Introduction
At Nuvinoo, we take privacy seriously—especially when it comes to children. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our wellness wearable device and companion mobile application.
Please read this policy carefully. By using Nuvinoo, you agree to the collection and use of information in accordance with this policy.
Children's Privacy — Our Commitment
Nuvinoo is designed for parents and guardians to monitor their children's wellness. We are committed to protecting children's privacy and complying with applicable laws, including:
- COPPA (Children's Online Privacy Protection Act) in the United States
- GDPR-K (provisions for children under GDPR) in the European Union
- Similar regulations in other jurisdictions
Important: Only parents or legal guardians may create accounts and manage data on behalf of children. We do not knowingly collect personal information directly from children.
Parents have the right to review, delete, or refuse further collection of their child's data at any time by contacting us.
Verifiable Parental Consent
To comply with COPPA, we verify parental consent through:
- Email verification with a confirmation link
- SMS verification or government ID check for sensitive operations (when required)
Wellness Device Disclaimer
Nuvinoo is a general wellness device designed to provide insights into your child's sleep, activity, and mood patterns. It is NOT intended to:
- Diagnose, treat, cure, or prevent any disease or medical condition
- Replace professional medical advice or diagnosis
- Monitor for specific health conditions or emergencies
If you have concerns about your child's health, please consult with your pediatrician.
Information We Collect
Account Information
When you create an account, we collect:
- Email address
- Name (parent/guardian)
- Password (stored securely using encryption)
- Child's first name and age (for personalization)
Wellness Data from the Wearable
The Nuvinoo wearable device collects:
- Sleep data: Sleep duration, sleep quality indicators, bedtime and wake time
- Activity data: Steps, movement patterns, active minutes, outdoor time estimates
- General wellness indicators: Rest patterns and activity levels throughout the day
Note: Nuvinoo does not collect precise GPS location, audio, video, photos, or biometric identifiers.
App Usage Information
We automatically collect certain information when you use our app:
- Device type and operating system
- App version
- Features used and interaction patterns
- Crash reports and performance data
How We Use Your Information
We use the information we collect to:
- Provide our services: Display wellness insights, trends, and recommendations in the app
- Generate AI insights: Analyze patterns to provide personalized suggestions for your child's wellbeing
- Improve our product: Understand how families use Nuvinoo to make it better
- Communicate with you: Send important updates about your account or our services
- Ensure security: Protect against unauthorized access and maintain the integrity of our systems
Data Sharing and Disclosure
We do not sell your personal information or your child's wellness data. We may share information only in the following circumstances:
- Service providers: Trusted third parties who help us operate our services (e.g., Supabase, Firebase) under GDPR-compliant Data Processing Agreements (DPAs)
- Legal requirements: When required by law, legal process, or to protect the rights and safety of Nuvinoo, our users, or others
- Business transfers: In connection with a merger, acquisition, or sale of assets, with continued protection of your data
- With your consent: When you explicitly authorize us to share information
Data Security
We implement industry-standard security measures to protect your data:
- Encryption of data in transit (TLS/SSL) and at rest
- Secure authentication and access controls
- Regular security audits and vulnerability assessments
- Limited employee access to personal data on a need-to-know basis
While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.
Data Protection Impact Assessment
We have conducted a Data Protection Impact Assessment (DPIA) as required by GDPR for the processing of children's health data. This assessment evaluates risks to privacy and outlines measures to mitigate those risks.
Privacy by Design
We build privacy protections into our product from the ground up, including:
- Data minimization (we only collect what's necessary)
- Default privacy settings (opt-in, not opt-out)
- Transparency in data use
- User control over data at all times
Data Breach Response
In the event of a data breach affecting personal information, we will:
- Notify affected users within 72 hours (as required by GDPR)
- Report to relevant supervisory authorities as required by law
- Take immediate action to mitigate harm and prevent future breaches
Health Data Consent (EU Users)
Under GDPR, wellness data (sleep, activity, rest patterns) is considered health data requiring explicit consent. By using Nuvinoo, you explicitly consent to the collection and processing of this health data for the purposes described in this policy.
Data Retention
We retain your data for as long as your account is active or as needed to provide our services. Specifically:
- Account data: Retained until you delete your account
- Wellness data: Retained for as long as you use our services, allowing you to view historical trends
- After account deletion: Data is deleted within 30 days, except where retention is required by law
Your Rights
Depending on your location, you may have the following rights:
- Access: Request a copy of the data we hold about you and your child
- Correction: Request correction of inaccurate information
- Deletion: Request deletion of your data
- Portability: Request your data in a portable format
- Withdraw consent: Withdraw consent for data processing where applicable
- Opt-out: Opt out of marketing communications at any time
To exercise these rights, please contact us at privacy@nuvinoo.com.
International Data Transfers
Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place to protect your data in accordance with this Privacy Policy and applicable laws, including Standard Contractual Clauses where required.
Third-Party Links
Our app may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.
Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website, updating the "Last updated" date, and, where appropriate, sending you a notification. We encourage you to review this policy periodically.
Contact Us
If you have questions about this Privacy Policy or our privacy practices, please contact us.
For concerns specifically related to children's privacy, you may also contact your local data protection authority.