Consumer Health Data Privacy Policy

Who this policy is for

BR Vault, Co, of New York, runs Twin Flame Journal. Washington's My Health My Data Act (RCW 19.373) requires this policy. It applies to Washington residents and to anyone whose consumer health data is collected in Washington. Some of what you record in the app could identify your physical or mental health, so we describe it here as consumer health data.

1. What we collect, why, and how we use it

• Mood check-ins: the mood you choose and, if you add them, its intensity, what would help and a note. Older check-ins may also hold where you felt it in your body and a chakra state. We use them to save your check-ins, show your trends and let Iris know how you have been.
• What you write or record: journal pages, sealed letters, scrapbook pages, habits, photos and voice notes, where they say something about your body, your mind, a treatment or a medication. We use them to store and sync them, show them back to you and, if you ask, transcribe a voice note.
• Conversations with Iris: your messages and her replies. We use them to write her replies and to carry the conversation forward. Iris also reads your recent moods and the titles of your recent journal pages and, on Pro, your check-in notes and excerpts from those pages. She does not read locked pages or what is in a sealed letter.
• Safety checks: each message to Iris is checked automatically for language that may indicate a crisis, such as thoughts of self-harm, so the app can show crisis resources. We keep a technical log of the result under a coded ID, never your words.

2. Where it comes from

From you, when you type, choose or record something in the app. And from the app, when it works something out from what you gave it: your mood trend, the result of a safety check, and Iris's replies.

3. What we share

We do not share consumer health data with third parties or affiliates, as the Act defines sharing, and we do not sell it.

4. Who receives it

No third parties and no affiliates. Companies that process it for us, only to run the app, are processors under the Act rather than third parties: our hosting and database providers, and our AI providers, which write Iris's replies and transcribe voice notes.

5. Your rights, and how to use them

• Confirm and access: ask whether we collect or share your consumer health data, get a copy, and get a list of any third parties and affiliates that received it, with a way to contact them.
• Withdraw consent: withdraw any consent you have given us to collect or share it.
• Delete: have it deleted. We delete it from our systems and tell the companies that process it for us to do the same. Copies in backups can take up to six months to clear.

To delete everything at once, use Profile → Settings → Delete Account in the app. For anything else, email twinflame@brmarketgroup.io from the address on your account, or write to us. You do not need to create an account to make a request, and we may ask for more information to confirm it is you. We answer within 45 days. If we need longer, we tell you why within those 45 days and take at most 45 more.

If we refuse a request, you can appeal by emailing the same address with "Appeal" in the subject. We answer in writing within 45 days. If we refuse your appeal, you can complain to the Washington Attorney General.

Everything that is not consumer health data is covered by our privacy policy.