Privacy Policy

1. Who We Are

MARKABLE Ltd. ("we," "us," "our") provides MARKABLE, a hormonal wellness platform. MARKABLE is a general wellness product, not a medical device. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use the MARKABLE service at markable.life and related applications.

2. What We Collect

We collect the following categories of information:

Information you provide

• Account information: Email address, name (optional), age range. If you choose to sign in with Google or Facebook, we receive your name, email address and profile picture from that provider. We use them to create and manage your account and to sign you in, and we use your email address as described in this policy.
• Health and wellness information: Information you choose to provide or generate through MARKABLE, including symptom and cycle-related responses, results from THINK cognitive tasks, results from SENSE vision and hearing checks, and numerical wellness data and scores generated from your selfie analysis. This information is collected to provide your wellness assessment, establish a personal baseline, and allow you to track changes over time.
• Communications: Messages you send us via email or contact forms

Information collected automatically

• Device information: Browser type, operating system, screen resolution
• Usage data: Pages visited, time on site, referral source
• Cookies: Analytics cookies for site improvement (see Section 6)

3. Your Selfie and Facial Data

This section is important. We want to be completely transparent about how your facial image is handled:

• Processing: Your selfie is analyzed by our AI to extract numerical wellness data points (texture values, tone values, volume measurements).
• Image storage: Your facial image is stored in encrypted form on our servers to enable your wellness profile generation and longitudinal tracking across multiple checks. You may request deletion of your stored images at any time.
• Numerical data: In addition to the image, we retain numerical wellness data derived from the analysis.
• No facial recognition: We do not use your image for facial recognition, identity verification, or any purpose other than wellness pattern analysis.
• Never sold: Your facial data is never sold, and it is never shared with or made available to third parties for their own purposes. It is processed only by service providers acting on our behalf to provide the service.

4. How We Use Your Data

We use health and wellness information only to provide MARKABLE's wellness features, including generating your results, establishing your personal baseline, tracking changes over time, and creating your wellness summary. We do not sell health and wellness information or use it for advertising.

We use your information to:

• Generate your personal hormonal wellness profile
• Track your wellness patterns over time (when you do multiple checks)
• Create your provider-ready wellness summary
• Improve our algorithms and wellness models (using only anonymized, aggregated data that no longer identifies you)
• Send you results and, if you opt in, wellness updates
• Respond to your questions and support requests
• Comply with legal obligations

We do NOT use your data to:

• Sell to third parties
• Create advertising profiles
• Perform facial recognition
• Make medical diagnoses

5. Who We Share Data With

We do not sell health and wellness information or use it for advertising. Where service providers process information on our behalf in order to operate the service, they may use it only for the purposes described in this policy and subject to our contractual requirements.

We share data only with:

• Service providers: Hosting (Cloudflare Pages), account sign-in (Clerk), analytics (Google Analytics 4, which runs only after you accept analytics cookies), web fonts (Google Fonts), a privacy-friendly visitor-count beacon (a Cloudflare Worker that records only a per-country daily count, no personal data), and payment processing. These providers process data on our behalf under strict contractual obligations.
• At your direction: When you choose to share your wellness summary with a healthcare provider.
• Employer and organisational wellness programmes: When MARKABLE is offered through your employer or another organisation, that organisation receives only aggregated, de-identified statistics. It never receives your individual results, images or answers.
• Business transfers: If MARKABLE is involved in a merger, acquisition or sale of assets, your data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.
• Legal requirements: When required by law, court order, or governmental request.

We do not sell, trade, or rent your personal information to anyone.

6. Cookies and Analytics

Analytics run only after you accept them in our cookie banner; until then no analytics cookies are set. We use:

• Google Analytics 4 (G-EKN2TP5SW8): To understand, in aggregate, how visitors use our site. Loads only after you accept. You can also opt out using Google's opt-out tool, and we honour the Global Privacy Control (GPC) browser signal as an opt-out.
• Essential cookies: To keep you signed in and remember your cookie choice. These set no analytics.
• Visitor counting: A privacy-friendly beacon (a Cloudflare Worker) that records only a per-country daily count of visits; no identifier is stored.

Web fonts: Our pages currently load fonts from Google Fonts, so your browser connects to Google and your IP address is processed by Google to deliver the fonts. We are moving to self-hosted fonts to remove this dependency.

We do not use advertising cookies, retargeting pixels, or social media tracking pixels.

7. Your Rights

You have the right to:

• Access: Request a copy of all personal data we hold about you
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your account and all associated data
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing of your data for certain purposes
• Withdrawal: Withdraw consent at any time where consent is the legal basis

To exercise any of these rights, contact us at privacy@markable.life. We will respond within 30 days.

8. GDPR (European Users)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland:

• Legal basis: We process your data based on your explicit consent (health and wellness information, which is special category data under Article 9 of the GDPR, facial data, and cookies), contract performance (providing the service), and legitimate interest (improving the product using anonymized data).
• Data controller: MARKABLE Ltd. is the data controller.
• Data transfers: Your data may be processed outside the EEA. Where this occurs, we ensure appropriate safeguards are in place (Standard Contractual Clauses).
• Supervisory authority: You have the right to lodge a complaint with your local data protection authority.

9. CCPA and CPRA (California Users)

If you are a California resident, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA):

• Right to know: What personal information we collect, use, and disclose
• Right to correct: Request correction of inaccurate personal information we hold about you
• Right to delete: Request deletion of your personal information
• Right to opt-out: Opt out of the sale or sharing of personal information (we do not sell your personal information; see the analytics opt-out below)
• Right to limit sensitive personal information: The health and wellness information you provide, and the facial data derived from your selfie, may be considered sensitive personal information. We use it only to provide the wellness service you request and do not use it for any other purpose.
• Non-discrimination: We will not discriminate against you for exercising your rights

To exercise any of these rights, contact us at privacy@markable.life. You may also designate an authorized agent to make a request on your behalf.

Do Not Sell or Share My Personal Information

MARKABLE does not sell your personal information in the traditional sense. However, the use of Google Analytics may constitute "sharing" of personal information under the CPRA. To opt out:

When you opt out, Google Analytics will no longer collect data during your visits to MARKABLE. This preference is stored in your browser. You can also install Google's browser opt-out plugin for a global solution across all websites.

We also honor the Global Privacy Control (GPC) signal. If your browser sends a GPC signal, we will treat it as a valid opt-out request and suppress analytics tracking automatically.

To submit a verifiable consumer request or exercise any other CCPA right, contact us at privacy@markable.life.

10. Illinois Biometric Information (BIPA)

If you are an Illinois resident, you have rights under the Illinois Biometric Information Privacy Act (BIPA). The facial geometry derived from your selfie may be considered biometric data. Because of this, we ask for your separate, explicit consent before we capture or analyze it, distinct from your general agreement to these policies, and you may withdraw that consent at any time. We store your facial image in encrypted form, with your consent, only for the purpose of generating your wellness profile and tracking it over time. Numerical data derived from the analysis is also retained. We do not sell, lease, trade, or otherwise profit from your biometric data, and we do not disclose it to third parties for their own purposes. It is processed only by service providers acting on our behalf to provide the service you request, or disclosed where required by law. You may request deletion at any time, and we will delete this data when it is no longer needed for the purpose you consented to, or within the period required by applicable law.

11. Data Retention

• Health and wellness information: Symptom and cycle-related responses, THINK and SENSE results, and assessment scores are retained as long as your account is active, or until you request deletion
• Facial images: Stored in encrypted form while your account is active. Deleted upon account deletion or upon your request
• Analytics data: Anonymized and aggregated data may be retained indefinitely for product improvement
• Account data: Deleted within 30 days of account deletion request

12. Security

We implement industry-standard security measures including:

• Encryption in transit (TLS/SSL) and at rest
• Access controls and authentication
• Regular security assessments
• Secure data processing practices

No method of transmission over the Internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

MARKABLE is a general wellness product and is not a HIPAA covered entity. Our safeguards include encryption in transit and at rest, access controls, written agreements with service providers that handle health-related data, and breach-notification procedures.

13. Children's Privacy

MARKABLE is designed for adult women in midlife and is not intended for anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting a notice on our website. The "Last updated" date at the top of this page indicates when the policy was last revised.

15. Contact Us

For privacy-related questions or to exercise your data rights:

• Email: privacy@markable.life
• General contact: hello@markable.life

Data Controller: MARKABLE Ltd.