Privacy Policy for Lumos

Effective Date: 9/1/2024

Lumos Health Inc. ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how Lumos ("the App") and the Lumos glasses ("the Device") collect, use, and share your information. We also provide additional information for clinical trial participants in a separate section below. By using our services, you agree to the collection and use of information in accordance with this policy.

1. Important Information About Lumos Glasses

The Lumos glasses, the hardware itself, do not collect any data. However, if you use the Lumos smartphone companion app, the app collects Bluetooth sensor data from the glasses. The app interprets these data, and for clinical users, the data may be stored for research purposes. For general users, the data is stored for general use and personalization purposes.

2. Location Permissions and Data Usage

The Lumos app requests location permissions on devices running Android 11 and above to enable Bluetooth functionality, as required by the Android operating system. However, Lumos does not collect, use, or store any location data. Location permissions are solely used to enable the app to connect with the Lumos glasses via Bluetooth, and no location data is recorded or shared.

3. Information We Collect

• Personal Information: When you create an account, we may collect your email address and other contact information for authentication and account management.
• Bluetooth Sensor Data: The app collects data from the Lumos glasses via Bluetooth, including information such as usage time of light therapy and ambient light levels.
• Cognitive Test Data: The App conducts cognitive tests, such as the Psychomotor Vigilance Task (PVT) and word-pair tests. We collect and store the results of these tests to monitor your cognitive performance and track your progress.
• Health and Behavioral Information: We collect health-related information such as your sleep patterns, responses to therapy, and other data related to the use of the Lumos glasses.
• Survey Data: We link to Qualtrics surveys, and upon completion, the survey data is sent back to Firebase, where it is stored and analyzed for research purposes.
• Communication Data: With your consent, we may collect information from email exchanges, text messages, and recorded video calls for participant management.

4. How We Use Your Information

• To Provide and Improve Our Services: We use collected data to deliver and enhance the functionality of the App and Device, ensuring an optimal user experience.
• Personalization: Information collected is used to personalize your experience, including adjusting light therapy settings based on your preferences and test results.
• Research and Development: For clinical users, the Bluetooth sensor data and other information collected may be used for research purposes to improve the effectiveness of our therapy solutions. For general users, the data is stored for personalization and general use.
• Communication: We use your contact information to provide you with important updates, respond to your inquiries, and send notifications related to your account or service.

5. How We Share Your Information

• With Service Providers: We may share your information with third-party service providers who assist us in operating the App and providing services. These parties are contractually obligated to maintain the confidentiality of your information.
• Legal Compliance: We may disclose your information if required by law or to comply with legal processes.

6. Data Security

• Cloud Data Protection: Participant data stored on the cloud, including Bluetooth sensor data from the glasses, is protected using encryption and authentication algorithms provided by Google.
• Physical Security: Non-anonymized clinical data will be securely stored on password-protected hard drives for 15 years after the trial, in compliance with regulatory requirements.

7. Data Sharing and Retention

• Public Data Sharing: After the clinical trial, anonymized data will be shared in publicly available databases (e.g., UW Dataverse, FRDR) for research purposes.
• Retention of Non-Anonymized Data: Non-anonymized data will be stored for up to 15 years post-trial for follow-up purposes, particularly regarding adverse events.

8. Your Choices

• Access and Update: You can access and update your account information through the App.
• Data Deletion Requests: At Lumos Health Inc., we respect your privacy and are committed to giving you control over your personal data. If you would like to request the deletion of your data associated with our services, you can do so by contacting us directly.
• Please send your data deletion request to hello@lumosglasses.com with the following information:
  • Your full name
  • The email address associated with your account
  • A description of the data you wish to have deleted
• We will process your request and respond within 30 days. Please note that in some cases, certain data may need to be retained for legal or regulatory reasons, even after a deletion request has been processed.
• Opt-Out: You may opt out of receiving promotional communications by following the instructions in those messages or contacting us directly.

9. Children’s Privacy

Our App and services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe we have collected such information, please contact us to remove it.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the effective date. We encourage you to review this Privacy Policy periodically.

11. Contact Us

If you have any questions about this Privacy Policy or your data, please contact us at:

Lumos Health Inc.
hello@lumosglasses.com

12. Additional Privacy Information for Clinical Trial Participants

Participants using the clinical version of the Lumos app may have additional data collected and handled in the following ways:

• Clinical Data Storage: All clinical data will be stored securely on Google Firebase under a custom project. This data is used to manage participant status and monitor protocol adherence via a password-protected dashboard, accessible only by authorized teams (e.g., investigators, data safety monitoring board).
• Other Data: Any participant communication data, including email exchanges, text messages, and recorded video calls (with consent), will be stored on Google Drive.
• Data Sharing After the Trial: Upon trial completion, anonymized data will be shared on publicly available databases (e.g., UW Dataverse or FRDR). Non-anonymized data will be securely stored for 15 years on password-protected hard drives, in case follow-up is needed regarding adverse events.
• Data Locking: Prior to data analysis, a snapshot of the study data will be taken by the data safety and monitoring team. This ensures data integrity before any further analysis is conducted.
• Participant Privacy Protection: All data stored in the cloud will be encrypted and protected using Google's authentication algorithms. Clinical staff, including any students, will be trained and required to sign confidentiality agreements prohibiting the sharing of participant data outside of authorized personnel.