Draft — this document is not in force until it is published.
Consumer Health Data Privacy Policy
Effective from TODO (YYYY-MM-DD).
This policy explains how Lalu collects, uses and shares consumer health data and how to use your rights. It is written for people in the United States, and in particular for consumers protected by the Washington My Health My Data Act (RCW 19.373), Nevada's consumer health data law (NRS 603A.400–603A.550) and the Connecticut Data Privacy Act (Conn. Gen. Stat. § 42-515 and following). It adds to our Privacy Policy, which describes all the personal data we handle.
In short: we collect health data only to keep the care diary you asked for, only with your consent, we share it only with the people your family invites, and we never sell it or use it for advertising.
1. Who we are
Lalu is provided by TODO - the owner's full name and the business name of the sole proprietorship (D-35), TODO - the registered business address from CEIDG, TODO (NIP, REGON). Write to privacy@babylalu.com about this policy or your rights. We have no affiliates.
2. What consumer health data means here
Consumer health data is personal information linked or reasonably linkable to a person that identifies their past, present or future physical or mental health. In a baby care diary almost everything you record about your child is consumer health data — feeding, sleep, diapers, medicines, temperatures. Data about pumping breast milk is consumer health data of the person who pumps.
3. The consumer health data we collect and how we use it
| Category | Examples | How we use it |
|---|---|---|
| Feeding | breastfeeding times and sides, bottles and amounts, solid foods, reactions to food | to keep the diary, show it to your family, compute totals and intervals you see |
| Sleep | when sleep started and ended | the same |
| Diapers | time, kind, colour and consistency | the same |
| Medicines | medicine name, dose, unit, reason, time given; medicine schedules | the same, to remind your family when a dose on a schedule you set is due, and to show the last dose of the same medicine before a new one is saved |
| Temperatures | the reading, the method of measuring, the time | to keep the diary and show it to your family |
| Your own events | events your family defines and their descriptions | to keep the diary |
| Notes, photos and voice notes | free text, photos (location data is removed on your device before saving) and voice notes added to entries | to keep the diary |
| The child's profile | date (and time) of birth, due date, sex, birth weight, profile photo | to show the child's age and the diary |
| Pumping (data of the person who pumps) | times, volumes, sides, kind of pump, notes and attachments | to keep the diary |
| Consent records | when consent was given, by whom, which version of the text | to prove consent and ask again when the text changes |
| History of changes | who added or changed an entry, when, and the values before and after | to show the family who did what and to restore mistakes |
We do not collect precise location, biometric or genetic data, and we do not infer health information from other data.
4. Where it comes from
- From you — what you type, photograph or record in the app.
- From other caregivers in your family — the people a parent invited to the same diary.
- From your device — only the photos and voice notes you choose to add.
We do not buy data and do not receive health data from any other source.
5. Why we collect, use and share it
Only to provide the diary you asked for: to store it, keep it the same on every device of every caregiver in your family, show it, compute the totals, intervals and reminders you see, let you export or delete it, keep it secure, and meet legal obligations. We do not use consumer health data for advertising, marketing, profiling or to train artificial intelligence models.
6. How we process it
The diary is stored first on your device. Once you create an account it is also stored on our servers in the European Union, sent over encrypted connections and backed up every day in encrypted form. Only the people who need it to run the service can access our systems, and they are bound by confidentiality. Our service providers (hosting, storage, e-mail) process data only on our instructions under written contracts consistent with this policy.
7. Consent
- Collection. Before a child can be added, the app asks the parent or guardian for consent to collect and process the child's health data to keep the diary — the child's profile and everything recorded about the child — in a separate step that says what we keep, who sees it and how to withdraw. Data about pumping is collected only after the person who pumps gives her own consent, for one family. Without consent, the data is not collected.
- Sharing. We share consumer health data only with the people a parent of the child invites to the family. Today, inviting someone is the parent's decision: the parent creates the invitation, and before it is created the app tells them the person will see the child's entire history, including entries made before they joined. The app does not yet ask for a separate consent to sharing.
Draft — not for publication. Whether the invitation, and the lactation consent, ask for a separate consent to sharing is being decided (O-31). This section and section 8 change with that decision; the policy stays a draft until then.
- Withdrawal. You can withdraw consent at any time in the app — More → Children → the child → Withdraw consent for a child, More → Settings → Data for the lactation consent. A child's diary disappears from the app at once and from our servers within 24 hours; pumping entries are erased at once. Each device removes its copy as soon as it connects.
8. Sharing and selling
| Category of consumer health data shared | Shared with |
|---|---|
| Everything in the family's diary (section 3) | the members of your family in the app — people a parent invited |
| The child's diary as CSV files, without photos, voice notes or other people's pumping | a parent of the family, as a copy valid 30 days, when another parent withdraws consent for the child or when the owner removes that parent from the family (sections 4 and 5 of our Privacy Policy) |
Nobody else receives consumer health data.
- We do not sell consumer health data and never will without a separate, signed authorization as the law requires.
- We do not share it with advertisers or data brokers, do not use it for targeted advertising, and do not allow any third party to collect it over time or across websites or apps.
- We do not use geofences.
- Our service providers (processors) receive data only to provide the service to you — see section 7 of our Privacy Policy. Error reports and payments never contain consumer health data, and notifications carry only their type and one identifier.
- We disclose data to authorities only where the law requires it.
9. Your rights
Depending on where you live, you have the right to:
- confirm whether we collect, share or sell your consumer health data, and access it — including a list of everyone it has been shared with and how to contact them. In the app: More → Settings → Data → CSV export, and More → Caregivers for the people who have access now; the full list, including former members, on request;
- correct it — edit any entry or profile in the app;
- get a portable copy — the CSV export, always free; it lists photos and voice notes without containing them, and we send those on request;
- delete it — delete an entry, a child, or your account (More → Account → Delete account); deletion reaches our service providers too, and deleted data leaves all encrypted backups within 60 days;
- withdraw consent to collection and sharing (section 7);
- opt out of targeted advertising, sale and profiling — we do none of these, so there is nothing to opt out of.
You can do most of this in the app at once. You can also write to privacy@babylalu.com from the e-mail address of your account so we can confirm it is you; we may ask for more information when we cannot. You do not need to create an account to make a request. We act within 30 days — the law allows up to 45 days, and Nevada requires deletion within 30 days of confirming the request. If a request is complex, we tell you why and answer within another 45 days at most. Responses are free, at least twice a year.
10. Appeals
If we decline your request, you can appeal: reply to our answer or write to privacy@babylalu.com with "Appeal" in the subject. We decide within 45 days (60 days in Connecticut) and tell you in writing what we did and why. If we still decline, you can complain to your state's Attorney General:
- Washington — Office of the Attorney General, atg.wa.gov
- Nevada — Office of the Attorney General, ag.nv.gov
- Connecticut — Office of the Attorney General, portal.ct.gov/ag
11. Changes
We tell you about material changes to this policy in the app or by e-mail before they take effect. We will not collect, use or share consumer health data in a way this policy does not describe without asking for your consent first.