BCH Scan app: Consumer Health Data Privacy Policy

This policy explains how BetterCallHealth LLP collects, uses and shares consumer health data through the BCH Scan mobile app (iOS and Android). It is published for consumers in Washington (My Health My Data Act, chapter 19.373 RCW), in Nevada (Senate Bill 370 of 2023) and in the other US states with similar laws, and we apply it to everyone who uses the app in the United States.

"Consumer health data" means personal information linked or reasonably linkable to you that identifies your past, present or future physical or mental health status. This policy supplements the privacy policy of the app, which describes all the personal data we process.

1. Who we are

2. What we never do

• We never sell consumer health data.
• We never use it for advertising, never build an advertising profile from it, and never send it to Meta or to any advertising network.
• We never collect your precise location, and we never set up a virtual boundary (geofence) around a place where health care services are provided.
• Your blood test values, their dates and your notes stay on your phone: they are never sent to our servers or to anyone else.

3. The consumer health data we collect, and why

3.1. The health situation you choose to declare, and how you feel

• Data: the situation you declare (for example Hashimoto's, irritable bowel syndrome, fibromyalgia, inflammatory bowel disease, rheumatoid arthritis) and the feelings you tick (fatigue, pain, digestion, sleep, weight, skin, mood).
• Purposes: to weight the reading of products according to your situation; and, in anonymized aggregate form, to develop BetterCallHealth products and services. The reading always describes the product, never your state of health: it is neither a diagnosis nor medical or dietary advice.
• Consent: collected only if you tick a dedicated box after reading the explanation. Without it, nothing is recorded and the app works in exactly the same way.

3.2. The readings of products for your situation

• Data: for each product you scan, the reading calculated for the situation you declared, saved with the scan.
• Purpose: to show these readings again in your history.

3.3. Label alerts

• Data: the allergens you choose to watch on labels.
• Purpose: to highlight them on the labels you scan. Optional, and can be changed or erased at any time in the Profile.

3.4. What you expect from the app

• Data: the goals you choose, for example "Understand my blood tests" or "Follow a change over time".
• Purpose: to choose which features the app puts forward for you. Optional, and can be changed or erased at any time in the Profile.

We collect no other category of consumer health data, and we use these data for no other purpose. Before collecting a new category or using these data for a new purpose, we would update this policy and ask for your consent first.

4. What we do not treat as consumer health data

Your product scans (the barcode, the product, its ingredient list and its score), your shopping list and your week describe products, not your health, and we never process them to infer your health status. We protect them in the same way: they are hosted with the data above, never sold individually and never sent to an advertising network. Your scans enter the anonymous statistics described in section 4 of the privacy policy only if you say yes in the Profile; these statistics never include the data listed in section 3 above, and no aggregate covers fewer than twenty people.

5. Sources

• You, in the app: what you type, tick or scan.
• Our method, which calculates the readings for your situation from what you provide.

We do not buy consumer health data and do not collect it from any other source.

6. Sharing

We do not share consumer health data with any third party or affiliate. It is stored on our own servers, operated for us by a single processor bound by a data processing agreement: Hostinger International Ltd (hosting, servers located in Paris, France). Our other service providers (sign-in sessions, emails, subscriptions, label reading, product records, advert measurement) receive no consumer health data.

If we were ever legally required to disclose these data (for example by a court order), we would do so only to the extent required.

7. Your rights, and how to exercise them

• Confirm and access: you can ask whether we collect, share or sell your consumer health data, and get a copy of it. In the app: Profile, Data, "Export my data". We have no third party or affiliate to list, because we do not share or sell these data.
• Withdraw consent: at any time in the Profile. Removing your situation erases the situation, the feelings and all readings already calculated for it. Label alerts and goals can be changed or erased in the same place.
• Delete: Profile, Data, "Delete my account" erases your account and all the data in section 3 from our active systems immediately. Backups are overwritten within 30 days. The page Delete your BCH Scan account explains the steps if you no longer have the app.
• By email: you can also make any of these requests by writing to privacy@bettercallhealth.com, with "Consumer health data request" as the subject. To protect your data, we may ask you to confirm the request from the email address linked to your account. You never need to create an account to make a request.
• Response time: we answer without undue delay and within 45 days. If we need more time, we may extend this period once by 45 days, and we will tell you why within the first 45 days. Requests are free of charge.
• Appeal: if we decline to act on your request, you can appeal by replying to our decision, or by writing to privacy@bettercallhealth.com with "Appeal" as the subject. We answer in writing within 45 days, explaining what we did or did not do and why. If we deny your appeal, you can submit a complaint to the Washington State Attorney General or, in Nevada, to the Nevada Attorney General.
• No penalty: exercising these rights never changes the price or the quality of the service you receive.

8. Security

Exchanges between the app and our servers are encrypted (TLS). Accounts are authenticated by signed tokens, checked on every request. Access to consumer health data is restricted to the people who need it to run the service, and access to the servers is logged.

9. Changes to this policy

The effective date and version number are shown at the top of this page. In the event of a material change, the app will inform you and, before any new category of consumer health data or any new purpose, ask for your consent.