NEUROVUS PRIVACY POLICY

Effective Date: 01/01/2025
Last Updated: 06/03/2026
Company: Neurovus, Inc.
Contact: garyroberts@neurovus.com

Your privacy is very important to Neurovus, Inc. (“Neurovus,” “we,” “our,” “us”).  We are committed to protecting your privacy consistent with the highest standards and best practices of organizations doing business on the internet.  We also maintain transparency about how we use and safeguard your information. This Privacy Policy explains:

  • What information we collect
  • How we use it
  • How long we retain it
  • How we protect it
  • Your rights and choices
  • Important limitations of our system

By using the any one of the following: Neurovus mobile application, the website www.neurovus.com (“site”), AI assistant (“NAVI”), and related services (“Services”) (collectively, the “Neurovus Platform”), you agree to this Privacy Policy.


1. WHAT NEUROVUS DOES (AND DOES NOT) DO

The Neurovus Platform is a general wellness platform designed to help users build awareness of short-term

Neurovus:

  • does not detect or evaluate emotional states
  • does not assess mental-health risk or severity
  • does not provide therapeutic or clinical guidance
  • does not monitor for crises or emergencies
  • does not offer mental-health diagnosis or treatment

All conversational interactions, biometric insights, and wellness nudges within Neurovus are educational in nature and intended solely for general self-awareness and wellness exploration.


2. INFORMATION WE COLLECT

We collect only the information required to provide personalized wellness interactions and maintain app functionality.

A. Personal Account Information

  • Name
  • Email address
  • Password or authentication credentials
  • Optional demographic information provided by the user

B. Biometric Pattern Data

(Collected through connected wearables such as Apple Health, Oura, WHOOP, Garmin, etc, and through optional voice biometric input.)

We collect:

  • heart rate variability (HRV)
  • sleep patterns
  • recovery patterns
  • daily strain/load
  • Voice-derived autonomic biometric data (if voice input is enabled — see Section 2F below)
  • activity/movement data
  • other non-clinical wellness metrics

Important:
Neurovus analyzes patterns only.
We do not interpret these metrics as emotional states, stress levels, or clinical indicators.

C. Behavioral Interaction Data

We may collect:

  • journaling frequency
  • interaction timing
  • app usage frequency
  • response patterns
  • engagement trends

We do NOT collect:

  • the content of journals
  • private user reflections
  • mental-health details
  • emotional disclosures

Only patterns, not contents.

D. Conversational Pattern Data

For NAVI’s adaptive timing (not emotional inference), we analyze:

  • length of messages
  • timing/cadence
  • interaction style
  • linguistic structure

We do not analyze:

  • sentiment
  • emotion
  • psychological meaning

Note on voice input: When a user chooses to interact with NAVI by voice, the same pattern-only limitations apply. Neurovus does not perform emotional tone classification or sentiment analysis on voice input. Voice interactions are transcribed for structural pattern analysis only. See Section 2F for voice biometric data collected separately through the acoustic biometric feature.

Neurovus does not perform sentiment analysis or emotional interpretation.

E. Device Data

  • device type
  • OS version
  • app version
  • IP address
  • crash logs
  • usage analytics

Used strictly for app performance and security.

F. Voice-Derived Autonomic Biometric Data (Optional Feature)
This section applies only when the voice biometric feature is enabled by the user. This feature is optional and may be toggled off at any time.

What we collect
When the voice biometric feature is enabled, Neurovus analyzes specific acoustic properties of a user’s voice to derive an autonomic biometric signal. This analysis is limited to:

  • Acoustic frequency characteristics associated with autonomic nervous system function
  • Vocal rhythm and respiratory patterning reflected in speech cadence
  • Signal variation over time compared to the user’s personal rolling baseline

This data is used solely to generate a vagal tone indicator — a physiological biometric signal reflecting autonomic nervous system state, comparable in function to heart rate variability (HRV) derived from a wearable device.

What we do NOT collect or analyze
Voice-derived autonomic biometric analysis does not include and is expressly prohibited from including:

  • Emotional state classification of any kind
  • Sentiment analysis
  • Stress or distress inference
  • Mood or affect detection
  • Psychological meaning derived from speech content
  • Speaker identification or voice fingerprinting beyond session continuity

Critical distinction: Vagal tone derived from voice is a physiological biometric measurement. Neurovus analyzes acoustic signal properties — frequency, rhythm, and variation — in the same way a wearable analyzes electrical signal properties to derive HRV. Neither process infers, classifies, or evaluates emotional or psychological state. The output is an autonomic nervous system pattern indicator, not a mental or emotional assessment.


Retention

Voice-derived autonomic biometric data follows the same rolling-window retention model as other biometric pattern data: retained for up to 120 days, then automatically and permanently deleted. Raw voice recordings are not stored. Only the extracted acoustic pattern values are retained.

Consent and control

  • Voice biometric analysis is optional and requires explicit user opt-in.
  • Users may disable this feature at any time without affecting other platform functionality.
  • Users may request deletion of all voice-derived biometric data independently of their full account deletion request.

3. HOW WE USE YOUR INFORMATION

Neurovus uses your information solely to:

A. Provide general wellness insights

  • short-term biometric pattern comparison
  • pattern-change notifications (non-clinical)
  • journaling/reflection prompts

B. Operate the NAVI wellness assistant

NAVI provides:

  • general education
  • reflection prompts
  • self-awareness check-ins
  • optional information on finding wellness professionals

NAVI does not interpret emotions, mental state, distress, diagnosable conditions, or crisis risk.

C. Personalize timing of wellness nudges

Nudges may be based on:

  • Biometric pattern variation (wearable-derived)
  • Vagal tone pattern variation (voice-derived autonomic biometric data, if feature is enabled)
  • behavioral engagement
  • conversational pattern characteristics

NAVI never uses emotional interpretation in its personalization model.

Voice-derived data used in personalization is limited to autonomic biometric pattern signals only. No emotional inference, sentiment classification, or psychological assessment is used for any purpose.

D. Improve the platform

Aggregated, anonymized data may be used to:

  • enhance general wellness algorithms
  • evaluate app performance
  • understand broad user engagement trends

We do not sell or share with third parties personally identifiable data for advertising or marketing unless you have authorized us to do so.


4. DATA RETENTION (ROLLING-WINDOW MODEL)

To protect privacy and minimize long-term risk, Neurovus uses short rolling retention windows:

A. Biometric Pattern Data — retained up to 120 days

Used for general pattern comparison only.

B. Behavioral Interaction Data — retained up to 90 days

Supports adaptive timing and lag-time analysis.

C. Conversational Pattern Data — retained 60–90 days

Patterns only, not message content.

Automatic Deletion

When each window closes:

  • older data is permanently deleted
  • only the rolling slice is kept
  • no long-term behavioral or emotional profile is created

Neurovus does not maintain multi-year behavioral, emotional, or biometric archives.


5. NO DATA EXPORT / NO PORTABILITY

To protect user privacy and prevent re-identification or misuse of sensitive pattern data:

  • Neurovus does not provide data export or download features
  • Neurovus does not transmit behavioral or biometric data to users or third parties upon request

Users retain the right to request full data deletion at any time.

This model protects user privacy and ensures wellness data is not misinterpreted outside the platform.


6. HOW WE PROTECT YOUR DATA

We use industry-standard safeguards including:

  • encryption in transit and at rest
  • access controls
  • anonymization for research use
  • routine security testing
  • least-privilege access architecture

Despite these measures, no system is 100% secure. Users assume responsibility for securing their own devices and login information.

Conversation Data Encryption

Neurovus applies a two-layer encryption model to all user conversations with NAVI. User prompts and their associated AI-generated responses are encrypted at the application layer before being written to our database, and again at the storage layer. This means that access to the database alone is insufficient to read conversation content. A secondary encryption key—maintained separately from the primary data store—is required to decrypt individual conversations. This architectural decision ensures that even in the event of unauthorized database access, conversation content remains protected. We treat user conversation data as among the most sensitive information we hold, and this dual-encryption approach reflects that standard.

Despite these measures, no system is 100% secure. Users assume responsibility for securing their own devices and login information.

Institutional and Employer Data Sharing

Individual participant data is never shared with employing departments, agencies, unions, or command staff. Departments receive only de-identified, aggregated trend data. No individual record, flag, pattern, or interaction is accessible to an employer under any circumstance.

7. COOKIES

We may place a “cookie” on your personal computer. A cookie is a small computer file that our computer sends to your computer and that your computer sends back to us each time you make a request from our site. Cookies help us recognize you when you visit our site again. We use cookies on our site to collect session data for several purposes to personalize and improve your individual viewing experiences on our site. Most Internet browsers automatically accept cookies. However, you can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the sites you visit. If you decide not to accept our cookies, you will still be able to access those parts of our site that are available to the general public, but you will not be able to view some information on our site, use some features designed to enhance your experience at our site or access many of the services offered at our site.


8. YOUR RIGHTS AND CHOICES

Regardless of jurisdiction, Neurovus provides the following rights:

A. Right to Delete

Users may request immediate deletion of all stored data.

B. Right to Restrict

Users may disable:

  • adaptive nudges
  • biometric connections
  • activity data sharing

C. Right to Access (High-Level Summary Only)

We may provide a high-level overview of:

  • what categories of data are stored
  • retention periods
  • deletion status

We do not provide detailed logs, message histories, or raw biometric/behavioral patterns.

D. Right to Withdraw Consent

Users can revoke wearable permissions or data sharing at any time.


9. CHILDREN’S PRIVACY

Neurovus is not intended for individuals under 18.
We do not knowingly collect or store information about minors.


10. NO MEDICAL, MENTAL-HEALTH, OR EMERGENCY SERVICES

Neurovus is not a clinical or diagnostic system.
It does not:

  • monitor for crises
  • detect emotional states
  • assess mental health
  • provide urgent intervention
  • replace professional care

If you are experiencing an emergency, call your local emergency services.


11. THIRD-PARTY LINKS AND INTEGRATIONS

Wearable integrations (such as Apple Health or WHOOP) are optional and governed by their own privacy policies.
Neurovus does not control third-party data practices.


12. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically.
When we do, we will notify users and update the “Effective Date” above.


13. CONTACT US

For privacy inquiries, data deletion requests, or questions:

Email: garyroberts@neurovus.com