An optional coaching feature in my planned app would, after explicit opt-in, send a short text summary (for example sleep duration or heart rate variability over the last week) to a third-party AI service to generate advice for that same user. The data is not used for advertising, marketing or data mining.
Guideline 5.1.3(i) allows disclosure of HealthKit-derived data only "for improving health management, or for the purpose of health research, and then only with permission", and DPLA 3.3.3(H) allows disclosure to a third party only with prior express consent and only to provide health, motion or fitness services.
Is a per-user coaching feature like this within what 5.1.3(i) and 3.3.3(H) permit?
Does it matter whether the summarised values were entered manually (and stored in HealthKit) or measured by a device?
I understand this is not a pre-approval; I would like to know how the rule is meant to be read. Thank you.
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