Privacy Policy

Last modified date:  April 30, 2018

Our Policy:

Akili Interactive Labs, Inc. (“Akili” or “we”) develops cognitive platforms (including the Project: EVO™ platform) and mobile applications which enable multiple clinical products for remote data-capture and intervention.  Our proprietary adaptive mechanics allow the software (including embedded software and third party software) to automatically personalize to the patient's ability level with no clinician input required.

Akili is committed to protecting the confidentiality, privacy and security of the data of its mobile app and website visitors (“you”, “your”). We want you to understand how we collect and use information, including personally identifiable data, so you can interact with Akili with confidence. Personally identifiable data (“Personal Data”) is data that includes a personal identifier like your name, address, email address, , and other similar information that can be used to identify you.

This Privacy Policy (the “Privacy Policy”) applies to our web sites, including but not limited to www.akiliinteractive.com, (together, the “Sites”), our mobile applications and platforms (“Apps”) and all related services (collectively, the “Services”). By proceeding to use the Sites you consent that we may process the data we collect from you in accordance with this Privacy Policy. The Privacy Policy applies to all users, including third parties, (e.g. teachers or caregivers) who may have been invited to use the app or services on behalf of another. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT VISIT ANY OF OUR SITES.

Akili may, without notice, at any time revise this Privacy Policy and any other information contained in the Sites. If we revise the Privacy Policy, we will revise the “last modified” date at the top of the Privacy Policy. If we materially change our Privacy Policy, we will notify you by posting a notice on the homepage of our Sites. Akili may also, without notice, at any time make improvements or changes  to our Services. It is your responsibility to check the Privacy Policy periodically for changes. Your continued use of the Services following the posting of changes will mean that you accept and agree to the Privacy Policy.

Information We Collect

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below.

When You Contact Us for Help

If you are a Study Participant, please contact your Researcher for help. You should not contact us through our Services or social media pages for help.

If you are a visitor to our Services, you should contact info@akiliinteractive.com for help. Whenever you contact us for help, we collect your name and email address along with additional information you provide in your request so that we can provide you with assistance.

When You Visit or Use our Services

When you use or access our Services, we may collect and use Personal Data, about you, as well as other information, such as:.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that you are solely responsible for the accuracy of the Personal Data you provide, including data related to Permitted Users and expressly consent that if you use the Services outside of the United States, your Personal Data will be transferred from your current location to the offices and servers of Akili and the authorized third parties referred to herein located in the United States and third countries.

Other Information We Collect:

Non-Identifiable Data

When you interact with Akili through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Akili may store such information itself or such information may be included in databases owned and maintained by Akili affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

Information from Other Sources

We do not collect any information about you from other sources outside your interaction with the Services.

Use of Your Information

Akili uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. We use the information we collect from you primarily to enable us to provide the Services to you in the best possible manner. In addition, your information may be used as follows:

If Akili intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Sharing Your Information

We don’t sell any data that could identify you, and we only share data about you when it is necessary to provide the Services. We may sell data, but only when the data is de-identified and aggregated.

Data That Could Identify You

We do not sell or rent Personal Data collected through Akili’s Services to anyone.  We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, under the following circumstances:

Such third parties have access to personal information as needed to perform their functions, but they are not allowed to use it for other purposes.

Data That Does Not Identify You (De-identified Data)

Akili may sell or share aggregated, de-identified data, including data you provide to us through our Services, with third party partners and with the public in a variety of ways, such as, but not limited to, by providing research or reports about health and fitness, publishing in scientific journals, using it in product development, and in commercial transactions. This research may be compiled and analyzed on an aggregate basis, and Akili may share this aggregate data with its affiliates, agents and business partners. When we provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from re-identifying it back to you. Akili may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

How We Use Cookies and Pixel Tags

Technologies We Use

A “cookie” is a small computer file that is sent to your computer when you visit a website or mobile app. When you visit the site or app again, the cookie allows that site or app to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Keep in mind, however, that some website features or services may not function properly without cookies.

A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.

While we use cookies and pixel tags, we do not track our users across websites or over time.

“Do Not Track” Requests

Although we would like to honor the browsers set with a “Do Not Track” signal, our Services do not currently respond to a DNT or similar signal as Akili awaits the results of efforts by the policy and legal community to determine the meaning of DNT and the proper way to respond. However, we believe that consumers should exercise choice regarding the collection of this type of data, which is why we disclose the cookies used and provide links to opt-out of those collection practices below. You can also visit our Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain of our Services.

We use the following third-party data analytics platforms to improve the Services in a variety of ways:

We use Countly analytics to allow us to see how you use our Services so we can improve your experience. We encourage you to read the Countly Privacy Policy https://count.ly/privacy  

Third Party Websites and Social Media Features

This Privacy Policy applies only to the Akili Services. The Services may contain links to other web sites not operated or controlled by Akili (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The Services may contain links to other sites, including those of third parties or business partners. While we seek to link only to sites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other websites use.  Any links from the Services do not imply that Akili endorses or has reviewed the Third Party Sites.  By accessing other third party websites or applications through our Sites, you are consenting to the terms and privacy policies of those websites. It is possible that other parties may collect Personal Data about your online activities over time and across different web sites when you use Akili’s Sites. We suggest contacting those sites directly for information on their privacy policies.

Our websites may include social media features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the entity providing them.

How Long We Save your Data

We may store your information indefinitely.

Security

Akili takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These procedures include, but are not limited to, firewalls, encryption, intrusion detection, and monitoring. We also limit access to any Personal Data we receive to employees who need access to that information in order to do their jobs. However, no data protection procedures are entirely infallible. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Akili via the Internet. As a result, while we strive to protect your Personal Data, we cannot guarantee that it will be 100% secure. Your transmission of your data to our Services thus is done entirely at your own risk.

Your Information

Backups of data that you provide to us through the Services, such as your email address, will remain in our archive servers.

If your information has been shared with a third party, as described elsewhere in this Privacy Policy, then that third party has received its own copy of your data. If you have been contacted by one of these third parties and wish to correct or delete your information, please contact them directly.

Email & Other Communications

We may need to contact you about your use of the Services. These communications are part of the Services and you may not opt out from receiving them. You can opt out from receiving other communications from us by contacting info@akiliinteractive.com.  Further, you acknowledge that features of the Services may, now or in the future, enable your tablet, mobile phone or other similar device to receive text message (SMS) alerts (the “Text Message Service”).  You will be required to opt-in to the Text Message Service if you want the Text Message Service activated.  Akili will not charge you for the text message (SMS) alerts you may receive from the Services.  However, message and data rates may apply from your mobile carrier in accordance with your wireless customer agreement with your carrier and you are responsible for any such charges.  You should consult your wireless service provider regarding its pricing plans.

International Visitors

Akili’s Services are hosted and operated in the United States (“US”). By using the Services, you are consenting to the transfer of your personal information to the US. If you are accessing the Services from outside the US, please be advised that US law may not offer the same privacy protections as the law of your jurisdiction.

California Privacy Rights

California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes. Akili does not share any California consumer personal information with third parties for marketing purposes without consent.

California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.

Users Only of Legal Age of Majority

Our Services are designed and intended for those who are at least 18 years old. By using the Services, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. No one under age 13 is authorized to submit any information, including  Personal Data, via our Services.  If you have reason to believe that a child under the age of 13 has provided Personal Data to Akili through the Services, please contact us, and we will endeavor to delete that information from our databases.

Other Terms and Conditions

Your access to and use of the Services is subject to the Terms of Service at https://my.akili.care/terms

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Akili other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Akili through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Akili shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Access to Information

To keep your Personal Data accurate, including Personal Data you provide related to Permitted Users current and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data or Permitted User data in our possession that you have previously submitted via the Services.

Contacting Us

We welcome any questions, comments, or complaints you may have regarding this Privacy Policy. Please do not hesitate to contact us by email at info@akiliinteractive.com or by writing to:

Akili Interactive Labs, Inc.
125 Broad Street, 4th floor
Boston, MA 02110
Attn: Legal Affairs

Copyright© 2018, Akili Interactive Labs, Inc. All rights reserved.