Consumer Health Data Privacy Notice

Keel / keelapp.co · Last updated: August 1, 2026

This Consumer Health Data Privacy Notice ("Notice") supplements our main Privacy Policy and applies to "consumer health data" as defined under applicable laws, including Washington's My Health My Data Act and similar state laws that regulate the collection, use, and disclosure of consumer health data.

Vermilion Inc (operating the Keel brand) ("Keel," "we," "us," or "our") provides this Notice to explain how we handle consumer health data in connection with the Keel Services (keelapp.co and the Keel mobile application).

1. What is consumer health data in the context of keel

Under applicable laws, "consumer health data" can include personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status.

In the context of Keel, the following categories of data may be considered consumer health data when linked to an identifiable individual:

Self-assessment responses that indicate whether a user may be experiencing acute compulsive sexual behaviour or crisis.

Personal limits you set regarding frequency, duration, time windows, or categories of adult content use.

Records of adherence to or deviation from those self-set limits.

Weekly review or measurement data showing patterns of use relative to limits you authored.

Any communications you send to support that describe personal struggles with adult content use or related behavioural patterns.

Important clarifications consistent with Keel's product design and brand:

Keel does not diagnose any condition.

Keel does not collect or process medical records, clinical diagnoses, treatment information, or data from health platforms (Apple HealthKit, Google Health Connect, etc.).

Keel does not host, link to, transmit, or analyze the content of any adult material.

Deviation data is presented as neutral measurement, never as a clinical judgment, "relapse," or moral verdict.

We deliberately route users who indicate acute compulsive crisis away from the product.

2. How we collect consumer health data

We collect consumer health data only in the following ways:

Directly from you when you complete onboarding, set or adjust limits, interact with measurement features, complete the self-assessment, or contact support.

Automatically when the Services record whether activity fell inside or outside the limits you set.

We do not purchase consumer health data from data brokers.

We do not collect consumer health data from third-party health applications or devices.

3. How we use consumer health data

We use consumer health data solely for the following purposes:

To provide the core self-command functionality (allowing you to set limits and see whether you are holding them).

To display neutral measurement and weekly reviews to you.

To operate the self-assessment off-ramp that routes users in acute crisis to external resources and prevents them from using the product when it is not appropriate.

To improve the product (in aggregated or de-identified form where possible).

To detect fraud, secure the Services, and enforce our Terms.

To comply with legal obligations.

We do not use consumer health data to:

Diagnose or treat any condition;

Create marketing profiles based on health or sexual behaviour status;

Target advertising related to adult content, recovery, or addiction treatment;

Share with partners, family members, or accountability systems (such features are permanently prohibited);

Sell the data.

We do not sell consumer health data.

We disclose consumer health data only:

To service providers who process it strictly on our instructions and under contractual obligations of confidentiality and data protection (for example, cloud hosting, analytics under our control, customer support tools).

When required by law, legal process, or governmental request.

To protect the rights, safety, or property of Keel, our users, or others.

In connection with a corporate transaction (merger, acquisition, etc.), subject to continued protection of the data.

With your direction or consent.

We do not disclose limit-adherence or deviation data to any third party for monitoring, accountability, or social purposes.

5. Your rights regarding consumer health data

Depending on your state of residence, you may have the right to:

Confirm whether we are collecting, sharing, or selling consumer health data about you.

Access the consumer health data we hold about you.

Delete consumer health data we hold about you (subject to legal retention requirements).

Withdraw consent where processing is based on consent.

Appeal a refusal to take action on a request.

To exercise these rights, email support@keelapp.co with the subject line "Consumer Health Data Request." We will verify your identity and respond in accordance with applicable law. You may designate an authorized agent; we may require proof of authorization.

We will not discriminate against you for exercising these rights.

6. Data retention

We retain consumer health data only as long as necessary to provide the Services, fulfill the purposes described above, comply with legal obligations, resolve disputes, and enforce our agreements. When you request deletion of your account, we will delete or de-identify consumer health data from our primary systems within thirty (30) days of verifying the request (except where longer retention is required by law). Deleted data may remain in encrypted backups for up to ninety (90) days, after which those backups are overwritten or destroyed in the ordinary course of business.

7. Geographic scope and additional protections

This Notice is intended to satisfy requirements under Washington's My Health My Data Act and similar state consumer health data laws. Even where a specific law does not apply, Keel's product design deliberately minimizes the collection and sensitivity of this data and prohibits its use for shame, surveillance, or clinical purposes.

8. Contact

Questions or requests regarding this Consumer Health Data Privacy Notice should be directed to:

Email: support@keelapp.co

Subject line recommended: "Consumer Health Data Request" or "Health Data Privacy Question"

Postal:

Vermilion Inc

347 5th Ave Rm 1307

New York, NY 10016-5015

United States

This Notice is effective as of the date above and may be updated from time to time. Material changes will be reflected by updating the date and, where appropriate, providing additional notice.