Consumer Health Data Privacy Policy

This policy explains how K-Gallery ("we," "us," or "our") handles consumer health data under the Washington My Health My Data Act. It applies to Washington residents and to anyone whose consumer health data we collect in Washington. It adds to our Privacy Policy. If the two differ for consumer health data, this policy controls.

1. Consumer Health Data We Collect

Our AI Skin Analysis feature collects the following data, which may be consumer health data:

• Skin analysis answers — Your skin type, the skin concerns you select (for example, acne or redness), your age range, and any notes you add.
• Face photo (optional) — A photo you choose to upload. It may show your skin condition and the shape and features of your face. We ask for your consent before you upload it. We use it only during the analysis request and do not store it.
• Analysis results — The skin concerns, severity, and scores that our AI service estimates from your photo, the explanation of your concerns, and the products recommended for your routine. Results can be inferred from your photo or your answers. They are cosmetic estimates, not medical diagnoses.

2. Sources

We collect this data directly from you, through the answers and photo you submit. Our AI service then generates the analysis results from that data. We do not buy consumer health data.

3. Why We Collect and Use It

• To create the skin analysis and product routine that you request.
• To save your reports so you can view them in your account.
• To keep the feature secure and to fix errors.

We do not use consumer health data for advertising. We do not sell consumer health data.

4. Who Receives It

We disclose consumer health data only to service providers that process it on our behalf, under contract, to provide AI Skin Analysis:

• AI services — The AI service providers that run the skin analysis and write the product explanations. Photos go only to AI endpoints with zero data retention.
• Data storage — Sanity, which stores your saved skin analysis reports.
• Hosting and error monitoring — The provider that runs our servers, and Sentry, which receives error reports without your answers or photo.

We do not disclose consumer health data to affiliates or data brokers. Our analytics and advertising tools do not load on our skin consultation pages. On other pages, we keep your skin answers and results out of our analytics and session recording tools.

5. Your Rights

If you are a Washington resident, or we collected your consumer health data in Washington, you have the right to:

• Confirm whether we collect, share, or sell your consumer health data, and access it. This includes a list of the third parties that received it and a way to contact them.
• Withdraw your consent to our collection and sharing of your consumer health data.
• Have your consumer health data deleted.

To make a request, email [email protected] with the subject "Consumer Health Data Request". Send it from the email address on your K-Gallery account so we can confirm your identity. If we cannot confirm it, we may ask for more information.

We respond within 45 days. If we need more time, we may extend this once by 45 days, and we will tell you why within the first 45 days. Responses are free up to twice a year. When we delete your data, we also tell our service providers to delete it. Copies in backup systems may take up to six months to delete.

We do not keep photos, so there is no stored photo to delete. To withdraw your photo consent, do not upload a photo. You can still use AI Skin Analysis without one.

6. Appeals

If we refuse your request, you can appeal. Reply to our decision email with the subject "Consumer Health Data Appeal". We will tell you in writing, within 45 days, what we did and why. If we deny your appeal, you can file a complaint with the Washington State Attorney General at atg.wa.gov/file-complaint.

7. No Sale and No Geofencing

We do not sell consumer health data. We do not use geofences around places that provide health care services.

8. Changes to This Policy

We may update this policy. The Last Updated date shows the current version. Before we collect or use consumer health data in a new way, we will tell you and ask for your consent.

9. Contact Us

Email [email protected] with any questions about this policy.