Consumer Health Data Privacy Notice

St.GABRIEL’s Pharmaceuticals, LLC

Effective Date: March 1, 2026

This Consumer Health Data Privacy Notice explains how St.GABRIEL’s Pharmaceuticals, LLC, a Delaware limited liability company (“St.GABRIEL’s,” “we,” “us,” or “our”), collects, uses, and discloses certain categories of consumer health-related data.

This notice applies to personal information that may qualify as consumer health data under applicable U.S. privacy laws, including laws such as the Washington My Health My Data Act and similar state privacy regulations.

This notice supplements our general Privacy Policy and focuses specifically on how we handle health-related information connected to our products, services, digital tools, and online interactions.


1. Scope of This Notice

This Consumer Health Data Privacy Notice applies to information that may reasonably be linked to an individual and that reveals or could be used to infer information about that person’s physical or health condition.

The notice covers consumer health data collected through:

  • our websites and digital platforms

  • mobile or web-based tools

  • consumer questionnaires and product finders

  • virtual consultations or support services

  • research programs or voluntary surveys

  • product purchases and customer interactions

It applies to interactions with St.GABRIEL’s whether online, through digital services, or through other consumer-facing channels.


2. What We Mean by Consumer Health Data

For purposes of this notice, consumer health data refers to personal information that identifies or can reasonably be linked to information about an individual’s health status or health-related characteristics.

Depending on the circumstances, this may include:

  • information about skin or dermatological conditions

  • symptoms or concerns related to physical health

  • information about treatments or health-related routines

  • biometric or facial analysis data derived from images or scans

  • indicators of physiological or biological characteristics

  • inferences about health conditions based on product usage or behavior

  • information that could suggest a consumer’s health interests or concerns

Under certain privacy laws, consumer health data may also include information that indirectly reveals health status, even if it is not medical data in the traditional sense.


3. Categories of Consumer Health Data We May Collect

Depending on the services used, St.GABRIEL’s may collect the following categories of consumer health-related information.

Information Provided Directly by Consumers

Consumers may voluntarily provide health-related information when interacting with our services. Examples include:

  • responses to product recommendation quizzes or questionnaires

  • participation in consumer research or product testing programs

  • communications with customer support representatives

  • submissions related to product reviews or feedback

  • information shared during voluntary consultations or advisory services

Such information may describe skin conditions, health concerns, treatment goals, or similar topics.


Image-Based or Biometric Information

Some of our digital tools may allow consumers to upload or capture photographs or images in order to receive product suggestions or educational information.

When these tools are used, automated systems may analyze visible features such as:

  • skin texture or tone

  • wrinkles or fine lines

  • pigmentation or discoloration

  • visible pores

  • surface irregularities

  • other dermatological indicators

These analyses may generate derived data or assessments used to help provide personalized product recommendations or educational insights.


Behavioral or Usage-Based Health Indicators

In certain circumstances, consumer health data may also include information inferred from consumer activity, such as:

  • browsing content related to specific health topics

  • engaging with educational materials concerning certain conditions

  • searching for products addressing particular symptoms

  • purchasing products intended for specific health concerns

  • using digital tools that evaluate or monitor physical characteristics

Information about device location or contextual usage may also be collected when interacting with our services, where permitted by applicable law.


4. How St.GABRIEL’s Uses Consumer Health Data

St.GABRIEL’s may use consumer health data for several purposes consistent with applicable privacy laws.

These uses may include:

Providing Requested Services

  • delivering digital tools or product recommendation systems

  • responding to consumer inquiries

  • enabling consultations or educational services

  • facilitating purchases and transactions

Personalization and Product Guidance

  • tailoring product suggestions to individual needs

  • improving relevance of digital tools and recommendations

  • providing customized content or experiences

Product Development and Research

  • analyzing trends related to product performance

  • conducting research and development activities

  • improving product formulations or services

Business Operations and Analytics

  • understanding how consumers interact with our platforms

  • evaluating effectiveness of services and tools

  • maintaining and improving system performance

Marketing and Communications

Where permitted by law, St.GABRIEL’s may use certain data to:

  • provide information about products or services

  • deliver relevant marketing content

  • personalize advertising or promotional communications


5. Sources of Consumer Health Data

St.GABRIEL’s may obtain consumer health data from several sources.

Directly From Consumers

Information provided voluntarily through:

  • forms and questionnaires

  • product reviews or feedback

  • customer service interactions

  • consultations or research participation

Automatically Through Technology

When consumers interact with our websites or digital tools, certain information may be collected automatically through technologies such as:

  • cookies and similar tracking technologies

  • analytics tools

  • usage logs and device identifiers

From Third Parties

We may also receive information from third parties, such as:

  • service providers assisting with our operations

  • marketing or analytics partners

  • publicly available sources where permitted by law


6. How We Share Consumer Health Data

St.GABRIEL’s may disclose consumer health data to certain categories of recipients as necessary to operate our services.

These may include:

Service Providers

Third-party companies that support our business operations, such as:

  • cloud hosting providers

  • technology platforms

  • customer service vendors

  • data analytics providers

  • payment processing services

These service providers are generally contractually obligated to use the data only for authorized purposes.


Corporate Affiliates

Consumer health data may be shared with affiliated entities within the St.GABRIEL’s corporate structure when necessary for operational, administrative, or research purposes.


Advertising and Marketing Partners

Where permitted by applicable law, certain information may be shared with advertising platforms or marketing partners to help deliver relevant content or advertisements.

This may include data used to:

  • measure marketing effectiveness

  • personalize advertising

  • deliver content across devices or platforms


Payment and Financial Institutions

When consumers purchase products or services, information necessary to complete transactions may be shared with:

  • banks

  • payment processors

  • financial service providers


Legal or Regulatory Authorities

St.GABRIEL’s may disclose information when required to do so by law or when reasonably necessary to:

  • comply with legal obligations

  • respond to lawful government requests

  • protect rights, safety, or property


7. Consumer Rights

Depending on the jurisdiction in which a consumer resides, individuals may have certain rights regarding their consumer health data.

These rights may include the ability to:

  • confirm whether we collect consumer health data about them

  • request access to such information

  • request deletion of consumer health data

  • withdraw consent for certain processing activities

  • obtain information about third parties with whom data has been shared

Consumers may exercise applicable rights by contacting St.GABRIEL’s using the methods described in our Privacy Policy.


8. Data Security

St.GABRIEL’s maintains reasonable administrative, technical, and physical safeguards designed to protect consumer health data from unauthorized access, disclosure, or misuse.

However, no method of transmission over the internet or method of electronic storage is completely secure, and absolute security cannot be guaranteed.


9. Changes to This Notice

St.GABRIEL’s may update this Consumer Health Data Privacy Notice periodically to reflect changes in our practices, legal requirements, or operational needs.

When updates are made, the revised notice will be posted with an updated effective date.


10. Contact Information

If you have questions about this Consumer Health Data Privacy Notice or our handling of consumer health data, you may contact:

St.GABRIEL’s Pharmaceuticals, LLC

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