privacy policy

pineal labs inc. (“we” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy. 

this privacy policy (this “policy”) describes how your personal information (as defined in section 1) is collected, used, and shared when you purchase, download, install, register with, access or use our app, sona (the “app”). 

by downloading, registering with, or using this app, you are consenting to the collection of personal information and use practices described in this policy, as modified from time to time by us in our sole discretion.  

section 1 - what do we collect?  what do we do with your information?

when you download the app, certain required information is sent to the app store, including your apple id, time of download, payment information, and your unique device identification number. the processing of these data takes place exclusively through the app store and is beyond our control. 

when you access and use the app, we automatically collect certain details of your access to and use of the app, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the app. we also collect information about your mobile device and internet connection, including the device’s unique device identification number, information about your web browser, operating system, ip address, mobile network information, the device’s telephone number, time zone, and some of the cookies that are installed on your device. this app collects real-time information about the location of your device. we refer to this automatically-collected information as “device information.”

we collect device information using the following technologies:

- “cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. for more information about cookies, and how to disable cookies, visit link: http://www.allaboutcookies.org.

- “log files” track actions occurring on the app, and collect data including your ip address, browser type, internet service provider, referring/exit pages, and date/time stamps.

- “web beacons” “tags,” and “pixels” are electronic files used to record information about how you use the app.

we use the device information that we collect to help us screen for potential risk and fraud (in particular, your ip address), and more generally to improve and optimize our app (for example, by recording the popularity of certain app content and verifying system and server integrity), and to assess the success of our marketing and advertising campaigns.

when you download, register with, or use this app, we collect other personally identifying data and information from you, such as your name, billing address, shipping address, email address, and phone number. we refer to this information as “order information.” 

when we talk about “personal information” in this privacy policy, we are talking about both device information and order information.

you may also use facebook connect to register for an account which links your user account to your facebook profile. we receive personal information about you from facebook, namely your email address and your name, which we use in order to identify you at registration and login. facebook also receives data about you from us. as the provider of the app, we have no knowledge of the content of the data transmitted or its use by facebook. further information can be found on facebook’s privacy policy. if you do not want information to be collected via facebook connect, please do not register via facebook connect. 

in addition to the uses set forth elsewhere in this policy, we may use personal information about you for various purposes, including to:

  • provide, maintain and improve the app and our products;

  • manage your account and send you related information, including confirmations, updates, technical notices, security alerts and support and administrative messages;

  • respond to your comments, questions and requests and provide customer service;

  • communicate with you about the app, products, offers, surveys, events and other news and information we think may be of interest to you;

  • monitor and analyze trends, usage and activities in connection with the app;

  • detect, investigate and prevent fraudulent transactions and other illegal activities and protect our rights and property;

  • personalize and improve the app and provide advertisements, content and features that match your profile or interests;

  • facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;

  • link or combine with information we get from others to help understand your needs and provide you with a better experience; and

  • carry out any other purpose for which the information was collected.

section 2 – consent

how do you get my consent?

you consent to our collection and use of device information by using or accessing the app. 

you consent to our collection and use of order information when you provide us with personal information to register to use the app, fill in forms in the app, subscribe to our service, complete a transaction or request further services.  

we will ask directly for your express consent to use your order information for a secondary reason, like marketing, or provide you with an opportunity to say no.

how do i withdraw my consent?

you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us via email at pineallabs@gmail.com.

if you decide you don’t want to receive marketing emails from us, you can opt out of marketing emails by clicking the “unsubscribe” link in our emails. 

section 3 - disclosure

subject to the terms of this policy, we shall never sell, rent, share or otherwise distribute or make available your personal information to third parties outside of our group of companies without your consent, except that we may access, use, preserve, and disclose your personal information to third parties if we believe in good faith that it is reasonably necessary to:

  • comply with applicable laws, regulations, legal processes, and governmental requests;

  • protect the safety of any person including to prevent death or imminent bodily harm;

  • detect, prevent, and address fraud, security, or technical issues; 

  • further process your personal information in accordance with the purposes for which it was originally collected;

  • enforce the terms of service; or 

  • protect our rights or property.

california privacy rights

if you are a california resident, california law may provide you with additional rights regarding our use of your personal information, including under the california consumer privacy act of 2018 (“ccpa”). to learn more about your california privacy rights under the ccpa, visit https://oag.ca.gov/privacy/ccpa.

we will not discriminate against you for exercising any of your ccpa rights. unless permitted by the ccpa, we will not:

  • deny you goods or services.

  • charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • provide you a different level or quality of goods or services.

  • suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

however, we may offer you certain financial incentives permitted by the ccpa that can result in different prices, rates, or quality levels. any ccpa-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

in addition, california's “shine the light” law (civil code section § 1798.83) permits users of our application that are california residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. to make such a request, please contact us via email at pineallabs@gmail.com. 

 

section 4 – retention of personal information 

we will only retain your personal information for as long as necessary to fulfill the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. we retain personal information for the duration of any actively engaged user of our app and services and for a period after this time as necessary and relevant to our legitimate operations and in accordance with applicable law obligations. this may include retention necessary to identify, issue or resolve legal proceedings. we may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. you cannot be identified from aggregate information retained or used for these purposes.  

section 5 – international users

our app is based in the united states. if you are visiting from the european union or other region with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the united states and processing globally.  by providing your information, you expressly consent to any transfer and processing in accordance with this policy while acknowledging that privacy laws in the united states may be different, and in some cases, less protective, than those in effect in your jurisdiction.  

users in the european economic area (the “eea”) and switzerland.  if you are a resident of the eea or switzerland, the following information applies. 

  1. purposes of processing and legal basis for processing: as explained above, we process personal data in various ways depending upon your use of our app.  we process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide services; and (3) as necessary for our legitimate interests in providing the services where those interests do not override your fundamental rights and freedom related to data privacy. 

  1. right to lodge a complaint: users that reside in the eea or switzerland have the right pursuant to the general data protection regulation (“gdpr”) to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. contact details for data protection authorities are available here: link: https://edpb.europa.eu/about-edpb/board/members_en.

  1. transfers: information we collect may be transferred to, and stored and processed in, the united states or any other country in which we or our affiliates or subcontractors maintain facilities. we will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards as described in article 46 of the gdpr.

  1. individual rights: if you are a resident of the eea or switzerland, you are entitled to the following rights. please note: in order to verify your identity, we may require you to provide us with personal data prior to accessing any records containing information about you.

    1. the right to access. you have the right to obtain (i) confirmation as to whether personal data concerning you is processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. 

    1. the right to rectification. you have the right to obtain the rectification of any inaccurate personal data concerning you. you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

    1. the right to request data erasure. you have the right to have your data erased from our app if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing. 

    1. a right to data portability. you have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from us. this right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.

    1. the right to restrict or object to our processing. you have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

if you would like to exercise any of these rights, please contact us via email at pinealalbs@gmail.com.

storage of your information

the data that we collect from you may be transferred to, and stored at, a destination outside the eea that may not be subject to equivalent data protection law. by submitting your personal data, you agree to this transfer, storing or processing. where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism and making sure that it is treated securely and in accordance with this privacy policy.

all information you provide to us is stored on our secure servers. we use encrypted ssl technology on the app. where we have given you (or where you have chosen) a password which enables you to access the app, you are responsible for keeping this password confidential. we ask you not to share a password with anyone, and suggest that you change your password frequently. 

we will only retain your personal data for as long as necessary to fulfill the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. we retain personal data for the duration of any actively engaged user of our app and services and for a period after this time as necessary and relevant to our legitimate operations, our terms of service and in accordance with applicable law obligations. this may include retention necessary to identify, issue or resolve legal proceedings. we may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. you cannot be identified from aggregate information retained or used for these purposes.  you may ask us to delete your information at any time and we will delete this information to the extent permitted by applicable law, document retention policy or court order. further, you have the right to update, correct or modify information we may have about you at any time by contacting us via email at pineallabs@gmail.com.

unfortunately, the transmission of information via the internet is not completely secure. although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our app; any transmission is at your own risk. once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

section 6 - third-party services

in general, the third-party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

however, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for your purchase-related transactions.

for those providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by those providers.

in particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. so, if you elect to proceed with a transaction that involves the services of a third-party service provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

as an example, if you are located in canada and your transaction is processed by a payment gateway located in the united states, then your personal information used in completing that transaction may be subject to disclosure under united states legislation, including the patriot act.

once you leave our app or are redirected to a third-party website or app, you are no longer governed by this policy or our app’s terms of service.

third-party links

when you click on links on our app, they may direct you away from our app. we are not responsible for the privacy practices of other sites and apps and encourage you to read their privacy statements.

twilio

only if you decide to extend the free trial period using the “invite friends” option, we share your phone contacts with twilio in order to distribute the invitations.

section 7 – security

to protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

although we have tried to create secure, reliable and trustworthy applications for our visitors, please be aware that the internet is generally not regarded as a completely secure environment, and that therefore the confidentiality of your personal information provided or transmitted via our app or by e-mail cannot be guaranteed by us. thus, we are not responsible or liable for the security of your personal information whilst in transit via the internet to us.

by using the app or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the app.  if we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the app or sending a message. you may have a legal right to receive this notice in writing.  to receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us via email at pineallabs@gmail.com. 

section 8 – cookies

by using or accessing the app, you are consenting to our use of cookies as follows:

we, and third-party vendors (such as google), use cookies to analyze user activity in order to improve the app. for example, using cookies we can look at aggregate patterns, like the average duration of daily usage. we can use such analysis to gain insights about how to improve the functionality and experience for all users, as well as serve ads based on past app activity.

google analytics 

as you navigate through and interact with our app, we may utilize automatic data collection technologies (such as google analytics for firebase) to collect anonymized information about your app visit, including via identifiers for mobile devices, cookies and similar technologies. we do this to help us estimate the size of our audience and their usage patterns in order to improve the user experience for everyone.

data collected may include, but is not limited to, demographic information like age and gender, system details like your browser version and operating system, your mobile device type, onsite behavior like which pages on our app that you visited and how long you stayed, and whether or not you completed any actions like making a purchase. nothing collected is personally identifiable.

we may allow others to serve advertisements on our behalf, on other sites across the internet, based on you visiting our app in the past. these entities may use cookies, web beacons, or other technologies to function properly and identify the effectiveness of those efforts.

you have the right to update, correct, or modify information we may have about you at any time by logging into your account, or emailing us at pineallabs@gmail.com. 

you may also adjust your ad personalization settings directly with google in their “ad personalization settings” link: https://adssettings.google.com/authenticated page.

opt-out options

users who wish to not have their data collected with google analytics can visit the network advertising initiative opt-out link: http://optout.networkadvertising.org/?c=1#!%2fpage.

section 9 - age of consent

our app is not designed nor intended to collect personal information from children under the age of 13 (or under 16 for individuals in the european union). to respect the privacy of children and to comply with the laws designed to protect children, children under the age of 13 should not provide any personal information.  we will not knowingly collect, use, or disclose personal information from a child under the age of 13 (under 16 in the eu), without obtaining prior consent from a person with parental responsibility (parent, guardian). we ask that parents supervise their children while online. if you have questions concerning our information practices with respect to children, or if you believe a child has provided us with personal information, please email us at pineallabs@gmail.com.

section 10 - changes to this privacy policy

we reserve the right to modify this policy at any time, so please review it frequently. changes and clarifications will take effect immediately upon their posting on the app. if we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.  your use of the app signifies your acceptance of this policy. if you do not agree to the terms of this policy, please do not use the app.  

if the ownership of all or substantially all of our business changes, or we otherwise transfer assets relating to our business or any of the services to a third party (such as by merger, acquisition, bankruptcy proceeding, or other change of control transaction), we may transfer or sell your information to the new owner. in such a case, unless permitted otherwise by applicable law, your information would remain subject to this policy unless we notify you otherwise.

section 11 – trademark rights

we and our affiliates, licensors and content providers are the owners of all the trademarks used on the app.  third parties are not allowed to use and apply any of the trademarks, logos and identifying marks without our express written consent.

section 12 - questions and contact information

if you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, contact our team via email at info@sona.care. 

we urge you to also carefully read our “terms of service” link: https://www.sona.care/terms-of-service for more information on the use of our app.

 

effective date: march 31st, 2020