Consumer health data at Forma

Scope and who is responsible

This policy applies to consumer health data Forma processes about a United States resident and sits alongside the general Privacy Policy and Terms of Service. Where it conflicts with the general notice for a United States resident, this policy applies to consumer health data. Forma Pose Ltd, company number 17392462, is incorporated in England and Wales, with its registered office at 23 Albert Embankment, London, United Kingdom, SE1 7GG. Forma is responsible for its own account, platform and rights processing. For a hosted study, the research organisation named in the study determines its study purpose and acts as controller; Forma processes the selected study information on its behalf under a written agreement. The service contact is 10 York Road, London SE1 7ND, United Kingdom, or eric@formapose.com. These roles do not remove the obligations that applicable United States law places on either party.

Consumer health data Forma processes

Forma processes the following consumer health data for a United States account, locally on your own computer or browser: posture measurements and scores derived from brief camera check-ins, such as visible head, shoulder and neck alignment and their confidence and quality values; workday load and posture-pattern summaries built from those measurements; discomfort and body-area reports you choose to record; and notification and reminder responses, such as whether you acted on, snoozed or dismissed a prompt. Because these observations can reveal information about your physical wellbeing, Forma treats them as health-related information and keeps them in encrypted local Health Data under your account.

Where the data comes from

The local posture features derive their information from the camera on your own device, which analyses short check-ins on the device, and the choices and responses you enter yourself, such as a discomfort report or a notification response. Forma does not obtain consumer health data about you from data brokers, advertisers, social networks or other third parties, and it does not infer it from your browsing or from other websites.

Why Forma processes it

The ordinary local features process this consumer health data only to show you your own on-device posture and workday insights, to keep your local history and any local reports, and to provide the reminders you enable. It is not used for advertising, marketing, profiling, employment, insurance, credit or eligibility decisions, and it is not used to identify you.

What Forma does not collect to its servers

The product does not send your consumer health data to Forma’s servers, except as described below for a hosted research study you choose to join. Camera frames, pose landmarks, coordinate arrays, posture measurements, scores, workday load, discomfort reports and notification responses stay on your device. Cloud reports are unavailable to United States residents, so no derived posture data is sent to Forma’s cloud report pipeline for a United States account. The exception for product data is a hosted research study you choose to join. When you give that study’s separate, per-study consents, Forma receives and stores, on the research organisation’s behalf, only the derived categories listed for the study: check-in times and whether you were at your desk, away or not visible; your posture score and posture measurements; workday load; notification interactions (whether a reminder was shown, opened, read in more detail, closed, snoozed, expired or interrupted, including reminders Forma held back); monitoring status events (a camera or Forma problem, monitoring paused, the computer asleep or locked, or signed out); survey email delivery records; invitation emails; and any paperwork you upload. Only the categories listed in that study and permitted by your recorded choices are admitted, not every category in this list. Forma provides the permitted categories to the named organisation and uses the contracted hosting processor described below; it does not send them to an AI-report provider or permit unrelated use. Withdrawal stops new collection and sharing once confirmed. These rules do not exclude information you deliberately provide in a support or data-rights request, which is used only to handle that request.

Categories shared and third parties

Apart from the consented study sharing described here, the product does not send consumer health data to third parties. Health-related information you deliberately include in a support or rights request may be handled by the service processors described in the general Privacy Policy, only as needed to handle that request. Forma has not shared consumer health data with a third party for a business or commercial purpose in the past 12 months other than as described. When you give the study’s separate consents, the recipients are: the research organisation named in the study you join, which is the controller for that study and receives only the derived categories listed for that study — check-in times and desk, away or not-visible presence; posture score; posture measurements; workday load; notification interactions (shown, opened, read more, closed, snoozed, expired or interrupted, and reminders held back); monitoring status events (a camera or Forma problem, monitoring paused, the computer asleep or locked, or signed out); survey email delivery records; invitation emails; and any paperwork you upload; and Cloudflare, which hosts the service and stores the shared study data as Forma’s processor under a data-processing agreement. Automated study capture never shares camera images, video, audio or pose coordinates. Paperwork that you separately upload can be a PDF, PNG or JPEG and can itself contain personal or health information. The research organisation’s own privacy notice governs how it uses the data it receives, and the organisation is responsible for its lawful handling of exported copies, while Forma remains responsible for its own processing and assistance with your rights. A participant code is pseudonymous, not automatically anonymous. Withdrawing the study consent stops sharing and deletes the study observations Forma holds for you; it does not itself erase exported copies, uploaded paperwork or the minimal consent and withdrawal evidence described below.

Your rights over consumer health data

You can exercise your applicable rights without discrimination or creating a new account.

• Access and confirm: ask what consumer health data Forma processes, its sources and recipients, including recipient contact details where required. Your device shows local posture information, and Settings provides readable exports.
• Delete: request deletion of Forma-held consumer health data without closing the account. For desktop account closure, Settings → Privacy and data → Withdraw consent & delete account removes the account’s local data on that device after server deletion completes. Forma Web Settings removes its local record and key. A pending or Retry state means deletion is not yet complete.
• Withdraw consent: use the withdrawal control for a study in Forma Settings. Once confirmed, new sharing stops and Forma-held study observations and survey delivery records are deleted. Paperwork and minimal evidence have the separate rules below. Your ordinary on-device access is unaffected by leaving research.
• Correct and port: ask to correct inaccurate information or receive a portable copy of the consumer health data Forma holds.
• Appeal: reply to a refusal or email eric@formapose.com. We will explain our decision and the applicable route to your state attorney general.

For a request, inability to sign in, pending deletion, earlier paperwork removal or confirmation of deletion, email eric@formapose.com or write to the service address above. Identify the account and relevant study where possible; do not send passwords or camera recordings. We use proportionate verification, may confirm control of the account email and accept authorised agents with appropriate authority. We respond within the deadlines that apply to the request and explain any lawful extension or refusal. Washington consumer-health requests ordinarily require a response within 45 days of receipt, with one notified 45-day extension where necessary; verification does not extend that initial period.

Forma deletes information it controls and communicates a valid deletion request to applicable processors and recipients, including the research organisation. That organisation must address its exported copies under applicable law, and Forma will assist; we cannot directly erase its independent systems. Backups must also follow applicable deletion requirements: for a Washington request, any permitted delay for archived or backup systems cannot exceed six months from authentication. We will explain any lawful retained records and the applicable deadline. You control exports, backups and other-device copies you made; deleting a local record does not withdraw a study or erase an exported copy. No policy, consent or study agreement waives mandatory privacy rights.

No sale and no geofencing

Forma does not sell consumer health data, and it does not “share” it for cross-context behavioural advertising or targeted advertising. Forma does not use geofencing around any health-care facility or other location to identify or send information to people who visit it. Forma honours the Global Privacy Control signal as an opt-out of sale and sharing; because Forma does not sell consumer health data or share it for advertising, the signal requires no additional advertising opt-out. It does not replace your separate choice to withdraw a hosted study’s consent.

Retention

Ordinary United States posture and notification history stays encrypted on your device until account deletion or local app-data removal; the local notification log has no automatic age-based expiry. Forma Web has the separate seven-day, browser-specific expiry described in the general notice. There is no server-side backup of that ordinary history. Selected observations for a study may remain in a separate encrypted local queue while an upload is pending, until delivered or cleared through withdrawal or deletion.

A hosted study has a separate server-side copy of only the categories you consent to. Study observations follow the study’s stated rolling period, within the platform’s range of 30 to 365 days, with a default of 365 days, and are deleted from Forma’s active store when you withdraw or their retention period ends. Uploaded paperwork expires no later than the study’s rolling period from upload, including an earlier post-withdrawal period normally of 30 days or a study-selected period no longer than that study’s retention. You may request earlier erasure; the study’s period cannot override applicable rights. Consent, withdrawal and study audit evidence are distinct from observations and may remain only as lawfully necessary. United States consent and arbitration receipts are detached when you delete your account and retained for six years, with the statement version, statement hash and keyed email hash as described in the general notice. If deletion fails, affected encrypted records or files and the custody information needed to retry may remain pending cleanup. Forma does not describe that state as completed erasure or authorisation for further research use. A retention rule or legal-evidence exception does not authorise continued collection, unrelated use or retention of all study health information.

Changes, security and contact

Forma will post material changes to this policy before they take effect and will seek a new choice where the law requires it. Forma protects consumer health data with the controls described in the general Privacy Policy, including encryption and least access. No system is completely secure, and Forma maintains incident, breach-notification and rights procedures appropriate to its scale. Questions, requests or complaints: eric@formapose.com, or Forma Pose Ltd, 10 York Road, London SE1 7ND, United Kingdom. A United States resident may also complain to their state attorney general.