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Privacy Policy

Effective date: 3/23/23

This Privacy Policy (the “Policy”) explains how BlinkTBI, Inc. (“us,” “our,” or “we”) collects, uses, and discloses personal information that we collect through the i-Blink mobile application (the “App”).


While we collect and process information related to your health through the App, please note that we are not a covered entity subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and that HIPAA’s requirements do not apply to the health information we collect and process through the App.
 

This Policy DOES NOT apply to information that:
 

  • We collect offline or on any other apps or websites, including websites you may access through the App; or
     

  • You provide to or is collected by any third party (see the “Third-Party Links” section below).


Our websites and other apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this Policy. This Policy may change from time to time (see the “Changes to this Policy” section below). Your continued use of this App after we revise this Policy means you accept those changes, so please check the Policy periodically for updates.

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Information We Collect

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When you use or access the App, we may collect certain information directly from you and automatically from your use of the App.

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Information We Collect Directly from You

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When you use or access the App, we may collect information that you directly provide us, such as the following:

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  • Account and contact information, such as your name and email address.

  • Demographic information, such as your date of birth, gender, race, and ethnicity. 

  • Authentication information, such as your password.

  • Images and video you submit through the App, such as video and images of your eyes and surrounding facial area, and a profile picture if you choose to submit one.

  • Self-reported information about your health conditions, and medications you take and other treatments you have undergone in connection with those conditions.

  • Any other information you submit through the App, including any information you provide in through questionnaires and contact forms within the App.

 

Information We Collect Automatically from Your Use of the App

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We also may collect certain other information automatically when you use or access the App, such as the following:

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  • Facial Scanning Information. When you use App functions that capture video and images of your eyes and surrounding facial area through your mobile device’s camera, we will automatically collect facial scanning information from the video and images as part of those functions. These App functions are not designed to identify you, but rather to provide inputs that the App uses to measure and assess your blink reflex and other parameters.

  • Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, logs, and other communication data and the resources that you access and use on or through the App.

  • Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.

  • Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs and audio and video clips.

  • Location Information.  When you use the App, we may automatically collect information about your approximate location, including general location information that may be associated with your device’s IP address.

 

How We Use, Disclose, or Otherwise Process Your Information

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We may use, disclose, or otherwise process information about you for purposes that include the following:

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  • Providing the App and our other products and services to you and others, including to measure and assess your blink reflex and other parameters, such as by conducting facial scans, and assist in assessing conditions you may have.

  • Conducting medical, scientific, and other research, including to develop and enhance new and existing products, features, and functionality.

  • Operating, evaluating, and improving our organization.

  • Understanding how you and others use our App and to determine what features and services may interest you and others.

  • To update or modify our App features and functionality.

  • To communicate with you, including about your experience with the App and to notify you of other products and services in which we think you may be interested.

  • To respond to your requests and inquiries.

  • Storing information about your preferences, recognizing you when you use the App, and customizing your experience.

  • To create aggregate or deidentified data.

  • To maintain the safety, security, and integrity of our App, other technology assets, services, and our organization.

  • Protecting the legal rights, property, safety, and security of us, our users, our customers, our employees, and others.

  • Complying with applicable law, other legal requirements, and industry standards.

  • To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.

  • To debug, identify and repair errors, or effectuate similar functional enhancements in connection with our App or other services.

  • Enforcing our policies, terms of use, contracts, or other legal rights.

  • To evaluate an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.

  • For such other purposes as you may authorize or we otherwise disclose when we collect your information.
     

Disclosure of Your Information

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We may disclose information about you:

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  • To family members whom you authorize to receive your information.

  • To your health care providers and payors whom you authorize to receive your information.

  • To our contractors, service providers, and other third parties we use to support our organization.

  • To third-party partners or participants in medical, scientific, and other research.

  • To comply with applicable law, other legal requirements, and industry standards.

  • To enforce our policies, terms of use, contracts, or other legal rights.

  • To investigate or prevent unlawful activities or misuse of the App.

  • To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.

  • To protect the legal rights, property, safety, and security of us, our users, our employees, and others.

  • To an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.

  • To such other parties as you may authorize or we otherwise disclose when we collect your information.

  • For the purposes described in the “How We Use, Disclose, or Otherwise Process Your Information” section above.

 

We may also aggregate or deidentify any information that we collect through the App, such that the information is no longer personally identifiable or attributable to you. We may disclose such aggregated or de-identified information to third parties for our and their own legitimate business purposes without restriction, and will take appropriate steps that are designed to prohibit those third parties from re-identifying the information.

 

Your Choices

 

You may choose not to provide the personal information we request through the App. However, not providing information we request may restrict your ability to use certain features of the App.

Some Internet browsers have a “do-not-track” feature that lets you tell websites that you do not want to have your online activities tracked. The App does not respond to “do-not-track” signals.  We do not allow other parties to collect personally identifiable information about your online activities over time and across different web sites when you use the App.

You may also choose to delete your App account by visiting the App Settings menu and selecting “Delete Account.”

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Third-Party Links

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The App may include links to or options to integrate with third-party websites, applications, information, and services provided by third parties. We are not responsible for the privacy policies or practices of those third parties. We encourage you to review the applicable privacy policies of such third parties if you elect to follow the links provided or integrate our App with third party applications and services.

 

How We Protect Your Information

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We maintain safeguards that are reasonably designed to protect the information collected through the App. 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. 

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Children Under the Age of 13

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The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under age 13. No one under age 13 is permitted to use or provide any information to us on or through the App.  If you believe we might have collected any information from or about a child under age 13, please contact us using the information below.

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Storage and Retention of Facial Scan Information

 

Unless otherwise required by a valid warrant or subpoena issued by a court of competent jurisdiction, we will securely destroy or erase facial scan information upon the earlier of (i) fulfilling the purpose for which we collected the facial scan information, such as providing you measurements and assessments of your blink reflex and other parameters and assisting in assessment of conditions you may have and conducting internal research and development, or (ii) three years from your last interaction with us. We will securely destroy or erase facial scan information in accordance with the reasonable standards of care applicable to our industry designed to destroy or erase the relevant information such that it cannot be practicably read or reconstructed.

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Changes to this Policy

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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.

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Contacting Us

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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@blinkcns.com or BlinkTBI, Inc. ATTN: Privacy Policy 635 Rutledge Ave, Suite 106 Charleston, SC 29403.

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