At TruNeura, accessible from TruNeura.com and other TruNeura websites and via our app, available in the Apple App and Android Play Stores, one of our main priorities is the privacy of our customers.

This Privacy Policy document contains the information collected and recorded by TruNeura and how we use it. We prefer to keep it simple, but in certain instances, we can’t.

Here’s a summary
• We do not, and a Customer should not consider, the information provided within TruNeura as medical advice. A Customer must consult a medical practitioner to address any questions the Customer may have before acting upon any information offered by the application. The use of TruNeura is a decision solely taken by the Customer at their own risk.
• If you want to understand more or edit or delete your personal data, you can contact us here.
• If a Customer has additional questions or requires more information about our Privacy Policy, they may contact our Data Protection Officer, whose details can be found at the end of this Policy.
• For customers who want to know in more detail the policies TruNeura has put in place to protect your personal information, a link can be found at the end of this privacy policy to TruNeura’s data protection policy.

‍TLDR (too long; didn’t read)
Customer privacy is critically important to us. At TruNeura, we have a few fundamental principles:
• Customer accounts are completely private by default.
• A customer can add as much or as little data as they want.
• Customers can delete their accounts and data at any time.
• We are very protective of our users’ data and privacy.
• It is easy to share a Customer Profile with Customer friends and coaches, but Customers don’t have to; the customer can disable data sharing at any time.
• Information a client posts or syncs may be seen by others depending on client settings.
• We do not sell client data, and only make money from people paying us directly.
• We do automatic tracking and syncing in the background as much as possible to minimize effort in keeping client data up to date.
• Aggregate information may be used for research, quality assurance, and improving the TruNeura service—for example, using population data to improve features or improve diagnostics.
• Connecting a third party service gives us access to that data, but does not send client TruNeura info to them. It is a one way connection. For example, if a client connects to Garmin or Apple Health, that gives us access to sync data from that source, but does not, unless a client specifically allows it, share data back with them.
• If a client does choose to share client data with someone on the TruNeura platform, we cannot be held liable for what they do with that data.‍

Privacy Policy Summary All the information on this website – www.TruNeura.com – is published in good faith and for general information purposes only. TruNeura.com does not make any guarantees about the completeness, reliability and accuracy of this information. Any action a client takes upon the information a client finds on this website (TruNeura.com), is strictly at client’s own risk. TruNeura.com will not be liable for any losses and/or damages in connection with the use of our website. From our website, a client can visit other websites by following hyperlinks to such external sites. While we strive to provide only quality links to useful and ethical websites, we have no control over the content and nature of these sites. These links to other websites do not imply a recommendation for any or all the content found on these sites and a client uses any external sites at client’s own risk. We also do not own any intellectual property on third party sites which are owned by third parties and we do not provide a client any rights to any third party intellectual property by linking to a third party site. Site owners and content may change without notice and may occur before we have the opportunity to remove a link which may have gone ‘bad’. Please be also aware that when a client leaves our website, other sites may have different privacy policies and terms which are beyond our control. Please be sure to check the Privacy Policies of these sites as well as their “Terms of Service” before engaging in any business or uploading any information.‍

Consent By using our website, web app and mobile app, a client hereby consents to our disclaimer and agrees to its terms.

Update Should we update, amend or make any changes to this document, those changes will be prominently posted here.‍

Personal information The privacy of client Personal Information is important to TruNeura. To better inform a client about client privacy, this policy describes what Personal Information we may collect about a client; how we use client Personal Information; how we protect it; and what choices a client has on how that Personal Information is used. We are committed abiding by the terms of the Personal Data Protection Act 2012 (PDPA), which comprises various rules governing the collection, use, disclosure and care of personal data. The PDPA was constructed based on references from the data protection regimes of key jurisdictions that have established comprehensive data protection laws, including the EU, UK, Canada, Hong Kong, Australia and New Zealand, as well as the OECD Guidelines on the Protection of Privacy and Transborder Flow of Personal Data, and the APEC Privacy Framework. These references are helpful for the formulation of a regime for Singapore that is relevant to the needs of individuals and organisations, and takes into account international best practices on data protection. This Privacy Policy applies to our website www.TruNeura.com (Website) mobile phone applications, namely “TruNeura” and any associated white-labeled applications. “Personal Information” is any non-public information about a person, whether true or not, from which that person may be identified by a third party. We at TruNeura respect client privacy and want a client to feel comfortable and protected when a client uses the services that our app and website offer. We may, from time to time, review and update this Privacy Policy to take into account new laws, regulations (such as the EU’s GDPR) and technology. All Personal Information that we collect, use, hold and disclose will be governed by the most recent Privacy Policy that has been posted on our website www.TruNeura.com.‍

What information we collect We need to gather information about a client so that we can effectively deliver the analytics and personalization services that our platform offers. We only collect information relevant to client platform experience. This may include but not be limited to client name, email address and phone number. A client may also provide personal information such as age, body measurements, activity metrics, personal health conditions and opinion surveys which offer a client a more personalized and valuable service and also allows us to tailor our program more specifically to a client and client objectives. This information will always be obtained with client permission. Client’s may find out in more detail the overall types of Personal Information for which TruNeura may collect as set out within TruNeura’s Data Protection Policy which is linked to the end of this Privacy Policy.

Collecting third party information Once a client is a registered user, they have the ability to provide information about a third party – information being name and email address. The sole purpose of collecting this information is to contact that person and invite them to join the TruNeura community and potentially share information with them. Each third party has the ability to request their information be removed from our records.

‍‍How we use client information TruNeura only uses client information for the purpose intended which is to facilitate client participation in an engaging and enjoyable platform experience. Client information is used for but not limited to registration, communication (such as confirmation and information emails), creating and administering client user accounts and potentially earning rewards for doing so. TruNeura may share user information with approved partners to enable the use of selected features and enhance client user experience. These selected features will be pre-approved by a client before any information is exchanged. Anonymised and aggregated data may be used for analytical purposes, but any data in a sample size below 20 participants or responses will not be shared. Individual performance statistics may be shared with another platform user designated by a client such as a coach or medical practitioner. TruNeura WILL NOT sell, reuse, rent, loan, give away or disclose client personal information to a third party without client consent unless required by law. Clients may find out in more detail the list of overall purposes for which TruNeura may collect, use or disclose their Personal Information within TruNeura’s Data Protection Policy which is linked to the end of this Privacy Policy.‍

How we protect client information Client information is crucially important to us so we ensure that we uphold security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal transfer or similar risks to client information. We use secure socket layer technology (SSL), password protection, firewalls, encryption and permission levels to protect client information. There is always an element of risk with submission or transmission of electronic information however we use our best endeavors to ensure client information is protected and secure. Should a client wish for their information to be updated, added to or removed a client can alter settings within the client user account or contact us via email, support@TruNeura.com. Clients may choose to stop receiving our promotional emails by following the unsubscribe instructions included within these emails, accessing the email preferences in client account settings page or a client can contact TruNeura’s Data Protection Officer who’s details are to be found at the end of this Policy.‍

Privacy settings Within our Services there are two sharing settings: Private, and SharedTruNeura apps are designed for client wellness and fitness benefits. As such, clients are able to control what Personal Information they share and with whom they share it. Adding coaches and other accountability partners to client profiles and sharing data will allow them to see it. Not approving coaches and friends and keeping client accounts private will keep their accounts completely private. We encourage a client to adjust the sharing settings to best meet client objectives and sharing comfort level.

‍Third party providers We may contract other companies and individuals to help us provide services. In order to perform their responsibilities to us, these other companies may have limited access to some of client Personal Information. As part of our contract with these companies, they will agree not to use the information they access for purposes other than fulfilling their responsibilities to us.‍

We use cookies Some of the TruNeura pages use cookies which are small files that may be placed on a client hard disk for record-keeping purposes. A cookie is a small amount of data that is sent to the client browser from a web server and stored on the client computer’s hard drive that helps us remember who a client is and make subsequent visits to the web page simpler. By using our website and agreeing to this policy, a client consent to our use of cookies. A client can remove cookies by following the directions provided in the client Internet browser’s “help” directory. If a client rejects cookies, a client may still use our site, but client ability to use some areas or functionalities may be limited.‍

Testimonials and Public forums Some TruNeura modules utilize community forums. Information posted on these forums can be viewed, collected and utilized by other platform members. A client can at any time contact us to remove client information from these forums. Should we not be able to remove the information a client requested, we will advise a client of the situation and why. We may display consented testimonials from satisfied participants of the TruNeura program on our website. Should a client wish a testimonial a client has provided to be removed, please contact TruNeura’s Data Protection Officer whose details are to be found at the end of this Policy.‍

Links to other websites This website contains links to other websites and the use of social media features. Client interactions with these external websites and social media features are governed by the privacy policy of the providing companies. TruNeura is not responsible for the privacy policies or practices of any third party.‍

Transferring data The TruNeura Head Office is based in the United States. Data may be transmitted to data storage facilities where we keep our central records. Client information may be transferred to data storage and processing facilities, other TruNeura offices or other service providers for TruNeura to provide our service for a client. We reserve the right, without providing notice or seeking additional consent from a client, to transfer or assign the personal information and rights that we have collected from a client and any agreements we have made with a client to a third-party in the event that we merge, sell or otherwise change control of our business or this website. To ensure that your Personal Information is accorded with the rightful level of legal protection, TruNeura will ensure Data Processing Agreements are entered into with each of these third parties.‍

Changes to our Privacy Policy We may periodically update this policy and encourage a client to review this at client want and leisure. The most updated policy will be listed on our website, www.TruNeura.com‍

Personal Data Protection Act 2012 For more detailed information about the PDPA, refer to www.pdpc.gov.sg

EU GDPR policy – for more detailed information about GDPR, refer to https://gdpr-info.eu/ GDPR disclosures on how we collect and use personal data. We collect client Personal Data in a number of ways and for various purposes, including:
• When a client registers for an account or interacts with our Services.
• When a client inputs Fitness and Wellness Data within our Services or uses our Services that collect or infer such data from mobile device sensors.
• When a client uses or interacts with a wearable or other connected device.When a client gives us permission to sync Apple Health data in the iPhone app.
• When a client gives us permission to sync Samsung or Google Fit data in the Android app.
• When a client gives us permission to collect Location Data in the mobile apps.
• When a client connects an integration to sync data to a client account.
• When a client communicates with us or signs up for promotional materials.
• When a client engages with our online communities or advertising.
• When a client accesses third party products and services.
• When a client connects with us through social media.
• When we collect data from third parties or publicly available sources.
• When we leverage and/or collect cookies, device IDs, location, data from the environment, and other tracking technologies.
• When we aggregate or centralize data.When we link a client to friends across platforms.
• When a client takes fitness tests or assessments, shares content or achievements, or invites friends.
• When we provide a client geographically relevant Services, offers, or advertising.
• When a client asks us to customize products or Services.When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes (Country/Region-Specific Disclosures may apply).

European Union rights‍If a client is habitually located in the European Union, a client has the right to access, rectify, download or erase client information, as well as the right to restrict and object to certain processing of client information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

How their personal data is being processed A client has a right at any time to request details from TruNeura on how, why and on what basis their Personal Data is being processed.

Confirmation of processing/access rights A client has the right to obtain confirmation that their data is being processed and to obtain access to it and certain other information, by making a subject access request (“SAR”).

Correction of personal data A client has the right to request TruNeura to correct any Personal Data it holds about the client if it is inaccurate or incomplete.

Rectify, restrict, limit, delete A client can also rectify, restrict, limit or delete much of client information by logging into the client account and deleting particular integrations, data points, or the entire account. A client can also contact TruNeura’s Data Protection Officer to carry out any of these matters as well.

Object Where we process client information based on our legitimate interests explained above, or in the public interest, a client can object to this processing in certain circumstances. In such cases, we will cease processing client information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Revoke consent Where a client has previously provided client consent, such as to permit us to process health-related data about a client, a client has the right to withdraw client consent to the processing of client information at any time. For example, a client can withdraw client consent by updating client settings or disconnecting an integration. In certain cases, we may continue to process client information after a client has withdrawn consent if we have a legal basis to do so or if client withdrawal of consent was limited to certain processing activities. In the event that such health-related data is disclosed to third party Affiliates of TruNeura, TruNeura shall inform such Affiliates of the Processing restriction unless to do so is impossible or would require disproportionate effort.

ComplaintsShould a client wish to raise a concern about our use of client information (and without prejudice to any other rights a client may have), a client has the right to do so with client local supervisory authority.

Children under the age of 18 The TruNeura Platform and Services are intended for adults. Users under the age of 18 are not permitted to use the Services. The Platform is not directed to, and we do not knowingly collect or solicit Personal Information from, children under the age of 18. If we learn we have collected or received Personal Information from a child under the age of 18, we will delete that information. If a client believes we might have any information from or about a child under the age of 18, please contact us using the contact information below.‍

Contact Us All enquiries related to our above Privacy Policy may be sent to TruNeura’s Data Protection Officer: Ivan Vatchkov at support@TruNeura.com for further detailed information of how TruNeura manages and protects the processing of your personal data, you may view TruNeura’s Data Protection Policy in full here.

Privacy Policy last updated on 7/5/2024