SONIPHI’S PRIVACY POLICY

Effective Date: March 26, 2020

Last Modified: March 26, 2020

  1. INTRODUCTION
  2. Soniphi, LLC (“Soniphi”, “we”, “us”, and “our”) is committed to protecting the privacy and security of your personal information collected through our VRI mobile application (the “App”). This privacy policy (“Privacy Policy”) describes how we treat the information we collect or receive in connection with your use of our App and participation in our research projects (“Study” or “Studies”), how such information is used, protected, and shared, and your choices regarding this information. This Privacy Policy does not form part of any contract to provide services. This Privacy Policy applies to users that download and use the App (the “Users”).

  3. INFORMED CONSENT
  4. To participate in any Studies, you must first review and sign an informed consent and authorization form (“Informed Consent“) for the Study. By using our App, you consent to the collection, use, and sharing of your information as described in this Privacy Policy and as outlined in the Informed Consent. To the extent anything in this Privacy Policy conflicts with the Informed Consent, the terms of the Informed Consent will shall govern. 

  5. INFORMATION COLLECTED BY SONIPHI
    1. Information You Provide: When you download the App and volunteer to participate in a Study, below are examples of the categories of information (which may include Personal Information) that may be collected from or about you through the App. “Personal Information” means information about an identifiable individual, including any information that alone or when in combination with other information may be used to readily identify, contact, or locate the identified individual. Personal Information does not include information that has been aggregated and anonymized. Such information includes:
      1. Contact Information: such as your first and last name, email address, home address, and phone number. Contact information will be segregated from the rest of the data collected from you through the App and during the Studies.
      2. Demographic Information: such as your age, gender, language preference, and race.
      3. Medical History Information:  such as your height/weight, prior medical diagnosis and testing (e.g., chronic lung disease, asthma, serious heart conditions, immunocompromised system, cancer, diabetes, liver disease), current and previous use of certain medications (e.g., blood pressure medication, cancer treatments), certain family history (e.g., history of cancer or heart conditions) and health habits (e.g., smoking).
      4. Audio Recording of Voice Samples: When you elect to submit audio recordings of your voice samples using the App, the audio recordings will be retained by Soniphi for a limited time to allow us to analyze your voice. Soniphi will not use your audio recordings in any way that is not identified in the Informed Consent document for the applicable Study.
    2. Information Received From Your Use of the App: Soniphi collects information created when you use the App to analyze how you use the App or to improve the App’s functionality. This may include:
      1. Technical Data. For example, information about your App usage (i.e date and time of usage), App version and installation ID, device identifier, device token, mobile network information, time zone, and technical data about your device, such as operating system and model. 
      2. E-mail communication. We collect the content you submit to us via e-mail, including text, links, images, gifs, and videos. 
      3. Location Information. In some cases we collect and store information about where you are located, such as by converting your IP Address into a rough geolocation. 

  6. USE OF INFORMATION
  7. Soniphi may collect and use information:

    1. To provide, maintain, and improve the App. This includes, for example, using information to create and update a user account; performing internal operations such as diagnosing problems and troubleshooting the application, conducting data analysis, testing, and research, and analyzing usage and activity trends.
    2. To enhance safety, integrity, and security of the users and App. This includes, for example, using device location, usage, and other information to prevent, detect, and combat fraud or unsafe activities, which in some cases can include using information from third parties; protect the personal safety of other users of the App or public; and to protect and defend the rights or property of Soniphi.
    3. To respond to and assist with user support services. This includes, for example, investigate and addressing users’ technical issues; and send you technical notices, updates, security alerts and support and administrative messages.
    4. For research, testing analysis, and development. This allows Soniphi to enhance the safety and security of the App; to analyze trends and publish research finding or reports; and develop new functionality, health-related products, and improvement activities.
    5. To conduct and support Studies. This includes contacting you with notices regarding Studies through in-app notifications, e-mail or otherwise.
    6. In connection with legal requirements. Soniphi may use collected information to investigate or address wrongdoing, claims or disputes related to use of the App; to protect and defend the rights or property of Soniphi; to comply with a legal obligation; to protect against legal liability; or as requested by regulators, governmental entities, and official inquiries. In these cases, Soniphi will make reasonable efforts to not disclose more than is necessary and provide notice of disclosure as practicable.

  8. INFORMATION SHARING AND DISCLOSURE
    1. Data Transfers in General.  Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
    2. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to United States and process it there.

      Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

      Soniphi will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

      We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies for their direct marketing purposes.

    3. As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; by law, regulation, a court, a warrant, subpoena, or other lawful request or demand by a governmental or law enforcement authority; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.
    4. Illegal Activities. Soniphi may share information if Soniphi, in its sole judgment, believes it is necessary to share information in order to investigate, prevent, or take acting regarding illegal activities, including breach of confidentiality, fraud, fraudulent misrepresentation, misuse of the App or violation of Terms of Service, situations involving potential threats to the physical safety of any person, or is otherwise required or permitted to do so by law.
    5. Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of the foregoing events shall be governed by the provisions of this Privacy Policy in effect at the time such Personal Information was collected.
    6. With Consent. Soniphi may share information if Soniphi obtains your express consent (or, where permitted by applicable law, your implied consent) to share such information.
    7. Information Shared with Our Agents: In some cases, we share information that we store (such as IP Addresses) with third parties, such as service providers, consultants, researchers, and other agents (“Agents“), for the purposes of operating, enhancing, and improving the App, and developing new functionality. For example, we may share information third-party consultants that may have access to information in the process of improving our processes and technology. Agents with whom we share such information for these reasons are generally bound by confidentiality obligations.
    8. Information Shared with Other Third Parties: We may share or disclose non-private information, aggregate information, or other non-personally identifying information with people and entities that we do business or collaborate with.
    9. Information Shared with Service Providers. Soniphi may share your information with companies that provide services for or on behalf of the Study, such as the independent third party institutional review board responsible for reviewing the Study and protecting your rights as a research participant, or third parties that have been hired to perform Study-related services, such as receiving and processing Study-related complaints, on our behalf. These companies are obligated to protect your information.
  9. AGGREGATE DATA
  10. Your general use of the App and any content submitted by you through a Study may be included in an anonymized fashion in aggregate reports, or used to train models and software in an anonymized fashion. The purpose of such aggregation or training is to allow Soniphi to analyze the data for the purpose stated in the Informed Consent form, and to develop software that predicts or identifies trends within such data and similar data. Such aggregate information may also be provided to certain third party service providers to provide analytics services. 

  11. CHILDREN’S PRIVACY
  12. Soniphi does not knowingly collect, maintain, or use Personal Information from anyone under the age of 18 and we do not want it. If we learn that we have collected any Personal Information from individuals under 18, we will promptly take steps to delete such information and terminate any associated accounts.

    No part of the App is directed to children under the age of 18. If you learn that your child has provided us with Personal Information without your consent, you may alert us at research@soniphi.com

  13. SECURITY
  14. Soniphi takes steps to ensure that your information is treated securely and in accordance with this Privacy Policy, including storing it in systems with limited access housed in facilities using physical security measures. Despite our security measures, total confidentiality cannot be guaranteed and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. 

    By using the App or providing your contact information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the App. Should a security system’s breach arise, Soniphi will notify you, and any applicable regulator, if we are legally required to do so. 

  15. OPT-OUT AND UNSUBSCRIBE
  16. Your privacy is important to us and we allow you to opt-out of receiving any content from us. Users may opt-out of receiving email communications from Soniphi by updating your account settings or contacting us here:

    Email: Research@soniphi.com

    Please note that if you opt out, Soniphi may still send you non-promotional messages related to your use of the App, such as information about your account.

  17. YOUR RIGHTS
  18. Under data protection laws, you can:

    • object to processing of your Personal Information;
    • request to restrict the processing of your Personal Information;
    • request us to transfer your data to another party;
    • request a copy of the Personal Information we hold about you in a structured, machine-reasonable and commonly used format.

    You have the right to withdraw consent. Where you have provided your consent to the collection, processing or transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

  19. ACCESS, DELETE, OR UPDATE YOUR INFORMATION AND QUESTIONS OR SUGGESTIONS
  20. Further to Section 10, you have the right to have your Personal Information rectified, erased or blocked. If you would like to rectify, access, update, delete, or block any information that Soniphi has collected from you through your use of the App or otherwise, or if you have suggestions for improving this Privacy Policy, please send an e-mail to research@soniphi.com

  21. CHANGES TO THIS POLICY
  22. Soniphi may revise this Privacy Policy, and shall notify you of any material changes.

    1. Posting of Revised Privacy Policy. We may amend this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the notice and, depending on the specific amendments, we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you access our App to stay informed about our information practices and the ways you can help protect your privacy. Should you disagree with any of our changes to our Privacy Policy, you may stop using our App, and we will destroy your Personal Information upon your request where possible.
    2. New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law. To the extent permitted by law, by using our App after such notice, you consent to our updates to this Privacy Policy. 
  23. DATA RETENTION
  24. Your participation in any Study is voluntary. We store the information we collect for as long as it is necessary for the purpose(s) for which we originally collected it, as described in the applicable Informed Consent form. We may retain certain information for legitimate business purposes or as required by law. We will delete your Personal Information when we no longer need to process them it relation to one or more of the purposes set out above. However, the such information may be processed and stored for a longer period in anonymized form in order for us to improve the App, and our obligation to delete your Personal Information does not extend to software, data models or anonymized data sets from which you cannot be identified.

  25. CONTACT
  26. If you have any questions about this Privacy Policy, please contact:

Soniphi 

research@soniphi.com