Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy (the “Policy”) supplements the See Privacy Policy and describes how The See App Company (“See,” “we,” “us,” and “our”) collects, uses, and discloses Consumer Health Data. It applies to consumers covered by the consumer health data laws of Washington, Nevada, and Connecticut, including Washington or Nevada residents and other individuals whose Consumer Health Data is collected in either state. If this Policy conflicts with our Privacy Policy concerning Consumer Health Data covered by these laws, this Policy controls.

“Consumer Health Data” means personal information that is linked or reasonably linkable to an individual and identifies or reveals that individual’s past, present, or future physical or mental health status, as defined by applicable law.

1. CATEGORIES OF CONSUMER HEALTH DATA WE COLLECT

Depending on the features you use and the information you choose to provide, we may collect:

  • Habit information and goals. Information about alcohol use, including frequency or quantity ranges, goals to reduce or stop drinking, concerns about drinking, automatic drinking, and thoughts or urges related to drinking; information about smoking or other habits; and goals related to changing those habits.
  • Wellness information. Information you provide about stress, anxiety, mood, depression, sleep, weight, wellbeing, meditation experience, and related concerns or goals.
  • Activity and progress information. Programs and content you select, meditation and listening activity, progress, streaks, reminders, questionnaire or check-in responses, and interactions with features intended to support your goals.
  • Information linked to health or wellness activity. Account identifiers, contact information, subscription status, device information, general location derived from an IP address, and usage information when linked to the information described above.
  • Inferences. Recommendations, trends, or other conclusions we derive from the information above to personalize your experience and support your selected goals.

2. SOURCES OF CONSUMER HEALTH DATA

We collect Consumer Health Data:

  • Directly from you when you answer questions, select a program or goal, complete a check-in, contact us, or otherwise use the Services;
  • Automatically from your interactions with the Services, including the content and features you use; and
  • From service providers that help us operate the Services, such as app stores, subscription providers, and technical service providers.

We may derive inferences from these sources, such as content recommendations or progress insights.

3. WHY WE COLLECT AND USE CONSUMER HEALTH DATA

We may collect and use Consumer Health Data to:

  • Provide and personalize the program, content, features, reminders, and recommendations you request;
  • Record and display your activity and progress;
  • Operate, maintain, secure, and troubleshoot the Services;
  • Provide customer support and respond to your requests;
  • Understand how the Services and content are used and improve them;
  • Detect and respond to security incidents, fraud, abuse, illegal activity, or violations of our Terms of Service; and
  • Comply with applicable law and protect our rights and the rights and safety of others.

We do not use Consumer Health Data to make decisions about eligibility for employment, housing, education, credit, insurance, or health care.

4. HOW WE DISCLOSE CONSUMER HEALTH DATA

The categories of Consumer Health Data described in Section 1 may be disclosed to the processor categories below, but only to the extent reasonably necessary for them to act on our instructions and help us provide the Services:

  • Cloud hosting, database, authentication, and data-storage providers;
  • Product analytics, crash-reporting, security, and technical-support providers;
  • Subscription-management, payment, and app-store providers;
  • Communications, customer-support, and push-notification providers; and
  • Professional advisers and other providers that help us comply with law, protect rights, and operate our business.

We require processors that handle Consumer Health Data to process it only under binding instructions and consistently with this Policy. We may also disclose information when required by law, in connection with a qualifying merger or acquisition, or to prevent or respond to security incidents, fraud, abuse, or illegal activity.

We do not currently share Consumer Health Data with corporate affiliates. We do not sell Consumer Health Data. We do not disclose Consumer Health Data to third parties for targeted advertising.

Third-party analytics and attribution providers may collect device and service-usage information over time and across websites or online services. We do not provide them with detailed habit-questionnaire answers or authorize them to use Consumer Health Data for targeted advertising.

5. YOUR RIGHTS

Subject to applicable law, you may:

  • Confirm whether we collect, share, or sell your Consumer Health Data and access that data;
  • Obtain a list of third parties and affiliates, if any, with whom we have shared or sold your Consumer Health Data;
  • Review, correct, or request changes to your Consumer Health Data;
  • Withdraw consent to future collection or sharing of your Consumer Health Data; and
  • Request deletion of your Consumer Health Data.

You can submit a request through the account settings in the See App or by emailing help@theseeapp.com with “Consumer Health Data Request” in the subject line. We may take reasonable steps to verify your identity before completing a request. You do not need to create a new account to submit a request.

If you withdraw consent, some features that depend on the affected information may no longer work. We will not unlawfully discriminate against you for exercising your rights.

6. DELETION AND RETENTION

When you submit an authenticated account-deletion request in the See App, access to the account ends immediately. The app asks whether you currently reside in Washington, Nevada, or Connecticut. We use that answer only to select the deletion and retention process that applies to the request.

If you answer yes, we remove Consumer Health Data from active use and schedule it for deletion from our live records within the period required by applicable law. We also notify applicable processors, contractors, affiliates, and third parties of the deletion request as required by law. Data in routine backups is isolated from ordinary use and deleted when the backup is restored or reaches the end of its retention cycle, within the period allowed by applicable law.

We retain limited subscription and transaction records for as long as reasonably necessary for accounting, tax, refunds, chargebacks, fraud prevention, and subscription or entitlement administration, or as permitted or required by law. We remove habit categories and other Consumer Health Data from those retained transaction records.

If you answer no, the retention terms in the See Privacy Policy apply. Those terms permit us to retain specified account and usage records in a restricted archive for as long as reasonably necessary and permitted by law for disputes, enforcement, fraud or abuse prevention, and legal claims. We do not use that archive to provide or personalize the Services, for marketing, for routine product analytics, or for artificial-intelligence processing.

Closing your account also opts your email address out of promotional emails. We may retain the email address in a marketing suppression list for as long as reasonably necessary solely to honor that opt-out. We do not use suppression-list information to market to you.

We may retain relevant records longer when an actual or reasonably anticipated dispute, fraud or security incident, legal process, or other legal obligation requires a documented hold. Information that has been irreversibly deidentified or aggregated so it can no longer reasonably be linked to you may be retained as permitted by law.

7. APPEALS

If we refuse to act on your request, you may appeal by emailing help@theseeapp.com with “Consumer Health Data Appeal” in the subject line and explaining why you believe the decision should be reconsidered. We will respond to an appeal within the period required by applicable law. If we deny your appeal, we will provide information about how you may contact the appropriate state attorney general.

8. SECURITY

We use administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of Consumer Health Data. No method of electronic transmission or storage is completely secure.

9. CHANGES TO THIS POLICY

We may update this Policy from time to time. We will post the updated Policy and revise the date above. Before collecting, using, or disclosing additional categories of Consumer Health Data or using Consumer Health Data for materially different purposes, we will provide additional notice and obtain consent when required by law.

10. CONTACT US

For questions about this Policy or our Consumer Health Data practices, contact us at:

The See App Company
PO BOX 201
1672 Falmouth Rd
Centerville, MA 02632
help@theseeapp.com