Consumer Health Data Privacy Policy

1. Scope

This Consumer Health Data Privacy Policy supplements Blemmy’s Privacy Policy and applies to consumer health data covered by Washington’s My Health My Data Act. It describes the consumer health data processed in connection with Blemmy, the sources and purposes of that processing, disclosures, and your rights. Blemmy LLC is the entity responsible for the processing described here.

2. Categories of consumer health data

Depending on how you use Blemmy, the app may process:

• skin and face photographs, which may show visible skin condition or changes over time;
• face and capture measurements used for photo consistency, including face presence, position, orientation, movement, face-to-camera distance, lighting, and quality warnings;
• skincare products, routine schedules, completion or skip history, notes, and reminders; and
• health or skincare information you voluntarily include in a support or privacy email to Blemmy.

Blemmy does not use face information to identify or authenticate you and does not create a biometric identity template.

3. Sources

Consumer health data comes directly from:

• you, when you take a photo, enter products or routines, or contact Blemmy;
• your iPhone camera and sensors, when the app derives capture guidance and measurements during features you choose to use; and
• Open Beauty Facts, when you choose barcode lookup and it returns a product name and brand for the scanned code.

Blemmy does not buy consumer health data from data brokers or other third parties.

4. Purposes of collection and use

Blemmy processes consumer health data only to:

• guide and capture consistently framed photos;
• store, align, compare, and display your photos and visible progress;
• create and track the skincare routines and reminders you request;
• look up a product name and brand when you choose to scan its barcode;
• sync your data across devices through your private iCloud database;
• create an export or copy that you request;
• respond if you voluntarily send health-related information to support; and
• protect legal rights, safety, and security or comply with law.

Blemmy performs photo and face analysis on your device. When iCloud is enabled for Blemmy, Apple processes synced consumer health data to provide the private CloudKit service. Blemmy LLC cannot view, retrieve, or manage the contents of your private database. The optional barcode lookup sends the request described below.

5. Consumer health data sharing

Blemmy LLC does not sell consumer health data and has no affiliates with which it shares consumer health data. Depending on your iCloud settings and the features you choose, the app may disclose consumer health data to:

• Apple: to sync photos, retained capture measurements, products, routines, and completion or skip history through your private CloudKit database when iCloud is enabled for Blemmy; if your device includes Blemmy data in an iCloud or computer backup; or if you save a photo to your Apple Photos library. Blemmy LLC cannot access the contents of the private database;
• A recipient you select: if you use the iOS share sheet to send an export or other copy to a person, app, or service; and
• Open Beauty Facts: if you choose barcode lookup. The app sends the scanned code and the technical information needed to make the API request. Open Beauty Facts returns the product name and brand to the app. Blemmy does not store the barcode after the lookup finishes.

If you voluntarily include consumer health data in an email, Cloudflare Email Routing and Blemmy’s mailbox provider process that message to deliver and store it for Blemmy. Blemmy uses the message only for the purposes described in Section 4 and does not sell it. Apple, Open Beauty Facts, Cloudflare, and a recipient you choose handle information under their own terms and privacy policies.

6. Your rights and controls

You can see your information in the app, export capture metadata, routine data, and history as JSON, save individual photos, and delete individual captures or all photos, products, routines, and history. Deletions sync to iCloud and your other devices when they connect. Deleting the app alone may leave synced data in iCloud. You can manage iCloud access and withdraw camera, Photos, or notification permissions through iOS Settings. Turning off iCloud access stops future sync but may not remove data already stored in iCloud. Because Blemmy LLC cannot access your private database, it cannot retrieve or delete that data for you.

For consumer health data Blemmy does receive—such as information voluntarily sent by email—you may request confirmation of collection or sharing, access, deletion, or withdrawal of consent by emailing privacy@blem.my. We may take reasonable steps to verify your request. If we deny your request, you may appeal by replying to the decision or emailing the same address with “Washington Privacy Appeal” in the subject line. If your appeal is denied, you may contact the Washington Attorney General.

7. Changes to this policy

We will post an updated version here before collecting or using consumer health data for a materially different purpose and will obtain consent where required by law.

8. Contact

Blemmy LLC
116 Agnes Road, Suite 200
Knoxville, TN 37919
United States
privacy@blem.my