Consumer Health Data Privacy Policy

1. The categories of consumer health data we collect, and why

We collect the following categories of consumer health data. For each, the purpose is stated, because that purpose limits what we may do with it.

Symptoms you record

Including the symptom, its severity, and the time you felt it. Collected to show you patterns between what you consume and how you feel.

Foods, drinks and products you record

Including ingredients, portions and timing. Collected for the same purpose. Ingredient lists are consumer health data in this context because we analyse them against your symptoms.

Health profile information you choose to provide

Including dietary restrictions, sensitivities and allergies, diagnosed conditions, medications and supplements, biological sex, year of birth, and pregnancy or cycle information where you enter it. Collected to make the analysis of your own data more accurate.

Bodily measurements you choose to provide

Including height and weight. Collected for the same purpose.

Data we infer or derive from the above

Including statistical associations between specific ingredients and specific symptoms, tolerance estimates, and sensitivity scores. Produced by algorithms operating on the data you recorded. Collected and generated to give you the results the product exists to provide. This is consumer health data even though some of its inputs are not.

Information you send to our assistant

Including the text of your messages, any photographs you send it, and voice recordings you make. Collected to answer you.

Connected device and wearable data

Where you choose to connect a service. Collected to add context to your own patterns.

Coarse location region

Where you allow it. Collected to provide location-relevant features. We do not collect precise location.

2. The categories of sources we collect it from

• Directly from you, which is the source of nearly all of it: what you type, record, photograph, scan, or speak into the app.
• From your device, where you grant permission, such as a coarse location region or a camera image you choose to capture.
• From services you connect, such as a wearable or health platform you authorise.
• Generated by us, meaning the inferences and statistical associations our systems derive from the data above.

3. The categories of consumer health data we disclose to processors

We disclose the following categories to the service providers listed in section 4, only so they can operate the service on our behalf:

• Symptoms you record.
• Foods, drinks, products and ingredients you record.
• Health profile information and bodily measurements you provide.
• Data we infer or derive, including ingredient and symptom associations.
• The text, images and voice recordings you send to our assistant.
• Connected device and wearable data.

4. The categories of third parties, and the specific affiliates, we disclose it to

Specific affiliates: none. Framework Films, LLC has no affiliates to which consumer health data is disclosed.

Third parties, each a service provider processing on our behalf under contract, and none permitted to use the data for its own purposes:

Anthropic (artificial intelligence provider)

The text of your conversations with our assistant, including symptoms, foods and notes, and any photographs you send it

Timescale Cloud (database hosting)

All stored consumer health data, at rest

Railway (application hosting)

All data in transit through our application programming interface

Vercel (web hosting)

The web application, and photographs you upload

Cloudflare (network)

Voice recordings and spoken replies, in transit only, between the app and our own speech server. Not stored there

Clerk (account identity)

Your email address and sign-in method, and the account identifier your health records are stored against. It receives no symptom, food, condition, measurement or inference, and it is listed because that identifier is what associates you with the data above

Our payment processor, our error-monitoring provider and our product-analytics provider are deliberately absent from this list because they receive no consumer health data. Payments receive billing details and your plan only. Error reports have the request body, cookies, headers and query string removed before they are sent. Product analytics receive named events such as “completed onboarding”, with no free text, and session recording is switched off.

We also transmit aggregate statistics that are not linked to you and cannot reasonably be used to identify you. Those aggregates are computed as counts and statistics only and never contain an identifier.

5. How to exercise your rights

Washington residents have the right to:

• Confirm whether we are collecting, sharing or selling your consumer health data, and to access that data, including a list of all third parties and affiliates to which we have disclosed it.
• Withdraw consent to our collection and disclosure of your consumer health data.
• Delete your consumer health data.

To exercise any of these rights:

• In the app: open Settings, then Privacy. You can download everything we hold about you, and you can delete your account and all associated data. Deleting your account removes your consumer health data from our live systems.
• By email: write to privacy@clearlabel.ai. Say which right you wish to exercise. We will verify your identity by the email address on your account.

We will respond within 45 days of receiving your request. If we need more time we will tell you why within that period, and we may extend it by a further 45 days.

If we deny your request, we will tell you why and how to appeal. To appeal, reply to our response or write to privacy@clearlabel.ai with the word “appeal”. We will respond to an appeal within 45 days. If we deny the appeal, you may contact the Washington Attorney General at www.atg.wa.gov/file-complaint.

Withdrawing consent stops further collection and disclosure. It does not by itself delete what we already hold; use the deletion right for that.

6. Representative in the European Union

We have not appointed a representative in the European Union under Article 27 of the General Data Protection Regulation. This service is operated from the United States, all processing takes place in the United States, and it is not offered to residents of the European Economic Area or the United Kingdom. If that changes, we will appoint a representative and name them in this section before offering the service there.

7. Changes to this policy

If we begin collecting a new category of consumer health data, or begin using it for a new purpose, we will disclose that here and obtain your affirmative consent before doing so.

8. Contact

privacy@clearlabel.ai

Framework Films, LLC, doing business as clearlabel.