Aluna Patient User Privacy Policy
This notice describes how Personal Data (dened below) and/or medical information about you may be
used and disclosed and how you can obtain access to this information. Please review it carefully.
INTRODUCTION
We at Knox Medical Diagnostics, Inc. d/b/a Aluna (“we”, “us”, the “Company”, or “Aluna”) value your
privacy and are committed to keeping your personal data condential. We use your data solely in the
context of providing the Aluna application (the “App”) to connect you with your healthcare provider
(each, a “Provider User”) who may monitor and analyze your health conditions through lung health data
such as FEV1% and PEF (as dened below) that we collect through an FDA-cleared digital spirometry
device (the “Device”) and information about your medications, symptoms, environmental factors, and
activity levels that you report on the App. The App and the Device, including all relevant content and
functionality associated with the App and the Device, are referred to collectively as the “Services.”
Privacy Policy Applicability
This Patient User Privacy Policy applies to personal data that Aluna collects from Patient Users of the
Aluna App, the Aluna Device, and the Services (“Personal Data”). The term “Personal Data” includes
any information that can be used on its own or with other information in combination to identify or
contact one of our users. Some of the Personal Data we collect and transmit may be considered “health
data” (i.e., data related to your physical health), “protected health information” or “PHI” (i.e., information
that relates to your past, present, or future physical health or condition(s); the provision of health care
to you; or the past, present, or future payment for the provision of health care to you), and/or medical
records as dened by state law.
We believe that privacy and transparency about the use of your Personal Data are of utmost
importance. Therefore, our privacy practices are intended to comply with the Health Insurance
Portability and Accountability Act (“HIPAA”) and relevant state law related to the use and disclosure of
medical records, where applicable. Additionally, in this Patient User Privacy Policy, we provide you with
detailed information about our collection, use, maintenance, and disclosure of your Personal Data. The
Patient User Privacy Policy explains what kind of information we collect, when and how we might use
your Personal Data, how we protect Personal Data, and your rights regarding your Personal Data.
For additional information related to how we use and disclose your Personal Data, health data, PHI,
and/or medical records data, please contact our Privacy Ofcer at inderjit@alunacare.com.
Note regarding third-party sites: Our Services may contain links to other sites that are not operated
by Aluna. If you click a third-party link, you will be directed to that third party’s site. We strongly advise
you to review the privacy policy(ies) of every site you visit. Aluna has no control over and assumes no
responsibility for the content, privacy policies, or practices of any third-party sites or services. This Patient
User Privacy Policy does not apply to your use of or access to any third-party sites or services.
Agreement to Patient User Privacy Policy Terms
BY ACCESSING AND/OR USING THE SERVICES YOU ARE ACKNOWLEDGING THAT YOU HAVE
READ AND AGREE TO THE TERMS OF THIS PATIENT USER PRIVACY POLICY. IF YOU DO NOT
AGREE, YOU MUST IMMEDIATELY CEASE USING THE SERVICES.
Patient User Privacy Policy Updates
Please note that we occasionally update this Patient User Privacy Policy, and it is your responsibility to stay
up to date with any amended versions. Any revisions to the Patient User Privacy Policy will be posted
on the Patient User login page(s) of the App. Any changes to this Patient User Privacy Policy will be
effective immediately upon providing notice via the Patient User login page(s) and will apply to all
Personal Data that we maintain, use, and disclose. If you continue to use the Services following such
notice, you are agreeing to those changes.
Aluna Patient User Privacy Policy
Version ___ Last Update: August 9, 2024
Aluna Patient User Privacy Policy
Account Deletion
If at any point you no longer agree to the use and disclosure of Personal Data, as described in this
Patient User Privacy Policy, you can delete your user account on the App (“User Account”) by sending a
deletion request to support@alunacare.com with the following information:
• Your name;
• Your login email address; and
• A statement that you are requesting account deletion.
Questions or Concerns
If you have any questions or concerns after reading this Patient User Privacy Policy, please do not
hesitate to contact us at support@alunacare.com. We appreciate your feedback.
COLLECTION AND USE OF PERSONAL DATA
What Personal Data Does Aluna Collect?
We collect six types of information from our Patient Users: (i) demographic data; (ii) device data;
(iii) self-reported health data; (iv) support data; (v) technology data; and (vi) geolocation data. Each
category of data is explained in depth below.
Demographic Data: Aluna collects demographic data from Patient Users, which may include,
but not be limited to, your name, birth date, gender, height, ethnicity, phone number, and e-mail
address. The collection of this demographic data is primarily used to create your User Account,
which you can use to securely receive the Services.
Device Data: We will collect information about your condition from a connected digital spirometry
device. This will include data about your Forced Expiratory Volume (“FEV1%”) and Peak Expiratory
Flow (“PEF”). We collect this information to provide you with the Services and to provide your
health care provider (i.e., the Provider User associated with your Device) with the information
necessary to monitor and analyze your health condition.
Self-Reported Health Data: In addition to Demographic and Device Data, we will collect
information about circumstances that may be affecting your health including medication usage,
respiratory symptoms, environmental factors, and exercise activities that you report via the
App. We collect this information to provide you with the Services and to provide your designated
Provider User with the information necessary to monitor and analyze your health condition.
Support Data: If you contact us for support or to lodge a complaint, we may collect technical or
other information from you through log les and other technologies, some of which may qualify
as Personal Data. Such information will be used for the purposes of troubleshooting, customer
support, software updates, and making improvements to the App and related Services in
accordance with this Patient User Privacy Policy. Calls with Aluna may be recorded or monitored
for training, quality assurance, customer service, and reference purposes.
Technology Data: We use common information-gathering tools and similar technologies to
automatically collect information, which may contain Personal Data from your computer or
mobile device as you navigate our App or interact with emails or other communications we have
sent you. The information we collect may include your IP address (or proxy server), Device and App
identication numbers, browser type, Internet service provider and/or mobile carrier, the pages
and les you viewed, your searches, your operating system and system conguration information,
and date/time stamps associated with your usage. This information is used to analyze overall
trends, help us provide and improve our Services, and ensure the proper functioning and security
of the App and Services.
Geolocation Data: With your consent, we may collect information about your location from your
mobile device (“Geolocation Data”). We use Geolocation Data for the purposes of identifying
environmental factors that could affect your lung health.
Aluna Patient User Privacy Policy
How Will Aluna Use Your Personal Data?
Aluna processes your Personal Data based on legitimate business interests, the fulllment of our
Services to you, compliance with our legal obligations, and/or your consent. We only use or disclose your
Personal Data when it is legally mandated or where it is necessary to fulll those purposes described
in this Patient User Privacy Policy. Where required by law, we will ask for your prior consent before
disclosing your Personal Data to a third party.
More specically, Aluna processes your Personal Data for the following legitimate business purposes:
• To provide the Services;
• To fulll our obligations to you under the Patient User Terms of Use;
• To communicate with you about and manage your User Account and/or the Device;
• To properly store and track your data within our system;
• To respond to lawful requests from public and government authorities, and to comply with
applicable state/federal law, including cooperation with judicial proceedings and court orders;
• To protect our rights, privacy, safety, or property, and/or that of you or others by providing proper
notices, pursuing available legal remedies, and acting to limit our damages;
• To handle technical support and other requests from you;
• To enforce and ensure your compliance with our Patient User Terms of Use or the terms of any
other applicable services agreement we have with you;
• To manage and improve our operations and Services, including the development of additional
functionality;
• To manage payment processing, if any;
• To evaluate the quality of service you receive, identify usage trends, and improve your user
experience;
• To keep our Services safe and secure;
• To send you information about changes to our terms, conditions, and policies; and
• To enable you to share Personal Data with your designated Provider User, which enables that
Provider User to monitor your condition as they deem appropriate.
Does Aluna Use Personal Data for Analytics?
Aluna or our third-party service providers may use Personal Data to monitor or analyze the use of the
Services. Presently, Aluna uses Firebase and internal analytics tools to gather insights on how you use
and interact with the Services.
Where Is Personal Data Processed?
The Personal Data we collect through the Services will be stored on secure servers in the United States.
Personal Data may be transmitted to third parties, which parties may store or maintain the data on
their secure servers. These third parties are not permitted to transfer your Personal Data outside of the
United States. The App is “native” to your device, meaning information you enter into the App may also
be stored directly on the device that you use to access and enter information into the App.
With Whom Does Aluna Share Personal Data?
We may share your personal information with the following categories of individuals/entities:
Business Partners and Vendors: We share Personal Data with a limited number of partners,
service providers, and other persons/entities who help run our business (“Business Partners”).
Specically, we may employ third-party companies and individuals to facilitate our Services,
provide Services on our behalf, perform Service-related functions, or assist us in analyzing how
our Services are used. Our Business Partners are contractually bound to protect your Personal
Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of
Personal Data may include, but is not limited to, the provision of services such as data hosting, IT
services, customer services, and payment processing.
Our Advisors: We may share your Personal Data with third parties that provide advisory services
to Aluna, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively,
Aluna Patient User Privacy Policy
“Advisors”). Personal Data will only be shared with Advisors if Aluna has a legitimate business
interest in the sharing of such data.
Provider Users: Your App and Device must be assigned to one or more Provider Users. As part of
the Services, we will share your Personal Data with your assigned Provider User(s). If at any point
you want to deny access to one or more Provider Users or be assigned to a new Provider User, you
can do so by emailing support@alunacare.com.
Third Parties Upon Your Direction or Consent: You may direct Aluna to share your Personal Data
with third parties. Upon your request and consent, we may share such Personal Data with those
third parties that you identify.
Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint
venture, assignment, transfer, or other disposition of all or any portion of Aluna’s corporate entity,
assets, or stock (including in connection with any bankruptcy or similar proceedings), we may
share your Personal Data with a third party.
Third-Party Researchers: With your consent, we may share de-identied data that is derived from
your Personal Data with third parties for research purposes. This means that the data we share
with third parties for research purposes will not identify you.
Government and Law Enforcement Authorities: If reasonable and necessary, we may share your
Personal Data to: (i) comply with legal processes or enforceable governmental requests, or as
otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that
violate this Patient User Privacy Policy or the Patient User Terms of Use; or (iii) bring legal action
against someone who may be violating the Patient User Terms of Use or who may be causing
intentional or unintentional injury or interference to the rights or property of Aluna or any third
party, including other users of our Services.
How Long Does Aluna Retain Personal Data?
Aluna retains your Personal Data only as long as necessary and as required for our business operations,
the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact period of
retention will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the personal
risk of harm for unauthorized use or disclosure; (iii) the purposes for which we process your Personal
Data, including whether those purposes can be achieved through other means; and (iv) business
operations and legal requirements. In general, Aluna strives to retain your data for no longer than 10
years after your Account is closed (the “Retention Period”); however, the above factors may extend or
decrease this Retention Period.
At the end of the applicable Retention Period, we will remove your Personal Data from our databases
and will require that our Business Partners remove any identiable Personal Data from their databases.
If there is any data that we are unable to delete entirely from our systems for technical reasons, we will
put in place appropriate measures to prevent any further processing of such data. Please note that once
we disclose your Personal Data to third parties, we may not be able to access that Personal Data and we
cannot force the deletion or modication of such information by third parties.
Aluna and its Business Partners reserve the right to continue using de-identied data indenitely,
even after Personal Data has been removed from Aluna’s databases. We may continue to disclose de-
identied data to third parties in a manner that does not reveal personal information, as described in
this Patient User Privacy Policy. Our continued use of de-identied data will comport with applicable
law.
How Does Aluna Protect Minors?
The Children’s Online Privacy Protection Act (“COPPA”) protects against the collection of identiable
information from children under the age of 13. If your child is under the age of 13, you must give consent
prior to allowing your child to use the Services.
The Aluna App does not allow children or any user to make a child’s information publicly available. You
have the right to review or ask us to delete your child’s personal information, as well as to refuse further
collection or use of your child’s personal information. To exercise these rights, please contact us at
support@alunacare.com with your request.
If you are a resident of California under the age of 18 and have registered for a User Account with us,
you may ask us to remove Personal Data that you have entered on the App.
Aluna Patient User Privacy Policy
PATIENT USER RIGHTS
What Rights Do Patient Users Have Concerning Their Personal Data?
As a user of Aluna’s Services, you may have certain rights relating to your Personal Data. These rights
are subject to local data protection and privacy laws, and may include the right to:
• Access Personal Data held by Aluna;
• Erase/delete your Personal Data, to the extent permitted by applicable data protection and
privacy laws and to the extent technologically feasible;
• Receive communications related to the processing of your Personal Data;
• Restrict the processing of your Personal Data to the extent permitted by law;
• Object to the further processing of your Personal Data, including the right to object to marketing;
• Request that your Personal Data be transferred to a third party, if possible;
• Receive your Personal Data in a structured, commonly used, and machine-readable format;
and/or
• Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal
Data, ensure it is complete.
Where the processing of your Personal Data by Aluna is based on consent, you have the right to
withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the
above rights, please contact us at support@alunacare.com.
How Can Patient Users Update, Correct, or Delete Personal Data or Their
User Account?
You have the right to request restrictions on uses and disclosures of your Personal Data. While we are
not required to agree to all restriction requests, we will attempt to accommodate reasonable requests
when appropriate.
If you need to make changes or corrections to information contained in your User Account, you
may contact us at support@alunacare.com. In order to comply with certain requests to limit use of
your Personal Data, we may need to terminate your ability to access and/or use some or all of the
Services. BY REQUESTING TO LIMIT USE OF YOUR PERSONAL DATA OR DELETE PERSONAL
DATA, YOU ACKNOWLEDGE AND AGREE THAT ALUNA WILL NOT BE LIABLE TO YOU FOR ANY
CORRESPONDING LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS
NECESSARY TO COMPLY WITH YOUR REQUEST.
You have the right to request deletion of any Personal Data from your User Account or the Services.
To request deletion of your Personal Data, please email us at support@alunacare.com and include
a description of the Personal Data you would like removed. We will respond to all requests for data
deletion as soon as reasonably possible.
Should you decide to delete your User Account entirely, you may do so by emailing
support@alunacare.com. By terminating your User Account, you agree that you will not be able to
access any information previously contained in your User Account. You further understand that it
may not be technologically possible to remove all of your Personal Data from our systems. While we
will use reasonable efforts to remove your Personal Data, the need to back up our systems to protect
information from inadvertent loss means a copy of your Personal Data may exist in a non-erasable form
that will be difcult or impossible for us to locate or remove.
PROTECTION OF PERSONAL DATA
Is Personal Data Secure?
Aluna understands the importance of data condentiality and security. We use a combination of
reasonable physical, technical, and administrative security controls to: (i) maintain the security and
integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of
your Personal Data; and (iii) protect against unauthorized access to or use of such information in our
possession or control that could result in substantial harm to you.
While Aluna uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH
TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA. ALUNA IS
Aluna Patient User Privacy Policy
UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED
OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT
BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL,
TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CANNOT
ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO
US. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE
FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA
AT ANY TIME.
What Safeguards Does Aluna Have in Place to Secure Personal Data?
Aluna stores Personal Data on secured servers and uses a combination of technical, administrative, and
physical safeguards to protect your personal information. Such safeguards include, but are not limited
to, authentication, encryption, backups, and access logs and controls.
How Can Patient Users Protect Their Personal Data?
You are solely responsible for preventing unauthorized access to your devices and your User Account
by protecting your account credentials and limiting access to your devices. Aluna has no access to or
control over your device’s security settings, and it is your responsibility to implement any device-level
security features and protections you feel are appropriate (e.g., password protection, encryption, remote
wipe capability). We recommend that you take all appropriate steps to secure any device that you use to
access our Services.
Please note that Aluna will never send you an email requesting condential information, such as
account numbers, usernames, passwords, or Social Security Numbers. If you receive a suspicious email
from Aluna, please notify us at support@alunacare.com.
Further, if you know of or suspect any unauthorized use or disclosure of your User Account information
or any other security concern, please notify Aluna immediately.
What If Aluna Experiences a Data or Security Breach?
In the event of a data or security breach, Aluna will take the following actions: (i) promptly investigate
the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities
within Aluna’s control which may have given rise to the security incident; (ii) comply with laws and
regulations directly applicable to Aluna in connection with such security incident; (iii) as applicable,
cooperate with any affected Aluna user or client in accordance with the terms of Aluna’s contract with
such user or client; and (iv) document and record actions taken by Aluna in connection with the security
incident and conduct a post-incident review of the circumstances related to the incident and actions/
recommendations taken to prevent similar security incidents in the future. Aluna will notify you of any
data or security breaches as required by and in accordance with applicable law.
ADVERTISING, MARKETING, AND TRACKING
Does Aluna Send Marketing or Advertisement Materials?
Presently, Aluna does not send marketing or advertisement materials. In the event that Aluna uses
your Personal Data to contact you with newsletters, marketing or promotional materials, or other
information that may be of interest to you, you may opt out of receiving such messages at any time by
following the unsubscribe link within the applicable message or by contacting us.
Can Patient Users Opt Out of Receiving Communications from Aluna?
We may send important and time-sensitive communications, including emails, to you regarding your
User Account, the Services, or the Device. You can choose to lter any User Account, Services, and
Device emails using your email settings, but we do not provide an option for you to opt out of these
communications.
If you consent to receive marketing or other communications not related to your User Account,
the Services, or the Device, we will provide you with the option to opt out of such marketing
communications within the applicable message.
Aluna Patient User Privacy Policy
What Is Aluna’s Cookie Policy?
Cookies are small les that a web server sends to your computer or device when you visit a web
application to keep track of your activity on that site. Cookies also exist within applications when
a browser is needed to view or display certain content within the application. Cookies hold a small
amount of data specic to a web application, which can later be used to help remember information
you entered in the application (like your email or username), preferences selected, and movement within
the application.
Presently, Aluna does not use cookies.
Do Not Track Disclosure
Some web browsers may transmit do not track (“DNT”) signals to websites with which the user
communicates. To date, there is no industry standard for DNT, and users cannot know how a given
company responds to a DNT signal they receive from browsers. Aluna is committed to remaining
apprised of DNT standards. However, Aluna does not support DNT browser settings and does not
currently participate in any DNT frameworks that would allow Aluna to respond to signals or other
mechanisms regarding the collection of your personal information.
CALIFORNIA PRIVACY RIGHTS
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and
obtain from us an annual list identifying the categories of personal customer information which we
shared, if any, with our afliates and/or third parties in the preceding calendar year for marketing
purposes. This list will be provided free of charge. Contact information for such afliates and/or third
parties must be included. If you are a California resident and would like a copy of this notice, please
submit a written request to the following address:
Knox Medical Diagnostics, Inc. d/b/a Aluna
650 California Street, Suite 700
San Francisco, CA 94108
