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Memrico Consumer Health Data Privacy Policy

Effective date: August 16, 2026

1. About this policy

This Consumer Health Data Privacy Policy supplements the Memrico Privacy Notice and applies where information Memrico, Inc. (“Memrico,” “we,” “us,” “our”) processes may be considered consumer health data under the Washington My Health My Data Act, chapter 19.373 RCW. It applies to Washington residents.

Memrico is a family photo and memory-sharing service. We are not a health service, we do not ask you about your health, and we do not try to learn anything about your health. However, Washington law defines “consumer health data” broadly enough to include categories of information that most people — and we — would not think of as health information at all, including biometric data. Because our service creates face data from the photos you upload, we publish this policy to address that law directly.

Nothing in this policy is an admission that any particular information we hold reveals anything about your health. It is a disclosure of what we collect and what you can do about it.

Capitalized terms not defined here have the meanings given in our Privacy Notice. Where this policy conflicts with our Privacy Notice as to consumer health data, this policy controls.

2. Categories of consumer health data we collect, and why

We collect the following categories of information that may be considered consumer health data under Washington law:

  • Biometric data — specifically, face data: face geometry derived from the photos and videos uploaded to your space, sometimes called a face template. We create face data only when face-recognition features are enabled.
  • Photographs and videos you or other members of your spaces upload, and which may depict you.
  • Location information contained in photographs, where a photo you upload carries location data recorded by the camera that took it.

Why we collect it, and how we use it. We collect and use these categories to provide the service you asked for: to group photos of the same person together, to let you find photos by person, to place photos on a map, to resurface memories, and to operate, secure, troubleshoot, and improve the service. We also use them as necessary to comply with legal obligations and to protect the safety, integrity, and security of the service and its users.

We do not sell consumer health data. We do not use it for advertising. We do not use it to train our own or any third party’s artificial-intelligence models. We do not use any of this information to infer, derive, or draw any conclusion about your physical or mental health status, and we do not use it to make decisions about you.

Face data is retained and destroyed according to our published Biometric Data Retention and Destruction Schedule.

3. Categories of sources from which we collect it

  • From you — photos and videos you upload, and information you provide in your account.
  • From other Memrico members — photos and videos uploaded by members of a space you belong to, or by members who have shared content with you. A photo uploaded by another member may depict you, and face data may be created from it.
  • From the content itself — face geometry and photo location information are derived by automated analysis of uploaded files, rather than provided directly by anyone.

We do not purchase consumer health data, and we do not obtain it from data brokers, advertising networks, or public sources.

4. Categories of consumer health data we share

We share the categories listed in §2 — face data, photographs and videos, and photo location information — only as described in §5, and only as needed to run the service.

We do not sell consumer health data, and we do not share it for advertising or marketing purposes.

5. Categories of third parties and affiliates with whom we share it

  • Service providers (processors) acting on our behalf, under written contracts that limit their use of the information to providing the service to us — currently including Amazon Web Services, which provides our cloud storage and the face-recognition processing that creates face data. We have directed our providers not to use content processed for Memrico to develop or improve their own services.
  • Other members of your spaces. Memrico is a sharing product. Photos and videos you upload are visible to the members of the space you upload them to, and photos uploaded by others may depict you and be visible to that space’s members. This sharing happens because you or another member chose it.
  • Legal, safety, and security recipients — law enforcement or other parties, where we believe in good faith that disclosure is required by law or valid legal process, or is necessary to protect the rights, property, or safety of Memrico, our users, or the public.
  • A party to a corporate transaction — if we are involved in a merger, acquisition, financing, reorganization, or sale of assets, consumer health data may be transferred as part of that transaction, subject to this policy.

Affiliates: Memrico, Inc. has no parent, subsidiaries, or affiliates. We do not share consumer health data with any affiliate.

6. Your rights, and how to exercise them

Under the My Health My Data Act, RCW 19.373.040, Washington consumers have the right to:

  • Confirm whether we are collecting, sharing, or selling consumer health data about you, and to access that data — including a list of all third parties and affiliates with whom we have shared or sold it, and a way to contact them;
  • Withdraw consent to our collection and sharing of your consumer health data;
  • Delete your consumer health data.

We do not sell consumer health data.

How to make a request. Email privacy@memrico.com, or use our data request form. You do not need a Memrico account to make a request. If you believe you appear in photos uploaded by a Memrico member and want your face data deleted, email us — we will act on your request as described here.

We will take reasonable steps to verify your identity before acting on a request. If we cannot verify it using commercially reasonable efforts, we may decline to act and will tell you why.

What happens when you ask us to delete. We delete the consumer health data from our records, including from archived and backup systems, and we notify our processors and any third parties with whom we have shared it so that they delete it too. Where the data sits in archived or backup systems, deletion may be delayed to allow for restoration of those systems, but never by more than six months from the date we authenticate your request. In practice we destroy face data considerably faster than that — see our Biometric Data Retention and Destruction Schedule.

If we turn down your request, we will tell you why, and you may appeal by replying to that decision or by emailing privacy@memrico.com. We will respond to your appeal in writing. If your appeal is unsuccessful, you may raise a concern or file a complaint with the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.

7. Changes to this policy

If we change this policy we will post the updated version on this page with a new effective date. If we intend to collect, use, or share categories of consumer health data, or to use it for purposes, not described in this policy, we will disclose those changes and obtain your affirmative consent before doing so.

8. Contact

privacy@memrico.com
Memrico, Inc., Woodinville, Washington