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Consumer Health Data Privacy Policy

Last updated

These policies are being finalized ahead of Iris’s launch and may change. Questions: privacy@irisjournal.app.

This policy is for residents of Washington (My Health My Data Act), Nevada (SB 370) and Connecticut, and anyone else covered by similar consumer health data laws. It applies to the Iris app and irisjournal.app, run by Gest Vantage LLC, Illinois, USA (“we”). It sits alongside our general Privacy Policy.

Consumer health data we collect

Iris is a journaling companion, so some of what you share may be consumer health data — information about your physical or mental health or wellbeing. We collect:

  • Setup answers: how you feel right now (kept at most 24 hours), what brings you to Iris, what tends to come up for you, what makes time for yourself difficult, what helps you recharge, and your goals.
  • Conversations: what you write or say to Iris about your feelings, mood, health, wellbeing or life, the transcripts of your voice calls, and the notes and recaps Iris keeps so it can follow a conversation.
  • Memory: facts Iris remembers about you when Memory is on, which may include health facts you chose to share (for example, a medication you take — never its dose).
  • Inferences: the replies and recaps Iris generates from the above.

We don’t collect precise location, biometric or genetic data, or data from health devices.

Where it comes from

Directly from you: what you answer during setup and what you type or say to Iris. Recaps, notes and memories are derived from your own conversations.

Why we collect and use it

  • To provide Iris: to write replies to you, keep your conversations and, if Memory is on, remember what matters to you across conversations.
  • To keep Iris safe and working, including showing crisis resources when someone may be at risk.

We collect consumer health data only with your consent, which you give on the consent screen when you set up Iris (“Agree and continue”). We don’t use it for advertising.

Who we share it with

We don’t sell consumer health data. We share it only with processors who handle it on our behalf, under contract, to provide Iris:

  • AI model providers, and the gateway that routes requests to them — to generate replies and run voice calls. They don’t train AI models on it.
  • Our hosting and database provider — to store it.

Our product analytics never receives what you write or say. Your analytics profile does hold the setup choices “what brings you to Iris” and “goals”, and only the number of answers you gave to the other setup questions. We don’t share consumer health data with any other third party or affiliate, except where the law requires it.

Your rights

You have the right to:

  • Know and access — confirm whether we collect, share or sell your consumer health data, see it, and get a list of the processors and third parties we have shared it with.
  • Delete — have your consumer health data deleted, including from our processors. In the app: Settings → Delete account. Or see Delete your account.
  • Withdraw consent — at any time, by deleting your account. Iris can’t reply without processing what you send it. To stop Iris remembering details across conversations, turn Memory off; to remove memories, delete them in Memory.

How to make a request. Email privacy@irisjournal.app from the email on your account. We’ll confirm it’s you and respond within 45 days, or tell you if we need up to 45 more days and why. Requests are free, up to twice a year.

Appeal. If we decline your request, reply to our answer with “Appeal” in the subject. We’ll respond within 45 days. If you’re not satisfied, you can contact your state attorney general — in Washington, at atg.wa.gov.

Contact

Gest Vantage LLC, Illinois, USA privacy@irisjournal.app