Privacy Policy

Last Updated: April 19, 2020

Effective: This Privacy Policy is effective as of the date of your first use of the Services.

Your privacy is important to us.

This is the Privacy Policy (“Policy”) of NuraLogix Corporation. (“Nuralogix”, “we”, “us” or “our” and terms of similar meaning), and is incorporated into and subject to the NuraLogix Terms of Use.  This Policy describes the types of Personal Information and data (hereinafter “Personal Information”) that may be collected, transmitted, received, used, disclosed or stored by us when you access or use our services, our “Anura” application (“Anura”) and our website (“Site”) located at www.anura.ai (such services, Anura and the Site are collectively referred to as the “Services”).  This Policy also describes how your Personal Information is used, shared and protected by us.  Unless defined where used, capitalized terms used herein shall have the meanings given in the Terms of Use.

THE USE OF OUR SERVICES INVOLVES COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION. BY USING THE SERVICES YOU ARE EXPRESSLY CONSENTING TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MUST NOT USE OUR SERVICES.

I. WHAT INFORMATION WE COLLECT

Whenever you access or use our Services, you may be asked to provide, or we may collect, your Personal Information.

Registration and Log-in Information

You are required to provide Registration Data to use our Services which may include a range of Personal Information and data including without limitation, your user alias, date of birth, gender, height, weight and information related to your wellness and lifestyle.

You are also given the option to create an account to access the full features of our Services. When creating your account, we may ask you to provide Registration Data that includes a range of Personal Information and data, including without limitation, your name, user alias, password, date of birth, gender, height, weight, information related to your wellness and lifestyle, email address, contact details, and personal telephone number.

Personal Physical, Biometric and Wellness Information

When you use Anura, we capture facial images and video through supported mobile device cameras for the purpose of analyzing your facial blood flow and facial features. Such Personal Information is used to provide you with status measurements (“Measurements”) such as heart rate and stress. To achieve more accurate Measurements, the processing and analysis may also require or involve additional Personal Information including, without limitation your age, weight, height, and gender.

Use Information

When you use our Services, we may receive information or data about you or relating to you that is voluntarily shared by you with us, such as product reviews, comments, your public profile, photos, videos, etc.

Customer Support Information

Any information that you provide to our customer support team.

Location Information

The Services may include features that use precise location data that is derived from your GPS, WiFi, compass, accelerometer, IP address, or public posts that contain location information. We collect this type of data if you grant us access to your location.

Log Data

When you use our Services, our servers automatically record certain information about how a person uses our Services whether through the use of cookies, web beacons, log files, and scripts, including without limitation device carrier-related information, configuration information, information about your interaction with our Services and your usage patterns, device information, application settings, and the date, time and/or location that a Measurement was taken.

II. HOW WE USE YOUR PERSONAL DATA

We use the PersonalvInformation you provide or which we collect mainly for the following purposes:

Service Provision

The core functions of our Services couldvnot be made available to you unless we collect, process and use the relevant PersonalvInformation about you. For example, we need to collect, process and analyze yourvpersonal facial features, facial blood flow and other relevant information to provide you with the Measurements.

Product and Service Development

We may also use your Personal Information for the following purposes, to which you expressly consent:

  • to improve and enhance our Services;

  • to provide you with product and service updates;

  • to troubleshoot and protect against errors;

  • to perform data analysis and testing;

  • to facilitate and process your searches and requests for information;

  • to ask for your opinions on our Services and conduct product surveys;

  • to measure consumer interest in our products and services;

  • to enforce our Terms of Use;

  • to provide you with system or administrative measures;

  • to show you personalized content, recommendations and advertisement;

  • to resolve service and billing disputes;

  • to create segment data, user group profiles or otherwise create anonymous, aggregated statistics about the use of our Services, which we may share with third parties (such as our partners, advertisers, industry bodies, the media and/or the general public) and/or make available to the public; and

  • to use for purposes as otherwise described to you at the time of collection.

Safety and Security

We may use your Personal Information to promote the safety and security of our Services. For example, we may use your Personal Information to authenticate users, detect and protect against fraud and abuse and other criminal activity, respond to a legal request or claim, and enforce our Terms of Use and policies.

III. HOW WE SHARE YOUR PERSONAL DATA

In general, we do not disclose the Personal Information about you to third parties without your consent or otherwise as specified in this Policy. We may disclose or share your Personal Information in the following circumstances:

Sharing of Personal Information by Nuralogix

We may disclose or share your Personal Information with third parties only in the ways described in this Policy, including as follows:

  • In certain situations, NuraLogix may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. NuraLogix may disclose your Personal Information

(i) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations),

(ii) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding,

(iii) as otherwise required or permitted under any applicable law, rule, or regulation,

(iv) in good faith, to protect or defend the rights or property of NuraLogix and other users, and (e) if NuraLogix is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information;

  • third party service providers: we may use third party service providers to provide certain data processing services for us (acting as our authorized data processors). Examples of authorized data processors could include: currently we use Amazon Web Services in the United States of America to help process and extract certain Personal Information collected during the Services which will in turn empower the function of Anura. When acting as our authorized data processors, they are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.

  • we may share anonymous, aggregate or generic data with third parties (such as our partners, advertisers, industry bodies, the media and/or the general public) for example, in public reports about stress or to partners under agreement with us. However, in these situations we do not disclose any information that could be used to identify you personally.

Shared Information

Our Services allow you to share your Measurements in various forms with others. For example:

  • You are able to share a link and/or image which will allow the recipient to access your Measurement(s).

Your Personal Information could be also shared by you, if you and other users are using and logging onto the same family or enterprise version of Anura (where available) whereby certain user(s) or the administrator user of such version of Anura (subject to specific settings made and/or availability of relevant functions) would have access to the Measurement results or information of the other users.

Any Personal Information shared by you in the above circumstances shall be deemed to have been done with your explicit consent. Please consider carefully whether or not you desire to share your Personal Information as described above.

IV. HOW WE PROTECT YOUR PERSONAL INFORMATION

We take various steps to protect your Personal Information from unauthorized access, use or modification and unlawful destruction and disclosure, for example:

  • we adopt encryption technology (such as SSL) to transfer and store your Personal Information;

  • we limit the access to your Personal Information on a strict need-to-know basis;

  • we put in place physical, electronic, and procedural safeguards in line with industry standards.

Please be aware that, despite our efforts, we do not warrant or guarantee that unauthorized access will never occur as no method of transmitting or storing information is completely secure.

V. INFORMATION RETENTION AND STORAGE

Information Retention

Measurements are stored with our cloud server providers, managed by us, but in an anonymized form.

To protect your privacy, certain information that we collect which can identify you as an individual is not stored. In particular, we do not store your facial image or video recordings neither on the device on which Anura is installed nor on the cloud. With regard to the Measurements, we store them on our servers or with cloud server providers managed by us, but in an anonymized form.

We will retain your Personal Information for as long as is reasonably necessary for the various purposes set out in Section II above or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of specific types of Personal Information.

We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; this retention period may extend past the point at which you close your account.

Information Storage

All information processed and collected to provide our Services outside of the device in which Anura is installed is stored on our servers or with cloud service providers managed by us located in the United States of America.

VI. YOUR RIGHTS

Accessing Personal Information

You have the right to access and correct your Personal Information we hold about you. In connection with your requested corrections, we may ask you for further information to help us respond to your request, including asking for government issued identification.

By logging into your account, you can access much of your Personal Information and Measurements from our Services on your user interface.

Deleting information

Subject to the limitations of applicable laws, you may request for us to delete your Personal Information. For example, you can edit or delete the profile data you provide and delete your account if you wish. Please note that if you request us to remove your Personal Information, you may not be able to use our Services.

We may also be required to retain some Personal Information by applicable laws, in which case you may not be entitled to remove it.

Objecting to Data Use

If you object to the processing of your Personal Information, you must terminate your usage of our Services.

Changing Authorization Scope or Withdrawing Authorization

You may change your authorization granted to us to process your Personal Information for certain purposes by deleting relevant information, turning off device functions, and /or changing privacy settings in Anura. You may also withdraw your authorization granted to us by deregistration so that we cannot continue collecting your Personal Information.

When you withdraw your consent or authorization, we cannot continue providing you with the Services, and will not process your corresponding Personal Information. However, your decision to withdraw your consent or authorization will not affect the processing of Personal Information previously conducted according to your authorization.

Responding to Your Requests

Subject to the applicable law, you are entitled to submit the above requests by contacting us at support-anura@nuralogix.ai.

Subject to applicable law, we reserve the right to charge a fee for requests that are duplicative, or require excessive technical means (for example, developing new systems or fundamentally changing current practices).

In certain situations, we may not be able to respond to your request. These situations may include, without limitation, situations:

  • relating to national security and national defense security;

  • relating to public safety, public health, and major public interests;

  • relating to criminal investigation, prosecution and trial;

  • where there is sufficient evidence that you do not have good faith intentions or you may abuse rights; and

  • where a response will result in serious damages to the legitimate rights and interests of you or other individuals and organizations.

VII.     UPDATES TO THIS POLICY

We may modify and revise this Policy from time to time. Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected.

Material changes to this Policy will be communicated to you through proper means. If we make material changes, we will let you know in a noticeable manner, explaining specific changes to the Policy in a manner including but not limited to emails, text messages, or special tips on Anura or our Site.

Please check for changes made to this Policy.

VIII. PRIVACY POLICY FOR MINORS

Our Services are not intended for minors. Person under the age of 18 must not use our Services without obtaining parental/guardian consents to this Policy (both for themselves and on your behalf). We do not knowingly collect Personal Information from any person under the age of 18 without such consent. Please contact us if you believe we have any Personal Information from any person under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.

IX. CONTACT US

If you have questions, suggestions, or concerns about this Policy, or about our use of your Personal Information, please contact us at support-anura@nuralogix.ai.