Consumer Health Data Privacy Policy
This policy is for people in Washington, Nevada and other states whose laws protect "consumer health data". It is part of our Privacy Policy (Section 15.IV) and uses its terms. Invictan Corp. ("we") makes FaceMorphs, a cosmetic tool. We do not collect, use or share information about anyone's physical or mental health, health conditions, treatments or health care.
1. The consumer health data we collect, and why
Some of these laws treat biometric data as consumer health data. The only such data we hold is in Harmon training uploads, which we receive only if you are 18 or over and have agreed to them on the App's consent page (using the App at 18 and over requires that consent). For each Harmon scan you then take with the App's camera, the App sends the front photo, the side photo if the scan has one, the facial landmark points the App placed on them, and the sex, date of birth and ethnic background you entered in the App.
We use them only to review the uploads and, if suitable, to train and test Harmon, the App's facial analysis model. We never use them to identify or authenticate anyone, for advertising, or to build a profile of you, and we never sell them.
2. Where it comes from
Only from you: your device sends it directly to our storage after you agree. We do not get consumer health data from anyone else.
3. Who we share it with
We share it only with Amazon Web Services, Inc., which stores it for us in the United States under a contract that limits its use. We do not share it with any affiliate or any other third party, and we do not sell it.
4. How long we keep it
Until you turn Help us improve off or delete your account, and never longer than 3 years after an upload. A version of Harmon already trained using your uploads cannot be un-trained, but your uploads are not used to train future versions after you withdraw.
5. Your rights, and how to use them
- Withdraw your consent and delete your uploads: turn off Help us improve in the App (Settings → Your Data → Face Data) on the device you sent them from, or delete your account (Settings → Account → Delete account). We then delete your uploads. At 18 and over the App then returns to its consent page and cannot be used until you agree again.
- Confirm, access or delete: ask us whether we hold consumer health data about you, for a copy of it, for the list of everyone we share it with, or to delete it, by emailing privacy@facemorphs.com.
- Appeal: if we decline a request, reply to our decision with "Appeal" in the subject line. If we deny your appeal, you can contact the Attorney General of your state.
We will respond within the time the law requires (45 days under Washington's law). To protect you, we may ask you to make the request in the App, or from the device or email address linked to the data. We will not discriminate against you for using these rights.
6. Contact
Invictan Corp., Attn: Privacy, 313 Front St, Lemont, IL 60439-8845, United States · privacy@facemorphs.com