Who We Are

The DēsAL™ GRHS Program (“the Program,” “we,” “us,” “our”) is operated by DESAL LLC, a Florida limited liability company:

DESAL LLC
7901 4th St N, Ste 300
St. Petersburg, FL 33702
kkellin@desalhealth.org

This Privacy Policy explains how we collect, use, and protect information from participants (Grand Rapids High School varsity football players and coaching staff) and, where applicable, their parents or legal guardians, through our website (desalhealth.org), text messaging (SMS), and program forms.

This Policy covers the Program’s website and communications. Your participation in the underlying research study, including what study data is collected and how it is used for research purposes, is separately governed by the informed consent document you signed for the study, which is conducted with Northern Arizona University (NAU). Where the two conflict, the signed consent document controls how research data is handled.

1. Information We Collect

Depending on your role and participation, we may collect:

• Contact information: name, mobile phone number, email address, and (for participants under 18) parent or guardian name and contact information
• Program data: skin carotenoid scan results, DCOA assessment responses (baseline, month 3, month 6), weekly adherence and micro-action check-in responses, position, unit, and roster information
• Communication records: SMS opt-in and opt-out status, message delivery logs, form submission timestamps
• Consent records: signed or submitted consent forms and consent dates

A note on the scan. The Prysm iO device estimates the amount of carotenoid pigment stored in skin. Because that pigment comes almost entirely from fruits and vegetables, the result is an indicator of plant food intake over roughly the previous month. It is not a medical test, it does not diagnose anything, and it does not identify you — it measures a chemical, not a physical characteristic unique to you.

2. How We Use Your Information

We use the information collected to:

• Operate the Program: send scan reminders, micro-action reminders, and assessment reminders by SMS and email
• Track program engagement and identify participants who may need additional outreach or support
• Support the research study conducted with NAU, in the manner described in your consent document
• Communicate with you about the Program, including administrative and safety related matters
• Maintain accurate program records

We do not sell your information. We do not use your phone number, your program data, or your health related information for marketing of any kind.

3. Mobile Information and Text Messaging

Information sharing with subcontractors who provide support services on our behalf — such as message delivery — is permitted, and those subcontractors may not use the information for their own purposes.

Twilio, our SMS provider, processes your phone number and message content solely to deliver Program texts. You can stop receiving texts at any time by replying STOP to any Program message. See our Terms of Service for full messaging terms.

4. Who Can See Your Information

Access to participant data is limited to:

• Program staff: Kevin Kellin (DESAL LLC) and Coach Greg Spahn
• The Principal Investigator, Dr. Jay Sutliffe, and the approved NAU research team
• Service providers who process data on our behalf under appropriate safeguards — currently Airtable (program data storage), Twilio (SMS delivery), Make.com (workflow automation), and Google (email). These providers do not use your information for their own purposes.

Individual scan results are not posted publicly, displayed on any board, or shared with other participants. Only position unit aggregates are displayed.

We may disclose information if required by law, or where necessary to protect the safety of a participant.

5. Participants Under 18

Most participants in this Program are minors.

Where a participant is under 18, we collect and use their information only with the consent of a parent or legal guardian, obtained as part of program enrollment. That consent specifically includes consent to send text messages to the mobile number provided at enrollment, whether that number belongs to the participant or to the parent or guardian.

Parents and guardians may at any time:

• Ask what information we hold about their child
• Request that information be corrected
• Request that their child be removed from program communications
• Change the mobile number that receives Program messages

These requests are subject to the research retention requirements described in the signed consent document. Contact us at kkellin@desalhealth.org.

We do not send marketing messages to any participant. All Program messages are operational: reminders and program administration.

6. Relationship to HIPAA and FERPA

This Program is not a HIPAA covered entity, and the information described in this Policy is not protected health information under HIPAA. The Program is not offered through a group health plan, does not bill insurance, and does not provide medical care. This is consistent with HHS guidance that a wellness program offered directly to participants, outside a group health plan or covered entity, is not itself HIPAA regulated.

The Program is operated by DESAL LLC and runs in cooperation with Grand Rapids High School. Program records — scan results, adherence responses, and consent records — are collected and stored directly by DESAL LLC rather than in a student’s school file. Depending on how Independent School District 318 characterizes records created through a school affiliated activity, some Program records may also fall within the Family Educational Rights and Privacy Act (FERPA) and district policy. DESAL LLC will follow the district’s determination and will enter a data sharing agreement or school official designation if the district requires one.

Parents and guardians may direct questions about student records to DESAL LLC, to the district, or to both.

Research data is separately governed by the signed NAU study consent document.

7. Data Storage and Security

Program data is stored in Airtable, an online database platform, with access restricted to named, authorized program staff and researchers. Access is controlled by individual accounts. We take reasonable measures to protect your information, but no method of electronic storage or transmission is completely secure.

8. Data Retention

We retain program and research data for the duration of a participant’s enrollment in the Program, plus three years following the end of the study, consistent with standard NAU research data retention practice — or for a longer period if required by the study protocol or by applicable law. Data no longer needed for these purposes is deleted or de identified.

9. Your Choices

• Stop SMS at any time by replying STOP to any Program text message.
• Get help by replying HELP to any Program text message, or by emailing kkellin@desalhealth.org.
• Ask questions or request corrections to your contact information by contacting Kevin Kellin at kkellin@desalhealth.org.
• Withdraw from the research study by following the process described in your original consent document. Note that stopping SMS alone does not withdraw you from the study.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date above will change. Material changes will be communicated to enrolled participants, and to parents or guardians where applicable.

11. Contact

DESAL LLC
7901 4th St N, Ste 300
St. Petersburg, FL 33702
kkellin@desalhealth.org

Research related privacy questions may also be directed to Dr. Jay Sutliffe, Principal Investigator, Northern Arizona University.