Legal

Consumer Health Data Privacy Policy

Some state laws, including Washington's My Health My Data Act and Nevada's consumer health data law, treat face measurements as health data. Here is how Terevu handles them.

Working draft. This page has not yet completed attorney review and should not be treated as final. It's published so product, engineering and counsel can review the same text.

Summary

Terevu is designed so that Second Pass LLC, which provides it, does not collect consumer health data. Second Pass does not share or sell it.

Terevu measures your expression, eyes, head position and hands on your own device, only to give you a quiet cue. Terevu is not designed to send those measurements to us or anyone else.

You can manage it on each device: delete one saved expression, or everything with Delete data from this device, at any time.

What counts as health data

Some laws treat biometric data as consumer health data. In Terevu, that means:

  • Live measurements: facial expression, head position, face size in the frame, mouth shape held for a second or more, where your eyes are looking, and whether a hand is near your face. They are used in the moment and discarded.
  • Saved expressions: a small set of numbers describing each expression you choose to save, and the cue sensitivity you choose, not an image.

What we collect, and why

Second Pass does not collect this data. Terevu is designed to process it on your device, for one purpose: comparing how you look right now with the expressions you saved, so it can give you a quiet cue when you drift. Second Pass does not use it, and Terevu is not designed to use it, to identify you, to infer emotions or health conditions, for advertising, or to train AI models.

Where it comes from

Your device's camera, only while you are saving an expression or running a live session, and only after you have agreed on Terevu's consent screen.

What we share, and with whom

None. Terevu does not share or sell consumer health data, and Second Pass has no affiliates that could receive it. The service providers listed in our Privacy Policy handle only purchase, Teams seat and technical records, not anything measured from your camera. If your employer provides Terevu, the admin console is not designed to show this data.

Your rights

You have the right to:

  • Confirm whether we collect, share or sell your consumer health data. We don't.
  • Access the consumer health data we hold. We hold none; what Terevu saved is in Your expressions on your device.
  • Learn which third parties and affiliates receive it. None do.
  • Withdraw your consent, and have your data deleted. Use Delete data from this device on each device, or write to us for help.

Making a request or an appeal

Write to [email protected] with "Consumer health data" in the subject. We'll answer within 45 days. If we decline your request, you can appeal by replying with "Appeal" in the subject; we'll respond within 45 days. If you're not satisfied, you can contact the Washington State Attorney General or your own state's attorney general.

More detail

Our Biometric Data Policy describes what Terevu reads, how long it is kept, and how to delete it. Our Privacy Policy covers everything else we hold.

Contact us

Second Pass LLC, 6605 Miami Lakeway S, Miami Lakes, FL 33014, [email protected].