Consumer Health Data Privacy Policy

This policy is for residents of Washington, Nevada, Connecticut, and any other state with a consumer health data law. It supplements our Privacy Policy. “We” means Michael Curtis (d/b/a Cleyra).

What We Collect

We collect consumer health data only if you are 18 or older and turn on “Help improve Cleyra” in the app. It's off by default. When it's on, we collect:

• App usage events — for example that you saved a check-in, added a photo, created a progress video, opened a tab, answered a review prompt, or started a subscription and which plan. These are linked to a random ID created for your install. Because the app is for isotretinoin treatment, this usage can suggest that you are taking a prescription medication. The events never include what you logged.
• Your setup answers — age range, gender, state or country, how you heard about us (including any app or site name you typed), and what you want the app to help with.

We do not collect your doses, symptoms, weight, photos, notes, appointments, treatment dates, precise location, name, email, or advertising identifiers.

Separately, everyone who sets up the app contributes to anonymous setup statistics: which setup screens were reached, fixed-choice setup answers, and the outcome of the subscription screen shown during setup. These use a code that exists only in the app's memory for that one setup session and are never connected to your device or to anything else you do, so they are not linked or reasonably linkable to you. We do not attempt to re-identify this data, and we contractually require the same of PostHog.

Where It Comes From

Directly from you, through the Cleyra app on your phone. We do not buy or receive health data about you from anyone else.

Why We Collect It

Only to understand how Cleyra is used and improve it — for example, which features help people stay consistent and what leads people to subscribe. We do not use it for advertising and we do not sell it.

Who Receives It

We share it only with two service providers that process it on our behalf, under contracts that limit them to that purpose:

• PostHog — our product analytics provider. Receives the usage events and setup answers. Stores them in the United States, discards IP addresses, and keeps them for up to one year.
• Helium — runs our subscription screens and handles purchases. Receives your setup answers so we can understand who subscribes.

We do not sell consumer health data, and we do not share it with anyone else unless the law requires it.

Your Rights

• Withdraw consent:turn off “Help improve Cleyra” in the app's Me tab. Sharing stops right away.
• Know and access: ask us whether we have your consumer health data, what it is, and who received it.
• Delete: ask us to delete it. We will delete what we hold and pass the request on to PostHog and Helium.

To make a request, email support@cleyra.skin. Because Cleyra has no accounts, please include the analytics ID shown under Privacy in the app's Me tab (it appears while Help improve Cleyra is on) so we can find the right data. Anonymous setup statistics can't be traced to you, so there is nothing of yours in them to find. We respond within 45 days. If we decline your request, you can appeal by replying to our answer, and we will respond to the appeal within 45 days. If you are not satisfied, you can contact your state attorney general.

Changes

If we change what we collect or who receives it, we will update this page and the effective date above, and ask for your consent again where the law requires it.

Contact Us

Michael Curtis (d/b/a Cleyra)
San Diego, California, USA
Email: support@cleyra.skin