Consumer Health Data Privacy Policy

Effective: April 2, 2026

1. Overview

Adaely Group LLC ("Company", "we", "our", or "us") operates the Burr application and related services. Certain shopping data may, when combined with other information, be considered consumer health data under Washington law. Out of an abundance of caution, we provide the protections described in this policy in compliance with the Washington My Health My Data Act (RCW 19.373).

This policy supplements our general Privacy Policy. Where this policy addresses consumer health data specifically, it controls over any conflicting provision in the general Privacy Policy.

2. What Is Consumer Health Data

Under Washington law, "consumer health data" includes personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. This includes information that is derived or extrapolated from nonhealth information by any means, including algorithms or machine learning (RCW 19.373.010(8)).

Burr is a grocery and shopping list application. Grocery purchase patterns may, when processed algorithmically, reveal information about dietary restrictions, allergies, or other health-related preferences. Because Burr processes your shopping data through algorithms and AI services, certain data we collect or derive may be considered consumer health data under Washington law. Burr does not diagnose health conditions or derive health data for health-related purposes. We provide the protections in this policy out of an abundance of caution.

3. Categories of Consumer Health Data We May Collect or Derive

The following categories of data may constitute consumer health data when processed through our algorithms:

  • Shopping item data: Item titles, categories, and purchase history that you enter into the app
  • Purchase pattern inferences: Purchase frequency, average purchase intervals, and predicted reorder timing derived by our Shopping Intelligence algorithms
  • Item priority scores: Algorithmically computed scores that predict which items you are likely to need soon, based on your purchase history
  • AI-processed categorizations: If you enable AI features, item data processed through Google Gemini for categorization and suggestions, which may reflect dietary patterns

We collect this data to provide shopping predictions and suggestions. We do not collect or process this data for the purpose of identifying health conditions.

4. Sources of Consumer Health Data

  • Directly from you: Shopping items, categories, and purchase history that you create and manage in the app
  • Derived by our algorithms: Shopping Intelligence features analyze your purchase history to compute purchase frequency, reorder predictions, and item priority scores
  • Processed by third-party AI: If you enable AI features, Google Gemini processes your item data to provide categorization and suggestions

5. How We Use Consumer Health Data

We use consumer health data solely to provide and improve the Burr shopping experience:

  • Generate shopping predictions and reorder reminders based on your purchase history
  • Provide AI-powered categorization and suggestions, if you enable AI features
  • Display item priority scores to help you plan shopping trips
  • Improve the accuracy of our Shopping Intelligence algorithms

We do not sell consumer health data. We do not use consumer health data for advertising, marketing to third parties, or any purpose unrelated to providing the Burr service. We do not use consumer health data to discriminate against consumers.

Household Sharing

If you join a household and share shopping items, other household members can see those items. Shared shopping items may reveal information about your dietary preferences, health-related purchases, or other health-related patterns. You control which items are shared.

6. Third Parties Who Receive Consumer Health Data

We share consumer health data with the following third party, and only when you have opted in to the corresponding feature:

Google LLC (Google Gemini API)

If you enable AI features in the app's Settings, your shopping item titles and categories are sent to Google's Gemini API for AI-powered categorization and suggestions. Google processes this data under its API Terms of Service and Data Processing Addendum. Under Google's paid API Data Processing Addendum, data submitted through the Gemini API is processed for the requested service only. Google may temporarily log prompts and responses for a limited period solely for safety monitoring and abuse detection.

When AI features are disabled, no shopping data is sent to Google. You may disable AI features at any time through the app's Settings.

We do not share consumer health data with any other third parties, affiliates, or data brokers. Adaely Group LLC has no affiliates or subsidiary entities.

7. Consent and Your Rights

We request your consent before any feature that processes consumer health data is activated. No health data is collected or shared until you affirmatively consent.

Under the Washington My Health My Data Act, you have the following rights regarding your consumer health data:

Right to Know / Access

You have the right to confirm whether we are collecting, sharing, or selling your consumer health data. You may request a list of all third parties and affiliates who have received your consumer health data. To exercise this right, contact [email protected]. We will respond within 45 days of receiving your verified request.

Right to Deletion

You have the right to request deletion of your consumer health data. You may delete your account and all associated data directly from the app's Settings, or by contacting [email protected]. Upon receiving a verified deletion request, we will delete your consumer health data within 45 days and direct any third parties who received your data (including Google, if AI features were enabled) to delete it as well.

Right to Withdraw Consent

You may withdraw consent for the collection of consumer health data at any time through the app's Settings (Privacy → Withdraw Health Data Consent). This deletes your Shopping Intelligence data while keeping your account. You may also withdraw consent by deleting your account entirely.

You may withdraw consent for the sharing of consumer health data with Google Gemini separately by disabling AI features in the app's Settings, without deleting your account.

Consent for collection and consent for sharing are independent. Disabling AI features stops sharing with Google but does not delete previously shared data. To request deletion of previously shared data, contact [email protected].

Right to Appeal

If we deny a request to exercise your rights, you may appeal by contacting [email protected] with the subject line "Health Data Privacy Appeal." You may also file a complaint with the Washington State Attorney General.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf by providing a signed written authorization to [email protected].

8. Data Security

We implement commercially reasonable technical and organizational measures to protect consumer health data from unauthorized access, use, or disclosure, as required by RCW 19.373.050. These measures include:

  • Encryption in transit (HTTPS/TLS) for all data transmission
  • Secure server infrastructure with access controls
  • Passwordless authentication to eliminate credential-based attacks
  • Regular security reviews of our systems and third-party integrations

9. Geofence Restrictions

Pursuant to RCW 19.373.080, Burr does not implement geofencing around healthcare facilities (including hospitals, clinics, pharmacies, mental health facilities, or reproductive health care facilities) for the purpose of collecting, deriving, or selling consumer health data. Burr's geofencing features are used solely for location-based shopping reminders at locations you explicitly save, such as grocery stores.

10. Changes to This Policy

We may update this policy from time to time. If we make material changes, we will provide at least 30 days' notice through the app or via email before the changes take effect.

11. Contact Us

If you have questions about this Consumer Health Data Privacy Policy or wish to exercise your rights, please contact us: