Consumer Health Data Privacy Policy
A separate policy for Washington and Nevada consumers, covering the health data this app handles.
- Effective date
- Last updated
Contents
This is a separate, standalone policy required by the Washington My Health My Data Act and Nevada SB 370. It applies to consumer health data. Our general Privacy Policy covers everything else.
1. Who we are
Dharmarajsinh Jethva and Asiqur Rahman, trading as DA App Ventures.
help@daappventures.com2. What consumer health data we collect
Glow gives cosmetic guidance, not medical care. We still treat the following as consumer health data, because a photo of your face, and what is drawn from it about your skin, may fall within these laws.
| Category | What it is |
|---|---|
| Images of your face | Each selfie you submit for a scan. We treat it as biometric data for this policy, although we do not use it to identify you and do not extract a face template from it. It is deleted after its scan |
| Physical characteristics inferred from your selfie | Your skin tone on the Monk Skin Tone Scale (1 to 10), your undertone, a colour season, how visible ten cosmetic signs look (such as visible redness, dryness or the look of dark spots), a short summary, and how confident the tone, undertone and colour season assessments were. All are generated automatically by AI |
| Information about your skin that you give us | Your skin type, how often your skin reacts to new products, your skin goals, and how your skin usually responds to the sun |
| Your routine | The morning and night ingredient types suggested for you, how often to use them, and why, worked out from the two categories above |
We do not collect: diagnoses, medications, treatment, reproductive or sexual health information, gender-affirming care information, genetic data, biometric identifiers used to identify you, or your location. The app does not ask for your location, and we do not use geofencing.
3. Where it comes from
All of it comes from you — the selfies you choose to submit and the answers you give about your skin — or is generated from your selfie by Google's Gemini AI, acting on our behalf. We do not buy health data, and we do not obtain it from data brokers, other apps, or any third party.
4. Why we collect it
Solely to provide the service you asked for: to analyse your selfie, give you your results and a routine, and show you your latest scan. Your skin tone is used only to match products and shades in your routine.
We collect it only with your consent. Before your first scan, the app asks you to agree on a screen titled "Before you start", and our server checks your most recent choice before every scan. You can withdraw that consent at any time (section 8).
We do not use it for advertising, for profiling, for research, or to train our own models.
5. Who we share it with
We do not sell consumer health data. We have never sold it and will not sell it. Under the Washington My Health My Data Act, selling consumer health data requires a signed authorisation from you, and we do not seek one because we do not sell it.
We share it with these service providers, only so they can help us run the app:
| Who | What they receive | Why |
|---|---|---|
| Google LLC (Firebase) | Your selfies until they are deleted, your results, your routines, and your skin profile answers | Hosting, storage, and processing |
| Google LLC (Gemini on Vertex AI) | Each selfie; and, for wording, your routine without the photo | To generate your results and the wording of your routine. On this paid service, Google does not use this content to train its models |
| Apple Inc. and Google LLC (Firebase Cloud Messaging) | Notification content, which contains no skin tone, no concern and no numbers | Delivery of push notifications to your device |
RevenueCat, which manages subscriptions, receives your account ID and purchase history but no consumer health data. We do not put consumer health data in crash reports. No third party collects consumer health data about your use of Glow over time or across other apps or websites. We have no affiliates.
We may also disclose it if legally compelled, or to protect someone's safety.
6. Where it is processed
In the United States. Our database, file storage and server functions, and the Gemini model that analyses your selfie, all run in Google Cloud's United States regions.
7. How long we keep it
Selfies are deleted after every scan, whether it completes or not. If a scan is cut off before it can clean up, an hourly clean-up deletes any selfie more than an hour old, so a selfie left behind is gone within about two hours.
Results and routines, including those from earlier scans that the app no longer shows, are kept until you delete your account. There is not yet a control in the app to delete a single scan; email us and we will delete earlier scans, or all of your results, without closing your account.
Your skin profile answers are kept until you change them or delete your account.
The app also keeps an offline copy on your phone of the results and skin profile it has shown you, so it works without a connection. Deleting the app from your phone removes it.
This policy is published on the basis that a photo of a person's face, and cosmetic observations about their skin, may themselves be consumer health data.
8. Your rights
If you are a Washington or Nevada consumer, you have the right to:
- Confirm whether we collect, share, or sell your consumer health data
- Access that data, including a list of who we have shared it with
- Withdraw consent to our collection and sharing of it
- Delete it
To delete: use the account deletion control inside the app — see how to delete your account. This removes any selfie not yet deleted, every result and routine, and your skin profile answers. We will also direct our service providers to delete it.
To withdraw consent: in the app, go to Settings > Legal > Withdraw consent, or email help@daappventures.com. We stop collecting and sharing your consumer health data: no new selfie is analysed until you agree again. Results you already have stay in your account; to have them deleted too, delete your account or ask us by email.
To correct: you can change your skin profile answers in Settings > Skin profile. Results cannot be edited, because they describe one photo, but you can take a new scan or ask us to delete them.
For anything else, email help@daappventures.com. We will respond within 45 days and may extend once by a further 45 days where reasonably necessary, telling you why. Access requests are handled manually.
If we refuse a request, we will tell you why and how to appeal. To appeal, reply to our response. If we deny your appeal, you may complain to the Washington State Attorney General.
9. Changes
If we change this policy we will post the updated version and change the effective date. We will not apply a material change retroactively to data already collected without your consent. If a change affects what you agreed to before your first scan, the app will ask for your consent again.