Privacy Policy

Last updated: February 15, 2022

Welcome to Linus Health (“our,” “us,” “we,” and “Linus Health”). Linus Health produces the Linus platform, an integrated, mobile-based brain health monitoring solution accessible from smartphones, tablets and user dashboards. Linus seeks to collect health and lifestyle data from individual users and apply advanced algorithms to analyze and package that data, with the goal of providing meaningful insights into brain health. At Linus Health, we are committed to respecting your privacy and safeguarding your information. This Privacy Policy describes what kind of information we collect and how we process, store, use and—if you have given your consent—share it. If you have any questions after reading this Policy, or if you would like to give feedback, please write to us at: privacy@linus.health. This Privacy Policy should be read alongside the Linus Health Terms of Use (“Terms”). Unless otherwise indicated, defined terms in the Privacy Policy have the same meaning as in the Terms. In addition, if you consented to participate in a Research study, the Research Consent form you signed may contain additional information about the use of your personal information. By submitting personal information to us through our platform or otherwise, you give us permission to receive, review, edit, store and use it for the purposes described in this Privacy Policy. You may withdraw your consent at any time. However, your personal information will no longer be processed for assessing your health if you withdraw your consent. What information we collect from you depends on the nature of your relationship or interaction with us or with any of our products, services, websites and marketing events and communications. The information we collect may include Personal Information, Personal Health Information, and Other Information, as detailed below.

  1. Personal Information. For the purposes of this Privacy Policy, “Personal Information” is defined as information that can be associated with a specific person and used to identify that person. Examples of personal information are your name, mobile number, e-mail address, and application password. You can choose not to provide your information, though you then would not be able to utilize the Linus Platform. Personal Information does not include information that has been anonymized so that it does not identify a specific user, or information that is in aggregate form.  Personal Information is processed in order to provide the Linus Platform to you. The lawful basis for processing is your consent.

  2. Personal Health Information. For the purposes of this Privacy Policy, “Personal Health Information” is information collected from and generated by the various modules within the app. Personal Health Information is processed in order to assist authorized parties in researching and treating diseases of the brain. The lawful basis for processing is your consent.

  3. Other Information. For the purposes of this Privacy Policy, “Other Information” is any information that does not independently reveal your specific identity or does not directly relate to an identifiable individual. Examples include device information, time and date of requests, and login activity. Gathering this information helps us to ensure that our applications work correctly and support our visitor and user analysis. The lawful basis for processing is our legitimate interest to improve the functioning of the Linus Platform.

HOW WE SHARE DATA

Personal Health Information is shared with the responsible healthcare providers and/or researchers. Please refer to their terms of service, our Terms of Use and any consent forms for further information on how this data is shared and used. In addition, data may be disclosed or transferred in connection with a lawful request by a government or regulator.  Data may also be transferred in the event of a sale or merger. Linus does not sell your data or otherwise use your data for marketing purposes.  Linus contracts with certain third parties to deliver the Linus Platform. These third parties are summarized below.

Third Party Services Location

  • Amazon Web Services - Database hosting
    410 Terry Avenue North, Seattle, WA 98109

  • Aural Analytics - Transcription analysis
    1475 N. Scottsdale Rd., Scottsdale, AZ 85257

HOW WE PROTECT YOUR INFORMATION

At Linus Health, we understand the importance of keeping Personal Information secure. We have implemented and maintain technical, administrative and physical security measures designed to protect your information from unauthorized access, disclosure, misuse, alteration, accidental loss or destruction. These security procedures and measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology but include firewalls, data encryption, physical access controls and information access authorization controls. Linus Health has adopted an incident response plan with a company protocol we follow in the event of any data breach. We take steps to regularly monitor our systems for vulnerabilities and to ensure that we only share information with those who need to know it.However, no website or internet transmission is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur, and we cannot warrant the security of any information that you provide to us. You are responsible for securing and maintaining the privacy of any password(s) and account registration information used with Linus Health, and verifying that the information we maintain about you is accurate and current. We are not responsible for protecting any information that we share with a third party based on an account connection that you have authorized.  We require that our third-party service providers and partners agree to keep the information we share with them confidential and to use the information only to perform their obligations in the agreements we have in place with them. Linus Health has implemented internal policies to ensure that such parties are required under contract to maintain privacy and security protections which are at least as consistent with our own policies and practices.

YOUR PRIVACY RIGHTS

We provide you with the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. Please be aware that, if you do not allow us to collect your information from you, we will be unable to assist in analyzing your health.  We will securely maintain your Personal Information or Personal Health Information in an encrypted format per this policy until you or your care provider or research institution request deletion of your personal information from our database per any written agreements we have with them or per applicable governing laws.

Your choices.  In accordance with applicable law, you may be entitled to exercise your rights and choices as follows:

  1. Account settings. You may update your profile, your account and any related information at any time to ensure that information is up to date.

  2. Devices. Some of our mobile services may use your device’s location information. You can adjust the setting of your mobile device at any time to control whether your device communicates this location information.

While we strive to allow you to exercise your rights with respect to your data, please note that in some cases you may need to correspond directly with your care provider or a research institution in order to fully exercise your privacy rights.

European Union or UK.  Under applicable data  protection law, you have certain rights with respect to your personal data. These rights also govern any transfer of your data that is being transferred outside of the EU, Switzerland or UK to the United States. Linus will comply with all applicable GDPR laws as defined in paragraph 14 (subparagraph 4) of our terms of use (www.linus.health/termsofuse) which are incorporated into this privacy policy which govern the existence of your rights and the transfer of your data (if applicable).

California, USA.  Under California Civil Code Section 1798.83, California residents are entitled to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. You may exercise your rights above by contacting us at our contact email address and we will review your request in accordance with applicable laws.

Privacy Relating to Minors As a company focused on serving the needs of businesses, Linus Health does not promote or market the Linus Health services to minors and we do not knowingly collect information from minors as defined by applicable law. If we discover we have received any Personal Information from a person under the age of 13 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 13, please contact us.

UPDATES TO THIS PRIVACY STATEMENT

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or to reflect any changes in how we process information. Currently, Linus Health has an automated decision making system that profiles individuals in our database who take our assessments to determine potential brain health risks, predicted outcomes, and make recommendations on ways you can improve your brain health. Any changes to this Privacy Policy will be effective when we post the revised Privacy Policy on this website. The “Last Updated” section at the top of this Privacy Policy states when this Privacy Policy was last revised and serves as notice of the update. Your use of the Linus Health Site or Content provided following these changes means you accept the revised Privacy Policy.

 

CONTACT US

If you believe your Personal Information has been used in a way that is not consistent with this Privacy Policy or your specified preferences, or if you have further questions related to this Privacy Policy, we encourage you to please contact our Privacy Team at the address below or by emailing privacy@linus.health.

 

COMPLAINT

You are entitled to lodge a complaint with any applicable regulatory authority in your jurisdiction if you feel that your Personal information is being used in a way that is not consistent with this Privacy Policy, your specified preferences or the applicable law(s) governing your jurisdiction.  

Written inquiries may be addressed to Linus Health at:

James Kuan - Data Privacy Officer

Linus Health

280 Summer Street, 10th Floor

Boston, MA 02210 

United States