Privacy Policy

Before reading our Privacy Policy there are a few things that we think are especially important for our users to understand about how we manage their data.

1. Pauser does not and will never sell any personal data. We made this app primarily to help people like us and this would not be in line with our values.

Pauser does not track or share any personal data with third party companies unless you specifically choose to enable that option (e.g. with Google Fit or Apple Health).
To protect your privacy, any health data that you choose to track for your own purposes is encrypted before it is backed up on our servers.
Pauser tracks as little personally identifiable data as possible to protect its users. We ask for information like Name, Age, Sex, Weight and Gender so as to offer personalized recommendations on improving mental health.

We recognize the sensitive nature of the health and personal data and strongly believe in the importance of data security, privacy, and anonymity.  We take your privacy seriously and we hope that you find our privacy policy clear and transparent. 

INTRODUCTION

This privacy statement explains how we, Pauser, Inc. (“Pauser”, “us”, “we” or “our”) use your personal data to provide you with the Pauser mobile application (The “Pauser App”) and website (www.Pauser.health). We are committed to protecting and respecting your privacy. Please read this Privacy Statement carefully to understand what personal data we collect from you and how we will use it. For any questions regarding this Privacy Statement, please reach out to our support team (support@pauser.health).

This Privacy Statement describes details around how we collect, store, use and distribute information through our software, website, documentation, and related services (together, the “Services”). This document should be read in conjunction with our Terms & Conditions. We strongly encourage you to review this Privacy Statement and Terms & Conditions carefully and ensure that they contain nothing that you are not prepared to agree to, before you decide to accept the Terms & Conditions and use our Pauser App or our website (www.pauser.health).

Consent

By using the Services, you consent to the use of your Personal Information as described in this Privacy Policy. You may remove/delete your account anytime which will also delete all your personal data from Pauser servers permanently.

Intended Users

The Services are designed and directed for users above the age of 18 years, and we do not knowingly gather Personal Information from visitors who are under 18. If we become aware that we have gathered Personal Information from a person under 18, then we will attempt to delete such information as soon as possible. If you believe that we have gathered Personal Information from a person under 18, please contact us at support@pauser.health

Collection of Information

Personal Information. By their nature, the Services track certain data that may be used to identify you individually. Currently, such information consists of your (i) Biometric Information, (ii) SNS Information, and (iii) mobile device data such as your phone’s unique device id number. When registering to use the Services and creating an account (“Pauser Account”), we may also ask you to provide certain information about yourself, such as your name, age, weight, sex, email address, phone number, social media username, and username and password (“Personal Contact Information”). Your Personal Contact Information, together with any other information we gather through the Services that may be used to identify, contact, or locate you individually, is collectively referred to herein as your “Personal Information.”

Data, Diagnostic & Login Information. You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages, or other materials using our Services (this is collectively referred to below as “Data”). Some of this Data may be stored and maintained on our servers. If you run into technical errors while using the Services, we may request your permission to obtain a crash report along with certain logging information from your system documenting the error (“Diagnostic Information”). Such information may contain information regarding your Operating System version, hardware, browser version, and your email address, if provided. Additionally, certain login information may be maintained in a cookie stored locally on your personal computing device (i.e., not on a server) to streamline the login process (“Login Information”).

Biometric Information. Certain features of the Services may actively record biometric information about yourself (such as Heart rate, HRV, Steps, Sleep score, Oxygen) as you use the Services. This tracking is accomplished through integration with your mobile device’s health tracking technology, such as Apple’s HealthKit API or Google Fit or Pauser companion app on your active-wearable devices. Such information is referred to as “Biometric Information.”

Information You Provide to Social Networking Sites. You can link your Pauser Account to your accounts on Social Networking Sites (“SNS”) such as Facebook when using the Services (this is in reference to future functionalities and not possible in current version). By linking your Pauser Account with your account on Facebook or another SNS, you are allowing us to access your information on that SNS. The information that we collect from your SNS account may depend on the privacy settings you have with that SNS. Therefore, you may be able to control the information that we collect from your SNS account by adjusting your privacy settings on that SNS. You can also de-link your SNS account from the Services at any time via your Pauser Account settings. The information we collect from your SNS account(s) is referred to as “SNS Information.”

Usage and Analytics Information. As you use our Services, we may also collect information with commonly used information-gathering tools, such as cookies, log files, and Web beacons. Such Information may include information regarding your mobile device (such as your device model and unique device id number), browser type, browser language, Operating System, Internet Protocol (“IP”) address, and the actions you take on our web site (such as the web pages viewed, and the links clicked) or while using the Services. Collectively, this information is referred to as “Usage and Analytics Information.”

Geo-Location Information. We collect information regarding your real-time geo-location while using the Services to provide activities and environment (weather, pollen-count and traffic) related information at or before the time of your stressful moments.

Use of Information

Information Collected	Use
Personal Information & SNS Information	We use your Personal Information and SNS Information to manage your account, to provide the Services, personalized your service experience, provide recommendation for better mental health, to maintain our customer/visitor lists, to respond to your inquiries or request feedback, for identification and authentication purposes, to send you administrative notifications (such as security, support or maintenance advisories), for service improvement, and to address issues like malicious use of the Services. We may also use your Personal Information (excluding Biometric information) to notify you about new features in the Services, and to send you general information about us and/or our partners. We will use location information to provide real-time location, temperature, pollen count and traffic density at the time of stressful moment so you can find out if any of these are a possible factor/cause of the stress. You can analyze the trend over time and configure Pauser to automatically prompt when a similar condition repeats so you can take a pause at the right time and prevent the stressful moment. We do not sell or share any Personal Information collected as part of the service usage.
Data, Diagnostic Information and Login Information	We use this information for the purpose of administering and improving our Services to you.
Biometric Information	We use this information to help you asses anomaly in heart rates and other biomarkers and compare it with life activities and events to find out the root-cause of mental stress and get a reminder to ‘take-a-pause’ if a similar situation occurs again. We also use this information to provide timely reminders for a rejuvenating short pause. We may also use your Biometric Information in a de-identified, aggregated, and anonymous way to monitor and analyze use of the Services, to increase the Services’ functionality and user-friendliness, and for the purpose of medical research. We do not disclose, sell or share to third parties user data gathered from the HealthKit APIs or from health-related human subject research for advertising or other use-based data mining purposes other than improving health, or for the purpose of health research. We do not use or disclose to third parties your Biometric Information for the purpose of advertising or marketing in any way. We do not share user data acquired via the HealthKit or CareKit APIs with third parties.
Usage and Analytics Information	We use this information to administer and improve our Services to you. We may also use your Usage and Analytics Information in a de-identified, anonymous way in conjunction with a commercially available analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality and user-friendliness, and to verify users have the authorization needed for the Services to process their requests.

If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled “Amendment of this Privacy Policy”.

Disclosures & Transfers

We have put in place contractual and other organizational safeguards with our agents to ensure a proper level of protection of your Personal Information (see further “Security” below). In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy.

Our service providers

From time to time we may need to employ third parties to help us provide the Services. These third parties may have limited access to databases of user information or registered member information solely for the purpose of helping us to provide the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose. Such agents or third parties do not have any rights to use Personal Information beyond what is necessary to assist us in providing the Services.

Law and Order

We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of us or our users; or (d) protect our property rights.

Successors and Assignees

We may disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Non-US Users

These Services are hosted in the United States and are intended primarily for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your Personal Information outside of those regions to the United States for storage and processing. By providing your Personal Information through the Services, you consent to such transfer, storage, and processing.

Security

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

We maintain safeguards that are reasonably designed to protect the information collected through the Services. Please note, however, that we cannot and do not guarantee the security of your information, as no method of data storage or transmission is 100% secure.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your username, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.

For any security-related issues, please email us at security@pauser.health

Sharing Information with Third Parties

You may be able to share Personal Information with third parties through use of the Services. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

The Services allow you to post content to SNS’s (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNS’s in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNS’s. We will not be responsible or liable for: (i) the availability or accuracy of such SNS’s; (ii) the content, products or services on or availability of such SNS’s; or (iii) your use of any such SNS’s.

We will share some of your personal data with third parties outside Pauser only where it is strictly necessary to provide our services to you, where required by law, where we have another legitimate interest to do so or where you specifically consent to it.  Personal data may be shared in the following circumstances:

Third Party Support Service Providers: For example: technology service providers, payment providers, data storage providers, and marketing platforms (e.g. for sending marketing emails),
Third Party Apps: some of your personal data may be shared with other Apps but only if you agree to that.  Please see the section below for further information.
When required to do so by law, regulation or court order
in response to a legitimate request for assistance by the police or other law enforcement agency.

Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.

Amendment of this Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 30 days from their posting on http://pauser.health/privacy or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.

Access and Accuracy

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete, or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: support@pauser.health

HIPAA

We are dedicated to maintaining the privacy and integrity of protected health information that we receive as part of your usage of Pauser application (“PHI”). PHI is Personal Information that we receive that relates to (a) your past, present or future physical or mental health or condition, (b) the provision of healthcare to you, or (c) your past, present or future payment for the provision of healthcare, which is created, received, transmitted or maintained by Company. This Privacy Policy describes how we protect your privacy as a visitor to or general user of our Site, our Mobile App and Services. You have additional rights under federal and state law with respect to the access to, use, and disclosure of Personal Information that constitutes PHI. For a more complete description of your rights with respect to PHI, please refer to our HIPAA Notice, which provides important information to you about how we may use and disclose your PHI. Our HIPAA Notice is available here: https://pauser.health/hipaa

You can help by keeping us informed of any changes such as a change of your Personal Contact Information. If you would like to delete your account, please check the appropriate option within the main menu system of Pauser application or contact us at support@pauser.health. If you would like to access your information, if you have any questions, comments, or suggestions of if you find any errors in our information about you, please contact us at support@pauser.health. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.

How We Protect Your Information

International Transfers

We operate internationally and your personal information may be transferred outside the jurisdiction you are located. The data protection laws in other jurisdictions may differ from the jurisdiction where you are located and may not provide the same level of protection compared to the laws in the jurisdiction in which you are located.

When we transfer personal information subject to the data protection laws of the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland outside of the EEA, UK, or Switzerland, we will rely on a legal framework that provides appropriate safeguards, which could include the standard contractual clauses, binding corporate rules, or another framework deemed adequate by the European Commission.

Additional Information for Individuals Located in the EEA, UK, and Switzerland

If you are in the EEA, UK, or Switzerland, you may have additional rights to withdraw consent, request access to, correction of, erasure of, or the transfer of your personal information, or object to or restrict the processing of your personal information. You may exercise these rights, if applicable, by contacting us as described in the “Contacting Us” section of this Policy. Individuals located in the EEA, UK, or Switzerland may also have the right to lodge a complaint with an EEA, UK, or Swiss supervisory authority, as applicable.

Additional Information for Residents of California

This section applies only to residents of the State of California and generally describes how we collect, use, and disclose the personal information of California residents and their households (“California Personal Information”). However, California Personal Information does not include, and this section does not apply to:

Personal information reflecting a communication or a transaction between us and a California resident acting as a representative of an organization that relates to the organization obtaining products or services from us.
Personal information, emergency contact information, and benefits administration information we collected about a California resident in the course of that California resident acting as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor to the extent we use that information within the context of that California resident’s role as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor.
Other personal information excluded or excepted from requirements of the California Consumer Privacy Act of 2018 (“CCPA”).

Additionally, this section applies only to the extent we direct the purposes and means of California Personal Information processing and otherwise qualify as a business subject to the CCPA.

California Personal Information We Collect

We may collect, and may have collected in the preceding 12 months, the following categories of California Personal Information, as described in more detail above in “The Information We Collect” section:

Identifiers, including online identifiers.
Commercial information.

Internet and other electronic activity information.
Inferences drawn from your activity.
Geolocation data.
Biometric information.
Other categories of personal information described in California law.

Sources of California Personal Information We Collect

We collect California Personal Information from the sources described in the “Information We Collect About You” section of this Policy.

Purposes for Which We Use California Personal information

We may collect and use the categories of California Personal Information described in the “California Personal Information We Collect” section above for one or more of the business and commercial purposes described in the “Uses and Purposes for Processing Your Information” section above.

Disclosures of California Personal Information for a Business Purpose

In the preceding 12 months, we may have disclosed the categories of California Personal Information listed below to the categories of third parties identified below for a business purpose:

Identifiers, including online identifiers—with our service providers.
Commercial information—with our service providers.
Internet and other electronic activity information—with our service providers.
Inferences drawn from your activity—with our service providers.

Geolocation data—with our service providers.
Biometric information—to such third parties as you may authorize.
Other categories of personal information described in California law—with our service providers.

Sales of California Personal Information

In the preceding 12 months, we have not sold California Personal Information. We do not sell California Personal Information, and we do not have actual knowledge that we sell California Personal Information of consumers under 16 years of age.

California Personal Information Rights and Choices

The CCPA provides California residents with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise those rights to the extent we direct the purposes and means of the processing of your California Personal Information processing and otherwise qualify as a “business” under the CCPA.

Access to Specific Information and Data Portability Rights.

California residents have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will disclose to you, depending on the scope of the request:

The categories of California Personal Information we collected about you.

The categories of sources for the California Personal Information we collected about you.
Our business or commercial purpose for collecting California Personal Information about you.
The categories of third parties with which we share your California Personal Information.
The specific pieces of California Personal Information we collected about you.
If we disclosed your California Personal Information for a business purpose, a list of the categories of third parties to whom we disclosed California Personal Information for a business purpose identifying the categories of California Personal Information disclosed to those parties in the preceding 12 months.

Deletion Request Rights.

California residents have the right to request that we delete California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will delete your California Personal Information from our records, unless an exception applies.

Exercising Access, Data Portability, and Deletion Rights.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at support@pauser.health or by visiting Privacy policy section on our website.

You may designate an authorized agent to submit requests on your behalf through a signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when submitted through an authorized agent, such as requiring you to verify your identity directly with us or to directly confirm the authorized agent’s permission to act on your behalf.

You may only make a verifiable consumer request for access or data portability once within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent of that person. In order to verify your request, we may require you to provide additional information, including account profile information such as your Services email address and other information elements necessary to verify your identity. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.

Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination.

Subject to certain exceptions, you have the rights to not receive discriminatory treatment for exercising your access, data portability, opt-out, and deletion rights described above.

Notice of Financial Incentive.

From time to time we may offer opportunities to participate in programs designed to incentivize your use of the Services, such as allowing you to enter into a gift giveaway if you take a specified number of measurements using the App within a designated time period. Under California law, these programs may be considered a financial incentive provided in exchange for the collection of personal information. We will provide you additional information regarding specific programs when we offer them.

Changes to this Policy

We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the Effective Date of the Policy, above. We encourage you to periodically review this Policy for the latest information on our privacy practices.

Contact Us

If you have any questions or comments about this Policy or our privacy practices, or you would like to ask for access to or amendment of deletion of your personal information, please contact us at: support@pauser.health

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