Consumer Health Data Privacy Policy
Effective 2026-09-30
Washington and Nevada require this to be its own page, separate from our general privacy policy. It covers the health-related data Drop collects, why each piece is collected, who processes it, and how to get it back or have it deleted.
Scope and effective date
Effective date: 2026-08-05 Applies to: the Drop Skincare mobile application and drop-skincare.com.
1. Consumer health data we collect
Drop treats the entire user health profile as consumer health data. This is deliberate and conservative: RCW 19.373.010(8)(b)(xiii) reaches "proxy, derivative, inferred, or emergent data… including algorithms or machine learning," which means the moment Drop's engine derives a skin condition from a product list, the product list is in scope too. Field-level scoping is not available to a product that infers.
| Category | Examples |
|---|---|
| Reproductive health status | Pregnancy status; breastfeeding/chestfeeding status |
| Declared skin conditions | Eczema flare, active rosacea, compromised barrier, fungal acne, perioral dermatitis, seborrheic dermatitis |
| Declared sensitivities | Named fragrance allergens; free-text sensitivities; fragrance-free / alcohol-free preferences |
| Care status | Whether a dermatologist manages your care |
| Age band | Collected as a safety input (some ingredients carry under-18 contraindications) |
| Skin attributes | Skin type, concerns, sun exposure |
| Product inventory | The skincare products you tell us you own, have used, or have finished |
| Routine and adherence | Your routine, the steps you complete, and when |
| Journal and reactions | Journal entries, reaction reports, and the chips you select |
| Photos | None. Progress photos are not a feature of the app. Shelf, product and ingredient-list photos you take are sent to Drop's AI provider to read the product or ingredient names. Drop does not store the photo: it keeps only the names it reads. The photos are never linked to your profile as images and never used to identify you. The "is a skin photo biometric data" question therefore does not arise, and cannot arise without amending this page first. |
Purposes. We collect this data to (a) build and adjust your routine, (b) apply ingredient safety rules — the contraindication checks that hold back products your profile flags, (c) show you cited explanations for what we flag, and (d) let you keep a record of your own skin over time.
We do not collect or use consumer health data to improve, train, tune, or evaluate our models or product.
Everything in the table above is collected because a feature you asked for needs it, which is the boundary the statutes draw. We hold ourselves to it concretely: on 2026-08-05 we stopped collecting skin tone and acne severity because no part of the product read them. They were collected for a feature we had not built yet, and intending to use something later is not the same as needing it now. If a field is not doing a job for you, we should not be holding it.
2. Sources of consumer health data
- Directly from you — onboarding answers, the skin & safety profile editor, journal entries, reaction reports, photos, and products you add.
- From your use of the app — which routine steps you complete and when.
- We do not buy consumer health data, and we do not receive it from data brokers, advertising networks, or other third parties.
3. Consumer health data we share, and with whom
We share consumer health data with the service providers listed below. Each processes it only on our instructions and only to provide the service we use it for — never for its own purposes. We are still executing the written data processing agreements that record those instructions; until each is executed, the limits below rest on the provider's published terms and our configuration rather than on a signed contract with Drop. We state that plainly rather than imply a safeguard we do not yet have.
| Recipient | What it receives | Why |
|---|---|---|
| Anthropic PBC (AI provider) | Pregnancy status, age band, declared conditions, and derm-care status — only when you have turned on personalized AI features | To generate and personalize your routine. Under Anthropic's API terms, what we send is not used to train their models; Anthropic handles it under those terms, including any short retention they allow. |
| Supabase (hosting/database) | All stored profile data | To host the application database and storage |
| PostHog (analytics, EU region) | Product-usage events — planned, not yet enabled; no data has been transmitted to PostHog | To understand how the app is used. Disclosed here in advance because this document is a closed-purpose framework. Opt-out available in the app under Me → Privacy. |
Anthropic acts as our processor: it works on our documented instructions, and does not train on them. It is not free to use what it receives for its own purposes, which is what separates processing from sharing. That characterisation currently rests on Anthropic's published API terms; the written agreement recording it is being executed and is not yet in place. Regardless of that characterisation, this transmission has its own separate opt-in — it is off unless you turn it on, enforced on our servers rather than in the app, and you can withdraw it at any time in the app under Me → Privacy. Withdrawing it stops the transmission; the app keeps working without personalised routine generation.
Specific affiliates. Washington requires naming specific affiliates. Drop has no corporate affiliates and shares consumer health data with none.
4. Third-party collection across sites and applications
Drop does not permit third parties to collect consumer health data across our website and application over time. We use no advertising SDKs and no cross-context behavioural advertising trackers.
5. Sale of consumer health data
Drop does not sell consumer health data. We earn affiliate commission when you choose to buy through a retailer link, and we are explicit about that elsewhere — but the commission is paid for a purchase, not for data, and the retailer learns nothing about you from us.
That is guaranteed by construction rather than by promise: no health attribute, condition code, or profile-derived parameter is transmitted in any outbound affiliate link or postback. More precisely: no Drop-originated identifier of any kind is present in the outbound URL — not an opaque one, not a hashed one, none. The URL is the static per-product string, byte-identical for every user.
6. Your rights
You may:
- Confirm and access the consumer health data we hold about you, including a list of every third party and affiliate we have shared or sold it to.
- Withdraw consent to our collection of your consumer health data, and separately to our sharing of it.
- Delete your consumer health data, including from backups and archived systems.
Exercising these rights never costs you service or price.
How. In the app: Me → Privacy → View & manage your data. Or email privacy@drop-skincare.com.
Timeline. We respond within 45 days, the window both statutes allow, applied to everyone rather than branched by state — and in practice usually much sooner. If we need more time we will tell you why and how much before the 45 days are up.
Deletion reach. Deleting your account deactivates it immediately; your data is purged from our production database within 30 days and from backups as they are overwritten on their retention cycle (the Privacy Policy states the cycle). We notify every processor that received your data so they delete it too.
Appeals. If we deny a request you may appeal by replying to the denial. If we deny the appeal, you may complain to:
- Washington Attorney General — Consumer Protection Division, https://www.atg.wa.gov/file-complaint
- Nevada Attorney General — Bureau of Consumer Protection, https://ag.nv.gov/Complaints/File_Complaint/
7. Security
We restrict access to consumer health data to what is needed to run the service. Access is row-scoped per user at the database layer, and processor access is bounded by contract.
8. How we notify you of material changes
Because this policy defines the limits of what we may collect and why, a material change requires new disclosure and fresh affirmative consent — we will not quietly widen it. We will notify you in the app before a material change takes effect, and every published version is retained with its effective date.
9. Contact
Drop Skincare LLC 8735 Dunwoody Place, Ste R, Atlanta, GA 30350, USA privacy@drop-skincare.com
This is the same entity named in the Terms of Service.
Questions, or to exercise any right above: privacy@drop-skincare.com