Consumer Health Data Privacy Policy

This policy is written for consumers in Washington State, under its My Health My Data Act, and we follow it for everyone whose data it describes. It adds to our Privacy Policy, which covers everything else ProductToReel collects.

The data it covers

The only consumer health data we collect is the face and voice of an AI avatar you choose to make of yourself. The Act treats images of a face and recordings of a voice from which a template, such as a faceprint or a voiceprint, could be extracted as biometric data, and so as consumer health data. We treat yours that way even though we never extract one: we never compute or keep a template of your face or your voice. If you don't make an AI avatar, we collect no consumer health data about you.

What we collect

• The clip for the check: a clip of about 12 seconds, with sound, that you record on your AI avatar page — your face, and your voice reading aloud a code shown on the screen, while you turn your head as asked.
• A portrait and a small thumbnail cut from the end of that clip.
• Your avatar's hello video, and the pictures and video takes made from your portrait for the videos you order.
• The facts of the check: when the code was shown and the clip uploaded, the clip's fingerprint (a SHA-256 hash, which can't be turned back into the clip), the automatic check's answers and the reviewer's decision.

Why we collect and use it

• To confirm that the face is yours and live, and to keep a record of your consent. A person at ProductToReel watches your clip for this; an AI model checks frames of it for picture quality and for content we don't accept, and is never asked who you are.
• To make the AI videos you ask for, of you speaking and holding your products, for your own ads.
• To check that the pictures and videos we generate keep your likeness, by comparing them with your portrait.

We use it for nothing else: never to identify or recognise you, never for advertising or our own marketing, and never to train AI models.

Where it comes from

Only from you: your device's camera and microphone, on your AI avatar page, after you sign the release. We get none of it from anyone else.

Your consent

We collect it only with your consent, which you give in a separate release on a screen of its own, before any camera opens. The release names what we collect, why, who processes it and how long we keep it. You can withdraw your consent at any time (see “Your rights” below).

Who receives it

We never sell it, and we share it with no third party and no affiliate (we have no affiliates). Only these processors receive it, to handle it for us, for the purposes above:

• Muapi.ai and the providers of the video models it runs: your portrait and the lines your avatar speaks, to animate it.
• OpenRouter and Anthropic: frames of your clip, your portrait and the pictures generated from it, for the checks above.
• Railway: storage (US).

How long we keep it

• The clip: until the reviewer decides, at most 7 days. A clip that fails a check is deleted at once, and one uploaded but never submitted, after 1 hour.
• A setup you never finish, and what is left of one that was turned down: 7 days.
• The portrait, its thumbnail, your avatar's hello video and the pictures made from them: until you delete your avatar, 12 months after it was last used (we email you 14 days before), or with your account.
• A record that you signed the release, without your face, your voice or the clip: 5 years after your avatar is deleted, so we can show your consent if it is ever questioned.

Your rights

Wherever you live, you can:

• confirm whether we collect, share or sell your consumer health data, see it, and get the list of the third parties and affiliates we have shared it with or sold it to — there are none — and of the processors that receive it;
• withdraw your consent at any time;
• have it deleted: “Delete my face” on your AI avatar page deletes it at once, and we delete it within 30 days of a request by email; either way, we also ask the processors above to delete any copy they still hold;
• not be treated differently for using any of these rights.

How to use your rights

Use “Delete my face”, or email hello@producttoreel.com from the address on your account. If you write from another address, we may ask you to confirm the request from your account first, so no one else can see or delete your data. It costs nothing. We answer within 45 days; if we need longer, we tell you why within those 45 days and take at most 45 more.

Appeal

If we turn down your request, in whole or in part, you can appeal by replying to our answer, or by emailing hello@producttoreel.com with “Appeal” in the subject. We answer an appeal in writing within 45 days, saying what we did or didn't do and why. If we turn the appeal down too, you can complain to the Washington State Attorney General (atg.wa.gov).

Changes

We post every change to this policy here, with its date. We never use your data for a purpose this policy doesn't name without asking for your consent again: when the release changes, you sign it again before your avatar is used.

Contact

hello@producttoreel.com. ProductToReel is operated by an individual sole trader based in Ukraine; the full legal name and address are provided on request.