Consumer Health Data Privacy Policy

1. Scope and Applicability

This Consumer Health Data Privacy Policy supplements the general MyNana Privacy Policy and applies specifically to personal information defined as “consumer health data” under the Washington My Health My Data Act (MHMDA, RCW 19.373) and comparable state health data privacy statutes.

MyNana (operated by Colibri Innovation LLC, Texas, United States) provides home safety assessment technologies designed to identify physical living space hazards and suggest environmental modifications. We do not provide medical diagnosis, treatment, or clinical care.

2. Categories of Consumer Health Data We Collect

Depending on your interaction with the MyNana App, we may collect the following categories of health-related information:

• Physical Mobility Characteristics: Information about mobility limitations, balance, gait stability, and the use of assistive mobility devices (such as canes, walkers, or wheelchairs).

• Fall History: Prior incidents or risk factors related to slips, trips, or falls within the home.

• Sensory Factors: Vision and eyesight limitations as they affect the ability to navigate steps, thresholds, or dimly lit rooms.

• Daily Living Routines: Information about nighttime bathroom navigation and transfer habits related to bathroom fixtures.

• Inferred Environmental Hazards: Safety risk assessments and hazard markers generated by our AI assessment service based on room photographs and user responses.

3. Sources of Consumer Health Data

We collect consumer health data from the following sources:

• Directly from you when you complete the safety assessment questionnaire within the App.

• From an adult child, family member, or authorized caregiver who completes the questionnaire on your behalf with your consent or valid legal authority where that authority covers this disclosure.

• Inferred from room photographs analyzed by our automated assessment system to identify physical fall hazards.

4. Purpose of Collection and How We Use Health Data

Consumer health data is collected and processed strictly to fulfill the primary purpose requested by you:

• To evaluate room photographs and pinpoint physical hazards (e.g., missing grab bars, slick tile, high tub edges, tripping obstacles).

• To formulate tailored, prioritized home modification recommendations and generate personal assessment reports.

We do not use consumer health data for behavioral advertising, marketing profiling, or any purpose unrelated to providing the requested safety assessment.

5. Disclosures and Third-Party Processors

We do NOT sell, license, rent, or trade consumer health data to data brokers, ad networks, or marketing aggregators.

We disclose consumer health data strictly to necessary service providers bound by confidentiality and data protection agreements to operate the assessment service:

• Google LLC (Google Gemini Developer API): Evaluates room photographs and relevant profile details—specifically including room type, physical mobility factors, assistive device usage, fall history, eyesight, age group, living situation, home tenure, and first name if entered—under commercial Paid Services terms to detect physical hazards and generate safety recommendations. Google’s published abuse-monitoring policy specifies a retention period of up to fifty-five (55) days for prompts, contextual inputs, photos, and responses, during which authorized personnel may review flagged content; this data is not used to train or fine-tune models except those specifically used for policy enforcement.

• Google LLC (Firebase / Google Cloud): Hosts backend API infrastructure and authenticates requests within the United States.

• Affiliates: MyNana does not share consumer health data with corporate affiliates, parent companies, or subsidiaries.

6. Your Consumer Health Data Rights

Under the Washington MHMDA and comparable laws, eligible consumers have specific rights regarding their consumer health data:

• Right to Confirm and Access: You have the right to confirm whether we collect, share, or process your consumer health data and access such data. You may also request a list of third parties and affiliates with whom we have shared your consumer health data, together with an available contact method.

• Right to Withdraw Consent: You may withdraw your consent for future collection or processing of your health data at any time.

• Right to Delete: You have the right to request the deletion of your consumer health data. Upon receiving a verifiable deletion request, we will delete your consumer health data from our records and instruct our service processors to delete or purge such data from their records in accordance with applicable legal requirements.

To exercise any of these rights, email privacy@mynana.com with the subject line “Consumer Health Data Request”. We will verify and respond to your request within forty-five (45) days. If reasonably necessary, we may extend this period by an additional forty-five (45) days by providing notice within the initial timeframe.

If we deny your request, you may submit an appeal by emailing privacy@mynana.com with the subject line “Consumer Health Data Appeal”. We will review and respond to your appeal in writing within forty-five (45) days of receipt, explaining our decision and the reasons for our determination. If your appeal is denied, you may contact the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.