Last modified date: January 12, 2018
Akili Interactive Labs, Inc. (“Akili” or “we”) develops cognitive platforms (including the Project: EVO™ platform) which enable multiple clinical products for remote data-capture and intervention. Our proprietary adaptive mechanics allow the software (including embedded software and third party software) to automatically personalize to the patient's ability level with no clinician input required.
Akili is committed to protecting the confidentiality, privacy and security of the data of its clients, associates, suppliers, and website visitors. We want you to understand how we collect and use information, including personally identifiable information, so you can interact with Akili with confidence. Personally Identifiable Information (“PII”) is data that includes a personal identifier like your name, address, email address, social security number, credit card number, and other similar information that can be used to identify you.
Information We Collect
When You Contact Us For Help
If you are a Study Participant, please contact your Researcher for help. You should not contact us through our Sites or social media pages for help.
If you are a visitor to our Sites, you should contact firstname.lastname@example.org for help. Whenever you contact us for help, we collect your name and email address along with additional information you provide in your request so that we can provide you with assistance.
When You Visit a Site
When you use or access our Sites, we may collect and use personally identifiable information, or “PII”, about you, as well as other information.
- Information that you provide directly to us by filling in forms on our Site, including your name, email address, street address, telephone number, or other information.
- Information provided to us when you communicate with us for any reason, including information you provide in emails you send us, or submissions you may make to our blog or content you post through our social media pages.
Information from Other Sources
We do not collect any information about you from other sources outside your interaction with the Sites.
Use of Your Information
We use the information we collect from you primarily to enable us to provide the Sites to you in the best possible manner. In addition, your information may be used as follows:
- De-identified data, including data you provide to us via our Sites, may be used to inform the health community about trends, for publication in scientific journals, for product development, in commercial transactions, for marketing and promotional use, or for sale to interested audiences. See “Sharing of De-identified Data That Does Not Identify You” to learn more.
- To provide you, including via your email address, with information relating to the Sites; and
- To administer our Sites, including by monitoring and analyzing traffic and usage patterns on our Sites.
Sharing Your Information
We don’t sell any data that could identify you, and we only share data about you when it is necessary to provide the Sites. We may sell data, but only when the data is de-identified and aggregated.
Data That Could Identify You
We will only share data that is PII with third parties under the following circumstances:
- With companies that are contractually engaged in providing us with services, such as order fulfillment, email management, credit card processing, and compiling statistics and reports regarding our audience and the users of the Sites. These companies are obligated by contract to safeguard any PII they receive from us.
Such third parties have access to personal information as needed to perform their functions, but they are not allowed to use it for other purposes. We do not sell or rent PII collected through Akili’s Sites to anyone.
Data That Does Not Identify You (De-identified Data)
Akili may sell or share aggregated, de-identified data, including data you provide to us through our Sites, with third party partners and with the public in a variety of ways, such as, but not limited to, by providing research or reports about health and fitness, publishing in scientific journals, using it in product development, and in commercial transactions. When we provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from re-identifying it back to you.
Technologies We Use
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.
“Do Not Track” Requests
Although we would like to honor the browsers set with a “Do Not Track” signal, the Sites do not currently respond to a DNT or similar signal as Akili awaits the results of efforts by the policy and legal community to determine the meaning of DNT and the proper way to respond. However, we believe that consumers should exercise choice regarding the collection of this type of data, which is why we disclose the cookies used and provide links to opt-out of those collection practices below.
We use the following third-party data analytics platforms to improve the Sites in a variety of ways:
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 responsible for the privacy practices other websites use. 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 web sites when you use Akili’s Sites.
How Long We Save your Data
We may store your information indefinitely.
We use commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect on our Sites. These procedures include, but are not limited to, firewalls, encryption, intrusion detection, and monitoring. We also limit access to any PII we receive to employees who need access to that information in order to do their jobs. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your PII, we cannot guarantee that it will be 100% secure. Your transmission of your data to our Sites thus is done entirely at your own risk.
Backups of data that you provide to us through the Sites, such as your email address, will remain in our archive servers.
Email & Other Communications
We may need to contact you about your use of the Sites. These communications are part of the Sites and you may not opt out from receiving them. You can opt out from receiving other communications from us by contacting email@example.com. Further, you acknowledge that features of the Sites may, now or in the future, enable your tablet, mobile phone or other similar device to receive text message (SMS) alerts (the “Text Message Service”). You will be required to opt-in to the Text Message Service if you want the Text Message Service activated. Akili will not charge you for the text message (SMS) alerts you may receive from the Sites. However, message and data rates may apply from your mobile carrier in accordance with your wireless customer agreement with your carrier and you are responsible for any such charges. You should consult your wireless service provider regarding its pricing plans.
Akili’s Sites are hosted and operated in the United States (“US”). By using the Sites, you are consenting to the transfer of your personal information to the US. If you are accessing the Sites from outside the US, please be advised that US law may not offer the same privacy protections as the law of your jurisdiction.
California Privacy Rights
California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes. Akili does not share any California consumer personal information with third parties for marketing purposes without consent.
California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.
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 PII, 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.
Akili Interactive Labs, Inc.
125 Broad Street, 4th floor
Boston, MA 02110
Attn: Legal Affairs