This Privacy Policy was last updated on November 15, 2021.
Nuevozen Corp. (“Nuevozen”) understands the importance of user privacy, and your privacy and privacy choices matter to us. This Privacy Policy will tell you what information Nuevozen collects and how that information is protected and used. We ask that you read this Privacy Policy carefully.
Nuevozen strives to offer users of its online website and services (“Users”) the many advantages of Internet technology and to provide an interactive and personalized experience. In order to do so, we may obtain certain personal information from you. The purpose of this policy (the “Privacy Policy”) is to inform you about the types of information we gather about you when you access or use of online interfaces and properties (e.g., websites and mobile applications), including the neuvozen.com website and the Nuevozen mobile application (collectively, the “Site”), as well as the services available to Users through the Site (the “Solution”), how we may use that information, and the choices you have regarding our use of that information. Use of the Solution is also subject to the Nuevozen Solution Agreement available at [URL]. If we collect personal health information from you as part of our use of the Solution, the Business Associate Agreement available at [URL] also applies.
BY INSTALLING, USING OR ACCESSING THE SITE OR THE SOLUTION, YOU ACCEPT THIS PRIVACY POLICY WITHOUT QUALIFICATION.
The content of the Site and the Solution, including without limitation, text, software, graphics, photos, sounds, documentation, reports, music, videos, audiovisual combinations, interactive features, links, and other materials, is for informational purposes only and does not constitute professional medical advice, diagnosis, treatment, or recommendations of any kind by Nuevozen. Nuevozen also cannot answer unsolicited emails requesting personal medical advice. You should always seek the advice of your qualified health care professionals with any questions or concerns you may have regarding your individual needs and any medical conditions. Never disregard professional medical advice or delay in seeking it because of something you have read on this Site. If you think you are having a medical emergency, please call your doctor or call 911 immediately.
Right To Modify Privacy Policy
Nuevozen reserves the right, at its sole discretion, to alter this Privacy Policy at any time by posting the amended Privacy Policy on the Site without prior notice to any User. For example, we may amend this Privacy Policy to comply with privacy laws, regulations and/or our own or industry standards, or as a result of changes to the Site, the Solution or our business practices. We encourage you to review this Privacy Policy each time you access or use the Site or the Solution. Any use of the Site or the Solution after our publication of any such changes shall constitute your acceptance of the Privacy Policy as modified.
Collection and use Of Information from Users
We may collect information on our Users in various ways, including by your voluntary submissions, and through “cookies” (as explained below) and other tracking technology. The information we collect is used in a variety of ways including, but not limited to: providing the Solution you; improving the Site and the Solution; notifying you about updates to the Site and the Solution; and/or informing you about products, services, and promotions in which you may have interest. With your authorization or as otherwise permitted under this Privacy Policy, we may also share the information you provide with third parties.
Personal Data
Personal Data refers to information that tells us specifically who you are, such as your name, phone number, email, or postal address, and possibly information relating to certain support or customer service issues (collectively, “Personal Data”). “Personal Data” does not include protected health information, which is subject to the Business Associate Agreement. While some actions, such as vising the Site, will not prompt a collection of Personal Data, you generally need to provide us with Personal Data to use the Solution or to obtain information through the Site, including to allow us to provide you with certain personalized or enhanced services that you have requested. How we collect and store information depends on the page you are visiting, the activities in which you elect to participate, and the Solution provided. As noted, you can access or use many pages and information on the Site without providing any Personal Data. Still, other pages and the Solution may prompt you to provide Personal Data.
We will process Personal Data collected through Site and the Solution in accordance with applicable law, and as described in this Privacy Policy. If you do not want to provide us this information, please do not use the Site or the Solution.
Aggregate Information
From time to time, we may collect general, non-personal, statistical information about the use of the Site, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they click on. This information represents a generic overview of our Users’ collective viewing habits and allows us and other third parties to modify information and the Solution based on user traffic and behavior. We collect this information through the use of technologies such as “cookies”, which are discussed in greater detail in this Privacy Policy. We collect this information in order to determine, for example, which areas of the Site are most popular and to enhance the Site for visitors. We may also group this information into aggregate visitor data in order to describe the use of the Site to our existing or potential business partners or other third parties, or in response to a government request. From time to time, we may use this information to optimize third-party offers of products and/or services. We also may share aggregated demographic and preference data with third parties to enable the provision of targeted information. However, please be assured that this aggregate data in no way will it personally identify you or any other Users of the Site or the Solution.
We may also de-identify and/or aggregate your data for various business purposes including product, service and program development and improvement. De-identified data, in individual or aggregated form, may also be used for research purposes both internally by Nuevozen or with research partners and other third parties for the advancement of clinical and scientific knowledge.
Cookies and Other Tracking Technologies
Like most websites, the Site also may collect information automatically and through the use of electronic tools that may be transparent to Users. For example, we may automatically collect non-Personal Data and data through the use of “cookies”. Cookies are small text files the Site uses to recognize repeat Users, facilitate the User’s ongoing access to the Site and facilitate the use of the Site. Cookies also allow a Site to track usage behavior and compile site usage information that will allow for the improvement of content and target advertising. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set your browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, please be aware that some features of the Site will not function or may be slower if you refuse cookies.
Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that the Site is accessed. An IP address is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that “serve up” webpages, automatically identify your computer by its IP address.
Our Use of Personal Data
We may use your Personal Data to update you on special offers related to our Site or the Solution, improve our Site and the Solution, provide announcements or information regarding health topics or the Solution, deliver other information we believe you will find most relevant, and useful and in any other way we may describe when you provide the information or to which you consent. We may occasionally contact you to gather customer service information to help us determine how we can improve the Solution and Site to better meet your needs.
The Solution collect certain information from you when you share that information with us and when you use the Solution. Our Site may collect information about your device and how it is being used. This includes the make and model of your phone, your mobile operating system and the type of browser you are using.
We may link the information we record using tracking technologies to Personal Data we collect at the Site for our own marketing and advertising purposes. In addition, we reserve the right to use IP addresses and other tracking technologies to identify a visitor when we feel it is necessary to enforce compliance with the Nuevozen Solution Agreement, to protect the Site, our customers or others, or when we believe in good faith that the law requires it.
Disclosures and Transfers of Information
We do not disclose Personal Data to third parties, except when one or more of the following conditions is true:
- You have authorized us to disclose such information;
- The disclosure is to financial service providers in order to fulfill and carry out the purchase and provision of the Solution requested by you;
- The disclosure is required by relevant law;
- The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets;
- The Personal Data to be disclosed is publicly available;
- The party to whom the disclosure is made controls, is controlled by, or is under common control with Nuevozen;
- The disclosure is reasonably necessary for the establishment or maintenance of legal claims;
- The disclosure is in our sole discretion about Users who we believe are engaged in illegal activities or are otherwise in violation of our policies, even without a subpoena, warrant or court order;
- The disclosure is to outside businesses to perform certain services for us, such as maintaining the Site, mailing lists, processing and delivering the Solution, sending postal mail, processing, providing marketing assistance, data analysis, etc.; or
- The disclosure is to persons or entities for which we are providing services, provided the disclosure is consistent with the purpose for which the Personal Data was obtained.
Our Service Providers
We may sometimes use other businesses to perform certain services for us, such as hosting or maintaining the Site, storing your information, processing orders or subscriptions, or providing marketing assistance and data analysis. We may provide Personal Data to service providers when that information is necessary for them to complete a requested transaction or otherwise perform their duties. Nuevozen will take reasonable steps to ensure that these service providers are notified of their obligations to reasonably protect Personal Data on Nuevozen’s behalf. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices.
Business Transfers
As we continue to develop our business, we may buy other businesses or their assets or sell some or all of our business assets. Personal Data and other customer information is generally one of the business assets involved in such transactions. Thus, in the event that Nuevozen or all of its assets are acquired, such information may be one of the transferred assets.
Protection of Nuevozen and Others
Nuevozen fully cooperates with law enforcement agencies in identifying those who use our Site or the Solution for illegal activities, and may in its sole discretion disclose Personal Data or other information to satisfy any law, regulation, subpoena, or government request or in connection with litigation. Nuevozen reserves the right to release Personal Data or other information about Users who we believe are engaged in illegal activities or are otherwise in violation of the Nuevozen Solution Agreement, even without a subpoena, warrant or court order, if we believe in our sole discretion that such disclosure is necessary or appropriate to comply with any laws, to operate the Site, or to protect the rights or property of Nuevozen, its affiliates, or any of their officers, directors, or employees, agents, third party content providers, suppliers, sponsors, or licensors. Nuevozen also reserves the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful.
Data Security and Integrity
We take reasonable precautions to protect the privacy, accuracy and reliability of any information you provide and to protect such information from loss, misuse, unauthorized access, disclosure, alteration and destruction. The Personal Data you provide and we collect is stored within databases that are controlled by us or by our service providers. As we deem appropriate, we use security measures consistent with industry standards, such as firewalls and encryption technology, to protect your information. However, since no security system is impenetrable, we cannot guarantee the security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. As a result, you transmit any information to or from the Site at your own risk.
If you create an account to use the Site and the Solution, you may be asked to choose a password for your account, in which case your online account information shall be protected by your password. The terms of the Nuevozen Solution Agreement apply to your use and protection of your account information and password.
International Transfers.
Personal Data collected from you may be stored and processed in the United States or any other country in which Nuevozen or its affiliates, subsidiaries, agents or contractors maintain facilities. If you are accessing Personal Data from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your data to the United States and processing globally. By providing your Information you consent to any transfer and processing in accordance with this Privacy Policy.
Accessing and Deleting Personal Data; Opt-Out
If you have submitted Personal Data to the Site or through the Solution, you may ask for access or changes to such information by contacting us at [email address]. We may require proof of your identity before we edit or provide you with the requested information. We will use reasonable efforts to supply you with this information and to correct any factual inaccuracies that you identify. Please also contact us at [email address] or if you do not want us to disclose your Personal Data to third parties or you want us to delete your Personal Data from our databases. Keep in mind, however, that there may be residual information within our databases, access logs, archived backups, and other records, which may or may not contain such information. The residual information will not be used for commercial purposes; however, we reserve the right, from time to time, to re-contact former Users of the Solution. We allow you to challenge the data that we hold about you and, where appropriate, you may have the data erased, rectified, amended, or completed.
Other Sites, Links, and Advertisements
Nuevozen expects its partners, advertisers and third-party affiliates to respect the privacy of our Users. However, third parties, including our partners, affiliates and other content providers accessible through the Site, may have their own privacy and data collection policies and practices. Also, you may be introduced to, or be able to access, information, websites or other features offered by other parties through the Site. Nuevozen is not responsible for the actions or policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party. While we support the protection of our User’s privacy on the Internet, Nuevozen expressly disclaims any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Data by third parties.
Children
We understand and share your concerns regarding your children’s access to Internet and the Internet’s access to your children. Consistent with the Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly request or accept Personal Data submitted to the Site by any visitor under 13 years of age. If we become aware that an individual under age 13 has provided information to Nuevozen through the Site, we will make commercially reasonable efforts to delete such information from our databases.
Applicable Law
This Privacy Policy shall be governed by the laws of the State of California, without regard to conflicts of law principles. Any action relating to this Privacy Policy must be filed and maintained in a state or federal court of competent jurisdiction located in California, and each User consents to exclusive jurisdiction and venue in such courts for such purpose. Nuevozen makes no representation that this Privacy Policy complies with the laws of any country outside the United States.
How to Contact Us
If you have any questions or comments about this Policy or our privacy practices, or to report any violations of the Policy or abuse of an Application, the Solution or the Site, please contact us by mail or email at the following:
Nuevozen Corp.
Attn: Privacy Officer
Address: 336 Bon Air Ctr, #299, Greenbrae, CA, 94904
E-mail: [TBD]
Specific Privacy Provisions related to the California Consumer Privacy Act of 2018
These specific privacy provisions apply solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
Our Site and the Solution collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, Nuevozen, through the Site and the Solution has collected the following categories of personal information from its Users within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | 🗹 |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | 🗹 |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | 🗹 |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | 🗷 |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | 🗷 |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | 🗹 |
| G. Geolocation data. | Physical location or movements. | 🗷 |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | 🗷 |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | 🗷 |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | 🗷 |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | 🗷 |
Our Site obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you subscribe to or purchase.
- Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
We may use or disclose the personal information we collect for the purposes set forth in this Privacy Policy.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Affiliates
- Service providers
- Law enforcement providers
- Third party applications and devices that you connect to your Nuevozen Account.
In the preceding twelve (12) months, Nuevozen has not sold personal information.
Your Rights and Choices
The CCPA provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you the information required under CCPA.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request in certain circumstances. If we deny your request we will explain to you why retaining the information is necessary to us or our service providers and allowable under the CCPA.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Emailing us at [email address]
- Visiting www.nuevozen.com
- Calling us at [Phone number]
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 more days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.