2. INFORMED CONSENT
3. INFORMATION COLLECTED BY SONAPHI
a. 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:
i. 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.
ii. Demographic Information: such as your age, gender, language preference, and race.
iii. 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).
iv. 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 Sonaphi for a limited time to allow us to analyze your voice. Sonaphi will not use your audio recordings in any way that is not identified in the Informed Consent document for the applicable Study.
b. Information Received From Your Use of the App: Sonaphi 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:
i. 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.
ii. E-mail communication. We collect the content you submit to us via e-mail, including text, links, images, gifs, and videos.
iii. 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.
4. USE OF INFORMATION
Sonaphi may collect and use information:
i. 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.
ii. 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 Sonaphi.
iii. 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.
iv. For research, testing analysis, and development. This allows Sonaphi 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.
v. To conduct and support Studies. This includes contacting you with notices regarding Studies through in-app notifications, e-mail or otherwise.
vi. In connection with legal requirements. Sonaphi 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 Sonaphi; to comply with a legal obligation; to protect against legal liability; or as requested by regulators, governmental entities, and official inquiries. In these cases, Sonaphi will make reasonable efforts to not disclose more than is necessary and provide notice of disclosure as practicable.
5. INFORMATION SHARING AND DISCLOSURE
a. 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.
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.
We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies for their direct marketing purposes.
b. 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.
c. Illegal Activities. Sonaphi may share information if Sonaphi, 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.
e. With Consent. Sonaphi may share information if Sonaphi obtains your express consent (or, where permitted by applicable law, your implied consent) to share such information.
f. 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.
g. 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.
h. Information Shared with Service Providers. Sonaphi 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.
6. AGGREGATE DATA
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 Sonaphi 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.
7. CHILDREN’S PRIVACY
Sonaphi 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 email@example.com.
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, Sonaphi will notify you, and any applicable regulator, if we are legally required to do so.
9. OPT-OUT AND UNSUBSCRIBE
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 Sonaphi by updating your account settings or contacting us here:
Please note that if you opt out, Sonaphi may still send you non-promotional messages related to your use of the App, such as information about your account.
10. YOUR RIGHTS
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.
11. ACCESS, DELETE, OR UPDATE YOUR INFORMATION AND QUESTIONS OR SUGGESTIONS
12. CHANGES TO THIS POLICY
13. DATA RETENTION
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.