Draft. 7 details on this page are still being finalized (highlighted below).
Drinkyin Consumer Health Data Privacy Policy
For residents of Washington State and Nevada
Effective date: [[EFFECTIVE_DATE]]
Last updated: [[EFFECTIVE_DATE]]
This is a separate, standalone policy required by the Washington My Health My Data Act (RCW 19.373) and Nevada SB 370 (NRS 603A.400–.360). It explains how [[LEGAL_ENTITY]] ("Drinkyin," "we") handles consumer health data.
It supplements our Privacy Policy. Where the two differ about consumer health data, this document controls. Terms not defined here have the meaning given in the Washington and Nevada statutes.
We apply the protections in this policy to every Drinkyin user in the United States and Canada, not only to Washington and Nevada residents. The statute-specific rights in §6 are guaranteed to Washington and Nevada residents and offered as a matter of policy to everyone else.
1. What we treat as consumer health data
Under these laws, "consumer health data" is personal information that identifies a consumer's past, present, or future physical or mental health status. In Drinkyin, that means:
| Category | Specific data |
|---|---|
| Bodily functions and measurements | Your hydration intake — the volume of every drink you log, your daily total, your progress toward a daily hydration goal, and your logging streak |
| Nutrition and substance intake | The nutrition snapshot saved with each log: calories, sugar and added sugar, caffeine, sodium, fat, saturated and trans fat, carbohydrates, fiber, protein, electrolytes, potassium, calcium, iron, magnesium, taurine, and vitamins B3, B6, B12, C and D |
| Alcohol consumption | Logs in the Beer and Alcohol categories, including volume and alcohol by volume (ABV) |
| Caffeine consumption | Logs in the Coffee, Tea, Energy, and Soda categories, and their caffeine values |
| Health conditions and sensitivities | The allergy / "watch out for" tags you save in Settings (for example caffeine, dairy, nuts) |
| Health goals and self-care | Your daily hydration target, your daily nutrient targets, your drink reminders and alarms, your routines (a drink you have logged automatically at a set time), and the goal-crossing alerts you receive |
| Health-related inferences derived from the above | Your weekly report, daily and hourly intake patterns, and the on-screen advice generated from your own numbers |
| Data written to Health Connect (Android, optional) | Hydration records — the volume of each drink — mirrored into Google Health Connect on your device. Nutrition figures are never written |
Precise location is not stored with consumer health data on our servers. The place attached to a drink log stays on your device and is never uploaded.
What is not consumer health data here: your email address, password, username, display name, avatar, follower graph, and technical server logs. Those are covered by the Privacy Policy.
2. Where it comes from
We collect consumer health data from exactly two kinds of sources:
- Directly from you — every value above originates from something you typed, tapped, scanned, or selected inside Drinkyin. Nothing is inferred about your health from outside sources.
- From public product databases you invoke — when you scan a barcode or pick a drink, the product's nutrition figures come from our drink database or from Open Food Facts. Those figures become consumer health data only once you attach them to a log of your own.
We do not buy, license, or receive consumer health data from data brokers, advertisers, employers, insurers, healthcare providers, or any other third party.
3. Why we collect it, and the consent behind it
We collect and use consumer health data only to provide the features you asked for:
| Purpose | Consent basis |
|---|---|
| Save your drink log and show your history, calendar, and weekly report | Necessary to provide the product you requested — logging drinks is the product |
| Fill the hydration ring and calculate today's nutrition totals | Necessary to provide the product you requested |
| Warn you when a drink would cross a daily target you set | Necessary to provide the product you requested |
| Send the reminders you configured | Your separate opt-in, revocable in Settings |
| Log the routines you set up, at the times you chose | Your separate opt-in — you create each routine yourself, and can pause or delete it in Settings |
| Sync your logs and settings to our servers so you can use several devices | Your separate opt-in — you must create an account and sign in; local mode collects nothing |
| Publish a check-in to the community feed | Your separate opt-in, per log — private is the default, and this version gives you no way to publish one |
| Mirror how much you drank into Google Health Connect (volume only) | Your separate opt-in, plus the Android system permission, revocable at any time |
| Attach a place to a log (stored on your device only) | Your separate opt-in, revocable in Settings |
We do not use consumer health data for advertising, for profiling, for scoring or ranking you, for training machine-learning models, or for any purpose you have not been told about here. If we ever want to use it for a new purpose, we will ask for your consent first — separately, unbundled, and in plain language — and a refusal will not degrade the rest of the app.
4. Who we share it with
We do not sell consumer health data. We have never sold it and will not sell it. Under Washington law a sale requires your signed, specific, revocable authorization; we do not ask for such an authorization because we do not engage in the practice. The same is true of Nevada's prohibition on sale without your authorization.
Consumer health data is disclosed only as follows:
4.1 To processors acting on our instructions
| Recipient | Role | What it receives |
|---|---|---|
| Supabase Inc. (United States) | Database, authentication, and file storage provider | Your synced logs and app state, including the categories in §1 |
| [[EMAIL_PROVIDER]] | Sends sign-in codes and service email | Your email address only — no consumer health data |
Each is bound by a written contract to process the data only on our documented instructions, to protect it, and never to use it for its own purposes. We have no affiliates with which consumer health data is shared. If that changes, we will list each specific affiliate by name in this policy before any sharing begins.
4.2 To other users — only when you publish
In this version nothing of yours is published to other users. The community feed is turned off, the app records every log as private, and our database rules let a signed-in account read only its own profile.
In versions that include the feed, marking a log public makes the drink, its volume, its nutrition snapshot, the time, and your profile readable by anyone using Drinkyin — your choice, made per log, with private as the default. Public check-ins appear in the feed for 24 hours.
4.3 To businesses — counts only
A shop or brand can see how many public check-ins its menu items received and how many distinct people made them. It never receives your identity, your private logs, or any individual record. This restriction is enforced in our database rules, not merely by policy.
4.4 When the law requires it
We may disclose consumer health data to comply with a valid subpoena, warrant, or court order, or to establish or defend a legal claim. We will notify you first where we are legally permitted to do so, and we will object to overbroad requests.
5. What we deliberately do not do
- No geofencing. We do not build, use, or purchase a geofence around any health care facility, pharmacy, addiction or recovery service, or any other in-person service, and we do not use location to identify, track, collect data from, or send notifications or advertising to anyone near such a place. Both Washington and Nevada prohibit this, and Drinkyin contains no such functionality.
- No advertising or analytics SDKs. There are none in the app, so no third party receives your health data as a side effect of using Drinkyin.
- No sale, no brokerage, no bundled consent.
- No uploading of the location attached to a log, ever.
- No inference about medical conditions, pregnancy, substance-use disorder, or any other health status. Drinkyin shows you arithmetic on numbers you typed in.
6. Your rights over consumer health data
If you are a resident of Washington or Nevada, you have the rights below. We extend them to all users.
- Confirm and access. Ask whether we are collecting, sharing, or selling your consumer health data, and get a copy of it.
- Know the recipients. Get a list of all third parties and affiliates with which we have shared your consumer health data, and, for each, an active email address or link they have provided so you can contact them.
Delete. Have your consumer health data deleted from our records. On receiving a verified deletion request we will:
- delete it from our live systems, including backups and archives, and from any place we store it;
- notify every processor and third party that received it and instruct them to delete it; and
- confirm to you when this is complete.
- Withdraw consent. Withdraw your consent to the collection and to the sharing of your consumer health data at any time, separately. Withdrawing consent stops future processing; it does not by itself delete what we already hold, so submit a deletion request as well if that is what you want.
- No retaliation. We will not deny you the Service, charge you a different price, or provide a lower quality of service because you exercised any of these rights.
How to exercise them
- In the app, immediately: turn off cloud sync by signing out; make logs private; delete individual logs; turn off reminders, location logging, and Health Connect; and erase everything on that device with Settings → Reset.
- By email: write to [[PRIVACY_EMAIL]] with the subject line "Consumer Health Data Request" and tell us which right you are exercising and which email address your account uses.
- Online form: [[PRIVACY_REQUEST_URL]]
Verification. We verify you by confirming control of the email address on your account. We will not ask you for identity documents or make you create an account in order to make a request.
Timing. We respond within 45 days of receipt. If we need more time we will tell you within those 45 days and may extend once by another 45 days. Deletion requests are honored within 30 days, and we will confirm when processors and third parties have been instructed to delete.
Appeal. If we deny your request, we will explain why and give you a way to appeal. We will decide an appeal within 45 days and, if we still deny it, will give you a link to submit a complaint to the Washington State Attorney General (atg.wa.gov/file-complaint) or, in Nevada, to the Nevada Attorney General's Bureau of Consumer Protection (ag.nv.gov).
7. Changes
If we change how we handle consumer health data, we will update this policy and give notice in the app before the change takes effect. We will not apply a materially different practice to consumer health data we already hold without obtaining your consent first.
8. Contact
[[LEGAL_ENTITY]]
Attention: Privacy Officer — [[PRIVACY_OFFICER_NAME]]
[[MAILING_ADDRESS]]
Email: [[PRIVACY_EMAIL]]
Washington's My Health My Data Act is enforceable by individuals under the Washington Consumer Protection Act. This document is not legal advice; have counsel review it before publication.