Consumer Health Data Privacy Notice
Effective Date:January 14, 2025
Dr. Squatch Consumer Health Data Privacy Notice
This Consumer Health Data Privacy Notice (Notice) supplements Dr. Squatch’s Privacy Policy and applies to “consumer health data” as defined by and subject to certain US state privacy laws, including the Washington’s My Health My Data Act (MHMDA). This Notice describes how Dr. Squatch, LLC and its brands, including without limitation Dr. Squatch and Jukebox, subsidiaries, divisions and affiliates in the US (collectively, “Dr. Squatch”, “we,” “us” or “our”) collect, use, share and otherwise process consumer health data in connect with our websites, messages, other online platforms, or anywhere else we link to or display this Notice (collectively, our “Platform”). This Notice is not, however, a contract and does not create any legal rights or obligations. This Notice further describes the following:
- The categories of consumer health data collected by Dr. Squatch;
- How we use the consumer health data;
- With whom we share the consumer health data; and
- How consumers can withdraw consent from future collection or sharing of their health data.
Categories of consumer health data collected and how we use or share it
The consumer health data we collect about you may vary depending on how you interact with our Platform and consents you may provide. Dr. Squatch sells personal care products such as soaps, deodorants, and lotions. Dr. Squatch collects personal preferences including product preferences, online preferences, and interests. It is possible to make inferences about our website visitors and customers based on their browsing and purchasing history on our website. For example, we may learn about our website visitors’ and customers’ health if you choose to take our online quiz, which helps us recommend products based on the quiz-taker’s preferences. We may learn health-related information if it is offered to us voluntarily when you contact us via email, phone or chat. We may also learn about health-related preferences based on information collected online with tracking technologies. Please see our Privacy Policy and Cookie Policy for more information about our use of tracking technologies.
In the event that a consumer experiences an adverse reaction in connection with any of our products, we will collect information from the consumer, including consumer health data, in order for us to fulfill our obligations under applicable law, including under the Modernization of Cosmetics Regulation Act (MoCRA).
The table below describes the categories of consumer health data we may collect and the purpose for which the data is collected and purpose for which it may be used or shared; the categories of such data that are shared; and the categories of third parties and specific affiliates with whom we share consumer health data. We do not “sell” consumer health data.
| Category of Consumer Health Data | Purposes for Collection, Use or Sharing & Manner of Processing | Categories of Third Parties or Affiliates With Whom Consumer Health Data Is Shared |
|---|---|---|
| Information about your health-related conditions, treatments, diseases or diagnoses, diagnostic testing, health measurements, symptoms, medicationInformation that identifies an individual seeking health-related servicesInformation derived or inferred from nonhealth information | To provide our products and services; to improve our products and services; to understand your interests; to provide product or service recommendations; to respond to your requests or questions; to communicate with you; for short-term, transient use, including nonpersonalized advertising; to verify or maintain the quality or safety of a product, service or device sold by us; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you | Our Affiliates ; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies |
| Biometric data (such skin analysis tools) | To provide product or service recommendations within the analysis tool; to comply with law or to protect ourselves or third parties. | Our Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies |
We may also collect, use, or disclose consumer health data to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal; to preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action that is illegal.
Sources of consumer health data
Sources of consumer health data we collect and use are:
· Directly From You. When you interact with us on our Platform (including one of our websites through our quiz experiences, interacting with a chatbot, responding to an email, or calling us), we (or our service providers) may collect the consumer health data you choose to share with us.
· From Our Affiliates. We may collect via our affiliates, subject to your consent.
· From Third Parties. We may receive consumer health data about you from third-party sources from companies that provide personal information to supplement what we already know about you, including data aggregators, subject to those third parties’ compliance with legal requirements, including legally-required consent.
· Inferences. We may infer certain health information about you based on information provided from any of the sources listed above.
We may use the data on an anonymized and de-identified basis for our business purposes, including for analysis, scholarship, monetization, research and development.
- Using Chat Features. Our website utilizes a chat feature to provide customer support. Use of the chat feature is completely voluntary. Chat sessions are recorded and used by both us and our chat service provider. We may now or in the future provide customer support via chatbox or email that utilizes artificial intelligence (AI) and natural language processing (NLP) to understand customer questions and automate responses to them, simulating human conversation. If you do not consent to these terms, please do not use the chat feature and contact us via email.
Consumer health data rights
You have specific rights with respect to your consumer health data:
- You have the right to know if we are collecting, using or disclosing your consumer health data, to access and obtain a copy of that data, and to receive a list of the affiliates and the third parties with whom we have shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties.
- If we are processing your consumer health data with your consent, you have the right to withdraw that consent for the collection and/or sharing (with third parties and affiliates) of your consumer health data.
- You also have the right to request that we delete your consumer health data.
We will do our best to honor your requests subject to any legal and contractual obligations. We will not discriminate against you for exercising any of your rights. In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
We may need to authenticate your identity and request before processing it, which may require us to obtain additional personal information from you. In order to authenticate your identity, we will generally require either the successful authentication of your existing account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name, email address and mailing address in the original request, as well as an explanation of the rights you wish to exercise. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.
Right to appeal
In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request.
Additional information for Nevada residents
We do not permit third parties to collect consumer health data over time and across different websites while you use our Platform. Where third-party cookies, pixels or tracking technologies are enabled on our Platform and where consumer health data is collected, such third parties are required to agree to act as our service providers. However, third parties may still be able to collect consumer health data from you over time and across different websites depending on your browser, browser add-ons, and permissions you set on your device used to access the Platform. Such collection by third parties is not related to our collection of consumer health data from you. We encourage you to view the privacy notices of those third parties for more information about their data practices and your privacy choices with regard to those activities.
Changes in notice
From time to time, we may change this Notice. We will notify you of any material changes to this Notice as required by law. We will also post an updated copy of this Notice on the Platform. Please check the Platform periodically for updates.