Privacy Notice for Akili Apps, Services, and Website
Last modified date: July 18, 2023
Thank you for your interest in our mobile and web-based applications, brought to you by Akili Interactive Labs, Inc.! We are excited to share our products and services with you! Below is our Privacy Notice for the applications, Akili’s related services, and Akili’s websites - feel free to reach out to us with any questions.
We want you to be fully aware of what data we collect, what we use it for, how we store it, and how you can ask us to review, modify, or delete it - all of which we describe below.
By creating an Akili account or login profile for our apps or services, or by visiting our Sites, you are representing that you are at least 18 years old, that any email, other contact information, or other personal information you enter is your own, and that you consent to receiving product and/or treatment-related communications to that email or directed at that contact information.
By downloading or using one of our applications or web dashboards, by communicating or enrolling with Akili, its agents, or Akili Assist®, and/or by using our websites (including but not limited to www.akiliinteractive.com, www.EndeavorRx.com, www.hcpendeavorrx.com, www.endeavorotc.com, my.akili.care, and www.thinkneuroplasticity.com (together, the “Sites”)), you are agreeing to permit Akili to process collected data in accordance with this Privacy Notice, which applies to all users of our products or services and visitors of our Sites, including your child and other people (for example, teachers or caregivers) who you may have permitted or invited to use Akili’s products or services. Please do not use our products, services, or Sites if you do not accept the terms of this Privacy Notice, the Terms of Use for our Products and Services, and the Terms of Use for our Sites.
If you are a clinical trial or study participant or caregiver of such a participant, please contact your study site or lead researcher for help; you should not contact us through our Sites, email, or social media pages for help.
What data is collected?
When you visit our websites, register and create an Akili account or login profile, through download or use of our apps, Sites, or web dashboards, if you enroll for EndeavorRx® treatment (for example via Akili Assist® ), when you communicate with Akili or its agents such as Akili Assist®, or through submission of any Akili webforms, questionnaire responses, or other information relating to our products or services, certain data may be collected, whether from or applicable to you, your child, or another individual, as summarized below. The data referred to above includes submitted data as well as data that is automatically collected by our products or services.
We obtain personal information from the following categories of sources as further explained below:
Directly from you. For example, from forms you complete.
Indirectly from you. For example, through information we collect in the course of providing services to you and from observing your actions on the Sites, apps, or web dashboards.
Automatically from you. As you navigate through the Sites, information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. Data collected through cookies, web beacons, or other tracking technologies will only be shared with contracted service providers as necessary to provide products or services, and data will only be shared with third parties when you opt-in.
We may have collected the following information in the last 12 months or beyond:
Identifiers, such as your name, nickname, email address, phone number, physical address, zip code, other contact information, or other unique personal identifier;
Internet/network information, such as information about your interaction with our apps, Sites, or web dashboards;
Device Information, such as device identifier, device operating system, internet protocol (IP) address, or similar unique identifiers
Protected classification characteristics under California, other state, or federal law, such as age, gender, and medical information, diagnosis, or condition;
Biometric information, limited to your behavioral characteristics;
Audio, electronic, visual, thermal, olfactory, or similar information, such as pictures;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your name, address, telephone number, medical information, or health insurance information;
Commercial information, such as records of products or services purchased, obtained, or considered;
Geolocation data, such as your physical location not more detailed than the city-level,
Sensitive Personal Information, such as data collected while using our products that may be considered health information, or information provided by a healthcare professional to fulfill and/or process a prescription; and
Other Data, such as passwords, activation codes, information you enter in the enrollment form, information regarding an individual’s (including your child’s) preferences, responses to assessments or questionnaires (such as the Vanderbilt assessment or other cognitive assessment), any photos or images that are uploaded, collected gameplay performance data or measurements, assessment data that is created using gameplay performance data, any text entered in any form or text box, any information submitted via Akili Assist®,, any information submitted via our web dashboard, and any responses from you or your child submitted in response to a survey.
How does Akili use and protect your data?
Akili is committed to keeping your personal data confidential as described below, and we will store your personal data in a secure manner.
Your data will be used:
to provide you with the tools, information, and functionality delivered through our products and related services, including but not limited to presenting you with the collected information;
to contact you or otherwise provide our support regarding your use of our products or services or any product recalls or modifications;
if you have enrolled for EndeavorRx treatment, to communicate with your healthcare professional or you (i) to confirm, obtain, or update your child’s prescription, (ii) to obtain information regarding your child’s treatment, (iii) to help us collect any missing information on your enrollment form, or (iv) to share treatment related information and data with you or your healthcare professional if you have given us this permission;
If applicable, to process, fulfill, or dispense a prescription or order sent to Akili from your healthcare professional, including to communicate with you regarding same;
if applicable, to communicate with your pharmacy for the purposes of fulfilling or dispensing any prescription you’ve received for EndeavorRx treatment;
to fulfill any explicit request or consent by you to share any of the data with other individuals, such as sharing with other caregivers or healthcare professionals specifically identified by you;
to share relevant content with you, such as related to pediatric ADHD or attention difficulties;
to ask for your feedback or ask you to participate in surveys regarding our products and services;
to help us evaluate, improve, and troubleshoot our products and services;
to monitor and analyze usage and trends regarding our products and services;
to detect, protect against, and address any error, fraud, wrongdoing, or illegal activity, and/or to enforce our Terms of Use or carry out our legal responsibilities;
to de-identify certain data and use the de-identified data for scientific analysis, research or research reports (including publications), improvement of our products and services, and/or analysis or development of our business;
to use Site data and logs for research to understand and improve the Sites and to troubleshoot the Sites;
to administer our Sites, including by monitoring and analyzing traffic and usage patterns on our Sites;
to process payment, if applicable; and
for any other purpose that is communicated to you or others when we collect or process any data or information.
We may confidentially disclose any personal information to our service providers, who process personal information on our behalf as needed to perform their functions in order to help us operate and provide our products and related services, but such service providers are not allowed to use that information for other purposes.
Akili may share personal information relating to internet or other similar network activity with third parties, such as marketing and advertising agencies, upon your choice to opt-in and only for the limited purpose for which you have opted in. We will not sell or share any other personal information.
We do not knowingly sell or share personal information of individuals under the age of 16.
Only Akili employees and our service providers who need to know your data for the purposes described above will have access to your personally identifiable data, and Akili will ensure that all such individuals are subject to stringent obligations to keep your personally identifiable data confidential and to use it only for the purposes described above. We may also confidentially use or disclose your information in the event of a corporate change in control resulting from, for example, a merger, sale of assets, or bankruptcy, solely for the purpose of effectuating any such corporate change in control, and any such use or disclosure will continue to be subject to the provisions of this Privacy Notice.
We may disclose your personal data if we believe that disclosure is reasonably necessary to comply with a law, regulation, valid legal process (e.g., subpoenas or warrants served on us), or governmental or regulatory request, to enforce or apply our Terms of Use, to protect the security or integrity of the Sites, and/or to protect the rights, property, or safety of Akili, its employees, users, or others.
We will not publicize any of your personally identifiable data without your express written permission. We use physical, electronic, and managerial procedures designed to safeguard and secure your information. However, no data protection procedures are entirely infallible, and, as a result, we cannot guarantee that your data or information will be 100% secure.
If you have separately opted-in for marketing communications from Akili or our partners (for example, during registration or via our website), we may also use the contact, demographic, or other registration information you provide to reach out to you with product and research opportunities. You may opt out of any such communications at any time by clicking the unsubscribe link in the communication or by contacting legal@akiliinteractive.com.
We may send the communications described above via phone, email, or SMS (unless you have not opted in for, or have opted out of, SMS), including using an automated dialer. Message and data rates may apply. You may opt out of any SMS messages by responding with “STOP”. To receive help, respond via SMS with “HELP”.
Retention of Personal Information
We maintain your information only for the amount of time it is needed to fulfill the legitimate purpose for which it was collected.
How We Use Cookies and Pixel Tags
A “cookie” is a small computer file that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Keep in mind, however, that some website features or services may not function properly without cookies.
A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.
We may use cookies and/or pixel tags to track our users across our Akili websites and/or over time, to provide the best user experience. We also may use cookies and/or pixel tags to target or personalize marketing, messages, or advertising to our Site visitors. Any cookies or pixels that share data with a third party will not be turned on unless you specifically opt-in to the cookies and pixels.
Akili will recognize the Global Privacy Control when a user has it enabled.
We use Google Analytics cookies to allow us to see how you use our Sites and services so we can improve your experience. You will be asked whether you would like to opt-in to the sharing of data collected with Google for this purpose. We encourage you to read the Google Analytics Privacy Notice. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on as well.
Third Party Websites and Social Media Features
The Sites may contain links to other sites, including those of third parties or business partners. While we seek to link only to sites that share our high standards and respect for privacy, we cannot be and are not responsible for the privacy practices other websites use or for the content or messaging on those other websites. By accessing other third party websites or applications through our Sites, you are consenting to the terms and privacy policies of those websites. It is possible that other parties may collect personally identifiable information about your online activities over time and across different websites when you use Akili’s Sites.
Our websites may include social media and other third party features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. If the data that would be collected would be shared with a third party, it will not be shared unless you opt-in to the sharing. Your interactions with these features are governed by the privacy notice of the entity providing them.
International Visitors
Our Sites are hosted and operated in the United States. By using the Sites, you are consenting to the transfer of your personal information to the United States. If you are accessing the Sites from outside the United States, please be advised that United States law may not offer the same privacy protections as the law of your jurisdiction.
Employees and Job Applicants
Employees and job applicants are subject to the Employee Privacy Notice. This Notice is posted internally and on the application page for any job postings.
Users Only of Legal Age of Majority
Our Sites are designed and intended for those who are at least 18 years old. By using the Sites, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age. No one under age 13 is authorized to submit any information, including personal information, via our Sites. Under no circumstances may anyone under age 13 use our Sites. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.
Although users of the Sites must be over the age of 18, we may still process the personal information of children under the age of 13. For more information about our practices with respect to such information, please see the “Children Under the Age of 13” section below.
Children Under the Age of 13
This section serves to inform parents and legal guardians about our practices for collecting, using, and disclosing personal information about children under the age of 13.
Collection, Use, and Disclosure Practices
We do not collect personal information directly from children under the age of 13. However, we may receive personal information about such children through other sources, such as caregivers. Specifically, we may receive the following personal information about children under 13 from their caregivers:
First and last name, and/or
Physical address
We may use and/or disclose such personal information about children under 13 for the purposes described in the “How does Akili use and protect your data?” section above.
What if you'd like to review, modify, correct, or delete your data?
If at any time you would like to review, delete, or modify any of your data that we’ve collected, please simply contact us at legal@akiliinteractive.com or call us at 857-254-3367. We will respond to you in a timely manner acknowledging your request or requesting additional information to verify your identity. Akili will not discriminate against you for exercising any rights you may have under any applicable data privacy or security laws or regulations. Please note that Akili may retain certain of your data for applicable legal, regulatory, or other reasons that are permitted by applicable data privacy laws and regulations. Please see below for more specific information on each type of request you can make:
Right to access personal information. You are entitled to request a copy of the specific pieces of your personal information we have about you.
Right to disclosure. You are entitled to certain information related to personal information we have collected about you, such as the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or sharing personal information, the categories of third parties to whom the business discloses, sells, or shares the personal information, and the specific pieces of personal information the business has collected about the you.
Right to correct. You are entitled to request that we correct any inaccurate personal information we have about you.
Right to deletion. You are entitled to request that we delete the personal information that we have collected from you, subject to certain exceptions under applicable privacy laws and regulations.
Right to opt out of sales and sharing of personal information. You are entitled to opt out of sales of your personal information to third parties and to opt out of the disclosure of your personal information to third parties for cross-context behavioral advertising, if applicable. Akili asks for you to opt-in before any data is shared with a third party in a manner that may constitute the sale or sharing of personal information under applicable privacy laws and regulations.
Right to non-discrimination. You have the right not to receive discriminatory treatment for exercising these rights.
To exercise your rights, please simply contact us at legal@akiliinteractive.com or call us at 857-254-3367. We will need to verify your request to exercise your rights. We generally are able to verify such requests by matching the information you provide with information we have collected about you. However, you may be asked to provide additional personal information for verification purposes. We may be unable to fully process your rights if we are unable to verify your request to a reasonable or reasonably high degree of certainty.
You are permitted to use an authorized agent to submit requests on your behalf if we can verify the authorized agent’s authority to act on your behalf (such as pursuant to a power of attorney or if you have separately verified your identity or the relevant authorization with us). You may submit a request via an authorized agent using the contact methods described above.
What if we change the terms of this Privacy Notice?
If we materially change this Privacy Notice, we will notify you by posting a notice on our website or notifying you via the email address you provided. Your continued use of one of Akili’s products or any related service or support following any such notification of changes means that you acknowledge and agree to the revised Privacy Notice.
Contact Information
If you have questions or concerns about our privacy policies or practices, you may contact us at legal@akiliinteractive.com.