At Nuuro, we are committed to safeguarding your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you use our website and mobile application ("App"). By accessing or using our services, you consent to the practices described in this policy.

 

Nuuro is committed to ensuring the protection of your personal data in compliance with the General Data Protection Regulation (GDPR). We prioritize your privacy and handle your personal data with utmost care.

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Effective Date: 19.09.2023

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1. Information we collect

We collect various types of information, including:

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• Personal Information: This encompasses details like your name, email address, and other particulars you provide during account registration and while using our services.

• Health Data: We may gather health-related data, including dietary preferences, health conditions, and results from home health test kits. This information helps us offer personalized recommendations.

• Usage Information: We collect data regarding your interactions with our platform, which includes IP addresses, device information, and data related to your app usage.

• Customer Information: This category encompasses information about you, such as your name, address, email address, and telephone number. We use this data for managing your account, determining relevant laws, enabling certain tests, and incorporating geographical location into our analysis.

• Self-Reported Health Information: This type of data includes details like height, weight, dietary habits, and existing health conditions. We use it for eligibility assessment, facilitating sample testing, contributing relevant information to our analysis, and conducting scientific research.

• Biological Samples: If you send biological samples, such as blood samples, to third-party labs for testing, please note that we do not receive the samples themselves but only the test results. These labs are bound by confidentiality agreements not to share your information with third parties except essential subcontractors.

• Test Results: These are the results we receive from laboratories or devices used for physiological data measurement. We retain this data as long as you maintain an account with Nuuro, but we will delete it upon your specific request. 

• Payment Information: Your payment information is necessary for processing payments through our third-party payment processor. We retain this data as required by tax and corporate laws.

• Correspondence: When you communicate directly with us, such as sending emails, online chat messages, or making phone calls, we process information related to that correspondence. We retain this data for as long as necessary to handle the correspondence, including addressing complaints.

• Website/App Usage Data: If you visit our website or use our app, we collect information about your activity. This includes direct information like IP addresses, browser type, and mobile device details. We also utilize third-party analytics providers like Google Analytics for more in-depth analysis.

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2. How we use your data

We process your data for various purposes, including:

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• Account Management: Managing your account and ensuring smooth service delivery.

• Eligibility Determination: Assessing your eligibility for our services and scientific research studies.

• Sample Testing: Facilitating the testing of samples by our partner laboratories.

• Analysis: Incorporating relevant information into our analysis, such as dietary habits and health conditions.

• Scientific Research: Conducting general scientific research.

• Fraud Prevention: Preventing fraud and other unlawful activities.

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We do not share Personal Data with anyone else, other than with:

• Our Nuuro AG: We share data within our company Nuuro AG (CH)

• Test Laboratories: When necessary, we engage partner laboratories for sample testing. These labs may involve physicians in jurisdictions requiring physician authorization for direct-to-consumer lab tests.

• Service Contractors: Various service providers assist us in processing personal data, including hosting, technology, security, fraud prevention, analytics, customer support, and payment processing.

• Professional Advisors: In specific situations requiring legal counsel, we may consult attorneys who are bound by strict confidentiality.

• Research Entities: In such cases, your personal details are replaced with an anonymous code.

Rest assured, we prioritize your data security and confidentiality in all interactions with these entities.

For any inquiries or concerns, please reach out to us at support@nuuro.com.

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We retain your data for specific purposes and in compliance with legal obligations. For example:

• Customer information may be retained for six years.

• Test results are kept as long as you maintain an account, but we will delete them upon your request.

• Biological samples are retained for durations determined by local applicable laws.

• Correspondence data is kept for the duration needed to handle the correspondence and an additional six years for legal purposes.

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You have rights concerning your personal data, including the right to access, correct, or delete it. We will notify you of any changes in our data processing purposes.

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Our service is powered in part by the OpenAI API, by using the Nuuro App you agree to OpenAI Terms of Use and Privacy Policy. To understand more about how OpenAI handles data, please refer to their Terms of Use and their Privacy Policy. 

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3. Anonymous data utilization

We may transform personal data into anonymous data, which cannot identify individuals. This process involves aggregating data from multiple sources and removing personal identifiers. For instance, we apply this approach to your self-reported health data, test results, and certain customer information.

These anonymized models enhance our understanding of the relationship between diet and health. They do not contain individual-specific details, as they're based on aggregated data from numerous users.

We may employ such anonymous data for legitimate business purposes, including service enhancement, analysis, and business promotion. Rest assured, we retain this data indefinitely.

 

4. Tracking tools, advertising, and your opt-out rights

Nuuro utilizes cookies and similar technologies like pixel tags, web beacons, clear GIFs, and JavaScript (collectively referred to as "Cookies") to enhance our service. These technologies help our servers recognize your web browser, track your service usage, analyze trends, understand our user base, and improve our service. Cookies are small pieces of data, typically text files, stored on your devices (e.g., computer, tablet, phone) when you access our service. We may also combine data we collect from you with information obtained from third parties who have placed their own Cookies on your devices.

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4.1 Social media advertising

We promote Nuuro through various advertising platforms, including social media channels like LinkedIn, Facebook Meta (including Instagram) and TikTok. To ensure our advertisements reach the most relevant audience, we employ certain advertising tools provided by these platforms.

For instance, we may use Facebook Meta's "Business Tools," including Facebook Pixel and conversions API, to tailor our advertising on Facebook and its associated platforms. These tools allow us to:

• Include a small script on our web pages (Facebook Pixel) to transmit information to Facebook when pages are loaded in your browser.

• Collect information automatically sent by your browser, such as IP addresses and browser version.

• Utilize a hashed version of certain data like email addresses, telephone numbers, first names, last names, birthdates, zip codes, and countries to maintain user privacy.

• Track page views and purchases made on our website to measure advertising effectiveness.

• Employ the conversions API to directly send information to Facebook, bypassing browser-based data transmission.

Facebook Meta may also use this data for its own purposes. To learn more about Facebook's data processing, including your data subject rights, please refer to Facebook Meta's Data Policy.

You have some control over how Facebook targets advertising; instructions can be found here. Additionally, various organizations offer opt-out options for advertising; examples include AboutAds and your online choices.

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For LinkedIn and TikTok, we comply with their respective privacy and advertising policies. LinkedIn offers opt-out options for advertising; please refer to their guidelines for more information. TikTok also provides users with ad preferences and options to control the ads they see; additional details can be found in TikTok's advertising policies.

You have some control over how these platforms target advertising; please review their specific instructions and settings to adjust your preferences.

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4.2 Mailing lists

You can subscribe to our mailing lists to receive updates and product information without creating a Nuuro account. We use the data you provide for these purposes.

We process this data with your consent. If you wish to stop receiving emails from us, click "unsubscribe from this list" at the email's bottom. Note that we'll retain essential information to respect your preferences in the future if you unsubscribe.

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4.3 User research

As a Nuuro customer, you may receive emails inviting you to participate in surveys, interviews, or focus groups regarding our products and services. These communications aim to gather your feedback and improve our offerings.

LinkedIn, Facebook Meta (incl. Instagram), and TikTok are used for promotional purposes. Nuuro does not share personal data for advertising purposes.

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5. Data security and retention

At Nuuro, we are committed to safeguarding your personal data from unauthorized access, use, and disclosure. To ensure the security of your data, we implement suitable physical, technical, organizational, and administrative measures. The specific security measures applied depend on the type of personal data and the way we process it.

We also urge you to play an active role in protecting your data by:

• Carefully selecting and safeguarding your password and other sign-on credentials.

• Limiting access to your computer or device and its browser.

• Signing out after completing your session.

While we strive to maintain the security of your account and stored data, please note that no method of transmitting or storing data on the internet is entirely immune to potential security risks.

In some instances, we may retain personal data for extended periods, as required by our legal obligations, dispute resolution, fee collection, or other lawful purposes, as permitted or mandated by applicable law, rules, or regulations.

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6. Personal Data of Children

Nuuro, in accordance with our terms of service, does not knowingly collect or request personal data from individuals under the age of 18 (or under 19 years of age if they reside in Alabama or Nebraska). If you are under the age of 18, please refrain from attempting to register for our service, using it, or providing us with any personal data.

Should we become aware that we have inadvertently collected personal data from an individual under 18 years of age, we will take prompt steps to delete such information. If you suspect that a child under 18 years of age has furnished us with personal data, please contact us at support@nuuro.com.

 

7. Your rights as a Data Subject under Swiss Data Protection Regulations

Our headquarters, located in Zurich, Switzerland, means that Nuuro is subject to Swiss data protection regulations, including the Swiss Federal Data Protection Act (FADP), irrespective of your citizenship or global residence. You may also have additional rights concerning your personal data, as outlined below.

In this section, we refer to "Personal Data" and "processing" in accordance with Swiss data protection regulations. Generally, "Personal Data" refers to information about an individual, and "processing" encompasses actions related to data, such as collection, use, storage, amendment, deletion, and disclosure. Nuuro will act as the controller for your personal data processed in connection with our services.

In cases where there is a conflict between this section and any other part of this Privacy Policy, the portion that offers greater protection for personal data shall take precedence in resolving such conflicts. If you have any questions about this section or whether it applies to you, please contact us at

support@nuuro.com.

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We will only process your Personal Data if we have a lawful basis under Swiss data protection regulations for doing so. Lawful bases for processing include:

• Consent: Unless specifically stated otherwise, we process your customer information, self-reported health information, samples, and test results with your consent. You have the right to withdraw your consent at any time, and we will cease processing your personal data accordingly.

• Contractual Necessity: To fulfill our contractual obligations, we need to collect customer information marked as required and all payment details.

• Compliance with legal obligations: As previously explained, we may sometimes need to process personal data to comply with legal obligations. When these obligations arise from Swiss law, such law provides a lawful basis for processing.

• Legitimate Interest: We process certain categories of personal data when we believe it is within our legitimate interest to do so, provided that we do not believe that your rights or freedoms will be disproportionately impacted by our processing. This includes device data, which is justified by our legitimate interest in maintaining a reliable and secure system free from errors and external security threats. Where we are required to process personal data due to legal obligations in the United States of America, we believe this justifies our processing of your data. We also rely on legitimate interest for processing Cookies. All information about your health, which would typically be restricted from processing under Swiss data protection regulations, is processed because you have given us your consent to do so.

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8. Miscellaneous

• We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. We will notify you of any material changes.

• If you have questions or concerns about our Privacy Policy, please contact us at support@nuuro.com.

• By using our website and/or app, you consent to the terms outlined in this Privacy Policy.

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