Platform Privacy Statement

Version 1.2
Last revised on: October 20, 2021
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Introduction

Holmusk Technologies, Inc. (“Holmusk”) makes available the NeuroBlu™ platform (“Platform”) to its business customers (any, a “Customer”). The Platform leverages real-world data to provide insights regarding behavioral health. This Platform Privacy Statement (“Privacy Statement”) explains how we collect, use, and disclose data in connection with the Platform (collectively, the “Services”).

Holmusk’s processing of information in connection with the Services is governed by this Privacy Statement, the relevant Customer agreement and applicable laws. In the event of any conflict between this Privacy Statement and the relevant Customer agreement, the relevant Customer agreement will control to the extent permitted by applicable law.

Information We Collect

Information collected via the Services. The Platform is not designed to collect personal data from Customer other than as described below.

Information collected about authorized users. We collect information about a Customer’s “authorized users” — the individuals (typically personnel) that Customer authorizes to create an account to access, search, view and otherwise interact with the Platform. The information we collect about authorized users includes:

Information provided to us by the Customer about its authorized users. This may include business contact information, such as name, email address, and phone number.
Information provided to us by authorized users. This may include personal information that end users provide when they register for an account or create a user profile (such as name, email address, telephone number), contact customer support, or otherwise correspond with us by phone, email, or other means.
Information about authorized users’ use of the Services. This may include information about authorized users’ use of the Services, including computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, general location information such as city, state or geographic area; and information about authorized users’ use of and actions on the Services, such as pages you viewed, how much time was spent on a page, navigation paths between pages, information about activity on a page, access times, and length of access. This information is collected using device recognition, recognition of data on devices, similar technologies.

Information We Make Available via the Platform

Through the Platform, we make available to our Customers and its relevant authorized users de-identified and aggregated data. Holmusk removes identifying data from information made available to Customers.

How We Use Information

We use the limited information we collect about authorized users in accordance with the relevant Customer agreement, to provide the Services and for related internal purposes, such as:

To maintain the Services;
To measure performance of and improve the Services and develop new products and services;
To create anonymous, aggregated and/or deidentified data that Holmusk may then use to analyze patterns to enhance Holmusk’s products and services and develop new ones; and
To respond to inquiries, complaints and requests for Customer support.

With respect to anonymized, aggregated and/or deidentified data that Holmusk derives through its customers’ using the Platform, such information does not and will not identify any particular user and/or the relevant customer.

We may also use information as we believe necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Services; (c) protect our rights, privacy, safety or property and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Information

We share the limited personal information we collect with:

the relevant Customer from which we obtained the information and any such third parties as the relevant Customer may direct in accordance with the Customer agreement;
With third-party service providers that help us manage and improve the Services; and
To measure performance of and improve the Services and develop new products and services;
With Holmusk subsidiaries and corporate affiliates for the purposes described in this Privacy Statement or in the relevant Customer agreement.

We may also share information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We may sell, transfer or otherwise share some or all of Holmusk’s business or assets, including information that we process as part of the Services, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Information Security

Holmusk uses commercially reasonable physical, electronic, and procedural safeguards designed to protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent a security problem. We recommend that Customer take steps to protect against unauthorized access to any devices or networks used to access the Services.

Cross Border Data Transfer

Holmusk may transfer information collected through the Services outside of the country from which it originated, including to the United States. See the relevant Customer agreement for additional information regarding how Holmusk safeguards the information it transfers across borders.

Data Retention

Holmusk may retain information for as long as necessary to (a) provide the Services; (b) comply with legal obligations; (c) resolve disputes; and (d)enforce the terms of its Customer agreements.

Changes to this Privacy Statement

Holmusk reserves the right to modify this Privacy Statement at any time. Similar to Holmusk’s Services, laws, regulations and industry standards may evolve which may make changes to this Privacy Statement appropriate. Holmusk will post the changes to this page.

Contact Us

If you have any question about this Privacy Statement, you can contact our privacy team at privacy@Holmusk.com.

NeuroBlu Privacy Centre