Resonance Rx Data Use Agreement
LUCID, Inc.
Last Update: October 18th 2023
1. ABOUT THIS DOCUMENT
LUCID Inc. (“LUCID”, “us,“ “we,” or “our”) is committed to data and privacy protection in connection with the use of our products, services and features thereof (collectively, the “Services”).
This Data Use Agreement (“Agreement”) has been put together to provide our users (“Users” or “you”) with information about the privacy practices of our Services and the use of the data being collected herein. We understand the importance of the information you are trusting us with and want to be transparent about how we handle it.
Please note that this Data Use Agreement only applies to the processing of personal data carried out by LUCID as a data controller.
2. DATA WE ARE COLLECTING
The following anonymized data are collected for each Resonance Rx user:
+ A 3D (x, y, z axis) ‘FaceMesh’ data point array capturing the microexpressions on your face and head motions**
+ Mood self-assessment data
**The ‘FaceMesh’ data point array is used to determine your response to the in-app content and mood. It does not include full video capture of you nor does it capture your likeness or personally identifiable traits.
3. HOW WE USE YOUR DATA
We use the information we are collecting for the following purposes:
SERVICE OFFERING: The data collected in the app is used to provide the service offering of ResonanceRx. Our recommendation systems learn what content works best for you based on the data we collect on your mood and responsiveness.
RESEARCH AND DEVELOPMENT: Anonymized data may be used for the sole purpose of research and development of new products and services for individuals like yourself. This data is aggregated and all identifiable user information is separated from these records. All data is stored in AES-256 level encrypted servers owned and maintained exclusively by LUCID, inc.
4. SHARING YOUR PERSONAL INFORMATION
We do not share personal information with third parties outside of our organization unless one of the following circumstances applies:
FOR RELEASE REQUIRED BY LAW - We may process and transfer personal information and any other information available to us in order to investigate, prevent or take action regarding illegal activities, or as otherwise required by law. Where possible, we will inform Users about such transfer and processing.
ANONYMIZED DATA - We may disclose aggregated information that does not include personal information and we may disclose non-identifying information and Log Data to third parties for industry analysis and consultation. Any information or Log Data shared in these contexts will not contain personal user information (only anonymized health data). The limitations and requirements in this Data Use Agreement concerning personal information do not apply to non-identifying Information.
5. INFORMATION SECURITY
The security of your information is very important to us. We use commercially reasonable security standards to protect the information collected and maintained through the Services and take appropriate measures to protect against any unauthorized access to personal information.
We have put in place appropriate physical, managerial and technical procedures to safeguard and secure the information we store. Access to personal information stored on our servers or servers operated by Service Providers on our behalf is restricted to authorized personnel, including LUCID employees. Any individuals having access to the information stored on such servers are bound by confidentiality agreements.
However, no data transmission over the Internet is completely secure. As such, we cannot guarantee the security of any information you provide to us or guarantee that information may not be accessed, disclosed, altered, or destroyed by unauthorized persons.
6. YOUR RIGHTS
RIGHT TO ACCESS YOUR PERSONAL DATA
You have the right to access your personal data that we use, collect or disclose. You may do this by contacting us.
RIGHT TO WITHDRAW CONSENT
You have the right to withdraw consent at any time. There is implied consent when you browse the site and expressed consent is given through a sign-on form in the application when you give your email. Withdrawing your consent may result in less access to our Services. The withdrawal of consent does not affect the collection, use, and disclosure of the personal information prior to the request for withdrawal.
RIGHT TO ERASURE AND OBJECTION TO DATA
You have the right to erase your data from our systems. We will comply with the request unless we have legitimate grounds not to. You may also object to our collection, use, and disclosure if it is out of the scope for the purpose of our Services or for legal compliance. If we do not have legitimate grounds to collect, use, or disclose your personal data, we will cease collection, use, and disclosure upon your objection.
HOW TO ACCESS THESE RIGHTS
In order to address the rights as stated above please contact our email. You should include the following information: your full name, company name (if applicable), address, and phone number. We may request additional information to identify you for your privacy interest. We have the right to deny requests that are unreasonable, repetitive, or manifestly invalid.
7. OUR CONTACT INFORMATION
If there are any concerns, questions or suggestions for this Data Use Agreement or for your personal information, please contact us at info@thelucidproject.ca.
LUCID Inc.
Attn: Legal Department
112 Adelaide Street East
Toronto, ON M5C 1K9
Canada