Consumer Health Data Privacy Policy

Plexar Personality Systems, LLC, a Colorado limited liability company that operates Plexality ("Plexality," "we," "us," or "our"), publishes this policy under Washington's My Health My Data Act (RCW 19.373). It explains what consumer health data PLEXAR Guide, our live video and voice conversation with an AI guide, may collect from Washington consumers, why, where it comes from, who receives it, and how to use your rights.

It applies if you live in Washington or if your data is collected in Washington. It adds to our Privacy Policy, in particular Section 6A, PLEXAR Guide and the Biometric & Perception Notice, which still apply.

1. Consumer Health Data We Collect

Expression signals, only if you turn expression reading on. In Washington, expression reading stays off unless you tick a separate box to turn it on. If you do and your camera is on, our video partner Tavus, Inc. analyzes your facial expressions and voice tone during the call to produce short-lived signals (for example, that you look puzzled). Washington law may count these as consumer health data, because they are inferences about how you are feeling. They are not used to identify you, the Guide does not tell you what it perceives, and an expression is never treated as a diagnosis.
A safety marker. If the words of a conversation show signs of crisis, the Guide shares crisis resources and we record, with that call, that this happened. We do not keep what was said unless you have chosen to keep transcripts.
The topic you choose for a call. In the Guide lobby you can pick or type what you would like to talk about. If that topic is about your health, it is consumer health data. We save it with that call, whether or not you keep transcripts.
Anything about your health you choose to say. Your Guide hears what you say. If you turn on written recaps and transcripts, anything you say about your health is saved with them. If you don't, we do not store your words.

We do not record or store video or audio of your calls, and we do not store expression signals.

2. Why We Collect It and How We Use It

Expression signals: only to adapt the live conversation, such as the Guide's pace and tone, and only for the duration of that call.
Safety marker: to run our crisis protocol, described at How PLEXAR Guide handles crisis moments, and to count how often crisis resources are shown. Any totals we report never include your identity.
Your topic: to shape that call around it and to show it with the call in your history.
Transcripts and recaps: so your Guide can pick up where you left off, and so you can read your recap.

We do not sell consumer health data, use it for advertising, or use it for any other purpose. Before we use it for a new purpose, we will ask for your consent.

3. Where It Comes From

From you, through your camera and microphone during a Guide call, and the topic you pick or type in the Guide lobby.
From Tavus's real-time analysis of your camera video and voice (expression signals).
From our own systems, which check the words of the conversation for signs of crisis and, if you keep them, write your recaps.

4. Who Receives It

We share consumer health data only with these companies, and only for the purposes in Section 2:

Tavus, Inc. produces the expression signals and receives your camera video, voice and words to run the call. Tavus processes your call under its own terms, which let it use call data to maintain and improve its services. When each call ends, we ask Tavus to delete that conversation. Privacy policy and contact details: tavus.io/privacy-policy
Google (Vertex AI / Gemini) receives the expression signals, your topic and your words with each turn of the conversation so it can generate the Guide's replies, and writes your recaps if you keep them. Our servers pass the signals along without saving them. Privacy policy and contact details: policies.google.com/privacy
PostHog, Inc., our product analytics provider, receives an event, linked to your account ID, each time crisis resources are shown on one of your calls, so we can count how often it happens. It does not receive what was said. Privacy policy and contact details: posthog.com/privacy
Functional Software, Inc. (Sentry), our error-monitoring provider, may receive a note that crisis resources were shown on a call if a technical error is reported during that same call. It does not receive what was said. Privacy policy and contact details: sentry.io/privacy
Our hosting providers (Supabase for our database, Vercel for our website) store the safety marker, your topics and any transcripts and recaps you keep, on our behalf.

We do not share consumer health data with any affiliated company. We disclose it to anyone else only where the law requires.

5. How Long It Is Kept

Plexality does not store expression signals. We do not control how long Tavus keeps data under its own terms, so we do not promise a specific period.
The safety marker is part of your Guide call records, which are deleted when you delete your account.
You can delete any conversation's topic, transcript and recap at any time, and they are deleted when you delete your account.
We keep a record of the consent choices you made, as described in Section 6A, so we can show what you agreed to.

6. Your Consent and How to Withdraw It

In Washington, expression reading starts only with your separate consent, given by ticking its own box, and transcripts and recaps are kept only if you choose to keep them. You can withdraw either consent at any time, or email us at privacy@plexality.com to do it for you:

Expression reading: turn it off in the Guide lobby, or use voice-only, which leaves Tavus nothing to analyze. The Guide works either way.
Transcripts and recaps: untick "Keep a written recap and transcript" in the Guide lobby. Voice-only does not change this choice.

A change in the lobby applies from your next call.

7. Your Rights

Under Washington law, you have the right to:

Confirm and access: find out whether we collect, share or sell your consumer health data, get a copy of it, and get a list of every company we have shared it with and how to contact them (the list in Section 4).
Delete: have your consumer health data deleted. We delete it from our systems and pass your request on to the companies listed in Section 4.
Withdraw consent: as described in Section 6.
Appeal: ask us to reconsider if we decline to act on your request.

We will not charge you for these requests.

8. How to Use Your Rights

Make a request: email privacy@plexality.com from the email address on your Plexality account, with "Washington health data request" in the subject. We may ask for information to confirm it is you before we act.
Our answer: we respond within 45 days of receiving your request. If we need more time, we will tell you why within those 45 days, and we may extend once by up to another 45 days.
Appeal: if we decline to act, reply to our decision with "Appeal" in the subject. Within 45 days of receiving your appeal, we will tell you in writing what we did and why. If we deny your appeal, you can contact the Washington State Attorney General at atg.wa.gov/file-complaint.
Without asking us: you can delete a conversation's topic, transcript and recap, or your whole account, yourself in Plexality.

9. Security

We protect consumer health data with the same or greater care than our other confidential data. Inside Plexality, access is limited to the people who need it to run or support PLEXAR Guide.

10. Changes to This Policy

We will update this page and its date when our practices change. We will ask for your consent before we collect new categories of consumer health data, use it for a new purpose, or share it with a new kind of recipient.

11. Contact Us

Plexar Personality Systems, LLC (Plexality)
Email: privacy@plexality.com