Consumer Health Data Privacy Policy

Effective Date: 08/21/26
Last Revised: 08/21/26

This Consumer Health Data Privacy Policy (the “Policy”) sets forth the practices of Syvell (“Syvell,” “we,” “us,” or “our”) with respect to the collection, use, sharing, and protection of Consumer Health Data, as that term is defined under the Washington My Health My Data Act, Chapter 19.373 of the Revised Code of Washington (the “Act”).

This Policy applies to residents of the State of Washington and to any individual whose Consumer Health Data is collected within the State of Washington (each, a “Consumer”). This Policy supplements, and does not supersede or replace, our Privacy Policy. In the event of a conflict between this Policy and our Privacy Policy with respect to Consumer Health Data, this Policy shall control.

Syvell is not a health care provider and does not provide medical advice, diagnosis, or treatment. Syvell offers for sale a consumer light therapy device.

1. Definition of Consumer Health Data

Under the Act, “Consumer Health Data” means personal information that is linked or reasonably linkable to a Consumer and that identifies the Consumer’s past, present, or future physical or mental health status.

Syvell offers for sale a light therapy device cleared by the United States Food and Drug Administration for the treatment of acne and for the reduction of the appearance of wrinkles. Accordingly, and without conceding that such information constitutes Consumer Health Data in all circumstances, Syvell treats the following as Consumer Health Data for purposes of this Policy: information indicating that a Consumer has viewed, inquired regarding, added to cart, or purchased the device, together with any information a Consumer voluntarily provides to Syvell concerning that Consumer’s skin.

2. Categories of Consumer Health Data Collected, and the Purposes of Collection

Syvell does not collect biometric data, genetic data, precise location data, diagnostic testing results, medication data, reproductive or sexual health information, or gender-affirming care information.

3. Categories of Sources

Syvell collects Consumer Health Data from the following categories of sources:

• Directly from the Consumer, in connection with the placement of an order, correspondence with Syvell, subscription to marketing communications, or submission of a review, survey response, or photograph.
• Automatically from the Consumer’s device and browser, through cookies, pixels, and similar technologies deployed on Syvell’s website.
• From Syvell’s service providers, in connection with the completion and fulfillment of a Consumer’s order.

Syvell does not purchase Consumer Health Data from data brokers and does not acquire Consumer Health Data from third-party lists.

4. Categories of Consumer Health Data Shared, and Categories of Recipients

Syvell shares the following categories of Consumer Health Data: purchase and transaction data; website activity data; and communications preference data. Information provided directly by a Consumer is shared solely with Syvell’s e-commerce platform and customer support providers, and solely to the extent necessary to respond to that Consumer.

Syvell shares Consumer Health Data with the following categories of third parties:

Syvell has no affiliates. Syvell does not share Consumer Health Data with any third party outside the categories enumerated above. Should Syvell add a new category of third party recipient, or use Consumer Health Data for a purpose not disclosed in this Policy, Syvell shall first disclose such addition or purpose and obtain the Consumer’s affirmative consent prior to any such collection, use, or sharing.

5. No Sale of Consumer Health Data

Syvell does not sell Consumer Health Data. Syvell shall not sell Consumer Health Data without first obtaining valid written authorization from the Consumer satisfying the requirements of RCW 19.373.070. Any such authorization shall be executed as a document separate and distinct from this Policy and from any consent otherwise provided to Syvell.

6. Consumer Rights

A Consumer is entitled to the following rights under the Act:

• Right to confirm and access. The right to confirm whether Syvell is collecting, sharing, or selling that Consumer’s Consumer Health Data, and to access such data, including a list of all third parties and affiliates with which Syvell has shared or sold such data, together with an active electronic mail address or other online mechanism by which the Consumer may contact each such third party.
• Right to withdraw consent. The right to withdraw consent to Syvell’s collection and sharing of that Consumer’s Consumer Health Data.
• Right to deletion. The right to request deletion of that Consumer’s Consumer Health Data. Upon receipt of a valid deletion request, Syvell shall delete such data from its records, including from all archived and backup systems, and shall notify all third parties and processors with which Syvell has shared such data and direct them to effect deletion.

Syvell shall not discriminate against any Consumer for exercising a right under the Act, including by denying goods or services, charging a different price or rate, or providing a different level or quality of goods or services.

7. Procedure for Exercising Rights

A Consumer may exercise the rights described in Section 6 by submitting a request to support@syvell.com bearing the subject line “Washington Health Data Request,” or by written correspondence addressed to:

Syvell
1308 E Colorado Blvd
Unit #3215
Pasadena, CA 91106

Contents of request. A request must identify the right the Consumer seeks to exercise and must include information sufficient to permit Syvell to locate the relevant records, ordinarily the electronic mail address or order number associated with the Consumer’s transaction.

Verification. Syvell may require verification of the requesting party’s identity prior to acting upon a request. Information provided for purposes of verification shall be used solely for that purpose.

Response period. Syvell shall respond to a request within forty-five (45) days of receipt. Should additional time be reasonably necessary, Syvell shall notify the Consumer within such forty-five (45) day period and may extend its response period by up to forty-five (45) additional days, stating the reason for the extension.

Denial and appeal. Should Syvell decline to act upon a request, Syvell shall notify the Consumer of the reason for such denial and shall provide instructions for submitting an appeal. A Consumer may appeal by responding to Syvell’s determination at support@syvell.com bearing the subject line “Appeal.” Syvell shall respond to an appeal in writing within forty-five (45) days, setting forth the reasons for its determination. Should Syvell deny an appeal, Syvell shall provide the Consumer with a method by which the Consumer may contact the Washington State Attorney General to submit a complaint. A Consumer may in all events submit a complaint directly at https://www.atg.wa.gov/file-complaint.

8. Retention and Security

Syvell retains Consumer Health Data only for so long as is necessary to accomplish the purposes set forth in this Policy, or for such longer period as may be required by applicable law, including records retained in satisfaction of tax, accounting, warranty, and medical device complaint-handling obligations.

Syvell restricts access to Consumer Health Data to those personnel and service providers for whom such access is necessary to accomplish the purposes set forth in this Policy, and maintains administrative, technical, and physical safeguards appropriate to the volume and nature of the data processed.

9. Amendments

Syvell may amend this Policy from time to time. Should Syvell materially change the manner in which it collects, uses, or shares Consumer Health Data, Syvell shall update this Policy and shall obtain the Consumer’s affirmative consent prior to applying such change to Consumer Health Data previously collected.

10. Contact

support@syvell.com
Syvell, 1308 E Colorado Blvd, Unit #3215, Pasadena, CA 91106