CONSUMER HEALTH DATA PRIVACY POLICY

Effective Date: June 22, 2026

This Consumer Health Data Privacy Policy (“Policy”) applies to MSR GROUP INC (“Misoora,” “we,” “us,” or “our”) and describes how we collect, use, and share consumer health data, and the rights Washington State residents have under the Washington My Health MY Data Act (MHMDA).

This Policy supplements our general Privacy Policy available at misoora.com/pages/privacy-policy.

1. Who This Policy Applies To

This Policy applies to Washington State residents whose consumer health data we collect through our AI Skin Analysis feature, available at ai.misoora.shop.

2. What Is Consumer Health Data

Under the MHMDA, “consumer health data” means personal information that identifies a consumer’s past, present, or future physical health status. This may include data derived from photographs used to assess skin conditions, appearance, or other physical characteristics.

We collect the following categories of consumer health data:

  • Photographs of your skin uploaded through the AI Skin Analysis feature, which may include facial images;

  • Derived skin metrics including skin texture, tone, pore visibility, moisture indicators, and similar cosmetic markers generated by our AI analysis model.

3. How We Collect Consumer Health Data

We collect consumer health data only when you voluntarily use our AI Skin Analysis feature and upload photos of your skin. By using this feature, you consent to the collection and processing of your consumer health data as described in this Policy.

We do not collect consumer health data through passive tracking, third-party data brokers, or any means other than your direct upload.

4. How We Use Consumer Health Data

We use your consumer health data solely to:

  • Provide AI-generated cosmetic analysis and personalized skincare product recommendations;

  • Display your skin metric history across sessions to track changes over time;

  • Generate your AI skin analysis report.

We do not use consumer health data for advertising targeting, identity verification, or any purpose unrelated to providing the AI Skin Analysis feature directly to you.

5. How We Share Consumer Health Data

We share consumer health data only with our AI processing partner, which analyzes uploaded photos and generates analysis results on our behalf. This partner is contractually prohibited from using your data for any independent purpose.

We do not sell consumer health data. We do not share consumer health data with advertising platforms, data brokers, or any third party for purposes other than providing the AI Skin Analysis feature.

6. Data Retention

Consumer health data (uploaded photos and derived skin metrics) is retained only as long as necessary to provide the AI Skin Analysis feature, and in no event longer than 3 years from the date of collection or your last interaction with the feature, whichever comes first.

You may request deletion of your consumer health data at any time as described in Section 7 below.

7. Your Rights Under the MHMDA

As a Washington State resident, you have the following rights with respect to your consumer health data:

  • Right to Access: access a list of the categories of consumer health data we have collected about you and the entities with whom we have shared it;

  • Right to Delete: request deletion of your consumer health data. We will delete and direct our AI processing partner to delete your data within the time required by applicable law;

  • Right to Withdraw Consent: withdraw your consent to the collection and processing of consumer health data at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal;

  • Right to Non-Discrimination: we will not discriminate against you for exercising any of these rights.

8. How to Exercise Your Rights

To exercise any of the rights described above, please contact us at:

Email: info@misoora.com

Subject line: “WA Health Data Request”

Please include your name, the email address associated with your account, and a description of your request. We will verify your identity before processing your request and respond within the time required by applicable law.

9. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will update the Effective Date at the top of this page and post the updated Policy on our Website.

10. Contact Us

For questions about this Policy or your consumer health data:

MSR GROUP INC

30 N Gould St, Ste 4000, Sheridan, WY 82801, United States

Email: info@misoora.com

Website: misoora.com