Privacy and Data Protection Notice
Effective October 30, 2020
Our Commitment to User Privacy and Data Protection
Welcome to the “Privacy Notice” of NeuTigers, Inc., (hereinafter “NeuTigers”, “we”, “us” or “our”) the provider of the CovidDeep Mobile Apps and the Website.
NeuTigers respects your privacy and is committed to protecting your personally identifiable information (“PII”). PII means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Examples of PII that can be collected name, address, phone number and email address. Your IP addresses can be considered PII if it identifies you or can be used to identify you.
This Privacy Notice will inform you as to how we at NeuTigers look after your PII if you provide it to us when you use our mobile apps (“Apps”) or visit our website (“Website”) and tell you about your privacy rights and how the law protects you. This Privacy Notice applies only to information collected through our Apps and Website and not to information collected offline.
It is important that you read this Privacy Notice together with any other privacy notice or other notice we may provide on specific occasions so that you are fully aware of how and why we are using your data. This Privacy Notice supplements any other notices and is not intended to override them.
If you have any requests concerning your PII or any questions with regard to our practices, please contact our Privacy Officer at PrivacyOfficer@NeuTigers.com.
This Privacy Notice applies to all information collected or submitted across all NeuTigers Apps and Websites.
Direct Interactions on the App
We do not collect personally identifiable information from users of our App. The App gives you the opportunity to collect a small amount of biometric data to perform a screening analysis to detect a potential COVID-19 infection. There is no account required to use the App. The test is capable of collecting the following information from you and, if available, your Connected Devices (defined below): Galvanic Skin Response, Blood Oxygen Saturation, Blood Pressure, Skin Temperature, Heart Interbeat Interval, and Health Questionnaire answers (hereinafter “Your Collected Information”). Your Collected Information stays on your device, in your control, and is not transmitted over the internet to NeuTigers or any other person or entity.
Connected Devices: For certain functionality involving compatible Bluetooth or otherwise connected sensor compatible devices, for example, a Bluetooth connected watch with a sensor, the communications software for such devices are provided by third parties. The App utilizes the information those devices communicate to your mobile device. Please read the privacy policies/notices of those Connected Device vendors to learn how those devices and the vendors are handling your data.
App Usage Information Performance and Usage Data. The App will collect the following “App Usage Information” for diagnostic and support purposes, and high level analytics regarding the use, but not the user, of The App: Instance Identifiers, Crash traces, Device make & model and the OS version, and if a Connected Device, the make & model, whether the use was connected via WiFi or cellular network, and using analytics software from New Relic (https://newrelic.com/products/mobile-monitoring), your temporary IP Address to derive the country and geographic region , but a not the specific address.
NeuTigers shall collect, analyze and use aggregated App Usage Information, technical data and related non-personal information to facilitate product development/improvement and to provide support and maintenance of the App. NeuTigers may use, store or disclose such information or material derived from such information to further enhance the functionality of the App.
Direct Interactions on the Website or Support Requests
WE MAY COLLECT, USE, STORE, AND TRANSFER PII ABOUT YOU ONLY WHEN YOU CONTACT US FOR SUPPORT OR YOU CONTACT US ON OUR WEBSITE:
We collect information from you only if you request support by sending email to firstname.lastname@example.org, on the App by selecting the Chat button, by visiting our Website or when you email an inquiry to us. If you contact us for any of these reasons, we may ask you to provide, and we will collect any or all of the following:
WHICH WE HAVE GROUPED TOGETHER AS FOLLOWS:
- Identity Data includes First and last name, or similar identifier
- Contact Data includes email address and/or telephone numbers.
- Technical Data from the App includes the operating system version and device make & model, connectivity information, namely, whether your connection was over WiFi, cellular or Bluetooth (which one), sensor details for your Connected Device, including the make/model/software version of your device, and method of connectivity, and the version of our software being used, and internet protocol (IP) address.
- Technical Data from visiting our Website includes the operating system, internet protocol (IP) address, browser type and version, and time zone setting on the device you use to access the Website.
- Usage Data includes information about how you use our Apps and Website, products and services.
- Customer Assurance and Communications Data includes all your communications with us regarding support.
- Automated technologies or interactions – As you interact with our Apps and Website, we may automatically collect Technical Data (described above) about your equipment, browsing or App interaction and patterns.
The Way We Use PII You Give to Us
If you contact us for support and provide us your PII, we will only use your PII in circumstances allowed by law. Most commonly, we will use your PII in the following circumstances:
Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your PII. If we need to rely on consent, we will request your consent at the page and point at which we need to collect the relevant PII. If you give us consent, you have the right to withdraw consent at any time by contacting us.
Purposes for Which We Will Use the PII You Give to Us
If you contact us for support then the table below describes the ways we plan to use the PII you provide to us during the support communication, the legal bases we rely on to do so, and our legitimate interests in collecting the PII, if appropriate.
Note that we may process your PII for more than one lawful basis depending on the specific purpose for which we are using your PII. Please contact us if you need details about the specific legal ground we are relying on to process your PII where more than one ground has been set out in the table below.
|Purpose/Activity||Types of Data||Lawful basis for processing including basis of legitimate interest|
|To administer and protect our business and this Apps and Website (including providing support, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To provide relevant support for Apps or respond to inquiries on our Website or via email, we may deliver content and announcements to you and measure or understand the effectiveness of the Apps and Website||(a) Identity|
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our Customer Assurance strategy)|
|To use data analytics to improve our Apps and Website, products/services, Customer Assurance, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Apps and Website updated and relevant, to develop our business and to inform our Customer Assurance strategy)|
We may disclose information, including PII, about you if we are obligated to do so for the following reasons:
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- To enable processors or sub-processors or other third-parties based outside the EEA. For a list of processors or sub-processors of suppliers or third-parties, please contact our PrivacyOfficer@NeuTigers.com
- For other NeuTigers affiliates that have a legitimate need for the PII; and
- For third-parties to whom we may choose to sell all or substantially all of our assets, or in a merger or other type of acquisition or change in ownership. If this happens then the new owners may use your PII in the same way as set out in this Privacy Notice.
For a list of third-party processors please contact our Privacy Officer at: PrivacyOfficer@NeuTigers.com.
We also collect Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your PII but is not considered PII pursuant to applicable privacy laws because this data does not directly or indirectly reveal your identity.
We do not collect any Special Categories of PII about you (that is, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offenses.
We strive to provide you with choices regarding certain PII uses.
- Opting out: You can ask us to stop sending you messages at any time by following the unsubscribe/opt-out links on any message sent to you or by contacting us via email at any time.
Change of Purpose
We will only use your PII for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your PII for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use it.
Please note that we may process your PII without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.
Retention of Information
We will only retain your PII for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for PII, we consider the amount, nature, and sensitivity of the PII, the potential risk of harm from unauthorized use or disclosure of your PII, the purposes for which we process your PII and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your PII are available in our retention policy which you can request from us by contacting our Privacy Officer at PrivacyOfficer@NeuTigers.com.
Under certain circumstances, you have the following rights under the data protection laws in relation to your PII, which are explained below:
- The right to access;
- The right to rectification (correction);
- The right to complain to a supervisory authority;
- The right to be forgotten;
- The right to restrict;
- The right to object to processing;
- The right to transfer; and
- The right to withdraw consent.
- Access/Confirmation: You can request access to your PII (commonly known as a “Access Request”). This enables you to receive a copy of the PII we hold about you and to check that we are lawfully processing it.
- How to Correct Your Information: You can correct factual errors in your PII by sending us a request that credibly and specifically documents the error(s) to our Privacy Officer noted below. Taking into account the purpose of the processing, you have the right to have incomplete or inaccurate PII corrected. We may need to verify the accuracy of the new PII you provide to us.
- Complain to a Supervisory Authority: If you are not satisfied with how we manage your PII please contact us at PrivacyOfficer@NeuTigers.com to provide us with an opportunity to address your concerns.
- Right to be Forgotten: You can ask us to delete or remove any PII we hold concerning you. This enables you to ask us to delete or remove PII where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your PII where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your PII to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Request restriction of processing: In some circumstances, you have the right to ask us to suspend the processing of your PII. Those circumstances are: (a) you contest the accuracy of the PII; (b) processing is unlawful but you oppose erasure; (c) we no longer need the PII for the purposes of our processing, but you require the PII for the establishment, exercise or defense of legal claims; or (d) you have objected to our processing of your PII, but we need to verify whether we have overriding legitimate grounds to use it. Where processing has been restricted on this basis, we may continue to store your PII.
- Object to Processing: You also have the right to object to our use of PII when we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing because you believe it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your PII for direct marking purposes and for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation. We will respect your request unless we have compelling legitimate grounds to process your PII which override your rights and freedoms.
- Data Transfer/Portability: You have the right to request the transfer of your PII to you or to a third-party. We will provide to you, or a third-party you have chosen, your PII in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.
- Withdraw Consent: You may withdraw consent at any time where we are relying on consent to process your PII. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Security and Storage of Information
We will keep your PII secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, access, destruction, or damage. We will do our best to protect your PII but we cannot guarantee the security of your data which is transmitted to our Apps and Websites, applications or services or to other websites, applications, and services via an internet or similar connection.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Third Party Links
Occasionally, at our discretion, we may include or offer third party products or services on our Website. These third-party websites, plug-ins and applications have separate and independent privacy policies. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we have no responsibility or liability for the content and activities of these linked websites. When you leave our Apps and Website, we encourage you to read the privacy notice of every website you visit. We still seek to protect the integrity of our Website and welcome any feedback that you may have about these Websites.
Our Commitment to Children’s Privacy
The Apps and Website will be utilized by children under the age of 13 provided we have consent from the child’s parent or guardian. However, the Apps and Website do not knowingly collect any PII from children under the age of 13. If a parent or guardian believes that the Apps and Website has collected PII from a child under the age of 13 that person should contact our Privacy Officer at PrivacyOfficer@NeuTigers.com and we shall remove the information from our records.
You may opt-out of receiving further information from NeuTigers by contacting our Privacy Officer. In your e-mail, please give us your full name, mailing address and statement that you do not wish to receive further information from NeuTigers.
Privacy Notice Changes/Amendments
We may change our Privacy Notice from time to time. We will always update the Privacy Notice on our Apps and Website, so please try to read it when you visit the Apps and Website (the ‘last updated’ reference tells you when we last updated our Privacy Notice). You should check this page occasionally to ensure you are happy with any changes to this Privacy Notice.
This version was last updated on October 30, 2020
How To Contact our Privacy Officer
Should you have other questions or concerns about these privacy policies, please send us an email at PrivacyOfficer@NeuTigers.com. Our Privacy Officer’s contact details related to data protection, is
307 Jay Street, 7th Floor
Brooklyn, NY 11201 USA