Effective date: 13 October 2026 · Version: 1.1
1. Scope
1.1. This Consumer Health Data Privacy Policy applies to consumers in Washington State and to residents of Nevada, Connecticut and other US states with consumer health data laws, including Washington's My Health My Data Act (RCW 19.373) and Nevada SB 370. It supplements the Luluna Privacy Policy (luluna.app/privacy). Where the two differ, this Policy prevails for consumer health data.
1.2. The controller is Onur Coşkun, Yakut Mah. 3851. Sk. No: 8 Kat: 3 Daire: 15, 38000 Kocasinan / Kayseri, Türkiye (support@luluna.app).
2. Categories of consumer health data we collect
When you use Luluna, you may record information about your baby that these laws may treat as consumer health data:
- sleep, feeding (breast milk, formula, solid foods) and nappies/diapers;
- length and weight;
- notes on stool colour and consistency;
- medicines, vitamins, vaccinations and reminders.
The app also stores a profile with your baby's name, date of birth and, optionally, sex.
3. Sources
Consumer health data is collected only from you, when you enter it in the app. We do not purchase health data or collect it from any other source.
4. Purposes
We collect and use consumer health data solely to provide the app's features to you: displaying your records, summaries, sleep windows, reminders and age-based guidance. We do not use it for advertising and do not use it to make decisions about you.
5. Consent
We collect and use consumer health data only after you consent to it on the consent screen when you first set up the app. You may withdraw consent at any time by using Profile → Delete my data.
6. Sharing
6.1. Consumer health data is shared only with Google (Firebase), which stores it on our behalf as a processor (Cloud Firestore, Frankfurt, Germany).
6.2. We do not sell consumer health data and do not share it with advertisers, data brokers or any other third party. If we ever wished to share it for any other purpose, we would first obtain your separate consent.
7. Your rights
7.1. You have the right to:
- confirm whether we collect, share or sell your consumer health data and to access it, including a list of the third parties with which it has been shared;
- have your consumer health data deleted (Profile → Delete my data deletes it immediately; you may also write to us);
- withdraw your consent.
7.2. How to submit a request. Write to support@luluna.app. Because accounts are anonymous, we may ask for information that allows us to locate your records. We respond within 45 days; this period may be extended once by an additional 45 days where reasonably necessary, in which case we will tell you.
7.3. Appeals. If we decline your request, you may appeal by replying to our response with the word "Appeal". We will respond to your appeal within 45 days. If your appeal is denied, you may contact the Washington State Attorney General (atg.wa.gov/file-complaint) or the attorney general of your state.
8. Changes
We will update this Policy if our practices change. Material changes will be reflected in the app's consent process.
9. Contact
Onur Coşkun, Yakut Mah. 3851. Sk. No: 8 Kat: 3 Daire: 15, 38000 Kocasinan / Kayseri, Türkiye · support@luluna.app
