TruNeura Privacy Policy
Last Updated: May 9, 2025
TruNeura, LLC (“Company,”“TruNeura,” “we,” “us,” or “our”) values your privacy. This PrivacyPolicy (the “Policy”) explains howwe handle your personal information on www.truneura.com ("Website"), on our mobile app("Mobile App"), and ondesktop application ("Desktop App,"together with the Website and Mobile App, the “Platform”) and related services (collectively, the “Services”).
[Your medical information, or "Protected Health Information" (PHI), is governed by our HIPAA Notice of Privacy Practices [1] ] (the “HIPAA Notice”). That notice outlines how we a use and share your PHI and your rights. In his Policy conflicts with HIPAA Notice, the HIPAA Notice shall prevail.] Would we use an existing notice that the Clinic refers to or does Kalibra have one we can use?
1. INFORMATION WE COLLECT 1
When you use the Platform, we may collect the following types of information:
Information You Provide
You may give us information directly when you register, use the Platform, enroll or purchase any Service, or contact us. This may include:
• Contact details: name, email, phone number, address
• Login credentials: username and password
• Payment details: credit card number, expiration date, security code
• For health care providers: job title, specialty, license info, date of birth, gender, languages, education, photo, SSN, Tax ID, NPI, bank info
• Personal health information
• Any other information you share
We may combine this with data we already have about you.
Information We Collect Automatically
We may automatically collect technical and usage data, including:
• IP address, browser type, device ID, operating system
• Pages visited, links clicked, and timestamps
• Location data (e.g., IP-based or GPS-based)
• Cookies, pixel tags, and similar technologies
• Diagnostic data if a system or app crash occurs, which may include memory state or part of a document you were using
By using our Platform, you consent to this data collection.
Information from Health Care Providers and Other Sources
We may obtain health records from your current, past, or future health care providers. This may include:
• Diagnoses, treatments, and general health info
• Lab results, test reports, and provider notes
• Family medical history and communication records (calls, emails, etc.)
2. HOW WE USE YOUR INFORMATION
We typically use the information we collect to:
• Provide, operate, and improve our Platform
• Communicate with you
• Provide you with Services or fulfil your requests for information
• Send you wellness or clinical service updates from us or trusted partners
• Analyze user behavior to enhance our Platform
• Personalize your experience on the Platform
• Conduct research (with your written consent, if required)
• Detect and prevent fraud or illegal activities, in line with our Terms of Use
• For any other purpose disclosed at the time of collection or with your consent
3. SHARING YOUR INFORMATION
We value your trust and want you to know when and with whom we may share your information:
Healthcare and Related Entities
We may share your information with healthcare providers, labs, insurance companies, and other entities involved in your care.
Authorized Vendors and Service Providers
We work with trusted third parties to deliver services like billing, payments, support, analytics, marketing, hosting, chat, and security. These partners may collect and monitor information (e.g., device data, site interactions, chat logs) but only use it to support our services.
Research Partners
We may share information for health-related research, which may require your separate written authorization.
Corporate Affiliates
We may share data with our corporate affiliates who follow this same privacy policy.
Business Transfers
If we are involved in a merger, sale, reorganization, or bankruptcy, your data may be part of the transferred assets.
Legal Requirements
We may disclose information to comply with legal requests or to protect the rights, safety, and interests of TruNeura, our users, and the public. We will try to notify you if legally permitted.
With Your Consent
We may share your information for any other reason disclosed at the time of collection or with your permission.
Third-Party Platforms
If you use services like Facebook, Google, or Twitter / X Corp to log in or share activity, those platforms may collect information about your use in line with their own privacy policies.
Public Forums
If you post in public areas on our site or linked platforms, your information may be seen and used by others. Be cautious when sharing personal information. We are not responsible for what others do with content you make public.
We do not sell your personal information, and have not done so in the past 12 months. We only use and disclose your personal data as described in this Policy.
4. SECURITY
We protect the information you provide using physical, electronic, and administrative safeguards. Some service features use SSL encryption to secure data transmissions. Your account is password-protected for added privacy and security. While we work to protect your data, we cannot guarantee the security of information sent over the Internet. Information collected by third parties may not be protected by the same security measures we use, and we are not responsible for securing data you share with them.
You are also responsible for protecting your personal information. Use strong passwords, update them regularly, and use secure browsers. If you suspect unauthorized account use or a security issue, email us immediately at support@truneura.com. Some parts of the Platform allow public comments, reviews, and other content. Avoid posting anything you don’t want to be publicly visible. You are responsible for any loss of privacy or harm from sharing such information.
5. YOUR CHOICES
Marketing and Health Communications: You can opt out of receiving general wellness or treatment-related messages by emailing us at support@truneura.com.
Data Deletion Requests: To request deletion of your personal information, email support@truneura.com. We may decline your request if it violates legal requirements or makes the information inaccurate. For more on your rights, see our HIPAA Notice.
Cookies and Similar Technologies: You can manage cookies through your web browser settings. To control Local Shared Objects (e.g., Flash cookies), refer to Adobe’s Settings Manager. Disabling cookies or similar tools may affect how the Platform function.
6. THIRD-PARTY ADVERTISING, LINKS, AND CONTENT
TruNeura works with third-party vendors and service providers to help deliver our Services. These partners may collect limited information about your use of our platform, but only to support our operations. Some of our websites may include links to third-party content that we don’t control.
2[We also allow third parties—such as advertising networks and business partners—to use cookies, pixels, local storage, and other technologies to collect information about your online activity. This helps them show you ads that match your interests and preferences on our site and elsewhere online. You can opt out of interest-based ads from participating companies through the Digital Advertising Alliance or Network Advertising Initiative websites. You may also be able to turn off targeted ads using settings in your mobile device or within the app. Instructions vary by device. Opting out limits interest-based ads but doesn't stop all ads. Also, you must opt out on each browser and device you use to fully disable cross-device ad tracking.
Some browsers send “Do-Not-Track” (DNT) signals. No consistent standard for interpreting these signals exist, so we currently do not respond to them.]
We are not responsible for the privacy practices of third parties, and their data handling is not covered by this Policy.
7. CALIFORNIA RESIDENTS
Under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), California residents have specific privacy rights in addition to those outlined in this Policy. This section applies only to California residents and is intended to supplement the practices described in our main Policy.
This section outlines how we collect, use, and share your personal information and the privacy rights you may have under California laws.
YOUR RIGHTS
Right to Know/ Access
You may request disclosure of:
• Categories of personal information collected, including sensitive information
• Sources of this information
• Business purposes for collecting, selling, or sharing it
• Categories of third parties to whom it’s disclosed
• Specific personal information collected about you
We are not required to:
• Retain information collected for a single, one-time transaction if not typically retained
• Reidentify data not maintained as personal information
• Provide this information more than twice in 12 months.
Right to Know About Disclosure
You have the right to know:
• Categories of personal information we sold or shared
• Categories of third parties receiving this information
• Categories of personal information disclosed for business purposes
• Categories of recipients of this disclosed information.
You may opt-out of selling or sharing your personal information for targeted advertising. See Section 6 for additional details.
If you opt out, we will not sell or share your data unlessyou explicitly authorize us later.
Right to Limit
You may limit our use of your sensitive personal information to:
• Providing goods or services you requested or reasonably expect
• Ensuring security and integrity, as reasonably necessary
• Short-term, transient purposes (e.g., non-personalized advertising shown during your current visit)
• Essential business functions like account servicing, customer support, payment processing, analytics, data storage, or similar services
• Verifying, maintaining, or improving the quality or safety of products or services we provide
• Other purposes authorized by law.
You may also ask whether we use or disclose your sensitive information for additional purposes.
Right to Deletion
Upon receiving a verifiable request, we will:
• Delete your personal information
• Instruct service providers and contractors to delete it
• Instruct third parties with whom we’ve sold or shared it to delete it, unless doing so is impossible or requires disproportionate effort
We may retain your information if necessary to:
• Complete a transaction, honor a warranty or recall, fulfill a request, or perform a contract
• Maintain security and integrity
• Debug and fix functionality issues
• Protect free speech or comply with the law
• Comply with the California Electronic Communications Privacy Act
• Conduct public or peer-reviewed research (with consent) when deletion would impair the research
• Use it internally in a way that aligns with your expectations
• Meet legal obligations
• Use it lawfully in a way consistent with the original purpose for which it was provided
Right to Correction
If we hold inaccurate personal information about you, you may request a correction. Upon receiving a verifiable request, we will make commercially reasonable efforts to correct it.
Protection Against Retaliation
You have the right not to be discriminated against for exercising your privacy rights under the CCPA/CPRA. We will not:
• Deny you goods or services
• Charge different prices or rates
• Provide a different level or quality of goods or services
• Suggest you may receive different treatment
We may offer different prices, rates, or service levels if they are reasonably related to the value of your personal information. This includes loyalty programs, rewards, discounts, or compensation related to the collection, sale, or retention of your personal information.
b. Exercising Your Rights
You may request to access, correct, or delete your personal information by emailing us at support@truneura.com. To verify your identity and state of residence, we may request additional information or email confirmation. Any data collected for verification will be used only for that purpose and deleted promptly, unless legally required to retain it.
c. Notice at Collection
(i) Categories of Personal Information Collected (See Section 1 for additional detail)
• Identifiers, such as name, address, ISP address, email address, and other similar identifiers.
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birth date, contact information, and payment information.
• Protected Classification Characteristics, such as age and gender.
• Internet/Network Information, such as device information, logs, and analytics data.
• Geolocation Data, such as location information from your device or generated based on IP address or Wi-Fi.
• Audio, images, and other similar information.
• Professional/Employment Information, such as your employer if your Account is tied to an account sponsored by your employer.
• Sensitive Personal Information, such as account log-in and password. Sensitive Personal Information is used only for limited purposes allowed under California law, such as providing goods or services reasonably expected by the consumer, which are uses that do not require an opt-out option.
(ii) Categories of Sources of Personal Information We Collect (See Section 1 for additional detail)
• Information you provide to us
• Communications from you
• Information collected during your use of the Platform
• Information sent by your mobile or desktop devices
• Information from our clients and partners
• Social media
• Mobile or desktop applications
(iii) Purposes for which Personal Information is disclosed to third parties (See Section 2 for additional detail)
• To provide services to you
• To operate and administer our business
• For business analytics purposes
• For our own marketing purposes
• To provide you with customer support
• For account and network security purposes
• To maintain legal and regulatory compliance
• To enforce compliance with our Terms, this Policy, and the HIPAA Notice
(iv) Categories of Third Parties that your Personal Information has been disclosed for business purposes (See Section 3 for additional detail)
• Vendors and other Service Providers
• Our business clients
• Third parties in connection with business transactions
• Our affiliates
• Government and other law enforcement agencies
(v) The Purpose for Sharing Your Personal Information
We share limited information to provide more relevant ads and measure their performance. In the 12 months before this Policy's effective date, we may have shared identifiers (like cookies or device IDs) for cross-context behavioral advertising as defined by California law. We do not share your name or directly identifying information. The categories of third parties involved in this sharing are listed in Section 6.
d. No Sale of Personal Information
In the 12 months before this Policy’s effective date, we have not sold any personal information as defined under applicable California law.
e. Retention of Personal Information
We retain your personal information as needed to provide our Services, fulfill the purposes in this Policy, comply with legal obligations, or as otherwise communicated to you. Residual copies may remain in our backups for a limited time before being automatically deleted or rendered inaccessible when deletion is not possible.
8. TRUNEURA SOCIAL MEDIA USAGE
We maintain social media accounts where we share updates and run promotions. If you follow or interact with us on these platforms, we may collect any personal information you choose to share. The social media platforms may also collect or share your information independently. We do not control, and are not responsible for, how these third parties use your data. Your interactions on social media are voluntary, and we recommend reviewing the privacy policies and settings of those platforms to understand how your information is handled.
9. INTERNATIONAL TRANSFERS
Your information is stored on secure servers with limited access and may be processed in the United States or other countries where our service providers operate. The Platform and our Services are intended for individuals in the United States and are not marketed internationally. If you are outside the U.S. and choose to use our Platform, utilize our Services, or provide personal information, you do so voluntarily and at your own risk, understanding that data may be transferred to countries with different privacy protections.
10. CHILDREN
Our Platform is not intended for children under 18. We do not knowingly collect personal information from anyone under the age of 18. If you are under 18, do not use the Platform site or submit any information without parental consent. If you are a parent or guardian and believe your child has provided us with personal information, contact us to request its deletion.
11. CHANGES TO POLICY
We may update this Policy periodically. The “Last Updated” date at the top reflects the most recent changes. We encourage you to review it regularly to stay informed. For material changes, we will notify you in advance by email. By continuing to use the Platform after changes take effect, you agree to the updated Policy. If you do not agree, you must stop using the Platform.