Jovia

Jovia Routine

Consumer Health Data Privacy Policy

Effective date: October 28, 2026 · Version: 1.1

This policy applies to consumer health data that Jovia Labs, Inc. ("Jovia", "we", "us") collects through the Jovia mobile app (the "App"). It is written for the Washington My Health My Data Act (RCW 19.373), Nevada's consumer health data law (NRS Chapter 603A, as amended by SB 370), the Connecticut Data Privacy Act, and other state laws that protect consumer health data. We apply it to everyone who uses the App. Our Privacy Policy covers all other information.

1. Consumer health data we collect

  • Check-in answers about your skin: how your skin feels (oily, dry, mixed or neutral) and whether you washed your face before checking in.
  • Check-in tags you choose, which can relate to your health: for example poor sleep, stress, alcohol, exercise, sun, sweat, picking at your skin, feeling unwell, and being on your period. The "On my period" tag is reproductive health information.
  • Check-in photos of your face, up to 9 per check-in (front, left and right), with each photo's quality information (a score and notes such as blurry, too dark or glasses likely). We do not create face templates or other biometric identifiers from them, and we do not store facial landmarks or face geometry, but because the photos show your face and skin, we treat them as consumer health data.
  • Your skincare routine and logs, including products you add yourself and your notes, to the extent they show the condition or care of your skin.
  • Inferences: we do not create inferences about your health from this data. If we ever offer skin analysis, we will ask for your separate consent first.

2. Why we collect and use it

Only to provide the features you ask for: your private photo record, your check-in history, your routine and logs, and your points and streak. We keep your photos so that, if we later offer skin analysis, you could see changes over time; we will not analyze them without your separate consent. We do not use consumer health data for advertising, marketing, or training artificial intelligence models.

3. Sources

We collect consumer health data only from you, through the App. We do not buy health data or receive it from other companies.

4. Consumer health data we share, and with whom

  • Processors. Amazon Web Services stores and processes consumer health data for us (hosting, database and encrypted file storage in the United States), under a contract that limits its use to providing that service.
  • Third parties and affiliates. We do not share consumer health data with third parties or affiliates, and we do not allow third parties to collect consumer health data through the App.
  • Legal requirements. We disclose consumer health data only if the law requires it, as our Privacy Policy describes, and we will challenge requests that are not legally valid.

You can ask us for a list of every processor and third party that has received your consumer health data, with their contact information (see section 8).

5. We do not sell consumer health data

We do not sell consumer health data, and we never will without your separate, signed authorization as the law requires.

6. Your consent

  • When you sign up, you consent to our collection of your check-in photos and answers by agreeing to this policy, together with the Terms of Service and the Privacy Policy. We record this consent separately from your acceptance of those documents.
  • We would ask for your separate consent before sharing consumer health data with anyone other than our processors, and before using it for a new purpose, such as skin analysis.
  • You can withdraw your consent at any time (section 8). We then stop collecting new check-in photos and answers. Your routine, logs and streak keep working.

7. Your rights

You have the right to:

  • confirm whether we collect, share or sell your consumer health data, and access it, including a list of all third parties and affiliates that received it, with their contact information;
  • withdraw consent to our collection and sharing of your consumer health data;
  • delete your consumer health data. If you delete your account in the App, we lock it at once and delete your data from our active systems 30 days later; if you ask us by email, we delete it within 30 days. We tell our processors to delete it. Copies in our encrypted backups expire within 35 days after that, well within six months;
  • appeal our decision on your request.

We do not charge for requests, and we will not treat you differently for using your rights.

8. How to use your rights

  • In the App: Account → Delete account locks your account at once and permanently deletes it and all of your consumer health data 30 days later. To keep your account, sign in again within those 30 days. You can skip or stop any check-in, and skip the check-in questions.
  • By email: write to admin@joviahealth.com with the subject "Consumer health data request" to access your data, get the list of recipients, withdraw consent, or delete specific photos or answers.

We verify your request through your account (for example by sending a code to your phone number) and answer within 45 days. If we need more time, we will tell you why and may extend once by 45 days.

Appeals. To appeal a decision, reply to it with the word "Appeal". We answer within 45 days and explain our reasons. If we deny your appeal, you can contact the Washington State Attorney General (atg.wa.gov/file-complaint), the Nevada Attorney General (ag.nv.gov) or the Connecticut Attorney General (portal.ct.gov/ag), or the Attorney General of your state.

9. Other protections

  • Only Jovia personnel who need consumer health data to provide or secure the App, or to answer your request, can access it.
  • We do not use geofences around places that provide health care services.
  • We do not use your consumer health data to infer or track your location.

10. Changes and contact

When we change this policy, we post the new version with a new effective date and keep earlier versions at joviahealth.com/legal/archive. We will ask for your consent again before we collect, use or share consumer health data in a new way.

Jovia Labs, Inc., 169 Madison Ave STE 99917, New York, NY 10016 · admin@joviahealth.com