Privacy Policy

Effective Date: October, 2020

Welcome to Applied Cognition.


We take your privacy seriously, and we want you to be familiar with how we collect, use, and share Personal Information from you. Please carefully read this privacy policy (the “Privacy Policy”) as it contains important information about your legal rights.

This Privacy Policy forms a part of the Terms of Use, which are binding terms between Applied Cognition, LLC and its affiliates and subsidiaries (“Applied Cognition,” “we,” or “us”) and you. Any capitalized terms that are not defined in this Privacy Policy will have the meanings given to those terms in the Terms of Use. This Privacy Policy applies to your access to and use of the following services, which we refer to collectively as the “Services”:

  • Applied Cognition’s mobile applications (the “Apps”)

  • Applied Cognitions health devices (the “Devices”)

  • the websites that Applied Cognition operates (including appliedcognition.com ) (the “Sites”); and

  • all related services and features that Applied Cognition provides.

In this Privacy Policy, we describe how we collect, maintain, use, disclose, and process certain information about you. By accessing or using the Services, you consent to this Privacy Policy and to our collection, maintenance, use, disclosure, and processing of Personal Information, all as described in this Privacy Policy. Please note that we enter into agreements (“Organization Agreements”) with employers sponsoring group health plans for their employees, health insurers, health care providers, research institutions, and other organizations (“Organizations”) that govern our use of Protected Health Information under HIPAA and certain other information about you that we receive from you or on behalf of the Organizations. To the extent that this Privacy Policy conflicts with any applicable Organization Agreement, the Organization Agreement will control. If you use the Services as a plan member or patient of an Organization and have questions about the treatment of your Protected Health Information, you should review the HIPAA Notice of Privacy Practices of the Organization or contact the Organization.

By using our Services, you agree that we may treat your information in the ways we describe in this Privacy Policy. If you do not agree with any term of this Privacy Policy or the Terms of Service, you may not use our Services.

What is the purpose of this Privacy Policy?

Personal Information regarding our users is an integral part of our business. This Privacy Policy explains how we collect, maintain, use, disclose, and process your information, which includes, among other things, gathering, storing, evaluating, modifying, deleting, combining, sharing, and transferring that information. Unless we obtain your permission, we will not share your Personal Information with other people or non-affiliated companies except as expressly permitted or required by this Privacy Policy.

We will not rent or sell your Personal Information, and we will not permit our business partners to rent or sell your Personal Information either. We may transfer Personal Information in connection with a transfer of part of our business, but if we do, we would require that the successor entity comply with the terms and conditions of this Privacy Policy.

What does the Privacy Policy cover?

This Privacy Policy covers how we use and disclose Personal Information that we gather from you beginning at the time that you first access one of our Sites or Apps and on an ongoing basis as you use or access the Sites, the Apps or other aspects of our Services.

 

What information do we collect?

We are developing a suite of Apps and Devices to measure brain health. The Longevity App supports academic medical centers and other Organizations in conducting clinical research studies to gather measurements about brain health or other information needed for their clinical research studies.

Longevity App

  • The Longevity App is only used for participants of research studies who have provided their written informed consent.

  • The Longevity App will collect reaction times from your touches of your mobile device touch screen. The Longevity App does not capture any content from the use of your phone except for your response to questions and messages that you receive in the Longevity App.

  • The Longevity App is only available for Android devices and requires the activation of the Android’s Accessibility Service. Please note that not providing consent to activate the Accessibility Service, or subsequently disabling the Accessibility Service, will affect important features of the Longevity App.

  • If you participate in a clinical research study, we share information collected during your use of the Longevity App with the Organization that is conducting or sponsoring the research study. This is described in “How Do We Share Your Information?”

When you access or use our Services, we collect the information you provide to us when you, for example:

  • Contact us with inquiries and comments

  • Complete and submit forms offered on the Services

  • Apply for employment

  • Use the interactive features of our Services

We may also obtain information about you from other sources and combine that information with information we collect from you directly. For example, if you participate in a clinical research study, we may receive information about you from the Organization that is conducting or sponsoring the research study.

How do we use your information?

We may use your information in the following ways:

  • Provide you the Services and fulfill your requests: We may use your information to register you, administer your account, and provide you the information, products and services that you request. For example, we respond to your questions when you contact us, assist with any problems you report about our Services.

  • Communicate with you: We may contact you to share information and materials that we think might be of interest to you, including information about products and services that promote health and wellness. You may unsubscribe from receiving emails about these products and services by using the unsubscribe link included in an email.

  • Enhance your experience: We use your information to personalize and enhance your experience when you use the Services, such as tailoring and remembering your preferences.

  • Improve our Services: Your information helps us improve the content and functionality of our Services. For example, we may conduct measurement activities and analyze trends, usage and activities in connection with the Services to create new features and content.

  • Protect Applied Cognition and our Users: We may use information about you to detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Applied Cognition and others.

  • Creation of De-Identified Information: We may use your Personal Information to create data that is de-identified in accordance with HIPAA, other applicable laws and our Organization Agreements with applicable Organizations. This de-identified information is not Personal Information, because it cannot be used to identify you, and may be used by us for any lawful purpose.

In addition to those purposes listed above, we may use your information for any other purpose disclosed to you at the time of collection.
 

How do we share your information?

We may share your information as follows or as otherwise described in this Privacy Policy:

  • With Organizations: If you are a clinical research study participant, a health plan member or patient of an Organization, then we will share your information with the Organization in accordance with the Organization Agreement and applicable law. You should review the Notice of Privacy Practices and/or other privacy policies of the Organization to understand how the Organization uses your information.

  • Other Service Providers: We may share your information, in an encrypted format, with third-party hosting and information security providers that provide computer, storage and information security resources to Applied Cognition.

  • In the Event of a Corporate Transaction: In the event we go through a business transition, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or sale of all or a portion of our assets, we may disclose your information to the party or parties to such transaction.

  • For Legal Purposes: We will disclose your information when we think it is necessary to investigate or prevent actual or expected fraud, information security breaches, criminal activity, injury or damage to us or others or when otherwise required by law, regulation, subpoena, or court order, or if necessary to protect our rights.

  • At Your Direction: We will share your information with third parties if and when you direct us to.

We may share de-identified information in all legally permissible ways.
 

How do we protect your information?

The security of your Personal Information is important to us. We have implemented and maintain reasonable technical, physical and administrative security measures intended to protect against unauthorized use, disclosure, alteration or destruction of the Personal Information we collect and maintain. You should keep in mind, however, that no data transmitted over the Internet is 100% secure and any information disclosed online can potentially be collected and used by persons other than the intended recipient. As a result, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit to or from our Services.
 

Note to international users

If you access or use our Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.
 

Your Rights

Account Information

Subject to any restrictions in our Organization Agreements, you may update, correct or otherwise modify information that we maintain about you at any time by logging into your online account or by emailing us at privacy@appliedcognition.com If there are restrictions in an applicable Organization Agreement, we will provide contact information for the Organization so that you can ask the Organization to modify your information. If you wish to deactivate your account, please email us at privacy@appliedcognition.com but note we may continue to store information about you as required by law or for our legitimate healthcare business purposes.

Choices

If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized or is to be disclosed to a third-party, we will provide individuals with an opportunity to choose whether to have their personal data so used or disclosed. Requests to opt out of such uses or disclosures of personal data should be sent to privacy@appliedcognition.com

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.

Push Notifications

With your consent, we may send push notifications or alerts to your mobile device. You can deactivate these notifications at any time by changing the notification settings on your mobile device or within our Apps.

 

Changes to this Privacy Policy

We reserve the right to change or replace this Privacy Policy at any time. Please check back from time to time to ensure that you are aware of any changes or updates to the notice. We will indicate the Privacy Policy’s effective date at the top of this page. Your continued use of the Services after changes have been posted indicates your consent to and amended terms of the Privacy Policy.

If we make material changes that would impact your use of the Services, we will endeavor to notify you of the changes, such as by posting a notice directly on the Services, by sending an email notification (if you have provided your email address to us), or by any other reasonable method.
 

Contacting Us

If you have any questions or comments about this Privacy Policy, please contact us at privacy@appliedcognition.com
 

Definitions

  • “HIPAA” is the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations.

  • “Personal Information” is information that can be used to identify, contact or locate you. Examples of Personal Information such as your name, address, email address, telephone number, unique device identifier of the device you use to access the Services and other information you choose to provide as well as Protected Health Information under HIPAA.

  • “Protected Health Information” is a subset of Personal Information that is protected by HIPAA. Your Personal Information is generally Protected Health Information if you are a health plan member or a patient of an Organization that is a “covered entity” under HIPAA and we are a “business associate” of the Organization under the Organization Agreement.