NEUROVUS PRIVACY POLICY

Effective Date: 08/01/2026

Last Updated: 07/31/2026

Company: Neurovus, Inc. (“Neurovus,” “we,” “our,” “us”)

Contact: garyroberts@neurovus.com

Your privacy is fundamental to what Neurovus is. This platform only works if the people using it trust it completely. 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 full 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 any one of the following: the Neurovus mobile application, the website www.neurovus.com (“site”), the 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 and self-awareness platform. It is not a clinical system.

Neurovus is NOT:

  • a detector or evaluator of emotional states
  • a mental-health risk assessment tool
  • a provider of therapeutic or clinical guidance
  • a crisis or emergency monitoring service
  • a mental-health diagnostic or treatment tool

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 platform 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

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 to 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.

Account Deletion and Service Separation

When a user deletes their account, or when a user separates from the profession or department associated with their enrollment, all stored biometric pattern data, conversational pattern data, and behavioral interaction data will be permanently deleted within 30 days of the deletion request or confirmed separation. Users who separate from service may submit a deletion request at any time using the contact information in Section 14. Neurovus does not retain individual data after account closure for any purpose, including research or platform improvement, unless the user has separately consented to research data retention under Section 6D.

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
  • routine security testing
  • least-privilege access architecture

Despite these measures, no system is 100% secure. We encourage users to secure their own devices and login information.

A. 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.

B. 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.

The only way individual information reaches another person is if the user chooses to share it. Users control who receives any notification or referral generated by the platform, and that choice is always voluntary. Neurovus will never send individual data to an employer, department, or agency without the user’s explicit, affirmative consent.

Legal Process. If Neurovus receives a subpoena, court order, or other legally compelled demand for individual user data, we will: (a) review the demand and challenge it where we have a good-faith legal basis to do so; (b) notify the affected user as promptly as the law permits, unless notification is prohibited by the order itself; and (c) disclose only the minimum information required to comply. We will not voluntarily cooperate with informal law enforcement or employer requests for individual user data.

C. Aggregate Reporting and Minimum Cell Size
Department-level trend data provided to administrators is aggregated across enrolled participants. To prevent re-identification of individuals in small departments or stations, Neurovus applies a minimum reporting threshold: no aggregate view is displayed unless at least 10 individuals are enrolled and actively contributing data during the reporting period. If enrollment at a given station or department falls below this threshold, trend data for that group is suppressed until the threshold is met.

This threshold applies regardless of department size. A 400-person department reporting data from an 8-person station is subject to the same minimum as an 8-person volunteer company. Neurovus reserves the right to increase this threshold as best practices in de-identification evolve.

D. Research Use (Opt-In Only)
Neurovus may use de-identified, aggregated data to improve the platform and contribute to published research on first responder wellness. Participation in research data contribution is opt-in only. No individual user data is contributed to research without the user’s separate, affirmative consent.

If you consent to research data contribution, you may withdraw that consent at any time. Withdrawal stops future contribution but does not require us to remove data already included in published or submitted research where removal is not technically feasible. Users can manage their research consent preference in account settings or by contacting us at the address in Section 14.

Research conducted using Neurovus data will be conducted in partnership with IRB-approved academic institutions. Neurovus will not share individually identifiable data with research partners under any circumstances.

E. Breach Notification
In the event of a data breach affecting user personal information or biometric pattern data, Neurovus will: (a) notify affected users within 72 hours of confirming the breach, or as soon as reasonably practicable; (b) describe in plain language what data was affected, what we believe occurred, and what steps we are taking; and (c) comply with applicable state breach notification laws. Notifications will be sent to the email address on file for the affected account.

F. We Do Not Sell Your Data
Neurovus does not sell, rent, or trade your personal information or biometric pattern data to any third party. This prohibition applies regardless of how “sale” is defined under applicable state law, including the California Consumer Privacy Act and its amendments. We do not share your data with advertisers, data brokers, or any party whose primary interest is in the data itself rather than in providing services to you.

7. AI DATA PRACTICES

NAVI, the Neurovus conversational wellness assistant, uses a large language model to generate responses. This section explains what information the AI layer receives, what it never receives, and where that processing takes place.

A. Where AI Processing Occurs

NAVI is powered by Claude, a large language model developed by Anthropic, accessed through Amazon Bedrock, a managed service operated by Amazon Web Services (AWS). Neurovus does not send user data to Anthropic’s public API or consumer services. Under this architecture:

  • AI requests are processed within AWS infrastructure and are not shared with Anthropic.
  • Your messages and NAVI’s responses are not used to train Anthropic models or AWS models.
  • Each request is processed statelessly. The AI service does not retain your messages or NAVI’s responses after a request is completed.

Neurovus separately stores your NAVI conversation history within its own systems so that NAVI can maintain continuity with you. That stored history is protected by the two layer encryption model described in Section 6A and is subject to the deletion rights described in Sections 4 and 9.

B. What the AI Layer Receives

When you send a message to NAVI, the AI layer receives only:

  • The text of your message, along with recent messages from the same conversation where needed for continuity
  • A summarized pattern context generated internally by Neurovus from your connected wearable data (such as Garmin, Apple Health, Oura, or WHOOP) and, if you have enabled it, voice derived autonomic biometric data

C. The Drift Profile

The Drift Profile summarizes how your physiological signals are trending compared to your own personal baseline. Neurovus systems calculate these trends internally and convert them into short pattern labels before any information reaches the AI layer. Examples of these labels include:

  • “HRV signal: drifting for 11 days, 22 percent below 14 day personal baseline”
  • “Resting HR signal: above 14 day personal baseline for 8 days”

These labels describe patterns relative to your own baseline only. They are not clinical values, diagnostic thresholds, or assessments of emotional or mental state. NAVI uses them solely as context for a supportive general wellness conversation.

D. What the AI Layer Never Receives

  • Raw wearable or biometric readings
  • Device identifiers
  • Timestamps from wearable data
  • Raw voice recordings
  • Your name, email address, account identifiers, department, or station

Neurovus does not attach identifying information to AI requests. Because your message text is sent as you write it, any personal details you choose to type into a message will be included in that request. We recommend avoiding names or identifying details about yourself or others when talking with NAVI.

E. Changes to AI Processing

If we change our AI provider or processing architecture in a way that affects any commitment in this section, we will update this policy and notify registered users as described in Section 13.

8. COOKIES AND TRACKING TECHNOLOGIES

Neurovus uses cookies and similar technologies on www.neurovus.com to enable core site functions and understand how the site is used. We do not use cookies to serve advertising or track you across third-party websites.

Cookies we set:

  • [SESSION COOKIE: name, purpose, duration; to be completed after site audit]
  • [ANALYTICS COOKIE: name, purpose, duration, provider; to be completed after site audit]
  • [Any additional first-party or third-party cookies; to be completed after site audit]

Your choices. Most browsers accept cookies by default. You can configure your browser to block or delete cookies; doing so may affect some site functionality. California residents and others covered by applicable privacy law may also opt out of certain data collection by [link to opt-out mechanism, to be completed after site audit]. Neurovus honors the Global Privacy Control (GPC) signal as an opt-out of sale or sharing of personal information to the extent required by applicable law.

9. 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.

10. CHILDREN’S PRIVACY

Neurovus is not intended for individuals under 18. We do not knowingly collect or store information about minors. If you believe a minor has provided us with personal information, contact us immediately at garyroberts@neurovus.com and we will delete it promptly.

11. 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
  • generate outputs intended for medical decision-making

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

12. THIRD-PARTY LINKS AND INTEGRATIONS

Wearable integrations (such as Apple Health, Oura, WHOOP, and Garmin) are optional and governed by their own privacy policies. Neurovus does not control third-party data practices. We encourage users to review the privacy policies of any connected services.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. When we do, we will notify registered users by email and update the “Last Updated” date above. Material changes will be communicated with at least 14 days’ notice before they take effect.

14. CONTACT US

For privacy inquiries, data deletion requests, research consent changes, or any questions about this policy:

Email: garyroberts@neurovus.com

Phone: 954-213-9933

Web: www.neurovus.com

We aim to respond to all privacy requests within 5 business days.