Consumer Health Data Privacy Notice

1. Scope

1.1 This notice is provided by algn technologies, Whitchurch, RG28 7FA (“algn”, “we”, “us”), contact hi@algn.io. It describes how we collect, use and share consumer health data as defined in Washington’s My Health My Data Act (RCW 19.373), Nevada’s SB 370, Connecticut’s consumer health data provisions and similar laws. We apply it to everyone in the United States.

1.2 It adds to our Privacy Policy. Where this notice is more specific or more protective, it applies.

2. Consumer health data we collect

2.1 Conversation content. What you say to Sera may include information about your physical or mental health, conditions, symptoms, treatment, medication, reproductive or sexual health, gender-affirming care, or bodily functions. We process it only in transit, to generate Sera’s reply and to write new memories back to your device. It is not stored on our servers.

2.2 Tone and energy baseline (optional). If you switch on tone and energy, we keep a small set of aggregate numbers describing the normal pace and energy of your voice. These could be considered health data because they relate to your wellbeing. We keep them only with your consent, encrypted, and you can delete them at any time.

2.3 Inferences on your device. Sera’s memories and pattern observations may include inferences about your health. They are created and stored in your memory vault on your device, encrypted with a key we never hold. We do not collect them.

2.4 Safety check signals. A safety check reads each conversation turn for signs of distress. Its output is used only to shape that reply and is not stored.

2.5 We do not collect precise location, biometric identifiers, genetic data, or data about your use of health services from any other source.

3. Why we collect it

3.1 We use consumer health data only to:

• provide Sera’s replies and write memories to your device, which is the service you asked for;
• pace Sera’s replies to you, if you switched on tone and energy; and
• respond with care and refer you to help if a conversation suggests you may be at risk.

3.2 We do not use consumer health data for advertising, marketing, matching, participation scoring, research (unless you separately opt in to a study that says so), or training AI models.

4. Where it comes from

4.1 All consumer health data comes directly from you, through what you say to Sera and, if you switch it on, through your voice.

5. Who we share it with

5.1 Processors only. We share consumer health data only with processors that act on our instructions under contracts that meet these laws: AI model servers that generate Sera’s replies, speech servers for transcription and voice synthesis, and cloud hosting and database infrastructure. Every processor that handles your words or voice works under zero data retention. They keep nothing, don’t train on it and don’t allow human review of it, and they receive requests from algn without anything identifying you.

5.2 Not with anyone else. We do not share consumer health data with third parties or affiliates for their own purposes. We do not share it with other members; only you decide what you tell another person.

5.3 List of processors. You can ask for the names of the processors that have received your consumer health data by emailing hi@algn.io.

6. Consent

6.1 Collection. We ask for your consent to process consumer health data when you join algn, before you first talk to Sera. We ask separately before you switch on tone and energy.

6.2 Sharing. We share it only with processors, as described in section 5. If we ever wanted to share it for any other purpose, we would first ask for your separate consent.

6.3 No sale. We do not sell consumer health data and never will.

6.4 Withdrawing consent. You can withdraw consent at any time by switching off tone and energy, deleting your tone baseline, or closing your account. Because Sera can’t work without processing what you say, withdrawing consent for conversation content means closing your account.

7. Your rights

7.1 You have the right to:

• confirm whether we collect, share or sell your consumer health data;
• access it, including a list of all third parties and processors with whom we have shared it and how to contact them;
• withdraw consent to our collection and sharing of it; and
• delete it. When we delete it, we also tell every processor that has it to delete it.

7.2 We will not treat you differently for using these rights.

8. How to use your rights

8.1 Email hi@algn.io from the address linked to your account, or use the in-app controls. We will confirm it’s you using your account, and answer within 45 days. If we need more time, we will tell you why and may extend by up to 45 more days where the law allows.

8.2 Much of what might count as health data never reaches us. Your memory vault is on your device, and you can see, edit and delete it yourself in the app.

8.3 Appeals. If we refuse your request, you can appeal by replying to our decision with “Appeal” in the subject. We will respond in writing within 45 days, explaining what we decided and why. If we deny your appeal, you can complain to your state Attorney General. In Washington, that’s the Washington State Office of the Attorney General (atg.wa.gov). In Nevada, it’s the Nevada Office of the Attorney General (ag.nv.gov).

9. Geofencing

9.1 We do not use geofencing around any place where health services are provided.

10. Changes

10.1 We will update this notice if our practices change, and ask for your consent again before any new collection or sharing of consumer health data.

11. Contact

11.1 algn technologies, Whitchurch, RG28 7FA. The quickest way to reach us is Report an issue. You can also email hi@algn.io.