Consumer Health Data Privacy Policy

Biraea is a service for announcing a pregnancy and a birth. That means some of what you type into it is, under this law, consumer health data. We collect the following categories.

About your pregnancy and your baby

• Due date. Used to show your own countdown, to order your task list, and to render the site you are building. It is the central fact the product is organised around.
• Birth details -- the date your baby was born, and any weight, length or other detail you choose to enter. Used to render your announcement.
• Labour and birth status -- whether you have marked yourself as "in labor" or your baby as "born". Used to send the announcement you asked us to send, to the people you chose.
• Pregnancy or infant loss. If you retire a site after a loss, we record that the loss happened, the general reason you selected, the date, and the exact words we showed you at the time. Used to stop the pregnancy countdown, to suppress marketing to you, and to stop anything already queued from being sent.

About the people around you

• Dietary restrictions, allergies and related notes that you or your guests enter on guest lists, RSVPs and meal trains. These can reveal a medical condition, so we treat them as health data even though they are usually mundane.
• Meal train and visit scheduling details, which relate to recovery after a birth.

Your private journal

• Journal entries -- the words, feelings and photos you write for yourself, which may describe your health and how you feel. Collected only after you agree to it. Used only to show them to you, and to copy one entry to your own site or scrapbook when you choose to share it. Photo location data is removed when you upload.

Your budget (optional)

• Budget Tracker (the Budget page in your dashboard) -- only if you choose to turn it on: the amounts you plan and spend, including the cost of prenatal care and birth, your baby's medical care and health insurance, with the date of each expense and whether someone else paid; the situation you pick to see an estimate (your type of insurance, such as a work plan, Medicaid or no insurance; the kind of birth you are planning for; how you plan to feed your baby; childcare; and your state); and the names, notes and payees you type. Collected only after you agree to it on a separate screen. Used only to show you your budget and typical costs for your situation, and to count the gifts claimed on your own registry and the cash gifts you have received. Turning the budget off deletes it; we keep only a record of when you agreed and when you turned it off, which is deleted with your account.

Submitted by your visitors

• Baby guesses -- predictions a visitor makes about birth date, weight, length or other details. These are guesses made by other people, not medical facts, but they are linked to your family so we disclose them here.

What we do not collect

We do not collect diagnoses, medical records, test or scan results, medication information, appointment information, genetic or biometric data, or precise location. We do not ask for them and there is no field for them. We do not ask who provides your care; the optional budget asks only what prenatal care and birth may cost you, your insurance situation and the kind of birth you are planning for. If you type any of this into a free-text box anyway -- including a note, or the name of a doctor or hospital you paid, in your budget -- it is held under this policy.

There are only three sources, and all of them are people:

• You, when you fill in your site, your account or your notification settings.
• People you invited -- guests and visitors submitting RSVPs, dietary needs, meal-train sign-ups, messages and guesses on your site.
• Our own calculation from what you entered, such as how many weeks pregnant you are, which is derived from your due date and nothing else, and, if you use the budget, your totals, which also count the gifts claimed on your own registry and the cash gifts you have received.

We do not buy, licence, or receive consumer health data from data brokers, advertising networks, analytics providers, social platforms, or any other outside source. Nothing about your health reaches us except by someone typing it in.

We share consumer health data only where it is necessary to deliver something you asked for. In practice that is a short list.

The categories of health data we share

• The content of announcements and notifications you send, which may state that you are in labour or that your baby has been born
• Birth details and due dates that appear on a site you have chosen to publish
• Dietary restrictions, where you have asked us to pass them to an event host

Who receives it

• The people you chose. Guests you send an announcement to, and — if you make your site public — anyone who visits it. This is the purpose of the product, and you control it.
• Invitations. If you ask us to email an invitation (to a baby shower, for example), Brevo receives each guest's name and email address, your names, the event's details and a link to the invitation, and delivers it. The guest, and anyone they forward it to, can open the invitation only as far as your site's own security allows, and invitation links stop working 30 days after the event's date, or one year after they're made if the event has no date. Biraea never sends invitation text messages: an invitation you share by WhatsApp or text message goes from your own phone. Our Privacy Policy describes invitation links and each guest's choices in full.
• Brevo (email and SMS delivery). Receives the recipient's contact details and the message content, which may state your labour or birth status. Because Biraea is a US company, our contracting party is Brevo's US entity, SIB Inc. US, registered in Delaware, rather than its French parent. Brevo in turn uses its own sub-processors to deliver messages — SMS to US numbers is routed through Twilio — and it publishes the current list in its terms of service. Contact: brevo.com/legal/privacypolicy · dpo@brevo.com
• Railway (application hosting, United States). Stores the database in which all of this lives. Contact: railway.com/legal/privacy · privacy@railway.app
• Cloudflare (network, DNS and email routing, United States). Carries the traffic and delivers mail sent to our published addresses. Contact: cloudflare.com/privacypolicy · privacyquestions@cloudflare.com

Each of these is a processor under RCW 19.373.060. Each is engaged under terms that permit it to process your data only on our instructions and only for the purpose described above, and each is required to act on a deletion request we pass on to it.

Who does not receive it

• No advertising network. We do not serve advertising on any page that reveals a pregnancy, a loss, or a health topic, and we do not send health data to any ad network from anywhere.
• No analytics company. Biraea uses no third-party analytics at all. Our own measurement never records your identity, and our pregnancy loss and mental health pages, your journal and your budget are excluded from measurement in code, not merely by promise.
• No data broker, insurer, employer, or law enforcement, absent a valid legal order we are obliged to obey.
• Nobody receives your private journal. It is stored with Railway, our host, like everything else, and it is never sent to anyone. An entry leaves it only when you share that one entry to your own site or scrapbook.
• Nobody receives your budget. It is stored with Railway, our host, like everything else, and it is never sent to anyone.
• Stripe processes our payments but receives no health data — only your name, email and payment details.

Affiliates

Biraea LLC has no affiliates, parents, subsidiaries or corporate relatives. There is no one inside the company's corporate structure to share your data with.

Biraea has never sold consumer health data and does not sell it. We hold no valid authorization to sell it under RCW 19.373.070, because we have never sought one.

We read "sell" the way the statute writes it — an exchange for monetary or other valuable consideration — which is broader than an exchange for cash. That is precisely why we keep health data away from advertising: an ad network that receives it gives something of value in return, and we are not willing to be in that position.

If this ever changed, the law would require us to obtain your separate, signed authorization first, on a specific form, with the right to revoke it. We would have to ask you in as many words. Silence would not be consent.

RCW 19.373.080 prohibits building a virtual boundary around a health care facility in order to identify people who go there, collect their health data, or advertise to them. Biraea operates no geofence of any kind, anywhere, and does not collect precise location data at all.

Under RCW 19.373.040 you have the following rights over your consumer health data. They are free to exercise, and using them will never degrade your service or cost you a feature.

Confirm and access

You may ask us to confirm whether we collect, share or sell your consumer health data, and to give you a copy of it — together with a list of every third party we have shared it with and a way to contact each one. That list is in Section 3, and it is complete.

You can download your data yourself, at any moment and without asking us, from Account Settings → Download my data. The export is JSON and it includes the health data described in Section 1.

Withdraw consent

You may withdraw your consent to our collecting or sharing your consumer health data. You can do this yourself from Account Settings → Consumer health data, or by writing to us.

Because most of what we hold is data the service cannot run without, withdrawing consent generally means we stop the processing and you stop using the affected feature -- we will tell you plainly which features are affected before anything happens, and withdrawal does not delete anything on its own. Deletion is the separate right below.

Two optional features rest on the consent you gave on their own screens, and each is withdrawn from its own settings. Your private journal: withdrawing stops new entries, and the entries you have stay until you delete them. Your budget: in Budget → Settings → Turn off and delete, turning it off withdraws your consent and deletes your budget at the same time; we ask you to confirm first. Backup copies are gone within 30 days. We keep only a record of when you agreed and when you turned it off, and we delete that record too when you delete your account or ask us to delete your budget data.

Delete

You may ask us to delete your consumer health data. When you do:

• We delete it from our live systems, and from our backups and archived copies, as those copies rotate out on their fixed schedule — we will tell you the outside date when we confirm your request.
• We notify Brevo, Railway and Cloudflare, and every other processor or third party we have shared it with, and require them to delete it too.
• Deletion is not reversible, and it may remove the site you built. We will say so clearly before we act, not afterwards.

On pregnancy and infant loss, specifically: a site retired after a loss is kept private for 30 days, like any retired site, and then deleted. We will never suggest that you delete it sooner.

How to make a request

Write to privacy@biraea.com with the subject line "Consumer Health Data Request", or post to Biraea, 522 W Riverside Ave STE N, Spokane, WA 99201. Tell us which right you are exercising. We may need to verify that the request is really yours, and if we cannot verify it we will tell you why rather than simply not replying.

We respond within 45 days. If we need longer we will write to you within those 45 days to say so and why, and we will then have up to 45 more.

If we say no

You may appeal any refusal. Reply to our decision, or write to privacy@biraea.com with the subject line "Consumer Health Data Appeal". A person will review it and we will respond within 45 days with our decision and our reasoning.

If we deny your appeal, you may complain to the Washington State Attorney General at www.atg.wa.gov/file-complaint. We will give you that link in the denial itself, not only here.

Under RCW 19.373.050 we restrict access to consumer health data to what is necessary, and maintain safeguards to protect it. In practice:

• Sensitive personal fields are encrypted at rest in the database, including guest free-text and address data, your journal entries, and in your budget the amounts, categories, the situation you pick, your state, and everything you type.
• Passwords are stored only as hashes and are never recoverable, by us or anyone else.
• All traffic runs over HTTPS.
• Access to production data is limited to the one person who operates Biraea, protected by two-factor authentication.
• Our pregnancy loss and mental health pages, your journal and your budget are excluded from all measurement in code, so that reaching them leaves no analytics trace.

If we begin collecting, using or sharing a category of consumer health data that is not listed in Section 1, or begin using it for a purpose not listed there, we will update this policy and obtain your consent before doing so — not after.

This policy is effective from the "last updated" date shown at the top of this page. When we make a material change to it, we post the new version here with its new date and tell you by email or with a notice on Biraea.

You can review the consumer health data we hold about you at any time by downloading your data (Section 6). To correct it, change it where you entered it, or write to us at the address below and we will correct it.

We do not allow third parties to collect information about your online activities over time and across websites through Biraea.

Questions about this policy, or about any of the rights above:

• Email: privacy@biraea.com
• Post: Biraea, 522 W Riverside Ave STE N, Spokane, WA 99201

Biraea LLC, a Washington limited liability company.