WE DO NOT SELL OR SHARE YOUR INFORMATION WITH ANYONE WITHOUT YOUR AUTHORIZATION OR YOUR CONSENT.

DATA IS COLLECTED ONLY WHEN IT IS NEEDED FOR DIAGNOSIS OR IN ORDER TO HELP OUR USERS LIVE HEALTHIER LIVES.

WE DO NOT SELL YOUR DATA TO MARKETERS OR ANY THIRD PARTIES TO BE USED FOR TARGETED ADVERTIZEMENT.

WE ENCRYPT DATA AT REST AND AT TRANSMIT TO PROTECT YOUR PHI (PROTECTED HEALTH INFORMATION) or PII DATA (PERSONALLY IDENTIFIABLE INFORMATION).

This Privacy Policy (“Policy”) describes how Kbrax, Inc. (“We”) collect, use and disclose Personal Information we receive when you use the MindPure mobile app orhttps://mindpure.com (“MindPure”) or otherwise interact with us, whether online or offline. It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns.

Please read this Policy carefully before using MindPure.

Kbrax, Inc. is a company incorporated in the State of Delaware, USA.

1 PERSONAL INFORMATION WE COLLECT

In this Policy, “Personal Information” means any information related to an identified or identifiable individual and does not include data whereby personally identifiable information has been removed (such as anonymous data).

We collect Personal Information about you from the different sources listed below.

Information Collected from You

You may provide us with Personal Information, including when you:

• register to receive our services;
• use MindPure application; and
• communicate with us.

The categories of personal information you provide may include:

• Contact details, such as your name, email address, telephone number and home address;
• Basic profile information, such as demographic information including date of birth and gender;
• Account details, including username and password;
• Health data, including information relating to your exercise regime, health, smoking, drinking, lifestyle and wellbeing, diet, sleep patterns and body metrics and any other information relating to your health, lifestyle and fitness you choose to upload to MindPure;
• Correspondence and communications data, including any Personal Information contained in your correspondence and communications with us, including survey responses;
• Marketing data, such as your marketing preferences.

We will indicate to you where the provision of certain Personal Information is required in order for us to provide you certain services. If you choose not to provide such Personal Information, we may not be able to provide the services you have requested.

Information Collected from You

We also collect the following information automatically when you use MindPure:

• Identifiers and usage data, including your IP address, advertising identifiers, engagement metrics and information about your device, including model, version and operating system.
• Phone contacts, we will automatically connect you with contacts in your address book who also use MindPure (note we do not store your address book and you can opt out of this using the settings function in the app).
• Transaction information, including details of payments made (if any) and services purchased.

Information Collected from Other Sources

We may obtain Personal Information about you from the following third parties:

• Third party apps, devices and wearables. If you choose to connect MindPure with a third-party health and fitness related application (such as Apple HealthKit) or device we will receive additional health and lifestyle data from the third-party providers of those apps or devices.
• Third party payment processors. If you have opted in to the [enhanced] MindPure service, we obtain Personal Information about you from our payment processors such as Apple App Store Payments. This information includes purchase details, username and transaction amount.
• Your medical practitioner or other healthcare provider. If you choose to provide us with access to some or all of your medical records as part of MindPure, we obtain these records directly from your medical practitioner or healthcare provider.

Aggregated Data

We also collect, use and share aggregated data such as statistical or demographic data for our purposes. Aggregated data may be derived from your Personal Information but is not Personal Information as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about your use of MindPure to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will be used in accordance with this Policy.

2 HOW WE USE PERSONAL INFORMATION

As a data controller, we will only use your Personal Information if we have a legal basis for doing so. The table at Annex 1 sets out the purposes for which we use your Personal Information as well as the legal bases which we rely on to process your Personal Information.

3 WHO WE SHARE YOUR INFORMATION WITH

We disclose Personal Information with the following recipients and in the following circumstances:

• Vendors and service providers. We may share your Personal Information with third party vendors (such as our medical kit providers) and other service providers that perform services for us or on our behalf, which may include providing data hosting, customer relationship management, payment processing, health data analysis, biospecimen storage and analysis and analytics services.
• Fitness and health applications or devices. If you choose to integrate third party applications (such as Apple HealthKit) and devices with MindPure, we may share certain integration information with these third parties, including username, device information and ID.
• Healthcare professionals. We may share your Personal Information with healthcare professionals, such as qualified physicians, in certain circumstances, e.g. where your biomarkers are out of range. We share certain contact information with these third parties, including name and contact information, and bio specimen results.
• Other members of the MindPure group. We share Personal Information about you with other members of the MindPure group, for example, where they provide services on our behalf or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.
• Research partners. If you provide your consent, we may share your Personal Information with third party research partners, such as universities and research institutions, for the purposes of carrying out statistical and scientific research.
• Law enforcement, regulators, governmental authorities and other parties for legal reasons. We may share your Personal Information with third parties if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or our safety, or the safety of our users, a third party, or the public.
• Purchasers and third parties in connection with a business transaction. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Personal Information as part of that transaction.

In addition, we may share your Personal Information with other third parties if you have provided your consent for us to do so.

4 YOUR RIGHTS AND CHOICES

If you are located in the UK and EEA, then you have the following rights in respect of your Personal Information that we hold in accordance with local privacy law:

• Right of access. You have the right to obtain access to your Personal Information.
• Right of portability. You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.
• Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.
• Right to erasure. You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.
• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.
• Right to object. You have a right to object to the processing we carry out on the basis of legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the "unsubscribe" link set out in any marketing communication or contacting us using the details set out below.
• Right to withdraw consent. If you have provided consent to any processing of your Personal Information, including in relation to the processing of your health information, you have a right to withdraw that consent.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

If you wish to exercise one of these rights, please contact us atprivacy@MindPure.health.

6 CHILDREN’S PRIVACY

MindPure is not directed to children under the age of 16 and we do not knowingly collect Personal Information relating to anyone under this age. If you learn that a child has provided us with Personal Information in violation of this Policy, please contact us using the details set out below.

7 DATA RETENTION

We store all Personal Information for as long as necessary to fulfil the purposes set out in this Policy, or for as long as we are required to do so by law or in order to comply with any regulatory obligation.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8 DATA SECURITY

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. However, the transfer of Personal Information through the internet will carry its own inherent risks and we do not guarantee the security of your data transmitted through the internet. You make any such transfer at your own risk.

9 COOKIES AND SIMILAR TECHNOLOGIES

MindPure uses cookies and similar technologies to distinguish you from other users of our service. This helps us to provide you with a good experience when you browse MindPure and also allows us to improve MindPure.  

Cookies are pieces of code that allow for personalization of your experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes.

We use the following types of cookies:

1. Strictly necessary cookies. These are cookies that are required for the operation of our service. They include, for example, cookies that enable you to log into secure areas of our website.
2. Performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the service when they are using it. This helps us to improve the way MindPure works, for example, by ensuring that users are finding what they are looking for easily.
3. Functionality cookies. These are used to recognize you when you return to MindPure. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
4. Advertising cookies. We use advertising cookies to measure the effectiveness of our online marketing.
5. Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our website. These third parties are responsible for setting out their own cookie and privacy policies.

The cookies we use are designed to help you get the most from MindPure but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of MindPure. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

1. Cookie settings in Internet Explorer
2. Cookie settings in Firefox
3. Cookie settings in Chrome
4. Cookie settings in Safari web and iOS.

If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org.

10 LINKS

MindPure may contain features or links to websites and services provided by third parties. Any information you provide on third-party websites or services is provided directly to the operators of such websites or services and is subject to those operators’ policies governing privacy and security, even if accessed via MindPure. We are not responsible for the content or privacy and security practices and policies of third-parties to which links or access are provided through MindPure. We encourage you to learn about third parties’ privacy and security policies before providing them with your Personal Information.

11 CHANGES TO THIS POLICY

We may update this Policy from time to time and so you should review this page periodically. When we change this Policy in a material way, we will update the "last modified" date at the beginning of this Policy. Changes to this Policy are effective when they are posted on this page. 

12 COMPLAINTS

If you wish to lodge a complaint about how we process your Personal Information, please contact us at privacy@kbrax.com. We will attempt to respond to your complaint as soon as possible.

13 OUR CONTACT INFORMATION

Kbrax, Inc. is the entity responsible for the processing of your Personal Information, and for the purpose of the General Data Protection Regulation, is the data controller in respect of the processing of your Personal Information.

If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Information, please contact our Data Protection Officer by email at privacy@kbrax.com.

• Contact details
• Account details
• Basic profile information

  To register you with MindPure.
  Administration of account (including sending you information regarding changes to our policies, other terms and other administrative information).

  Performance of a contract
  To the extent the processing concerns special categories of personal data, we will request your explicit consent.
  Performance of a contract

• Health data (including medical records and data from third party apps and devices (if applicable))
• Biospecimens (including analyses and results derived from these, such as blood assay results and genomics data)
• Basic profile information

  To provide you with our services (including providing you with a biological age and a rate of aging) and carry out research to improve our services.
  To carry out statistical and scientific research.

  Performance of a contract
  Explicit consent
  To the extent the processing concerns special categories of personal data, we will request your explicit consent.
  Explicit consent

• Contact details

  To process delivery of medical kits where applicable to connect you with other users and allow you to invite contacts to use the service.

  Performance of a contract
  It is in our legitimate interests to make our services social and allow you to interact with friends when using the service.

• Correspondence and communications data
• Contact details

  To respond to queries and complaints and provide you with information and materials that you request from us.

  It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to maintain good customer relations.

• Transaction information

  To maintain accounts and records as required under applicable law.

  Compliance with a legal obligation.

• Contact details
• Marketing data

  Marketing and advertising (including sending you newsletters and measuring the effectiveness of our marketing).

  Either consent (if required under applicable law).
  Where consent is not required under applicable law, such processing is necessary in our legitimate interests, namely to develop and grow our business.

• Identifiers and usage data

  To administer MindPure, including resolving technical issues, troubleshooting, data analysis, testing and research and statistical purposes.
  To analyze the use of MindPure, including for the purposes of improving MindPure to ensure that content is presented in the most effective manner for you.

  It is in our legitimate interests to monitor MindPure to ensure that it functions properly and is secure. It is in our legitimate interests to carry out analytics to understand how our users interact with MindPure and improve our services based on this information.