Privacy Policy

Who we are

Our website address is: http://aciana.com.

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Additional information

How we protect your data

What data breach procedures we have in place

What third parties we receive data from

What automated decision making and/or profiling we do with user data

Industry regulatory disclosure requirements

Docisn Privacy Policy

Privacy Policy

We value the trust You (defined below) place in Us (defined below). That’s why We (defined below) insist upon the highest standards for secure transactions and customer information privacy. Please read the following statement to learn about Our (defined below) information gathering and dissemination practices.

aciana Health Technologies India PVT LTD (“aHTI”, which also include its affiliates), having its registered office address at 52 & 53 1ST CROSS, SRIRAMA LAYOUT JNANAJYOTHINAGAR MALLATHALLI Bengaluru, Karnataka 560056.

aHTI is committed to respecting the privacy of every person who shares information with it or whose information it receives. Your (defined below) privacy is important to Us (defined below) and We (defined below) strive to take care and protect the information We (defined below) receive from You (defined below) to the best of Our (defined below) ability.

This Privacy Policy (“Privacy Policy”) applies to the collection, receipt, storage, usage, processing, disclosure, transfer and protection (“Utilization”) of your Personal Information (defined below) when You use the Docisn website available at URL: www.aciana.com.*** (where *** represents various domain names) operated by aHTI (“Website”) or mobile application of brand name “Docisn” available for download at Google Play Store, Apple App Store, Windows App Store (“Application”) operated by aHTI or avail any Services offered by aHTI through the Website or Application.

The terms ‘You’ or ‘Your’ refer to you as the user (registered or unregistered) of the Website, Application or Services and the terms ‘We’, ‘Us” and ‘Our’ refer to aHTI.

1 CONSENT:

1 You acknowledge that this Privacy Policy is a part of the Terms of Use of the Website and the other Services, by accessing the Website or Application or by otherwise providing Us Your Personal Information Yourself or through a Primary User or by making use of the Services provided by the Website or Application, You unconditionally signify Your (i) assent to the Privacy Policy, and (ii) consent to the Utilisation of your Personal Information in accordance with the provisions of this Privacy Policy.

2 You acknowledge that You are providing Your Personal Information out of Your free will. If You use the Services on behalf of someone else (including but not limited to, Your child – minor or major or as a legal representative of an individual with mental illness) or an entity (such as Your employer), You represent that You are authorized by such individual or entity to (i) accept this Privacy Policy on such individual’s or entity’s behalf, and (ii) consent on behalf of such individual or entity to Our collection, use and disclosure of such individual’s or entity’s Personal Information as described in this Privacy Policy. Further, You hereby acknowledge that the Utilization of Your Personal Information by aHTI is necessary for the purposes identified hereunder. You hereby consent that the Utilization of any Personal Information in accordance with the provisions of this Privacy Policy shall not cause any wrongful loss to You.

3 YOU HAVE THE OPTION NOT TO PROVIDE US THE PERSONAL INFORMATION SOUGHT TO BE COLLECTED. YOU WILL ALSO HAVE AN OPTION TO WITHDRAW YOUR CONSENT AT ANY POINT, PROVIDED SUCH WITHDRAWAL OF THE CONSENT IS INTIMATED TO US IN WRITING. If You do not provide Us Your Personal Information or if You withdraw the consent to provide Us Your Personal Information at any point in time, We shall have the option not to fulfill the purposes for which the said Personal Information was sought and We may restrict You from using the Website, Application or Services.

4 Our Website or Application are not directed at children and We do not knowingly collect any Personal Information from children. Please contact Us at grievances@Docisn.co if You are aware that We may have inadvertently collected Personal Information from a child, and We will delete that information as soon as possible.

2 CHANGES TO THE PRIVACY POLICY:

1 We reserve the right to update (change, modify, add and/or delete) this Privacy Policy from time to time at our sole discretion. There is a tab at the end of the Privacy Policy which indicates when the Privacy Policy was last updated.

2 When We update Our Privacy Policy, we will intimate You of the amendments on Your registered email ID or on the Website or Application. Alternatively, aHTI may cause Your account to be logged-off and make Your subsequent account log-in conditional on acceptance of the Agreement. If You do not agree to the amendments, please do not use the Website, Application or Services any further.

3 PERSONAL INFORMATION COLLECTED: In order to provide Services to You we might require You to voluntarily provide Us certain information that personally identifies You or Secondary Users related to You. You hereby consent to the collection of such information by aHTI. The information that We may collect from You, about You or Secondary Users related to You, may include but are not limited to, the following:

1 Patient/Caregiver/Doctor/Health Care Professional Name,

2 Birth date/age,

3 Blood group,

4 Gender,

5 Address (including country and pin/postal code),

6 Location information, including Your GPS location,

7 Phone number/mobile number,

8 Email address,

9 Physical, physiological and mental health condition, provided by You and/or Your Healthcare Service provider or accessible from Your medical records,

10 Personal medical records and history,

11 Valid financial information at time of purchase of product/Services and/or online payment,

12 Docisn Login ID and password,

13 User details as provided at the time of registration or thereafter,

14 Records of interaction with aHTI representatives,

15 Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used,

16 Master and transaction data and other data stored in Your user account,

17 Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in Our log files, the pages of our Website or Application that You visit, the time and date of Your visit, the time spent on those pages and other statistics (“Log Data”),

18 User’s tracking Information such as, but not limited to the device ID, Google Advertising ID and Android ID,

19 Any other information that is willingly shared by You.

(collectively referred to as “Personal Information”).

4 HOW WE COLLECT PERSONAL INFORMATION: The methods by which We collect Your Personal Information include but are not limited to the following:

1 When You register on Our Website or Application,

2 When You provide Your Personal Information to Us,

3 During the course of Services provided to You by Us,

4 When You use the features on Our Website or Application,

5 Through Your device, once You have granted permissions to Our Application (discussed below),

6 Through HSP pursuant to consultation on the Website or the Application,

7 By the use of cookies (also discussed below),

8 We collect information that Your browser/app sends whenever You visit Our Website or Application, such as, the Log Data. In addition, We may use third party services such as Pixel that collect, monitor and analyze this. This information is kept completely secure.

5 USE OF PERSONAL INFORMATION: YOUR PERSONAL INFORMATION MAY BE USED FOR VARIOUS PURPOSES INCLUDING BUT NOT LIMITED TO THE FOLLOWING:

1 To provide effective Services;

2 To debug customer support related issues;

3 To operate and improve the Website or Application;

4 TO PERFORM ACADEMIC/STUDIES, CLINICAL OR OTHER RESEARCH AND ANALYSIS FOR OUR UNDERSTANDING, INFORMATION, ANALYSIS, SERVICES AND TECHNOLOGIES IN ORDER TO PROVIDE ALL USERS IMPROVED QUALITY OF CARE; AND ENSURING THAT THE CONTENT AND ADVERTISING DISPLAYED ARE CUSTOMIZED TO YOUR INTERESTS AND PREFERENCES;

5 To contact You via phone, SMS, email or third-party communication services such as Whatsapp, etc. for appointments, technical issues, payment reminders, obtaining feedback and other security announcements;

6 To send promotional and marketing emails from Us via SMS, email, snail mail or third-party communication services such as WhatsApp, Facebook etc.;

7 To advertise products and Services of aHTI and third parties;

8 To transfer information about You, if We are acquired by or merged with another company;

9 To share with Our business partners for provision of specific services You have ordered so as to enable them to provide effective Services to You;

10 To administer or otherwise carry out Our obligations in relation to any Agreement You have with Us;

11 To build Your profile on the Website or Application;

12 To respond to subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims;

13 To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of Our Terms of Use, breach of Our agreement with You or as otherwise required by law;

14 TO AGGREGATE PERSONAL INFORMATION FOR RESEARCH FOR ACADEMIC/STUDIES, CLINICAL OR OTHER RESEARCH, STATISTICAL ANALYSIS AND BUSINESS INTELLIGENCE PURPOSES, AND TO SELL OR OTHERWISE TRANSFER SUCH RESEARCH, STATISTICAL OR INTELLIGENCE DATA IN AN AGGREGATED AND/OR NON-PERSONALLY IDENTIFIABLE FORM TO THIRD PARTIES AND AFFILIATES WITH A PURPOSE OF PROVIDING SERVICES TO THE USERS OR FOR THE ADVANCEMENT OF SCIENTIFIC KNOWLEDGE ABOUT HEALTH AND DISEASE.

(collectively referred to as “Purpose(s)”)

6 SHARING AND TRANSFERRING OF PERSONAL INFORMATION:

1 You hereby consent and authorize Us to publish feedback obtained by You on Our Website or Application.

2 User’s financial information are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, User is advised to exercise discretion while saving the payment details.

3 To the extent necessary to provide You with the Services, We may provide Your Personal Information to third party contractors who work on Our behalf to provide You with Services. These third-party contractors have access to information needed to process Services only and shall not use it for other purposes. Each third-party contractor, the data processor to which We transfer Personal Information shall have to agree to comply with the procedures and policies or put in place adequate measures on their own for maintaining the confidentiality and secure Your Personal Information.

4 You acknowledge that aHTI may be obligated to by law to disclose or transfer your Personal Information with Courts and Government agencies in certain instances such as for verification of identity, or for prevention, detection, investigation, prosecution, and punishment for offences, or in compliance with laws such as intimation of diagnosis of an epidemic disease. You hereby consent to disclosure or transfer of Your Personal Information in these instances.

5 Notwithstanding the above, We are not responsible for the confidentiality, security or distribution of Your Personal Information by third-parties outside the scope of Our Agreement. Further, We shall not be responsible for any breach of security or for any actions of any third-parties or events that are beyond the reasonable control of Us including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.

6 We may share Your Personal Information with Our other corporate and/or associate entities and affiliates to (i) help detect and prevent identity theft, fraud and other potentially illegal acts and cyber security incidents, and (ii) help and detect co-related/related or multiple accounts to prevent abuse of Our Services.

7 PERMISSIONS: Once You download and install Our Application, You may be prompted to grant certain permissions to allow the Application to perform certain actions on Your device. These actions include permission to:

1 read/write/modify/delete data in relation to the Application on Your device’s storage;

2 view/access information relating to networks/access networks, including permission to send and receive data through such networks/access networks;

3 determine Your approximate location from sources like, but not limited to, mobile towers and connected Wi-Fi networks;

4 determine Your exact location from sources such as, but not limited to, GPS;

5 view/access device information, including but not limited to the model number, IMEI number, operating system information and phone number of Your device;

6 access device information including device identification number required to send notification/push notifications.

8 USE OF COOKIES:

1 Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to You on the Website and/or Application.

2 We may store temporary or permanent ‘cookies’ on Your computer/device to store certain data (that is not Sensitive Personal Data or Information). You can erase or choose to block these cookies from Your computer. You can configure Your computer’s browser to alert You when We attempt to send You a cookie with an option to accept or refuse the cookie. If You have turned cookies off, You may be prevented from using certain features of the Website or Application.

3 We do not control the use of Cookies by third parties.

9 SECURITY:

1 The security of Your Personal Information is important to Us. We have adopted reasonable security practices and procedures including role-based access, secure communication, password protection, encryption, etc. to ensure that the Personal Information collected is secure. You agree that such measures are secured and adequate. We restrict access to Your Personal Information to Our and Our affiliates’ employees, agents, third party service providers, partners, and agencies who need to know such Personal Information in relation to the Purposes as specified above in this Policy, provided that such entities agree to abide by this Privacy Policy.

2 While We will endeavour to take all reasonable and appropriate steps to keep secure any information which We hold about You and prevent unauthorized access, You acknowledge that the internet is not 100% secure and that We cannot guarantee absolute security of Your Personal Information. Further, if You are Secondary User, You hereby acknowledge and agree that Your Personal Information may be freely accessible by the Primary User and other Secondary Users and that aHTI will not be able to restrict, control or monitor access by Primary User or other Secondary Users to your Personal Information. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused in relation to Your Personal Information.

11 THIRD PARTY LINKS: During Your interactions with Us, it may happen that We provide/include links and hyperlinks of third-party websites not owned or managed by Us (“Third-party Websites”). It may also happen that You or other Users may include links and hyperlinks of Third-party Websites. The listing of such Third-Party Websites (by You, other Users or by Us) does not imply endorsement of such Third-party Websites by aHTI. Such Third-party Websites are governed by their own terms and conditions and when You access such Third-party Websites, You will be governed by the terms of such Third-party Websites. You must use Your own discretion while accessing or using Third-party Websites. We do not make any representations regarding the availability and performance of any of the Third-party Websites. We are not responsible for the content, terms of use, privacy policies and practices of such Third-party Websites. We do not bear any liability arising out of Your use of Third-party Websites.

12 ACCESS: If You need to update or correct Your Personal Information or have any grievance with respect to the processing or use of Your Personal Information, or request that We no longer use Your Personal Information to provide You Services, or opt-out of receiving communications such as promotional and marketing-related information regarding the Services, for any reason, You may send Us an email at grievances@Docisn.co and We will take all reasonable efforts to incorporate the changes within a reasonable period of time.

13 COMPLIANCE WITH LAWS: You are not allowed to use the services of the Website or Application if any of the terms of this Privacy Policy are not in accordance with the applicable laws of Your country.

14 TERM OF STORAGE OF PERSONAL INFORMATION:

1 aHTI may keep records of communications, including phone calls received and made for making enquiries, orders, feedback or other purposes for rendering services effectively and efficiently. aHTI will be the exclusive owner of such data and records. However, all records are regarded as confidential. Therefore, will not be divulged to any third party, unless required by law.

2 aHTI shall store Your Personal Information at least for a period of three years from the last date of use of the Services, Website or Application or for such period as may be required by law.

15 GRIEVANCE OFFICER:

We have appointed a grievance officer, whose details are set out below, to address any concerns or grievances that You may have regarding the processing of Your Personal Information. If You have any such grievances, please write to Our grievance officer at support@aciana.com and Our officer will attempt to resolve Your issues in a timely manner.

DOCISN FACE SCANNER PRIVACY POLICY

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE SERVICES.

You must be 18 years of age or older to use the Services. It is expressly prohibited for minors under the age of 18 to create or use an Docisn Face Scan account.

Your privacy is important to us, and we are committed to protecting it through our compliance with this privacy policy (“Policy”). The information provided below describes how and why we process your personal data, which you share with us and which we collect when you access or use our services, the Docisn mobile and/or web application (“Docisn”) .

Personal data (hereinafter “Personal Data”) means any information relating to an identified or identifiable natural person. Unless defined where used, capitalized terms used herein shall have the meanings given in the Terms of Use.

The information provided does not apply to third-party online websites, pages or services that can be accessed via hyperlinks through the Services. Clicking on those hyperlinks may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Services, we encourage you to read the privacy policy of every website or mobile application you visit.

In connection with Docisn, Personal Data we may process may include sensitive information about you. We always ask for your explicit consent, before any sensitive information processing activity (e.g. collection, storage, disclosure, etc.) happens, as described in this Policy.You can withdraw your provided consent at any time by deleting your account and uninstalling Docisn

To protect your privacy, certain Personal Data 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 when you use Docisn. This information does not leave your device and is not stored on your device.

WHO WE ARE

Aciana Health Technologies (“Aciana”, “we”, “us” or “our” and terms of similar meaning) provides the “Docisn Face Scanner” application (“Docisn”), and its websites located at aciana.com (the “Sites”), to help you measure, track, and record your personal wellness status including, but not limited to heart rate, stress and blood pressure. We refer to the services provided by or through Docisn and the Sites as the “Services”.

It is important that you have read and understood the present Terms of Use in conjunction with our Privacy Policy before using Docisn.

These Terms of Use, together with the Aciana Privacy Policy (collectively, the “Terms”, as may be amended from time to time), govern your use of Docisn, the Sites, and the Services.

WHAT INFORMATION WE PROCESS

Whenever you access or use our Services, we may process (e.g., collect, use, store, transfer, etc.) different kinds of Personal Data about you, depending on which NuraLogix service you use: (a) the Docisn (mobile/web) app, or (b) the NuraLogix Websites. References to “DeepAffex” refer to NuraLogix’s cloud-based software that determines your personal wellness data and measurements based on facial blood flow information collected by Docisn.

We will process the relevant personal data about you in accordance with this Policy, and as follows:

Types of Personal Data Processed	Applicable Service (NuraLogix Websites or Docisn app)	Description/Purpose of Processing
Identification and Contact Data	NuraLogix Websites	IP Address, and users may optionally provide contact details such as, First name, Last name, Email, Phone number, Company name, Country/Region, and a free form Message.
License Management	Docisn (mobile/web) app	Device token (JWT) – DeepAffex generated UUID assigned as an authorization token, returned to Docisn as confirmation/verification of valid license registrationNOTE: The device token is NOT bound with any user-information nor with any form of device-type attributes such as IMEI, serial-number, mac-address. An assigned token is used only to authorize/permit application transactions with the DeepAffex service.
Application Analytics	Docisn (mobile/web) app	App name/bundle-identifier/version – as reported by Docisn Device OS Type (iOS, Android, Windows, Browser) – as reported by DocisnCollected and processed at point of application registration/initiation of service use.
Identification and Contact Data	Docisn (mobile/web) app	IP addressEmail addressDevice tokenLocation dataCollected and processed at point of application registration/initiation of service use and measurement requests.
Identification and Contact Data	Docisn (mobile/web) app users may optionally register for access to the DeepAffex portal. If they do, an email address is collected.	Email address or usernameAssociated with the DeepAffex portal for access, verification, and password resets.
Personal Demographics	Docisn (mobile/web) app	To achieve more accurate Measurement results, the processing and analysis may also require or involve additional Personal Data including, but not limited to, the following:AgeWeightHeightSex at birthAn encrypted payload containing relevant data is generated and transmitted to DeepAffex.
Images and Videos	Docisn (mobile/web) app	When the service is in use, your device will capture, but does not store or transmit to DeepAffex, images and video through supported mobile device cameras for the purpose of extracting and analyzing the following: Facial blood flowFacial landmarks and featuresAn encrypted payload containing relevant data, but not picture or video images, is generated and transmitted to DeepAffex.
Wellness Data and Measurements	Docisn (mobile/web) app	Images and videos (see row above) are used by DeepAffex to provide Body Shape Index, Signal to Noise Ratio, Body Mass Index, NuraLogix™ General Wellness Score, Heart Rate Variability, NuraLogix™ Mental Score, NuraLogix™ Physical Score, NuraLogix™ Mental Stress Index, Waist-to-Height Ratio, NuraLogix™ Vitals Score, Facial Skin Age, Breathing Rate, Pulse Rate, Irregular Heartbeat Count, NuraLogix™ Physiological Score, or other similar derived data. This data is the output data generated from providing the Services as opposed to what is collected.
Log Data	Docisn (mobile/web) app	When Docisn is used, our servers automatically capture certain information about how a person uses Docisn whether by log files, and scripts, including without limitation IP address, configuration information, information about interaction with our Services, device information, and the date, time and/or location that a measurement was taken.

HOW WE COLLECT YOUR DATA

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your personal data (sensitive data included) by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:

use our products or Services (Use Information)
When you use our Services, we may receive or collect information or data about you.
create an account on Docisn (Log-in Information)
Docisn users may optionally register for an account and access to the DeepAffex portal. If you choose to do so, you may be required to provide log- in information which may include your email address. Your account will maintain a record of your Wellness Data and Measurements.
give us feedback or contact us (Customer Support Information)
Any information that you provide to our customer support team from the correspondence that you send to us, any conversations you have with us and any feedback that you give us.

Third parties: We may receive personal data about you from third parties.

Cookies
For Docisn web we use so-called “technical cookies”, which allow us to recognize you as a returning user with each access. Such data is not passed on to third parties.

On the NuraLogix Website, we also use Google Analytics cookies to help us to improve our website by collecting and reporting information on how you use it. For more information check our Website Cookie Policy. The cookies collect information in a way that does not directly identify anyone. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the NuraLogix Website may become inaccessible or not function properly.

HOW WE USE YOUR PERSONAL DATA
We use the Personal Data you provide or which we collect from you. We have included below a list of all the ways in which we use your personal data and the lawful bases (where applicable) we rely on to do so.

Provide the Service

Purposes: provide you with our Services and create an account as described in our Terms of Use to produce the Wellness Data and Measurements (i.e. the creation of wellness measurements based on the extraction and analysis of your facial blood flow data) and provide our customer support to you.
Types of Data: Identification and Contact Data, Personal Demographics, Images and Videos (as described above), Log Data, Wellness Data and Measurements.
Retention Period: If you choose to create an account, your Wellness measurements are stored until your user account is deleted or for a further time where legally required. If you do not choose to create an account, we will not store your Wellness Data and Measurements. Personal Demographic will be retained on your device until you delete that information or uninstall Docisn.

Analyse, Develop, and Improve Technical Functionalities, and Ensure the Security of Our Services

Purposes: We continuously strive to provide the best experience possible. We therefore may use your Personal Data to analyze, develop, and improve technical functionalities and ensure the security of our Services.
Types of Data: Personal Demographics, Video and Images (as described above, only an encrypted payload containing relevant data, but not picture or video images), Location Information and Log Data.
Retention Period: Your Personal Data is stored for this purpose until your user account is deleted, or for a longer period where legally required, or such period as is necessary to anonymize the data, test features or functionality and deploy patches and other bug fixes.

Direct Marketing, Commercial Communications

Purposes: The processing of Personal Data collected on the NuraLogix Website for “direct marketing, commercial communications” is subject to your expressed and specific consent (provided on the NuraLogix Website). We may process your Identification data, for marketing purposes, by sending newsletters, commercial communications and / or advertising material, on products or services offered by us. Personal Data collected on the Docisn (mobile/web) app is not processed for this purpose.
Types of Data: Identification and Contact Data.
Retention Period: Your Personal Data (with the exception of Personal Data collected on the Docisn app) is stored for this purpose for 30 days after your user account is deleted, the consent is withdrawn or for a further time period where legally required.

Other Purposes

Safety and Security

If necessary, we may use your Personal Data to promote the safety and security of our Services and our users. We may use your Personal Data to monitor operations, authenticate users, detect and protect against fraud and other criminal activity and enforce our Terms of Use and other policies. We will rely on our legitimate interests when processing Personal Data in detecting and preventing fraud and illegal conduct or if necessary for complying with a legal obligation to which we are subject

Manage and Defend Legal Claims

If necessary, we may use your Personal Data to manage and defend legal claims (e.g., in connection with a dispute or a court proceeding). We will in such a case process the Personal Data collected which is necessary to manage and defend the legal claim in question. The processing is based on our legitimate interest of managing and defending legal claims. Your Personal Data is stored for this purpose for such a period as is necessary to manage or defend the legal claim.

For this purpose, we may also share certain information with other parties. Please see below.

Fulfill Legal Obligations

Finally, we may use your Personal Data to fulfil legal obligations that we have (e.g., accounting requirements or obligations under data protection laws). We will in such case process the Personal Data collected which is necessary to fulfill the legal obligation in question. Your Personal Data is stored for such a period as is necessary to fulfill respective legal obligations.

For this purpose, we may share your Personal Data with other parties. Please see below.

We will only use your Personal Data for the reasons we have set above. If we need to use your Personal Data for any other reason, we will notify you via email and/or a prominent notice in Docisn or on the NuraLogix Website, and tell you the reason along with the relevant lawful basis, unless the law prevents us from doing so.

HOW WE SHARE YOUR PERSONAL DATA

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

Sharing of Personal Data by NuraLogix
We may share your Personal Data with third parties only in the ways described in this Policy, including as follows:

In certain situations, NuraLogix may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. NuraLogix may disclose your Personal Data (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 (v) 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 in Docisn or on our Site of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data.
We may use third party service providers to provide certain data processing services for us (acting as our authorized data processors) with whom we have a data protection agreement in place. 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. Examples of authorized data processors could include Amazon Web Services.
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. Additionally, we may share with third parties the content of reviews of Docisn that you create in the Docisn app store.

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

You can share a link and/or image which will allow the recipient to access your Measurement(s).
Any Personal Data shared by you in the above circumstances will be shared by you with your consent. Please consider carefully whether you desire to share your Personal Data as described above.

HOW WE PROTECT YOUR PERSONAL DATA
We take the security of your data seriously. We have adopted industry standard practices in terms of security which include technical and organizational security measures.
We take various steps to protect your Personal Data from unauthorized access, use or modification and unlawful destruction and disclosure.
For example:

we have adopted encryption technology (such as SSL) to transfer and store your Personal Data.
we limit the access to your Personal Data 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.

DATA RETENTION AND STORAGE

Data Retention

We retain certain Personal Data in accordance with our retention policies. In principle, unless otherwise stated, your Personal Data will only be stored until the purpose of the collection and storage no longer applies. Personal Data may be stored for longer in order to:

(a) communicate with you about any questions or complaints you may have after you have stopped being a user of our Services; or
(b) to comply with the rules on accounting, reporting or any other applicable law.

Furthermore, Personal Data may be stored if this has been provided for by the competent legislator in regulations, laws or other regulations to which we are subject. Personal Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the Personal Data for the purpose of concluding or fulfilling a contract.

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

We will retain your Personal Data for as long as your account is active or as needed to provide you Services. We will retain and use your Personal Data 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 as set out in this Policy.

In certain circumstances, we may aggregate your Personal Data (so that it will no longer identify you) for research, analytical or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you would like further information on how long we keep your Personal Data, please contact us using the details set out at the end of this Policy.

Storage Location

All Personal Data processed and collected to provide our Services outside of the device in which Docisn is installed is stored in one of various jurisdictions with cloud service providers managed by us.

You can ask us for more information about where we may transfer or store your Personal Data and how we will take steps to ensure your Personal Data is protected by using the contact details at the end of this Policy.

YOUR RIGHTS

Your access to certain rights depends on the country in which you are based, and you may have certain rights in relation to the use of your Personal Data. If you wish to exercise your rights, please contact us at: privacy@nuralogix.ai

You have the right to:

To Be Informed

You have the right to be provided with clear, transparent, and easily understandable information about how we use your Personal Data, and about your rights. This is what we are doing, providing you with the information in this Policy.

To Access Your Personal Data

You have the right to request access to your Personal Data and request a copy of your Personal Data that we store. If you have created a user account, you can view certain information directly from our Services on your user interface or by sending us a specific request.

To Update Your Personal Data

You have the right to request that Personal Data that is incorrect or incomplete is corrected or completed. If you have created a user account, you can update certain information directly in your account or by sending us a specific request.

To Withdraw Consent

If we rely on your consent to the use of your Personal Data you have the right to, at any time, withdraw your consent. The consent withdrawal does not affect the legality of the processing carried out previously based on the consent. Please note that if you withdraw your consent, you may not be able to use our Services.

You can withdraw your consent connected to Docisn at any time by deleting your account and uninstalling Docisn.

To Delete Personal Data (Right To Be Forgotten)

You can at any time request that your user account be deleted. Moreover, under certain circumstances, you have the right to request that your Personal Data be deleted.

Please note that if you request the removal of your Personal Data, you may not be able to use our Services.

We may, however, still need to keep your Personal Data if we are obligated to keep certain data to fulfill legal obligations or to manage or defend legal claims.

To Restrict the Use of Your Personal Data

You have, under certain circumstances, the right to request that the use of your Personal Data be restricted. If you have requested restriction of the use of your Personal Data, please note that you cannot use the platform during the time that the use of your Personal Data is restricted.

To Object To the Use of Your Personal Data

Certain use of your Personal Data is based on our or others’ legitimate interest. You may have the right to object to the use of your Personal Data based on a legitimate interest for reasons which concern your particular situation. In such a situation, we will stop using your Personal Data where the use is based on a legitimate interest, unless we can show that the interest overrides your privacy interest or that the use of your Personal Data is necessary in order to manage or defend legal claims.

To Not Be Subject to a Decision Based Solely on Automated Decision-Making

You may have the right not to be subject to such type of automated decision-making about you, unless: (a) you gave us your explicit consent to use your Personal Data to make our decision; (b) we are allowed by law to make our decision; or (c) our automated decision was necessary to enable us to enter a contract with you.

To Transfer Your Personal Data (Data Portability)

You have the right to obtain a copy of certain information that you have provided to us in a structured machine-readable format which allows you to transfer your Personal Data to another recipient.

Responding to Your Requests

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

We will respond to all requests that we receive from users in accordance with applicable data protection laws. Subject to applicable laws, we reserve the right to refuse the request if it is manifestly unfounded or manifestly excessive. In these scenarios, we will inform you of the reasons why and your corresponding rights.

We may ask you to provide proof of your identity before we can answer your requests. In certain situations, depending on the jurisdiction in which you are based, we may not be able to respond to your request.

Lawful Basis

We will only use your personal data where we have a valid lawful basis to do so in accordance with the applicable Additional Privacy Laws. Where we mention our “legitimate interests”, this is the lawful basis we rely on when we feel that it is necessary to use your Personal Data for a reason which is in our and/or your interests and which does not unfairly affect your rights over your Personal Data.

Providing the Service

The processing of Personal Data is based on your consent and the necessity of the processing for the performance of the contract. The legal basis for the processing of sensitive data (health data) is your explicit consent.

Analyse, develop and improve technical functionalities, and ensure the security of our services

The processing of Personal Data is based on our legitimate interest in developing/improving, ensuring the technical functionality and the security of our Services. Special categories of Personal Data (sensitive data) may be processed for statistical and research purposes focused on analyzing, developing and improving technical functionalities, and ensuring the security of our services in accordance with the appropriate safeguards (such as: pseudonymization or anonymization).

Direct Marketing, Commercial Communications

The processing of Personal Data collected on the NuraLogix Website for “direct marketing, commercial communications” is based on your consent. Personal data collected on the Docisn (mobile/web) app is not processed for this purpose.

Storing your Personal Data

All Personal Data ,we will ensure we have put adequate measures in place to protect your Personal Data to an equivalent data protection standard as in the regions.

Right to lodge a complaint with the competent EEA supervisory authority

If you are in the regions, as a data subject, you have a right to lodge a complaint with the competent supervisory authority under the conditions provided in Additional Privacy Laws and Regulations or seek a remedy in the national courts if you think that your rights in relation to your Personal Data have been breached. However, we would be grateful if you could give us the opportunity to address your complaint in the first instance by using the contact details provided at the end of this Policy.

UPDATES TO THIS POLICY
We may modify and revise this Policy from time to time. Any information that we collect is subject to the version of the Policy in effect at the time such information is collected.

Any changes we make to our Policy in the future will be posted on this page, and where appropriate, you will be notified by email or notifications via Docisn. We therefore encourage you to review the Policy from time to time to stay informed of how we are processing your Personal Data.