PureSight Privacy Policy

Introduced: August 2024

1. INTRODUCTION

LOGIC FUSION LLC, a company registered and acting under the laws of Florida, having its registered office at 4713 Southern Breeze Dr, Naples, FL, US 34114 (“Logic Fusion”, “Company”, ”we”, “us”, or “our”), takes your privacy seriously. This Privacy Policy (the “Policy”) explains our data protection commitment and practices and describes the types of information we may process when you use our services accessible at https://puresight.org/
and corresponding subdomains/landing pages (the “Web Platform”).

When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data or to an identification number (“Personal Data”).

Our Privacy Policy applies to all users and others who access the Web Platform (”Users”) and/or persons whose Personal Data we may process as a result of our business activities. We also refer to such persons by “you” in the text. The reference to the services available on the Web Platform is the “Services”.

For the purposes of General Data Protection Regulation (EU) 2016/679 and applicable national legislation implementing the GDPR and, if applicable, the UK Data Protection Act 2018 and the UK GDPR (hereinafter collectively the “GDPR”), we are the data controller, unless otherwise stated. We compiled this Privacy Policy and adjusted our processes towards Personal Data in compliance with GDPR as the highest standard for the protection of our Users` data rights.

PLEASE READ THE FOLLOWING PRIVACY POLICY FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL DATA MAY BE PROCESSED CAREFULLY.

2. SCOPE

This Privacy Policy applies to Personal Data obtained through our Web Platform or when you otherwise interact with us.

The Web Platform may contain links to other websites not under our control. We are not responsible for other websites' information practices or content. You should always review the policies of third-party products and services to make sure you are comfortable with how they collect and use your information.

3. INFORMATION WE PROCESS

Your privacy is our high priority, so we prefer, to the maximum possible extent, using instruments that disable the collection of clearly identifiable information and provide us with information in aggregated, encrypted, anonymized, and/or pseudonymized (non-identifiable) form. However, we understand that some categories of such information we use may be deemed Personal Data, in particular, for the purposes of GDPR. With regard to such Personal Data, the rules set out in this Privacy Policy are always strictly followed.

1. Information that you submit

You may provide personal information directly when you use our Web Platform. This information is necessary to adequately perform the contract between you and us. Without such information, it is impossible to provide the complete functionality of the Web Platform and perform the requested services. Depending on the Web Platform's functionality, the following information can be processed:

General Information. To receive Services, you may need to share the following information:

• Gender;

• Date of birth;

• Zodiac sign.

Contact Information. You may share it when you purchase the Services or contact us via email:

• Name;

• E-mail address, and any other content included in the email;

• Password or passcode;

• Other information you decide to share when you log in via third-party services; it may also include technical identifiers necessary for the authentication service to run.

To provide you with the Services, the Web Platform technically accesses your camera to make a scan of your palm. We cannot collect, store, or use the data contained in your camera roll. We may save the photo you made for scanning and receiving the Services in our database as needed to provide you with the requested Services only.

The account on the Web Platform is automatically created when you share your email and complete the payment process for a subscription. You may delete your account in the account settings on the Web Platform. If you choose to delete your account, your Personal Data will be removed from our storage, but some categories of your personal information may be stored for a longer period, as prescribed by this Policy and/or applicable laws (this may include, without limitation, storage of your consent log).

Information you submit via web landing pages. If you access our landing pages on our website, we may ask you to indicate some Personal Data on these pages necessary to proceed with your request to get our services. For example, you may need to indicate your age, gender, interests, etc. Please note that information about your date of birth and gender is transmitted to our service providers or databases, but stored separately from your email, so we cannot match this information with your personality. Still, we protect it as other categories of Personal Data.

Other data you may submit to us. Also, we may collect other data that you submit to us as you participate in any interactive features of our Services, participate in a survey, contest, promotion, sweepstakes, activity, or event, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us.

Other persons` Personal Data. If you are providing information (including Personal Data) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Data as described in this Privacy Policy.

2. Information collected automatically

Information from the Web Platform. When you use the Web Platform, information about your device and user behavior may be collected and processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual. However, a set of this information may allow us to identify you as a separate user of our Services, therefore we treat such information as Personal Data and protect it as prescribed by law. We process Personal Data based on the contract between you and us or our legitimate interest in improving our Web Platform and giving our users the best experience. If we do not access such data, we may not be able to provide you with all the Web Platform`s features. To process your Personal Data for our marketing purposes, we rely either on legitimate interest or your consent basis, as the case may be.

Device Details. When you use a mobile device to access our Web Platform, some details about your device are reported subject to your privacy choices as provided by your device functionality. For example, device identifiers and other metadata. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, uniquely identifying your mobile device (but not your personality). Device identifier enables generalized reporting and analytics. In this regard, the following information may be collected and processed:

• Information about the device itself: type of your device, type of operating system, and its version, model, and manufacturer, device ID.

• Information about the internet connection: mobile carrier, IP address, timestamp, and duration of sessions.

• Location-related information: IP address, general location information.

• Device identifiers and technical identifiers (e.g. IDFA).

• Information about the Web Platform: name, API key (identifier for application), version, and Web Platform properties can be reported for automated processing and analysis; we also process information about the web browser you used to access the Web Platform.

• Cookies and similar technologies. When you use the Web Platform, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information downloaded to your device when you access the Web Platform. The text file is sent back to the server each time you use the Web Platform. This enables us to operate the Web Platform more effectively. For example, we will know how many users access specific areas or features within our Web Platform and which links they clicked on. We use this aggregated information to understand and optimize how our Web Platform is used, improve our marketing efforts, and provide content and features that interest you. We may ask advertisers or other partners to serve ads or services to the Web Platform, which may use cookies or similar technologies. We also store your email and product ID in order to enable the creation of an account for you and your use of our Services.

Payment Information. Our payment service providers (Stripe and PayPal) responsible for billing, processing, and charging for web subscriptions, handle your Personal Data and keep it safe and secure. We cannot access or use your credit or debit card information.

Information collected through the Web Platform. When you access and use our Web Platform, we may, once we obtain your consent or under another legitimate basis, automatically process the following data:

• Web Logs. As is true with most websites and services delivered over the Internet, we may gather certain information and store it in log files when you interact with our Web Platform. This information includes
  
  internet protocol (IP) address as well as browser type, operating system, identification numbers associated with your device, and your mobile carrier.

• Analytics information from Web Platform. We collect anonymized and aggregated analytics information when you use our Web Platform to help us improve our products and services.

• Google Analytics. Our Services use Google Analytics, a web analytics service of Google Ireland Limited (Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). The use includes the "Universal Analytics" operating mode. This facilitates the assignment of data, sessions, and interactions across several devices to a pseudonymous user ID and, thus, the analysis of a user's activities across devices. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

• Cookies and other tracking technologies. We use cookies to enable the Web Platform functionality, making it easier for you to navigate our site and enjoy our Services. For more general information on Cookies, please visit http://www.allaboutcookies.org/. You can also change your browser's settings to delete already set cookies and not to accept new ones.

3. 
   
   Information received from third parties

We may also obtain information from third parties, such as:

• Marketing partners, and publicly available sources. As a rule, this information does not help to identify you, but if under certain circumstances it does, we will treat it as Personal Data.

• 
  Social media and authentication services. We may have access to certain information from a third-party social media or authentication service if you log into our Web Platform or Website through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third-party service, you authorize us to access and store your name, email address(es), profile picture URL, and other information that the third-party service makes available to us, and to use and disclose it under this Privacy Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services.

4. THE LEGAL BASES AND PURPOSES OF PROCESSING YOUR PERSONAL DATA

Without first notifying you, we will not collect or use your Personal Data. We will handle your Personal Data using one or more of the following legal bases, depending on which features of our Services you use:

1. Contract. We use your Personal Data to fulfill our contractual obligations and provide the Services to you.

2. Consent. For example, when you purchase a subscription, we may ask you to permit us to process your Personal Data.

3. Legitimate interest. We may process your Personal Data in relation to our interests in providing the Services to you, our legitimate commercial interests, our interest in protecting the security and integrity of the Services, and wider societal benefits, as allowed under the law.

4. Legal obligations. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.

We may use your Personal Data for the following purposes and under the applicable legal basis:

If we need to process your information for a specific purpose not clearly outlined in this Policy and not concerning our ability to provide you with all requested Services and features of the Web Platform, or a justified legitimate interest, we will ask you for consent while amending the list of purposes above.

5. SHARING OF YOUR INFORMATION

General principles and prohibitions. We will only share your information with our service providers as this Privacy Policy describes. Without your permission, we do not share Personal Data with third parties for their marketing purposes (including direct marketing). We do not share the scans of your palm with third parties for marketing and other purposes not related to providing you access to our Services. We will not rent or sell your Personal Data to any third parties.

Personnel. We share your Personal Data only with our employees and contractors, agents, and auditors who need to know or otherwise access Personal Data according to their scope of professional responsibilities and who are bound in writing by confidentiality and other obligations sufficient to protect Personal Data under this Privacy Policy.

Protection measures. While integrating external services, we choose service providers that can assure they apply all necessary technical and organizational measures to protect users` personal data. However, we cannot guarantee the security of any information transmitted from us to any such processor due to technical accidents that may arise out of our reasonable control. Provided that we followed all demands of applicable personal data protection legislation, we are not responsible for any accidental loss or unauthorized access to your Personal Data through the fault of third parties.

1. Disclosures made by you

Certain features of our Services allow you to make some of your measurements public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you share at your discretion.

2. Service providers and subcontractors

Processing to make the Web Platform run

We occasionally engage outside businesses to process your Personal Data on our behalf. They are the “processors” of your Personal Data. Processors assist us in managing the Services, facilitate our communication with you, and carry out other related tasks. To complete these objectives, they may process specific Personal Data on our behalf, acting under our instructions and subject to demands of applicable data protection laws. To the degree applicable legislation requires, we will execute data processing agreements with our processors and maintain responsibility for their actions.

We may engage the
following third-party service providers to provide us with the necessary infrastructure for the delivery and improvement of our services:

We also engage Artificial Intelligence (AI) service providers to enable the Web Platform`s analyzing and information functionality. These service providers may be used as a generative AI tool enabling functionality for processing your input and therefore they may get access to the content of your input. We encourage you to review your input carefully to exclude the sharing of Personal Data by accident. We do not intentionally disclose your Personal Data to such service providers, however, some technical data may be shared only as it is necessary for the service to properly function.

Processing for marketing and marketing analytics purposes

With your consent, we may share some of your Personal Data with our marketing and promotional service providers. We do this to market our Web Platform and Services, to help new users find out about us, and to develop our business by increasing awareness about the Services.

These are processors we engage for the above purpose:

These lists may be amended or modified from time to time according to our business needs, on our sole discretion and without giving notice to you, but provided that such extension in sharing of your Personal Data do not require your consent as legal basis for processing. If so, we will ask you for consent while informing you of modifications for further processing.

Our Web Platform does not track your precise location data.

3. Business transfers, legal requirements, and protection of our rights

We may disclose your personal information if it is needed for objective reasons, due to the public interest, or in other unforeseen circumstances:

• to the extent permitted and as restricted by law, in response to subpoenas, court orders, or legal processes, including to meet national security or law enforcement requirements;

• when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or enforce our agreements, policies, and terms of service;

• if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice in our Web Platform of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

Depending on the circumstances, we may rely on legitimate interest or legal obligation as a legal basis for the above processing activities. 

4. Aggregated or anonymized data

We may share aggregated or anonymized information that does not directly identify you with other third parties, not mentioned above, such as our partners and research entities, for statistical, analytic, and scientific purposes. Anonymization and further use of anonymized information are done under our legitimate interest and aimed at contributing scientific value in our activities to increase awareness about heart health and general well-being across society worldwide.

6. YOUR PRIVACY RIGHTS

We are committed to giving you extensive privacy rights in relation to your Personal Data, regardless of the nation or region you are from. This includes all individuals in the EEA, the UK and/or Switzerland.

Please refer to Section 4 of this Policy to discover legal bases and specific purposes for processing of your Personal Data.

Your rights under the GDPR:

• the right of access. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of the personal data along with certain other details.

• the right to rectification. If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible.

• the right to erasure. You may ask us to erase your Personal Data in some circumstances, such as when we no longer need it, or you withdraw your consent. If we share your Personal Data with others, we will alert them to the need for erasure where possible.

• the right to restriction of processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restrictions on processing. If we share your Personal Data with others, we will tell them about the restriction where possible.

• the right to data portability. You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that we processed with automated means. We will give you your Personal Data in a structured, commonly used, machine-readable format. You may reuse it elsewhere.

• the right to object. You may ask us at any time to stop processing your Personal Data, and we will do so:

  • if we are relying on a legitimate interest to process your Personal Data – unless we demonstrate compelling legitimate grounds for the processing, or your Personal Data is needed to establish, exercise, or defend legal claims; or

  • in certain circumstances, if we are processing your Personal Data for direct marketing purposes.

• the right to withdraw consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

• the right to make a complaint with the data protection authority. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

Your rights under California Consumer Privacy Act of 2018 (CCPA):

• The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information in Section 5 of this Policy.

• “Sales” of Personal Information under the CCPA. Without limiting our ability to disclose information as described in the section of our Privacy Policy entitled “Business transfers”, for purposes of the California Consumer Privacy Act we do not and will not sell your Personal Data, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

• Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

• Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

• Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

Your rights under Virginia Consumer Data Privacy Act (VCDPA):

• Opt out of the Processing of your Personal Data for Targeted Advertising. Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

• Confirm whether your Personal Data is being Processed. You may confirm whether your personal data is being processed by emailing us.

• Appeal a Case about your Request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us to initiate an appeal of this decision. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

• If your appeal is denied, you may contact the Office of the Virginia Attorney General by these means:

• Office of the Attorney General | Virginia.gov
  www.virginia.gov/agencies/office-of-the-attorney-general/#vagov
  202 North Ninth Street
  Richmond, VA 23219

Notice for Nevada residents:

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

How to exercise your rights:

You may contact us at
privacy@logicfusion.net
to exercise your rights. Please be as accurate as possible in defining the subject line and filling the body of your request email; otherwise, we may not be able to respond to it properly. Logic Fusion LLC will be responsible for responding to your requests, including under the GDPR and the local states data protection laws. Please bear in mind that we ensure the above-mentioned rights only with respect to the information that we physically access and store or if we have a technical opportunity to ensure your rights.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

We work in the cross-border area and provide our Web Platform and Services to our users around the world.

We and third-party organizations that provide data processing technologies for the Services or our third-party advertising partners may transfer the processed information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country or to an international organization where data protection and confidentiality regulations may not provide the same level of personal data protection as your country does.

We try to ensure that the recipient of any personal data provides proper protection of the personal data received, in accordance with the current legislation on protecting such information. By agreeing with this Policy, you agree that we may transfer your personal data to any third country, a territory, or one or more specified sectors within that third country or to the international organization.

For the purposes of data processing, we recourse to the third-party services or the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to our service providers. Please note that we cooperate only with those service providers that have passed our security and reliability check. If applicable, we are party to data transfer agreements/data processing addendums or equivalent legal instruments with each of our service providers, and we will (i) keep each document up to date with current law and (ii) only engage in personally identifiable information transfers from safeguards area to outside safeguards area in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. Where we transfer your Personal Data as described above, we will take steps to ensure that your Personal Data receive adequate security protection where it is processed, and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission.

8. RETENTION

We generally retain your personal information for as long as is necessary for performing the functional service of the Web Platform and to comply with our legal obligations. If you no longer want us to use your Personal Data that we physically access and store, you can request that we erase your personal information and close your account.

9. SECURITY

The security of your personal information is highly important to us. Services we use to maintain the Web Platform follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your Personal Data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. We do our best to protect your personal data, but we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law. We will also take specific steps to address the breach as necessary in the given situation. These steps may include logging you out of all devices, resetting a password (sending you a temporary password to use), and carrying out other activities and actions that are deemed to be reasonably necessary.

If you suspect or become aware of any security incident within the Services, please let us know at privacy@logicfusion.net.

10. CHILDREN'S PRIVACY

General limitation. The Services are not intended for children and we do not knowingly collect or solicit any personal information from children under 12. If we learn that we have collected personal information from a child under age 12 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 12, please contact us at privacy@logicfusion.net.

Limitations for users from the European Economic Area and the United Kingdom. The use of the Services by residents of EEA or the UK younger than 16 years old is prohibited. If you know that a person under 16 is using the Services, please contact us at privacy@logicfusion.net and we will take measures to delete such information and/or delete the child’s account.

11. CHANGES TO THE PRIVACY POLICY

This Privacy Policy is updated regularly.

Whenever we change this Privacy Policy, we will post those changes to this Privacy Policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

12. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us via email at privacy@logicfusion.net.