Consumer Health Data Privacy

This Consumer Health Data Privacy Policy supplements the Ken Beauty Privacy Policy and explains how Ken Beauty LLC handles “consumer health data.” It applies to Washington residents and to individuals whose consumer health data is collected in Washington. It may also be applied more broadly as a business practice.

1. What consumer health data means

Consumer health data is personal information linked or reasonably linkable to a person that identifies or may reveal past, present, or future physical or mental health status. In Ken Beauty’s Services, this may include health, wellness, beauty, medication, treatment, procedure, symptom, reaction, photograph, voice, video, or related information submitted for a consultation or matching service.

2. Categories of consumer health data we may collect

Skin concerns, hair concerns, desired outcomes, and related observations.

Medical conditions, health history, allergies, medications, supplements, pregnancy or breastfeeding status, and other health or wellness information voluntarily provided.

Past or planned cosmetic, aesthetic, medspa, medical, or DIY procedures and treatments.

Reactions, complications, symptoms, side effects, sensitivities, or contraindication-related information.

Current skincare products, beauty products, peptide-related information, or wellness routines.

No-makeup photographs, before-and-after photographs, uploaded images, and visual information that may reveal health status or treatment history.

Age or date of birth, contact information, and identifiers associated with the health information.

Consultation audio, video, transcripts, written notes, recaps, and messages.

Inferences or conclusions reasonably drawn from the information solely to provide the requested educational consultation or matching service.

3. Sources of consumer health data

You, including through forms, uploaded files, email, Zoom, telephone, direct messages, customer support, and community communications.

A person you authorize to provide information on your behalf.

[Jotform or final intake provider], Zoom, Read AI, email providers, and other processors used to transmit, record, transcribe, store, or deliver the service you requested.

Information you have made public and specifically direct us to review, such as a public social-media post, when relevant to your request.

4. Why we collect and use consumer health data

To provide the one-on-one consultation, product matching, skin-booster matching, beauty education, recap, or other service you request.

To communicate with you before, during, and after the requested service.

To maintain an accurate record of your submitted information, consent, consultation, and recap.

To operate and secure the form, meeting, recording, transcription, storage, and email systems needed to provide the service.

To identify and address technical, security, fraud, harassment, or legal issues.

To comply with applicable law, enforce agreements, and establish or defend legal claims.

To generate internal, aggregated, or de-identified operational statistics. We do not use identifiable consumer health data for targeted advertising, audience building, or public marketing.

5. Consent and necessity

Before collecting consumer health data through an intake form, Ken Beauty will provide a clear consent request identifying the categories collected, the purpose, the processors or recipient categories involved, and how consent may be withdrawn. Consent to collect health data will not be hidden inside general Terms of Service. Information strictly necessary to provide a product or service you specifically request may also be processed to fulfill that request as permitted by law.

You may decline to provide optional health information. However, if requested information is necessary to deliver the consultation safely and meaningfully, Ken Beauty may be unable to provide or may discontinue the service.

6. Categories of consumer health data shared

Ken Beauty does not sell consumer health data. Ken Beauty does not share consumer health data with affiliates or unrelated third parties for advertising, marketing, data brokerage, or audience creation. Consumer health data may be disclosed to processors acting on Ken Beauty’s instructions when necessary to provide the requested service, including:

[Jotform or final intake provider] for secure form submission and file upload.

Zoom for the video consultation.

Read AI for recording, transcription, notes, and storage when recording is enabled and consented to.

Email, cloud-storage, security, and information-technology providers needed to transmit, protect, or store the information.

Attorneys, insurers, courts, regulators, or authorities when reasonably necessary to obtain legal advice, protect rights or safety, respond to legal process, or comply with law.

A service provider may qualify as a processor rather than a “third party” under applicable law when it processes information only on Ken Beauty’s behalf and consistently with the disclosed purpose. Ken Beauty will seek contractual restrictions appropriate to the nature of the service and information.

7. Third parties and affiliates with whom health data is shared

Ken Beauty currently has no affiliate entities with which it shares consumer health data. We do not intentionally share consumer health data with unrelated third parties. If this practice changes, we will update this Policy and obtain any consent required before the new sharing occurs.

8. Sale of consumer health data

Ken Beauty does not sell consumer health data and does not request authorization to sell it. If this practice ever changes, a separate authorization meeting applicable legal requirements would be required; it would not be combined with the consultation consent or conditioned on purchasing goods or services.

9. Consumer rights

Subject to applicable law and verification, you may have the right to:

Confirm whether Ken Beauty is collecting, sharing, or selling your consumer health data.

Access your consumer health data and receive information about any applicable third parties or affiliates with whom it was shared or sold.

Withdraw consent from future collection or sharing.

Request deletion of consumer health data from Ken Beauty’s records, including applicable systems and processors, subject to lawful exceptions and backup timing permitted by law.

Appeal a refusal to act on a request.

Exercise rights without unlawful discrimination.

10. How to submit a request or appeal

Email thekenbeauty@gmail.com with the subject line “Consumer Health Data Request.” Identify the request and provide the email address, order, form, or consultation involved. Do not send additional sensitive health details unless requested through a secure method. We may request information reasonably necessary to authenticate the request.

We aim to respond without undue delay and, when Washington law applies, within 45 days after receipt. If reasonably necessary, the response period may be extended once by up to 45 additional days, with notice and an explanation. Health data in archived or backup systems may require additional time for deletion as permitted by law. Requests are generally free up to the frequency required by law.

To appeal a denial, reply within a reasonable period with the subject line “Consumer Health Data Appeal” and explain why you believe the decision should be reconsidered. We will respond in writing within the time required by applicable law. If an appeal is denied, information about contacting the Washington Attorney General will be provided when required.

11. Withdrawal of consent

You may withdraw consent prospectively by emailing thekenbeauty@gmail.com. Withdrawal does not invalidate processing that occurred lawfully before withdrawal. If the information is necessary to provide an active consultation or requested service, withdrawal may prevent completion of that service and does not create a right to a refund except where required by law or expressly stated in writing.

12. Retention and deletion

Consultation forms, photographs, signed consents, recordings, transcripts, recaps, and related consumer health data are generally retained for up to five years after the consultation or last related activity, unless deleted earlier following a valid request, retained with consent, or required for security, fraud prevention, legal compliance, or the establishment or defense of legal claims. Valid deletion requests will be communicated to applicable processors and contractors. Backup deletion may be delayed only as permitted by applicable law.

13. Security

Access to consumer health data is limited to Ken and to processors or professional advisers whose access is necessary for the disclosed purpose. Ken Beauty uses reasonable safeguards appropriate to the nature and volume of the information, including account controls, limited access, two-factor authentication where available, secure transmission offered by providers, and reasonable vendor restrictions. No system is completely secure.

14. Changes to this Policy

We will not collect, use, or share additional categories of consumer health data or use existing data for materially new purposes without updating this Policy and obtaining affirmative consent when required. The effective date above identifies the current version.

15. Contact