Consumer Health Data Privacy Policy

Effective date: 2026-12-15

Version: 2026-11-07.1

This policy explains how GemndAI LLC ("Gemnd", "we", "us") collects, uses and shares consumer health data in the Gemnd app and on our website.

Consumer health data is personal information that is linked, or can reasonably be linked, to you and that identifies your past, present or future physical or mental health. It includes what we infer or derive about your health, including by algorithms or machine learning.

Washington's My Health My Data Act (RCW 19.373) requires this policy. We follow it for every Gemnd user, wherever you live, and we give everyone the rights in section 5. We ask for your consent before collecting consumer health data on its own screen, as Washington requires and as Minnesota and Virginia require for sensitive and health information.

Our Privacy Policy covers the other personal information we handle, including what Nevada's consumer health data law asks us to tell you.

In the app, this policy is at Settings → Your data and devices → Consumer health data privacy policy.

1. Consumer health data we collect and how we use it

Gemnd is an AI companion that you talk to by text and voice, and that remembers you. You decide what to tell your companions. When you talk about your health, or ask your companion a general question about health, we collect it. Gemnd is not health care and is never offered as a health service: companions give general information, as any AI would, and never diagnose or treat.

What you tell your companions about your health

What it is. Anything you type, dictate or say in a call about your physical or mental health. For example:

• conditions, illnesses, injuries, disabilities and symptoms;
• mood and emotional wellbeing, such as depression, anxiety or loneliness;
• medications, treatment, therapy, surgeries and procedures;
• sexual or reproductive health, such as contraception, pregnancy, fertility, sexual function or sexually transmitted infections;
• gender-affirming care.

It also includes your companion's replies and your conversation titles when they repeat or refer to what you said. It also includes anything about your health you write into a selfie request or a custom look.

How we use it.

• To write your companion's replies, in chat and in calls, including answers to general health questions you ask.
• To notice when what you describe may need urgent care, so your companion tells you to call 911 or see a doctor. This reading shapes that reply only; we don't store it.
• To speak your companion's replies aloud, in calls and when you have a reply read aloud.
• To search the web when your companion needs current information to answer you. The search words your companion writes can reflect what you told it.
• To keep your conversation history, so you can read it and your companion can pick up where you left off.
• To form memories, as described below.
• To create your companion's pictures and videos when your selfie or look request mentions your health.
• To run automated safety checks on your messages, companion settings and requests, never your companion's replies, so that companions stay within our content rules and Gemnd can show you crisis resources when you may be at risk.

Memories, notes and summaries about you

What it is. Health facts and summaries that Gemnd's AI creates from your conversations, such as "takes medication for anxiety" or "had knee surgery in March". This includes:

• memories you ask your companion to keep or correct;
• notes your companion saves about you, including a short profile with your name, your work and an "about you" description;
• summaries of earlier conversations;
• a search index of your memories that our own systems compute.

How we use it. So your companions remember what you have shared, stay consistent with you, and can bring it up when it matters. That includes the replies, spoken replies and web searches described above.

You can see, edit, stop using or forget each saved memory in Memory. Your profile notes, conversation summaries and the search index are not shown there. They are deleted when you delete your account, or sooner if you ask us (section 5).

Health details in your companion settings

What it is. Anything about your health that you write into a companion's settings, such as how you would like to be supported on a hard day, or a topic to avoid. It also includes changes your companion makes to its own settings because of something you said, together with the words that prompted the change.

How we use it. To shape how your companion talks with you.

Safety signals

What it is.

• A record that Gemnd showed you crisis resources, such as the 988 Suicide & Crisis Lifeline, after one of your messages.
• A record that an automated safety check found signs of distress or a risk of self-harm in a message. This record keeps a one-way fingerprint (a hash) of what the check looked at, never its text.
• Entries in our operational logs for each automated safety check, including the score it gave for signs of self-harm, and a note when a safety response was given. They carry coded identifiers and no message text.
• A record that your companion turned down a request, naming only which of our rules applied and the kind of request in our own words, for example a request for a diagnosis. It never holds your words.

How we use it. Only to show you crisis resources, to keep Gemnd safe, to keep your companion consistent when it has turned something down, and to meet laws that require us to detect and respond to signs of suicidal thoughts, self-harm or eating disorders.

If the law requires us to report how often we showed crisis resources, we will report only totals that cannot be linked to you, and we will not try to re-identify them.

Reports you send

What it is. If you report a companion's reply, selfie or custom look, we keep what you reported and any note you add. Either may contain health information.

How we use it. So a person can review the report, and so we can improve our safety rules.

Your voice, when your iPhone can't transcribe it

What it is. Gemnd turns your speech into text on your iPhone whenever your iPhone can. When it can't, your voice is streamed over an encrypted connection to our speech-recognition provider, which turns it into text. In a call, the audio passes through our call service on the way.

How we use it. Only to turn your speech into text.

• We keep the text as part of your conversation. We do not keep the audio, and we do not record calls.
• Our speech provider is set not to keep the audio after transcribing it, and not to use it to improve its models.
• Washington law can treat some voice recordings as biometric data. Gemnd does not create voiceprints or any other template of your voice, and never uses your voice to identify you.

The selfie for an age check

What it is. If your app store can't confirm that you are 18 or older, you take a short selfie age check, run by our provider Didit, before your first conversation. Didit measures facial features in the selfie to estimate your age and checks that it shows a live person. Washington law treats this biometric data as consumer health data.

How we use it. Only to confirm that you are 18 or older. It is never used to identify you.

• Didit tells us only whether the check confirmed your age. We never receive the selfie, the measurements or your estimated age.
• Didit deletes the selfie and the measurements as soon as the result reaches us, and in every case within 30 days.
• The check asks for its own consent before the camera opens. Our Privacy Policy has the full retention schedule.

Messages you send us

What it is. Anything about your health in an email or letter you send us, including a privacy request.

How we use it. To answer you and to handle your request.

Only these uses

We use consumer health data only for the purposes in this section.

• We do not use it for advertising or marketing.
• We do not sell it.
• We do not use it to set your price or your plan.

Any new purpose, such as training AI models, would first need an updated policy and your consent.

2. Where we get it

• From you: what you type, say and choose in Gemnd, and what you send us.
• From your iPhone's microphone: only while you dictate a message or are in a call.
• From your camera, through Didit: only the selfie for an age check, if you take one.
• From our systems and our processors' AI models: they create memories, notes, summaries and safety signals from what you share.

We do not buy consumer health data or receive it from other companies.

3. Who we share it with

Third parties and affiliates

We do not sell consumer health data, and we do not share it with any affiliate or with any company for its own use. The only third parties that may receive it are:

• Courts, law enforcement and other government agencies, only when the law compels us, such as a valid court order, search warrant or subpoena, and only the consumer health data it requires. We review every request first and, unless the law forbids it, we tell you before we disclose.
• Others who help us respond to security incidents and illegal activity, such as law enforcement, a person or company harmed by fraud or illegal activity, or a security firm. We disclose consumer health data to them only to prevent, detect, protect against or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activity, or activity that is illegal under Washington or federal law; to keep our systems secure; or to investigate, report or help prosecute those responsible. We disclose only what that purpose needs.

We do not disclose consumer health data to enforce our Terms of Use or to defend legal claims without your consent.

If Gemnd is merged with or sold to another company, a company that takes over consumer health data must comply with Washington's My Health My Data Act and this policy.

Processors

Our service providers ("processors") process consumer health data on our behalf, only to provide Gemnd to you. They do so under binding contracts that set our instructions and forbid any other use. Washington law does not treat processors as third parties.

These are the kinds of processors we use, and the consumer health data each one receives:

• AI model hosting and routing: your conversations, memories, notes and companion settings, to write replies, memories and summaries.
• Content-safety checks: your messages, your companion settings, and the words of selfie and look requests you write.
• Age checks: the selfie for an age check and the measurements made from it, deleted within 30 days at the latest.
• Speech recognition and voice synthesis: your voice when your iPhone can't transcribe it, and the text of replies your companion speaks aloud.
• Call audio service: the audio of a call while it is active. That is your companion's voice, and your voice when your iPhone can't transcribe it.
• Image and video generation: the words of a selfie or look request you write, when they include anything about your health, and the images and videos made from them. Our image and video generation provider, fal, and the model providers it runs for us keep request data and generated files for their own periods: we ask fal not to keep requests or their results in its request history and to delete the files it makes one hour after making them, and the Subprocessors page lists each model provider's period. Those model providers work under fal's agreements with them, which are not published.
• Web search for companion answers: search queries your companion writes, which can reflect what you have told it.
• Cloud hosting, databases and storage: all of the consumer health data in section 1.
• Operational logging and monitoring: the safety log entries described in section 1, including self-harm scores, with coded identifiers and no message text.
• Support mailbox: messages you send us.

Our Subprocessors page names our current processors and says what each one does. In the app, it is at Settings → Your data and devices → Subprocessors.

4. Your consent

Before we collect it

Before your first conversation, Gemnd asks for your consent to collect and use consumer health data as this policy describes. It asks on its own screen, after the Allow AI processing screen. That consent is separate from our Terms of Use, our Privacy Policy and your AI-processing consent, and it is never part of another choice.

The screen tells you:

• which consumer health data we collect: what you tell your companions about your health, the memories and summaries made from it, health details in your companion settings and safety signals;
• why: to reply to you, speak, remember you, keep you safe and create your companion's look;
• who receives it: our processors, on our instructions only, with a link to our Subprocessors page, which names every processor;
• how to withdraw your consent: Settings → AI processing.

You agree by tapping Allow. We record that you agreed, the version of this policy you were shown and when, and we keep that record for 6 years after your account ends, without your email address or any link to your conversations.

If you do not agree, you can keep your account, download your data or delete it. Your companions cannot talk with you, though, because anything you tell them may include health information, and they need to process what you say.

The selfie age check asks for its own consent, as section 1 describes.

We collect consumer health data only with that consent, or where collecting it is necessary to provide something you asked for, such as answering an email or letter you send us.

Sharing

Apart from the disclosures in section 3, we do not share consumer health data with third parties or affiliates. If that ever changed, we would ask for your separate consent first.

Selling

We do not sell consumer health data, and we do not ask anyone to authorize a sale.

Withdrawing consent

Go to Settings → AI processing, and withdraw your health-information consent or turn AI processing off.

• We stop using AI to process what you write and say, stop forming memories and safety signals from it, and stop sending your conversations to our processors, right away. We still keep anything you send us yourself, such as an email.
• Chat, calls, memory updates and avatar creation pause until you turn AI processing back on.
• Anything already sent to a processor before you turned it off cannot be recalled.
• Your conversations and memories stay until you forget memories, delete your account or ask us to delete them. You can still download or delete your data.

To stop only new memories, turn off Remember new conversations in Memory.

5. Your rights and how to use them

Your rights

• Confirm and access. You can find out whether we collect, share or sell your consumer health data, and get a copy of it. In the app: Settings → Your data and devices → Download my data. The download includes your conversations, memories, notes, companion settings, safety records and reports. It does not include the safety entries in our operational logs or what you wrote in an email to us. For a copy of those, email privacy@gemnd.ai and we will send it to you.
• Get the list of third parties and affiliates. If we have ever disclosed your consumer health data to a third party under section 3, we tell you which one and how to contact it. On request, we also send you our list of processors and how to contact each one.
• Withdraw consent and stop collection. See section 4.
• Delete.
  • One memory: Memory → open the memory → Forget this. This removes the memory and its earlier versions. The messages it came from stay in your conversation history. To delete those too, email us.
  • Everything: Settings → Delete account.
  • Anything else, such as specific messages, your profile notes or conversation summaries: email us.

How deletion works. We delete your consumer health data from our live systems within 30 days after we confirm that the request comes from you, and in every case within 45 days after we receive it (60 days if we extend the deadline as explained under "When we answer"). That includes the safety entries in our operational logs, which are deleted automatically within 30 days. We notify every processor and any other recipient we disclosed it to, so they delete their copies too. Our image and video generation providers keep request data and generated files for 30 days. Our Privacy Policy explains when backup copies expire. We keep a record of your request and our answer for 24 months, and it holds only what you wrote to us and what we replied.

How to make a request

• Use the in-app controls above.
• Email privacy@gemnd.ai from the email address on your Gemnd account.
• Write to GemndAI LLC, 160 East Sunrise Highway #1016, Freeport, NY 11520, United States.

To protect your data, we confirm that a request comes from you before we act on it, for example by sending a code to your account's email address.

• You do not need to create an account to make a request. If you already have one, we may ask you to use it.
• If we cannot confirm that a request comes from you, we will ask you for more information.
• Someone you authorize can make a request for you. We will confirm it with you directly.

When we answer

We respond within 45 days after we receive your request. If we need more time because a request is complex, or because you have sent several, we will tell you why within those 45 days, and we will take no more than 15 more days.

Requests are free. We may decline a request that is manifestly unfounded, excessive or repetitive, and if we do, we will tell you why.

Appeals

If we decline a request, in whole or in part, you can appeal:

• reply to our decision email with the word "Appeal" in the subject line; or
• email privacy@gemnd.ai with "Appeal" in the subject line.

We will tell you in writing, within 45 days, what we did and why.

If we deny your appeal, you can complain to your state attorney general:

• Washington: Office of the Attorney General, file a complaint online.
• Anywhere else: the attorney general of the state where you live.

6. Contact us

GemndAI LLC

160 East Sunrise Highway #1016, Freeport, NY 11520, United States

Email: privacy@gemnd.ai