Consumer Health Data Privacy Policy for Washington Residents
Last Updated: August 30, 2026
This Washington Consumer Health Data Privacy Policy (this “Policy”) describes the practices of MitoSynergy, LLC (“MitoSynergy,” “we,” “our,” or “us”) with respect to consumer health data, as that term is defined in the Washington My Health My Data Act (RCW 19.373.005 to 19.373.900) (the “Act”), collected from Washington State residents who participate in the Color Reset Guarantee program (our hair color restoration money-back guarantee program, the “Color Reset Guarantee”) through the Color Reset Guarantee App (the “App”).
This Policy applies to consumer health data collected through the App in connection with the Color Reset Guarantee. It does not apply to personal information we collect from individuals who are not Washington residents, or to personal information that does not constitute consumer health data under the Act. Our general Privacy Policy, available athttps://mitosynergy.com/policies/privacy-policy, describes our data practices for all other personal information.
This Policy sets forth MitoSynergy's baseline privacy practices with respect to consumer health data. Where you have entered into additional agreements or provided separate consents affording greater privacy protections, those agreements and consents supplement this Policy and are not diminished or superseded by it.
MitoSynergy is a cosmetic dietary supplement company. The Color Reset Guarantee is a consumer satisfaction guarantee for a cosmetic supplement product. It does not constitute health care, medical treatment, or a therapeutic program, and MitoSynergy does not provide health care services, render diagnoses, or prescribe treatment. Progress photographs collected through the App are submitted by participants to document cosmetic appearance changes and to verify compliance with program submission requirements. Photographs are not used to assess, diagnose, treat, or monitor any health condition, and results of the Color Reset Guarantee program are not guaranteed.
Please read this Policy carefully. If you do not agree with our practices, you should not participate in the Color Reset Guarantee program. If you have questions about this Policy or our consumer health data practices, please contact us using the information provided below.
Consumer Health Data We May Collect
To the extent that personal information we collect in connection with the Color Reset Guarantee constitutes consumer health data under the Act, we collect the following category of consumer health data:
• Visual information and bodily measurements. Progress photographs you submit through the App, which depict the crown and scalp of your head. The App’s submission guidelines require that photographs depict only the scalp and prohibit the inclusion of facial features. Photographs are collected to document cosmetic appearance changes over the course of the program, to verify compliance with the photograph submission requirements of the Color Reset Guarantee, and for any other purpose for which you have separately provided consent.
We use this consumer health data for the following purposes, and for any other purpose for which you have separately provided consent:
• Program administration. To administer the Color Reset Guarantee, verify compliance with program submission requirements, and process and validate refund claims submitted under the Terms of the Color Reset Guarantee.
• Recordkeeping. To maintain records sufficient to evaluate refund claims and fulfill our obligations under the Terms of the Color Reset Guarantee.
• Program communications. To communicate with you about your program participation, submission status, and related matters.
• Legal compliance. To comply with applicable legal obligations, respond to legal process, and protect our rights, property, and safety and that of our customers and others.
We do not use progress photographs for marketing, advertising, or any external purpose. We do not use photographs to infer personal characteristics unrelated to cosmetic appearance, and we do not generate biometric identifiers or templates from photographs.
Sources of Consumer Health Data
We collect consumer health data directly from you when you submit progress photographs through the App in connection with your enrollment and participation in the Color Reset Guarantee. We do not obtain consumer health data about you from third-party sources.
Disclosure of Consumer Health Data
We do not sell your consumer health data.
The only category of consumer health data we share is participant progress photographs and associated submission metadata (such as submission date, submission count, and program enrollment information). These are shared only with: (i) the App developer; (ii) cloud hosting and storage providers used to maintain and operate the App; and (iii) third-party service providers engaged to assist in claim administration and refund processing. We contractually require all such processors and service providers to operate subject to confidentiality and data use obligations and, for purposes of this Policy, such vendors are treated as extensions of MitoSynergy with respect to the consumer health data they process on our behalf. For purposes of this Policy, such vendors are treated as extensions of MitoSynergy with respect to the consumer health data they process on our behalf.
We do not share your progress photographs with advertising or marketing vendors. Photographs are not used for any marketing, advertising, or commercial purpose, and are not publicly displayed, licensed, or otherwise commercialized.
We may also disclose consumer health data as permitted by applicable law, including:
• Security and fraud prevention. To prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is unlawful under Washington or federal law, and to preserve the integrity or security of our systems.
• Business transfers. To a third party acquiring our assets in connection with a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of our assets, subject to the requirements of the Act.
• Legal process and protection. To investigate, report, or take legal action to protect our rights, property, or safety, or the rights, property, or safety of our customers or others, and to comply with applicable law or legal process.
Your Rights
If you are a Washington resident, you have the following rights with respect to your consumer health data under the Act:
• Confirm and Access. You may request confirmation of whether we collect, share, or sell consumer health data about you and request access to such data, including a list of all third parties and affiliates to whom we have shared or sold your consumer health data and a means to contact them.
• Withdraw Consent. You may withdraw your consent to our collection and sharing of your consumer health data at any time.
• Deletion. You may request that we delete your consumer health data. Because your progress photographs are the record we use to verify your eligibility for a refund under the Color Reset Guarantee, deletion of photographs before your refund claim has been validated will affect your eligibility for the refund. We will explain the consequences of deletion before processing your request and will not discriminate against you for exercising this right.
• Appeal. If we decline to act on your request, you may appeal our decision by contacting us using the information below. If your appeal is denied, we will provide you with information on how to contact the Washington State Attorney General to submit a complaint.
We will respond to verifiable consumer requests without undue delay, and in all cases within 45 days of receipt. We may extend the response period by up to an additional 45 days when reasonably necessary, provided we notify you of the extension and the reason before the initial 45-day period expires. To exercise any of the rights described above, please contact us using the information provided below. We may need to verify your identity before responding to your request. You may designate an authorized agent to submit a request on your behalf; we will require proof of authorization before acting on such a request.
Data Security
We maintain commercially reasonable administrative, technical, and physical security measures designed to protect consumer health data from unauthorized access, use, alteration, disclosure, or destruction. Access to consumer health data is restricted to employees, processors, and contractors with a need to access the data to fulfill the purposes described in this Policy. No security measures are perfect or impenetrable, and we cannot guarantee the security of your consumer health data.
Data Retention
Consumer health data collected through the Color Reset Guarantee is retained only for so long as necessary to administer the program and process refund claims, as further described in our general Privacy Policy available at https://mitosynergy.com/policies/privacy-policy. Our general Privacy Policy contains a specific retention schedule for participant photographs tied to program milestones, including the status of pending refund claims. Upon expiration of the applicable retention period, consumer health data is deleted or de-identified in accordance with our data retention practices.
Changes To This Policy
We may update this Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the revised Policy on our website and update the Last Updated date. We will obtain your consent before collecting or using consumer health data for any purpose not described in this Policy.
Contact Us
If you have questions about this Policy or our consumer health data practices, or to exercise any of the rights described above, please contact us at:
MitoSynergy, LLC
2942 N 24th St, Ste 115
Phoenix, AZ 85016-7849
Email: info@mitosynergy.com