Numen Privacy Policy
Cleancard Inc. d/b/a Numen (“Numen,” “we,” “our,” and/or “us”) values the privacy of individuals who use our mobile application (“App”) in connection with the Project GUIDE study (the “Study”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information when you use our App.
Please note that the personal information we collect from the App is also subject to the informed consent you signed to participate in the Study (“Informed Consent”). The Informed Consent may contain additional provisions relating to the collection, use, and disclosure of your personal information that go beyond the terms of this Privacy Policy.
Information We Collect
We may collect a variety of information from or about you or your devices from various sources, as described below.
A. Information You Provide to Us.
Registration Information. When you register for the App, we ask you for your name, email address, and year of birth.
Health Data. We will collect the health information described in the Informed Consent, such as survey responses and the color measurements recorded by the device when it scans your sample. We will de-identify this information before we analyze it.
B. Information We Collect When You Use Our App.
Device Information. We receive information about the device you use to access our App, such as your IP address, the type of device you are using and your browser type.
Usage Information. We automatically receive information about your interactions with our App, like the dates and times of your visits.
How We Use the Information We Collect
We use the information we collect:
- As described in the Informed Consent;
- To provide, maintain, improve, and enhance our App;
- To conduct the Study;
- To understand and analyze how you use our App and develop new products, services, features, and functionality;
- To generate anonymized or aggregate data containing only de-identified, non-personal information that we may use and disclose for any lawful purposes such as to publish reports;
- To find and prevent fraud and abuse, and respond to trust and safety issues that may arise;
- For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
- For other purposes for which we provide specific notice at the time the information is collected.
How We Disclose the Information We Collect
Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our App.
Study Partners, IRB, and Regulators. We may share your information with members of the Study’s research team, the Institutional Review Board (IRB) overseeing the Study, and the FDA and other regulatory agencies, if required for inspection.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the App.
Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.
Consent. We may also disclose your information with your permission.
Security
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
Minors’ Privacy
We do not knowingly collect, maintain, or use personal information from minors under 18 years of age, and no part of our Service(s) is directed to children. If you learn that a minor has provided us with personal information in violation of this Privacy Policy, then you may alert us at clinical@numen.com.
International Visitors
Our App is hosted in the United States and intended for visitors located within the United States. If you choose to use the App from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the App. By providing any information, including personal information, on or to the App, you consent to such transfer, storage, and processing.
Update Your Information
You may withdraw your consent to participate in the Study as more fully described in the Informed Consent. However, because we collect your personal information for research purposes with your consent, you cannot request deletion of you personal information.
Changes to this Privacy Policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the App, we will notify you through the App, by email, or other communication.
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at clinical@numen.com.
Last Updated: Mon Aug 3rd