Effective date: 9 November 2026
This Consumer Health Data Privacy Policy explains how Ivivaco Pty Ltd trading as Match My Makeup (“MMM”, “we”, “us”) collects, uses, shares and deletes consumer health data through the Match My Makeup App.
It applies to you if you live in Washington or Nevada, or if your consumer health data is collected in Washington. It is published to meet the Washington My Health My Data Act (RCW 19.373) and Nevada’s consumer health data law (Nevada Senate Bill 370). It also sets out our biometric information retention and destruction schedule for users in Illinois, Texas and other states.
This policy supplements our Privacy Policy, which describes the rest of our data practices. If the two conflict on consumer health data, this policy applies.
We collect four categories of consumer health data, all connected with your Beauty Profile.
| Category | What it includes | Source | How we use it |
|---|---|---|---|
| Face Scan photo (biometric data) | The photo of your face taken during Face Scan | You, through your device camera | Only to generate your Face Scan results |
| Face Scan results | Estimated skin age and skin concerns such as fine lines, redness, acne, firmness, pigmentation and texture | Generated from your photo by Google’s Gemini AI on our behalf | To build your Beauty Profile and recommend complexion and skincare products |
| Skin concerns you tell us | Skin concerns you select in the Beauty Profile questions | You | The same as Face Scan results |
| Inferences | Product recommendations based on your skin concerns, such as products suited to redness | Generated by MMM | To show you recommendations in the App |
We collect Face Scan data only with your consent, given on the Face Scan consent screen before the camera opens. Face Scan is available only to users who confirm they are 18 or over. We collect skin concerns you enter yourself only because you have asked us to use them to build your Beauty Profile.
We also use consumer health data to keep the App secure and to comply with the law. We do not use it for advertising, and we do not use it to train artificial intelligence models.
We do not collect precise location data. We do not use geofencing around health care facilities or anywhere else, and we do not use your location to infer anything about your health.
We do not share consumer health data with third parties or with affiliates. We disclose it only to the processors below, which handle it on our behalf, under contract, and only to provide their services to us.
| Processor | Data it handles | Purpose | Location |
|---|---|---|---|
| Google LLC (paid Gemini API) | Face Scan photo | To analyse the photo and return Face Scan results | United States and other countries where Google operates |
| Linode LLC (Akamai Technologies) | All consumer health data described in section 2 | Hosting and storage of the App | United States (Fremont, California) and India |
We may also disclose consumer health data where the law requires it, for example in response to a valid court order. We will tell you about any such disclosure where the law allows.
We do not sell consumer health data. We will never sell, lease, trade or otherwise profit from your Face Scan photo or Face Scan results.
We keep consumer health data only as long as we need it for the purpose it was collected, and never longer than the limits below. This schedule is also our written biometric information retention and destruction policy under the Illinois Biometric Information Privacy Act and the Texas Capture or Use of Biometric Identifier Act.
| Data | How long we keep it | How it is destroyed |
|---|---|---|
| Face Scan photo | Deleted from MMM’s server within 1 minute of the analysis being completed. Google may keep it for a limited period under its Gemini API terms for abuse monitoring and legal compliance. | Permanent deletion from MMM’s server; deletion by Google under its terms |
| Face Scan results | Until you delete them, withdraw consent or delete your account, and in any event no later than 3 years after your last use of MMM | Permanent deletion from active systems within 30 days; from backups within 1 year. |
| Skin concerns you tell us | Until you delete them or your account, and no later than 3 years after your last use of MMM | As above |
| Inferences | Regenerated each time you view recommendations; deleted with your Beauty Profile | As above |
If the law requires us to keep any of this data for longer, for example because of a legal claim, we keep it only for that purpose and only as long as required.
You have the following rights over your consumer health data:
How to make a request. Email appsupport@matchmymakeup.com with “Consumer Health Data Request” in the subject line, or use the in-app options above. We will ask you to confirm the email address linked to your account so we can verify that the request is yours. You can use an authorised agent, who will need your written permission.
When we respond. We will respond within 45 days of receiving your request. If we need more time, we may extend this once by up to 45 days and will tell you why within the first 45 days. Requests are free, up to twice in any 12-month period.
Appeals. If we decline your request, you can appeal by replying to our decision with “Appeal” in the subject line. We will give you a written decision within 45 days, with our reasons. If your appeal is refused, you can complain to the Washington State Attorney General at atg.wa.gov or the Nevada Attorney General at ag.nv.gov.
We will not treat you differently, or deny you any part of the App other than Face Scan itself, because you exercise these rights.
Security. Only staff and processors who need consumer health data to provide the App can access it. We protect it with encryption in transit, access controls and other reasonable safeguards. We exclude it from error reports and application logs.
Changes. If we change how we collect, use or share consumer health data, we will update this policy and change the effective date. We will ask for your consent again before using your data in a new way that requires it.
Contact. Ivivaco Pty Ltd trading as Match My Makeup, 1501a, Tower 1, 520 Oxford Street, Bondi Junction, NSW 2022, Australia. Email: appsupport@matchmymakeup.com.
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