Introduction
This Privacy Policy (the “Policy”) describes the type of information that MyLÚA Health, Inc. (the “Company,” “we” or “us”) gathers from users of the MyLÚA Health app (the “Services”). The Services comprise an AI-powered care coordination service that can support users throughout pregnancy.
Collection, Use, and Sharing of Personal Information
“Personal Information” means information that can be associated with a particular user. The chart below details what Personal Information we collect.
| What Personal Information We Collect | How We Collect the Personal Information | Why We Collect the Personal Information |
|---|---|---|
| Information you provide directly including name and email address. | We request this information as part of creating an account to use the Services. | We collect this information to allow us to manage user accounts for the Services. |
| Information you provide directly related to demographics, income, and symptoms. | We request this information as part of creating an account to use the Services. | We collect this information in order to provide users with insights regarding pregnancy. |
| Log and usage data, including IP address, device information, browser type, and settings, and information about your activity with the Services. | The Services automatically logs this information when users interact with the Services. | We use this information to administer and improve the Services, including the user experience. |
| Device data, including IP address, device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information. | The Services automatically log this information when users interact with the Services. | We use this information to administer and improve the Services, including the user experience. |
We may transfer information as explained below under “Third-Party Contractors,” “Business Transitions,” and “Compliance with Law and Prevention of Harm.”
Third-Party Contractors – We may use contractors (“Service Providers”) to perform limited services on our behalf, such as providing email services. Service Providers are required to obtain only the Personal Information they need to deliver the service they were hired to perform, to maintain the confidentiality of Personal Information, and not to use Personal Information for any purpose other than the service they were hired to perform.
Business Transitions – We may share information with businesses that are legally part of the same group as the Company, or that become part of that group. We reserve the right – in the event of a business transition such as a merger – to transfer Personal Information to a new business owner, on the condition that such Personal Information must be treated in accordance with this Policy.
Compliance with Law and Prevention of Harm – We may disclose your Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our users, yourself or the public. We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Aggregated and De-identified Data – As noted above, this Policy addresses the collection and sharing of Personal Information, that is, information that can reasonably be connected with a particular user. We may occasionally de-identify and/or aggregate Personal Information – to the extent permitted by law – to the point that it can no longer be associated with a particular user. When that occurs, such information is no longer Personal Information.
No Sale of Personal Information – We do not sell Personal Information.
Data Privacy Rights for Users
Users may request information about our collection, use, and disclosure of their information (a “Request to Know”), including:
- The categories and specific pieces of Personal Information we have collected about the user;
- The categories of sources from which we have collected the user’s Personal Information;
- The business or commercial purpose for collecting or selling the user’s Personal Information;
- The categories of Personal Information we have sold about the user; and
- The categories of Third Parties with whom we have shared, disclosed for a business purpose, or sold the user’s Personal Information, and which categories of Personal Information we have sold to which categories of Third Parties.
Users may also request that we delete their Personal Information (a “Request to Delete”). We do not discriminate against users on the basis of their exercise of their privacy rights.
Users may also opt out of marketing communications from us by utilizing the unsubscribe links in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to messages that we send, or by contacting us at [INSERT].
Requests to Know
Users may submit a Request to Know by completing the form provided at [INSERT] or by emailing us at [INSERT].
Users may submit two types of Requests to Know: (1) A request for the specific pieces of Personal Information that we have collected about you in the past twelve months; or (2) a request for the categories of Personal Information that we have collected about you in the past twelve months, and we have used and disclosed that Personal Information.
When you submit a Request to Know, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If you submit a Request to Know for the specific pieces of information that we have collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the Request to Know.
If we are able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why we are not required to provide the requested information. If we are unable to verify your identity, we will respond by explaining why we cannot verify your identity. We will confirm receipt of your Request to Know within 10 days and will respond to your Request to Know within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.
If we provide the information requested, we will provide the information free of charge and in a readily useable portable format. We have no obligation to provide Personal Information to you more than twice in a 12-month period. If a Request to Know or series of Requests to Know are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Know, or may refuse to process the Request(s) to Know.
Requests to Delete
Users may submit a Request to Delete by emailing us at support@myluahealth.com. When you submit a Request to Delete, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If we are able to verify your identity, we will respond to your Request to Delete by (a) deleting your Personal Information and, if applicable, directing any of our Service Providers to delete your Personal Information; or (b) explaining why we are not required to delete your Personal Information. We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the Personal Information. We will specify the manner in which we delete your Personal Information.
If a Request to Delete or series of Requests to Delete are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Delete, or may refuse to process the Request(s) to Delete.
Protection and Retention of Personal Information
We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Information. The appropriate administrative, physical, and technical safeguards employed by us may vary depending on the nature of Personal Information collected, with more stringent measures applied to information of a sensitive nature.
However, no method of transmission over the Internet, or method of electronic storage, is entirely secure. Therefore, while we strive to use commercially reasonable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality. Please be aware that certain Personal Information and other information provided by you in connection with your use of the Services may be stored on your device (even if that information is not collected by us). You are solely responsible for maintaining the security of your device from unauthorized access.
Personal Information will be retained for as long as is reasonably necessary to achieve the purposes set forth in this Policy, and to comply with all applicable laws.
Other Provisions
- Accessibility and Language – Any person that is unable to access this Policy through the Services may request this Policy in an alternative format or language by contacting us at support@myluahealth.com.
- International Users – The Company and its servers are located in the United States and are subject to applicable local, state, and federal laws. Users who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all applicable laws, rules, and regulations. Users who choose to access the Services consent to the use and disclosure of information in accordance with this Policy and subject to such laws. We may limit the Services’ availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time and in our sole discretion. We do not represent or warrant that the Services, or any part thereof, are appropriate or available for use in any other jurisdiction.
- Children’s Privacy – The Services are neither directed to nor structured to attract Users under the age of 16. If you are under the age of 16, you are not permitted to use the Services without parental permission. If we become aware that we have inadvertently received Personal Information from a User under the age of 16 without parental permission, we will delete such information from our records.
- Do Not Track – The Services do not currently recognize or respond to browser-initiated “Do Not Track” signals as there is no industry standard for such signals. We will continue to review developments in browser technology and may adopt a standard once one is created.
- Changes to This Policy – This Policy may change from time to time as our business practices evolve, and as the legal and regulatory environment in which we operate changes. We will not reduce your rights under this Policy without your explicit consent. Any changes to this Policy will be posted here, and we will provide additional notice if and when they become significant.
- Contact Us – If you have any questions about this Policy, please contact us at support@myluahealth.com.
International Users
The Company and its servers are located in the United States and are subject to applicable local, state, and federal laws. Users who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all applicable laws, rules, and regulations. Users who choose to access the Services consent to the use and disclosure of information in accordance with this Policy and subject to such laws. We may limit the Services’ availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time and at our sole discretion. We do not represent or warrant that the Services, or any part thereof, is appropriate or available for use in any other jurisdiction.
Children’s Privacy
The Services are neither directed to nor structured to attract users under the age of 16. If you are under the age of 16, you are not permitted to use the Services without parental permission. The Company does not knowingly collect Personal Information from users under the age of 16. If you are a parent with concerns about children’s privacy issues in conjunction with the use of the Services, please contact the Company at support@myluahealth.com.
Do Not Track Signals and Collection of Information for Third-Party Advertising
We are required to disclose how we respond to “Do Not Track Signals” and whether third parties collect personally identifiable information about users when they use online services. We honor “Do Not Track” signals and do not track, use cookies, or use advertising when a “Do Not Track” mechanism is in place.
Amendments
We may modify or amend this Privacy Policy from time to time. If we make any material changes, as determined by us, to this Privacy Policy, including in the way in which Personal Information is collected, used, or transferred, we will notify you by email to the address specified in your profile or by means of a notice on the Services prior to the change becoming effective.
Contact Information
If you have questions about this Policy, please contact support@myluahealth.com.
Effective Date
The effective date of this Policy is July 29, 2024.