a topic page's ID can name a condition. Earlier versions also kept a list of the pages you had opened; this version does not add to it and removes it So your other devices, Apple Watch and Apple TV can continue where you left off Written to your own iCloud key-value storage. Also named in the Handoff message to your nearby devices
Questions you type into Ask A question you send in Ask, on the iPhone, iPad, Mac, Apple Vision Pro or from Apple Watch To answer it Answered on the device, only if you turned Ask on: by Apple's on-device model, or, where Apple Intelligence cannot answer, by the optional model you chose to download. Not saved, and not sent to us, to Apple or to Hugging Face. A question typed on Apple Watch travels to your iPhone to be answered
Values the app calculates Percentage of logged days with a dose taken, current streak, days logged, mood and energy average, one sentence describing what was logged Feedback on your own logging Calculated when displayed, not stored

Fields the app does not let you fill in. The app's data model also contains fields for hours of
sleep, symptoms, age, health conditions and current medications. No screen in the shipping app fills
any of them in.
Sleep is left empty, symptoms are stored empty, and the age, conditions and
current-medications fields are never written. We list them here so that this policy describes the store
honestly, not to suggest the app collects them.

Ask and on-device AI. Ask is off until you turn on Enable on-device Ask in More. It answers with
Apple's on-device model where Apple Intelligence is turned on and ready. Where it is not, on a device
with enough memory, the Ask screen offers an optional model that also runs on the device; it downloads
from Hugging Face only if you agree in a dialog that names the model and its size, and answering never
starts a download. Before a question reaches either model, the app refuses questions about doses,
interactions, tapering, pill identification, diagnosis, risk scores or your own medicines, and answers
a question that suggests someone may be in danger with 988, Poison Help and 911 instead of a model.
Before the downloaded model sees your question together with the library passages, the app runs the
same check on that whole text and, if a passage matches, shows the check's fixed reply instead. Ask
does not see your medication records, your journal or the medicines you follow. The switch earlier
versions showed, "Allow one model download", is gone; it downloaded nothing, and the app removes the
choice it recorded.

Purpose, stated once and plainly: every purpose above is showing your own information back to you,
letting you continue on your own devices, and helping you prepare to talk to a pharmacist or
physician
. There is no secondary purpose. We do not use this data for advertising, marketing,
profiling, product analytics, research, model training, or any use-based data mining. There is no such
use, because we never receive the data.

We do not collect any consumer health data beyond what is listed above. If that ever changes, we
will disclose the new category here and ask for your consent before collecting it.


Subscription tiers and consumer health data

No new collection when you subscribe

OmniRx offers one paid upgrade, OmniRx Pro (monthly, annual or lifetime), in addition to the free
tier. Upgrading does NOT trigger new consumer health data collection.

Both tiers:
- Process the same categories of consumer health data (listed above)
- Use consumer health data for the same purposes
- Store data in the same places (on your device, with the last page's ID and the widget's line in your own iCloud account)
- Send it to the same places (your own iCloud account and, if you turn it on, your Apple Watch — never to us)

Pro lets you follow every medicine you take instead of one, and log with no cap instead of 30 logs in
total. It does not change what data is collected, how it is processed, or where it goes.

What changes between tiers

What subscription affects What subscription does NOT affect
How many medicines you can follow at once (one, or any number) Whether medication records are processed (yes in both)
How many dose logs you can add (30 in total, or no cap) Where records are stored (on the device in both)
What syncs to iCloud (the same in both; never your records)
Reading, correcting, deleting and exporting your records (free in both, and kept if Pro lapses)

StoreKit data is not consumer health data

When you buy Pro, Apple's StoreKit on your device tells the app whether Pro is active. Purchase
records are payment records, not consumer health data
under RCW 19.373.010.

StoreKit transaction data:
- Does not identify your health status, condition, disease, or treatment
- Is used only to decide whether Pro features are on
- Is held by Apple and StoreKit; OmniRx does not write its own copy and sends nothing about it to us
- Is not affected by "Delete all my data"; your purchase stays with your Apple Account

Apple separately processes your Apple Account ID and payment method when you subscribe. That processing is governed by Apple's terms, not ours.


Categories of sources

There is one source: you, using the app on your own devices.

OmniRx does not obtain health data from:


Categories of consumer health data shared

None.

Prameya shares no consumer health data with anyone. Not with us, not with third parties, not with
affiliates, not with service providers or processors.

List of third parties and affiliates we share consumer health data with

None. The list is empty.

Prameya has no affiliates. We use no processor, contractor or service provider that touches consumer
health data, because no such data reaches us.

About Apple's services — so the list above is not misleading

The app itself sends a limited set of items to services Apple runs for your own Apple Account.
Prameya does not receive any of it and cannot read it:

The app makes no request to any server of ours.

About Hugging Face — so the list is not misleading either

Hugging Face receives no consumer health data. If, and only if, you choose the optional on-device
Ask model on the Ask screen and tap Download in the dialog that names the model, its size and
Hugging Face, the app downloads that model's files from Hugging Face:

Model From Hugging Face repository (pinned commit) Download
MiniCPM5 2B openbmb/MiniCPM5-2B-MLX (8a9ad753) about 1.4 GB
Gemma 4 E2B mlx-community/gemma-4-E2B-it-qat-4bit (42f62737) about 4.4 GB
Gemma 4 E4B mlx-community/gemma-4-E4B-it-qat-4bit (0f35c6f6) about 6.8 GB

Which one a device is offered depends on its memory (none on 6 GB or less or without Metal 3 graphics;
see the main policy).
Like any file download, the request gives Hugging Face your device's IP address and standard request
headers (including a user agent naming OmniRx), and names the model repository, commit and files. It
carries no token or account, and never a question, a medicine name, a record or anything else you
entered. The model then runs on your device; your questions never go to Hugging Face. We do not receive
the request. The files stay in the app's private storage, excluded from device backup, until you remove
them.

About iCloud — so the same claim is not misleading either

Your medication records, journal entries, habit records, profile record and the list of medicines you
follow are not placed in iCloud by the app.
The database holding the records is created with iCloud
sync switched off, and the list of medicines is kept in the app's settings storage on the device.

The ID of the last label or topic page you opened, and the widget's line, are placed in iCloud by
the app
, as described above, because that is how Continue and the Home Screen widget work across
your devices. The widget's line says whether you follow a medicine, never which one. Earlier versions
also placed there a list of the pages you had opened. This version does not add to it, and removes it
each time it opens on iPhone, iPad, Mac or Apple Vision Pro. "Delete all my data" removes all of
them.

Separately from anything the app does, Apple's whole-device iCloud Backup can include the app's
data if you have that turned on — see the right to delete below.


Selling consumer health data

We have never sold consumer health data and we will not.

Washington and Nevada both require a specific, separate, signed authorization before consumer health
data may be sold. We have never sought one and do not intend to. If that ever changed, it would require
your explicit written authorization first — silence, an app update, or a change to this policy could
never substitute for it.


Geofencing

OmniRx uses no geofencing. The app does not request or use location at all. It does not establish a
virtual boundary around a health care facility, or anywhere else, and it does not use location to
identify, track, collect data from, or send messages or advertising to anyone.

Washington prohibits geofencing within 2,000 feet of a facility providing in-person health care
services; Nevada prohibits it within 1,750 feet. Neither prohibition can be triggered by an app with no
location access.


Who inside Prameya can see your data

Nobody. There is no administrative console, no support-side lookup tool, no database, and no
production access path. Your data is on your device and in your own iCloud account, which we cannot
open.

If you email us for support, only the person answering support email — currently the address
admin@prameya.legal — sees whatever you choose to put in that email. Please do not send us your
medication history; we do not need it and would rather not have it.


Your rights, and how to use them

You have these rights under Washington's My Health My Data Act (RCW 19.373.040), and comparable rights
under Nevada law. We extend them to everyone, wherever you live.

1. The right to confirm what we are doing

You can ask us to confirm whether we are collecting, sharing, or selling your consumer health data, and
to give you a list of all third parties and affiliates we have shared or sold it to.

Our answer, in advance: we are not collecting it on any server, we have never shared it, we have never
sold it, and the list of third parties is empty.
Ask anyway if you would like it in writing — email
admin@prameya.legal and we will send it.

You can also see what the app holds without asking us: More → "Open, correct or delete one
record"
lists every medication record, journal entry and habit record the app holds and opens any of
them. More → "Export every record as text" prints all of them, field by field — each medication
record with its date, medicine name, whether you recorded it as taken or skipped, the reasons and the
note on it; each journal entry with its scores, anything reported with it and its note; each habit
record; the medicines you follow and the names of medicines you have stopped following; and the
profile row the app created for itself. Nothing is summarised, sampled or truncated. There are no
attachments to return, and that export says so: OmniRx cannot take or store a photograph, a scan, a
recording or a file of any kind. The app keeps the names of medicines you have stopped following only
so it can leave them off the You tab; this export is the one place they are shown, and "Delete all my
data" removes them. More → "Export my logs as text" remains available
and is a shorter summary written to be handed to a pharmacist. Both exports are shown on screen for you
to copy; nothing is uploaded and we never receive a copy.

You can withdraw consent to our collection and sharing of your consumer health data at any time.

In practice, you can do all of this yourself, immediately:

You may also email admin@prameya.legal to withdraw consent in writing. We will confirm and record
it. Withdrawing consent does not undo processing that already happened on your own device.

3. The right to delete

You can ask us to delete your consumer health data.

4. The right not to be discriminated against

Using any of these rights does not change the app. There is no reduced-functionality tier, no penalty,
and no different price.

How to make a request

Email admin@prameya.legal with what you want. You do not need an account, because there are none.
Please tell us how to reach you.

If we say no

If we refuse a request, we will tell you why, and you may appeal. Send your appeal to the same
address with "Appeal" in the subject line. We will review it and respond in writing within 45 days,
explaining our reasoning.

If we deny your appeal, you may submit a complaint to your state's Attorney General:

Washington residents: a violation of the My Health My Data Act is a violation of the Washington
Consumer Protection Act, which gives you a private right of action under RCW 19.86.090. You do not have
to wait for the Attorney General to act.

Nevada residents: SB 370 is enforced by the Nevada Attorney General. It does not create a private
right of action.


How long your data is kept

For as long as you keep it. It is on your device and, for the last page's ID and the widget's line,
in your own iCloud account, so you decide. "Delete all my data" removes both; deleting the app removes the
device copy. A question you type into Ask is not kept at all.

We keep nothing, so there is nothing for us to retain or to age out.


OmniRx collects consumer health data only when you enter it or open a page, and only for the purposes
listed above. Before the app processes your health data for any new purpose, or collects a new category
of it, we will disclose that here and ask for your affirmative consent first.

What the app asks you at first run. The first time you open OmniRx, before you reach the rest of
the app, it shows a disclosure screen explaining what OmniRx is, what it will not do (no diagnosis, no
dosing, no interaction checking, no pill identification), that your records stay on your device, and
that your appearance choice and the IDs of the topic and medicine-label pages you open sync through
your own iCloud account — including that a label page's ID includes the medicine's name. You
acknowledge that screen to continue, and the app records the acknowledgement, its date and a version
number for the disclosure text. If we materially change what that screen says, the version number
increases and the screen is shown again, so you see the change rather than being carried past it.

The other choices are separate and later, and each is off until you turn it on in More: Enable
on-device Ask
, Daily reminder (which is when the system asks for notification permission), and
Show medicine names on Apple Watch. The optional Ask model is a choice of its own, made on the Ask
screen in a dialog that names the model, its size and Hugging Face; nothing downloads before you tap
Download there. On iPhone, iPad and Mac, where Apple's age rules apply to your Apple Account, the
system may also ask you, after the notice, to share an age range. It is not health data, stays on
your device, and is explained in the main policy under Children.


What OmniRx is not

OmniRx is educational and habit-support software. It is not medical advice. It does not diagnose,
does not calculate doses, does not check drug interactions, does not produce tapering plans, and does
not identify medicines from photographs. Its optional daily reminder is a local notification that says
"Reminder", with no medicine name, and it is not a critical alert. Talk to your pharmacist or physician
about your medicines.

HIPAA does not apply. Prameya is not a health care provider, health plan, or business associate,
and OmniRx is not provided to you through one. We claim no HIPAA compliance. What protects your data
here is that it stays on your device and in your own iCloud account — and the rights in this policy.


Changes to this policy

If we change how OmniRx handles consumer health data, we will update this page and change the effective
date above, and summarize what changed at the top. We will not collect, use, or share a new category of
consumer health data, or use it for a new purpose, without disclosing it here first and obtaining your
affirmative consent.

7 October 2026 — what changed. With an app update:

24 September 2026 — what changed. With an app update:

23 September 2026 — what changed. This policy was rewritten to describe what OmniRx does today:

The first-run notice, which you acknowledge before using the app, now describes the label-page IDs
in iCloud too.
Where an older entry below says something different — for example that no screen sends your text to
a model, or that nothing is written to the iCloud preferences container — this entry replaces it.

What changed in this revision (August 24, 2026): the app now offers per-record review,
correction and deletion, and a complete per-field export, so sections 3 and 4 describe those
controls instead of denying they exist. This revision also adds subscription tier disclosures
(it named Plus and Premium tiers, which were never offered for sale — the only paid upgrade is
OmniRx Pro; see the 23 September 2026 entry above), explaining that upgrading does not change what consumer
health data is collected, how it is processed, or where it goes. No category of consumer health data,
no source, no recipient and no purpose changed, so the effective date is unchanged and no new consent
is sought.

What changed in this revision (August 8, 2026): this version corrects statements so they match the
code that actually ships. In particular: the right to delete described all-or-nothing deletion only,
which was accurate for the build shipping on that date; the category table now describes only what
the app actually records, and names the fields that exist in the data model with no screen to fill
them in; the AI row now says plainly that no screen sends your text to the model today; the iCloud
position is stated exactly (no health data syncs, and a preferences-only container exists that
nothing currently writes to); the iCloud Backup limitation is stated as a limitation on deletion;
the first-run disclosure is described as it ships; and internal review markers that were mistakenly
published have been removed.

Prior versions are available on request from admin@prameya.legal.


Contact

Prameya LLC
Email: admin@prameya.legal