Welcome to Alula Technologies Limited website. Your privacy is of utmost
importance to us. This Privacy Policy outlines how we collect, use, disclose,
and safeguard your information when you visit our website. By accessing or
using our site, you agree to the terms of this Privacy Policy. If you do not
agree with the terms, please do not access or use our site.
Your Data Protection and Privacy Matters
Alula Technologies are committed to respecting your data privacy while
providing data protection and security of your personal data that you generate
when using our products. As part of our commitment and compliance with GDPR (General Data Protection Regulation) and POPIA (Protection of Personal Information Act)
Regulations if you wish to confirm that Alula Technologies are processing
your personal data, or to have access to the personal data that Alula
Technologies may have about you, please contact our Data Protection
Officer at dpo@alulatechnologies.com.
Our Principles
At Alula, we are committed to empowering you with a complete view of all your
personal identifiable information and protected health information relating to
the products you have used.
Control. You are in control of the personal information you provide to us,
which includes sharing, use, and retention.
Access. We empower you with access to your data as provided so that you can
take charge of your personal identifiable information and protected health
information.
Transparency. We are committed to transparent collection, storage, sharing, and
processing of your personal identifiable information and protected health
information.
Protection. The privacy and protection of your personal information is of the
utmost importance to us. We are committed to strong security measures and
providing you with information regarding collection, processing, and storage of
your personal information
Introduction
Alula Technologies Limited (“we, “us,” “our” or “Alula”) operates the
http://alulatechnologies.com/ and related services (VivaScore™, HealthCloud,
Ovation Solutions and Platform2Go). Our goal is to empower you with control
over and the ability to share your personally identifiable information and
protected health information. To this end, we collect, process, use, and may
store the personal information you provide to us through your, laptops,
smartphones, tablets, mobile applications, provider portals, activity trackers/
wearables and other electronic devices and services.
Our Privacy Policy outlines:
how we may process this information
what information we collect
how we may use this information; and
choices about accessing and updating information.
This Privacy Policy applies to all our Sites as well as to the API services and
applications we provide, and related products and services, collectively known
as the “Services.” In addition, our Cookie Policy explains our use of browser
cookies and other similar tracking technologies, which are part of this Privacy
Policy.
Contact Details
If you have any questions about this Privacy Policy or our privacy practices,
we can be contacted in the following ways:
Full name of legal entity: Alula Technologies Limited
Postal address: 33 Great Portland St, London W1W 8QG
By accepting our Terms of Use you consent to the collection, use,
storage, and disclosure of personally identifiable information as outlined in
the Terms of Use and in this Privacy Policy.
Connecting your Personal Information to Our Services
We handle your personal identifiable information (PII), including protected
health information (PHI), in compliance with relevant security regulations,
healthcare privacy and our contractual commitments to our clients. Currently,
we serve as a conduit between:
Entities responsible for collecting and storing health data
Organisational clients utilising our services to gather data from consumers
Consumers like yourself
Through our service, you have the option to grant us authorisation to access,
collect, use, store, and disclose your personal information, which may include
sensitive data related to HIV, sexually transmitted diseases, mental health
conditions and treatment, substance abuse conditions and treatment, and other
relevant information, for the duration of your use of our services.
Important Definitions
The following definitions are provided to help you understand our Privacy
Policy.
Service or Services: Our Sites as well as the API services and applications
we provide, and related products and services, as accessed by a user whether a
user has an account or not.
Personal Identifiable Information and Protected Health Information:
Personal Identifiable Information is information that can identify you, either
alone or in combination with other information. This includes Protected Health
Information that is identified under Protection of Personal Information Act
(POPIA) in South Africa, General Data Protection Regulation (GDPR) in the
European Union, the UK General Data Protection Regulation (UK GDPR) in the UK,
and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) in
the United States of America. Please review the section “Information We Collect
from You” for more details.
Anonymised (or De-identified) Information: De-identified or anonymised
information does not identify you based on individual pieces of information or
combinations of information. Your direct information (e.g., name) and indirect
information (e.g., Device ID) are removed, such that you cannot be reasonably
re-identified as an individual. This includes de-identified demographic
information, de-identified location information, information about the computer
or device from which you access any of the Alula websites or other online
services, or other analysis we create.
Aggregate Information: Your individual information is combined and compiled
with other individuals’ information for the purpose of analysis. The
aggregation process involves de-identification of personal information such
that you and other individuals cannot be reasonably re-identified as specific
individuals.
Customers: Customers are business partners of Alula that may incorporate
our Services as a component or feature of the Customer’s products (e.g., a
chronic condition management platform that uses data from Alula HealthCloud to
measure your activity levels) or may deliver features within our Services
(e.g., a pharmacy that provides your prescription history).
Information We May Process
Whenever you access or use our Services, we may process (e.g., collect, use,
store, transfer, etc.) different kinds of Personal Data about you, depending on
which Alula Technologies service you use: (a) the Alula Technologies Websites
(b) the VivaScore™ (mobile/web) app, or (c) HealthCloud , or (d) Ovation
Solutions, or (e) Platform2Go.
References to VivaScore™ refers to your personal wellness data, data collected
from wearable devices and activity platforms, generated health score, and
measurements based on the use of rPPG technology that processes video clips
generated by your camera of your mobile device when taking a 30-second video
selfie to assess your general wellness which is intended for Investigational
Use Only.
The VivaScore™ and HealthCloud Services are not medical advice and should not
be a used as a substitute for clinical judgment by a health care professional.
The VivaScore™ and HealthCloud Service is intended to improve your awareness of
your general wellness and is not intended to diagnose, treat, mitigate, or
prevent any disease, symptom, disorder, or abnormal physical condition.
You must consult with a health care professional or emergency services if you
believe you may have a medical issue and need medical attention.
We will process the relevant personal data about you in accordance with this
Privacy Policy, and as follows:
Identification and Contact Data from Alula Technologies, VivaScore™,
HealthCloud, Ovation Solutions, Platform2Go (mobile/web): IP Address, and users
may optionally provide contact details such as, First name, Last name, Email,
Phone number, Company name, Country/Region, and a free form Message.
Employer/ Employee Data from Alula Technologies, VivaScore™, HealthCloud,
Ovation Solutions, Platform2Go (mobile/web): When your employer decides to use
our Services to enable you to join and manage your employee benefits, your
employer provides us with information which includes, but is not limited to,
your name, address, Identity number, title, salary, commencement of employment
and information regarding your employment. We may also ask for details of your
spouse, partner, or other immediate family member if they are to be included as
the beneficiary of a policy or product. Where you submit such details, you do
so on behalf of the relevant family member and you acknowledge and accept that
it is your responsibility for letting them know (i) that you have done so, (ii)
what details you have submitted and (iii) the purpose of submitting the
details. It is your responsibility to keep your personal details and those of
any relevant family member updated. If we require sensitive personal data, we
will ensure that the collection and use is in strict accordance with the
"application legislation" principles of data protection and data privacy.
Application Analytics from Alula Technologies, VivaScore™, HealthCloud,
Ovation Solutions, Platform2Go (mobile/web): App name/bundle-identifier/version
– as reported by VivaScore™. Device OS Type (iOS, Android, Windows, Linux,
MacOS, Browser) – as reported by VivaScore™. Collected and processed at point
of application registration/ initiation of service use.
Identification and Contact Data from Alula Technologies, VivaScore™,
HealthCloud, Ovation Solutions, Platform2Go (mobile/web): IP address,
Email address, Device token, Location data. Collected and processed at point of
application registration/ initiation of service use and measurement requests.
App users may optionally register for access to any of our services if they do,
an email address or username is collected associated with the registered
service for app access, verification, and password resets.
Personal Demographics Data from Alula Technologies, VivaScore™,
HealthCloud, Ovation Solutions, Platform2Go (mobile/web): To achieve more
accurate measurement results, the processing and analysis may also require or
involve additional Personal Data including, but not limited to, the following
which is provided by you – Age, Weight, Height, Gender at birth. An encrypted
payload containing relevant data is generated and transmitted to Alula
HealthCloud.
Images and Videos specifically from VivaScore™ app (mobile/web) and
HealthCloud: When the service is in use, your device will capture, but will not
store or transmit to Alula Technologies, images, and video through supported
mobile device cameras for the purpose of extracting and analysing Facial blood
flow and Facial landmarks and features. An encrypted payload containing
relevant data, but not picture or video images, is generated and transmitted to
Alula HealthCloud.
Wellness Data and Measurements from VivaScore™ app (mobile/web) and
HealthCloud: Images and videos (see row above) are used to provide Body Mass
Index, General Wellness Score, Heart Rate Variability, Mental Score, Physical
Score, Mental Stress Index, Waist-to-Height Ratio, VivaScore™, Facial Skin Age,
Breathing Rate, Pulse Rate, Irregular Heartbeat Count, Physiological Score, or
other similar derived data. This data is the output data generated from
providing the Services as opposed to what is collected.
Log Data from Alula Technologies, VivaScore™, HealthCloud, Ovation
Solutions, Platform2Go (mobile/web): relating to any of our products or
services. Our servers automatically capture certain information about how a
person uses the product, service, portal, whether by log files, and scripts,
including without limitation IP address, configuration information, information
about interaction with our Services, device information, and the date, time,
and/or location.
Information We Collect From You
We gather personal information as part of providing services to all our users.
Upon becoming a user of our services, we will only gather information that you
authorise for submission Information may include personal identifiable and
protected health information inclusive of data you report about yourself and/
or information collected from devices or third parties to which you have
consented. We strongly believe in maintaining the confidentiality of all
personally identifiable and protected health information that identifies an
individual, including your past, present, or future physical or mental health
condition, and your Digital Health Check data.
Account Information: We may collect personal information, including but not
limited to, identifying data such as name, email address, password, and address
information to set up and manage your account. If our services are provided by
your employer or their service provider, your personal information may be
forwarded to set up our services for your use. Depending on the services used
and your location, we may also collect your South African Identity number,
passport number, National Insurance number, Social Security number, date of
birth, current benefit coverage, and other official identifiers, such as a
driver's license number.
Health Information: We may collect information that you consented to
sharing such as personal activities, health and wellness data, medications,
tests, medical records, and health issues submitted through the services.
Sensitive Information: Information considered sensitive may include genetic
information, HIV testing or status, disabilities, medical conditions, mental
health, race, ethnicity, sexual orientation, and gender assigned at birth. This
information may be recorded in information shared with us by a third party such
as a doctor to which you consented to sharing
Device Information: We may collect device identifiers such as serial
number, device type, IP address, browser type, language preferences, and
location, operating system, date and time of your access, internet service
provider, or mobile carrier, internet domain and host name, and referral URL.
Cookies and Similar Technologies: We use cookies and similar technologies
as described in our Cookie Policy.
We recommend that you review that policy to learn about our practices and the
controls available to you.
Profile Information: We collect the information that you voluntarily enter
into a user profile. This may include pictures, nicknames, and other personal
details. This information is available to third parties that you consent to
sharing your personal information through our services.
Research and Studies Information: Your personal information is collected
when you voluntarily participate in research and studies through our services.
Information from Your Use of Services: We collect information related to
your use of our services, such as which healthcare provider you use, which
menus you use, pages you view, or search results you click on. You may interact
with our support team during the use of our services, in which case, we would
collect information about your communications.
If you visit the site, whether or not you become a user of our services, please
note that we will maintain web logs to record data about all visitors and
customers who use this site and interact with the services, and we will store
this information. These logs may contain IP address information, types of
operating systems you use, the date and time you visited the site, and, if you
are a user of our services, information about the type of any personal tracker
or other device or service you connect to the services and information about
the data uploaded from any such device or service.
All web logs are stored securely and have restricted access by a limited number
of employees who must adhere to strict guidelines regarding user data security
and privacy.
How We Use Your Information
We utilise your personal information to provide you with our Services,
employing various methods.
Here is how we use your information:
Verifying your identity and granting access to the Services, enabling you to
share your personal information with selected third parties.
Ensuring restricted access to your personal information.
Gathering personal data provided by you, imported by you (e.g. from
devices), or authorised by you (e.g. lab test results).
Storing Digital Health Check data with the aim of calculating a Health
Score, empowering users to monitor their health over time. This data is
retained for 24 (twenty-four) months, in accordance with Alula Technologies
Data Retention and Destruction Policy.
Transmitting information to third parties authorised by you to receive your
personal information through our Services.
Generating exports of your personal information as per your authorisation.
Sending account notifications and updates about your Services.
Developing new Services and enhancing existing ones.
Conducting scientific and statistical research and studies.
Addressing technical issues with our Services or enforcing our Terms of
Service.
Identifying and safeguarding against errors, fraudulent activities,
malicious behaviour or other suspicious or criminal actions.
Alula Services: If you choose to create an Alula account, we may use your
personal information to inform you about or present products or services that
we believe may interest you.
We will not provide your personal information to any third party for their
or any other third party’s direct communications without your express
consent.
You can opt out of receiving these communications by following the
instructions in each email we send you.
Additionally, you can inform our Data Protection Officer at any time at dpo@alulatechnologies.com if
you no longer consent to these communications.
If you unsubscribe, you will no longer receive these communications, but we
will continue to contact you regarding our Services and respond to your other
requests.
Non-Personal Data Use
We may also use non-personal information to analyse data into useful
information. This process of data analysis is done using Anonymised and
Aggregate Information, is non-personal, and allows us to find correlations and
patterns in the data.
How We Share Your Information
We prioritise the protection of your personal information and uphold strict
standards regarding its sharing. This is how we handle your data:
No Sale of Information: We do not sell, lease, or rent your
individual-level information to any third party, including our customers,
without your explicit consent.
Sharing with Vendors and Service Providers: To support our business
operations and provide certain services, we may share personal information with
vendors and service providers. These parties, including hosting services, cloud
services, email communication software, and web analytics services, will
access, process, or store personal information solely for the purpose of
fulfilling their obligations to us. Each vendor and service provider are
required to enter into a Data Privacy Agreement with us.
Business Transfers: In the event of a merger, acquisition, or other
business transfer, your personal information may be shared during the due
diligence process and transferred to a successor or affiliate as part of that
transaction.
Legal Requirements: We may disclose personally identifiable information
as required or permitted by law, including for compliance with legal
processes and requests from law enforcement agencies. We reserve the right to
report unlawful activities to law enforcement agencies and may disclose
information to protect our rights or property.
Information Sharing with Others: You can share your information with
others through our Services, such as exporting personal information or
sending it to authorised recipients. Your consent is required for sharing
personal information with third parties, such as healthcare professionals. You
may also participate in research or clinical studies by providing express
consent.
Automated Decision Making: With your explicit consent, we may use
information provided by you, such as health data from wearable devices, to
continuously update your account. This allows for real-time updates, such as
updating your health score automatically based on data from sources like Apple
Watch.
Anonymised Data Sharing: We may use and share anonymised or aggregated
information for various purposes, including service improvements, public
health, research, and analytics, while ensuring legal compliance.
Transfer of Data Overseas: Personal Identifiable Information (PII)
collected from you is processed, stored, and hosted in the United Kingdom.
De-identified data may be transferred outside of the United Kingdom. If you are
a South African Citizen and avail of Alula Technologies services, your data is
stored in the Republic of South Africa.
Your privacy and consent are paramount, and we adhere to stringent protocols to
safeguard your personal information.
Personal Information Security
The protection of your data is our top priority. We implement rigorous security
measures to safeguard your personal information and ensure its confidentiality
and integrity. This is how we protect your data:
Technical, Physical, and Administrative Controls: We employ all
reasonable technical, physical, and administrative controls to prevent
unauthorised access or disclosure of your personal information and to ensure
its proper use. These measures include robust access controls, stringent access
management policies, and comprehensive information security policies.
Data Storage: Your Personal Identifiable Information (PII) and
Protected Health Information (PHI) is securely stored within the geographic
region of its collection, in strict accordance with the applicable Data Privacy
Regulations governing that area. This adherence includes, but is not limited
to, the General Data Protection Regulation (GDPR) for data collected within the
European Union and United Kingdom.
Data Protection Safeguards: We maintain a high level of data protection
through various safeguards, including regular data backups, stringent audit
controls, access controls, and data encryption protocols.
Secure Transmission: Our Site and Services utilise Secure Socket Layer
(SSL) technology to encrypt all connections to and from our platform. This
ensures the security of electronic data transmissions, safeguarding your
information during transit.
Continuous Monitoring: We continuously monitor our systems for any
potential security threats or vulnerabilities. Our dedicated team employs
advanced security measures to detect and mitigate risks promptly.
Despite our comprehensive security measures, it is important to note that no
data transmission or storage system is entirely infallible. If you have any
concerns about the security of your interactions with our Site or Services or
suspect unauthorised access to your account, please contact our Data Protection Officer immediately at
dpo@alulatechnologies.com . We take all reports of potential security breaches
seriously and will investigate and address them promptly to ensure the ongoing
protection of your data.
Your Access and Choices
Fitness Device Access and Choices
As the owner of your health data, you retain full control over how your fitness
device interacts with the VivaScore App. In line with your preferences, you
decide which services and data are shared from your paired fitness device to
the VivaScore App. You can access, modify, or delete personal, and health
information shared from your fitness device at any time.
Your options regarding data management between your fitness device and the
VivaScore App include:
Review Personal Information: You can review the personal and health information stored on your fitness device.
Modify Personal Information: Depending on the features of your fitness device, you may have the ability to update certain information (e.g., specific health data) through your device’s data sharing settings.
Control Data Sharing: You have the authority to choose which personal and health data points are shared with the VivaScore App, giving you control over which data is stored and accessed.
Manage Data Export: Your fitness device may provide options to export personal information shared with the VivaScore App, depending on its capabilities.
Delete Data: You can delete your personal and health data from your fitness device, though doing so will affect data stored within the VivaScore App.
Uninstall and Delink: You may uninstall or delink your fitness device from the VivaScore App at any time.
Reinstall and Pair: You can reinstall and pair your fitness device with the VivaScore App as necessary.
For any assistance with your fitness device, please contact the product owner or manufacturer.
VivaScore App Access and Choices
You have full control over your personal data within the VivaScore App. If you need any help, feel free to contact our Data Protection Officer at dpo@alulatechnologies.com .
Your options regarding data management of your personal data within the VivaScore App include:
Review Your Personal Information: Access and review personal information provided during account setup within the VivaScore App.
Update Your Personal Information: You can modify personal information, including contact details, or update health data such as age, height, weight, BMI, gender, smoking status, and diabetes status.
Consent: Your explicit consent is required to use the VivaScore App. Without consent, access to the app will not be granted.
Request Your VivaScore Data: You can request an extract of your personal data by emailing our Data Protection Officer at @alulatechnologies.com . We will follow strict verification processes to confirm your identity and ensure that the data requested belongs to you as the data subject.
Request Deletion of Your Data on VivaScore: You can request the deletion of your personal data via our Data Protection Officer at dpo@alulatechnologies.com . We will follow strict verification processes to confirm your identity and ensure that the data requested belongs to you as the data subject.
Uninstall/Reinstall the App: You can uninstall or reinstall the VivaScore App at any time, while keeping control of your account and data.
Your Personal Information With Our Services
You authorise the personal information that is collected, stored, maintained,
processed, and used within our Services.
Deleting or De-authorising Your Data
You may request to delete any personal information and to de-authorise the
collection, use, storage, and disclosure of personal information in the future
by sending us an email our Data Protection Officer at dpo@alulatechnologies.com. Any such deletion or
de-authorisation will have no effect on sharing of personal information before
we receive and are able to act upon such a request.
During the use of our Services, you may authorise us to send your personal
information to customers or third parties who are providing you value. You will
have full transparency regarding whom within the ecosystem you previously sent
your personal information. To delete a copy of your records from these
entities, you will need to follow their policies and procedures for data
deletion.
Exporting a Copy of Your Data
You can export a copy of your personal information that is stored within our
Services. If you have questions about exporting Personal Information from our
Services, please contact our Data Protection Officer at dpo@alulatechnologies.com.
Changes to Your Personal Information
We work with multiple medical and wellness providers to enable you to obtain
and hold copies of your personal information. We may also provide tools for you
to manually enter health data or collect data from devices. While we strive to
collect complete and accurate information from the sources provided to us, we
do not have control over the accuracy, completeness, or quality of information
entered or sent to us. For example, you may identify incorrect, incomplete, or
outdated information from a third-party provider. If you have questions or find
issues with your personal information, it is your responsibility to identify
issues and ensure corrections are made to the original source of information.
For manually entered information, you are responsible for reviewing
information and making corrections.
For a device, you should contact the device’s manufacturer.
For a care provider, you should contact the provider who controls your
original information.
Your Responsibility to Protect Your Personal Information
You are responsible for the handling, sharing, re-sharing, and distribution of
your personal information. We disclaim any responsibility or liability for any
consequences arising from your disclosure of personal information. Furthermore,
if you transmit personal information electronically to another person, whether
on or off our Site or Services, we shall not be held accountable for any harm
or consequences resulting from third-party use or re-sharing of your
information. We strongly advise sharing personal information only with
individuals and third parties whom you trust.
Additionally, we emphasise the importance of safeguarding the integrity of your
data. It is your responsibility to ensure that your personal accounts and login
credentials are kept secure and inaccessible to unauthorised individuals. When
using public or shared devices, such as those in libraries or internet cafes,
always remember to log out of our Site or Services.
If you access our Site or Services via your employer's network or through
public internet connections, such usage is undertaken at your own risk. It is
incumbent upon you to verify the privacy and security policies of the company
regarding internet usage.
Please note that we cannot verify the identity of any non-employee individuals
you may encounter while using our Site or Services, nor can we vouch for the
authenticity of any information provided by others.
Third-Party Sites and Trusted Relationships
When using our Site, you may encounter links to other websites. It is important
to understand how your privacy and security may be affected when navigating
these third-party sites.
Below are a few guidelines for navigating Third-Party Sites liked from Alula
Technologies:
Our Approach: We prioritise the protection of your personal information. We
do not share your data with third-party sites unless it is authorised under
the Terms of Use or with your explicit consent, where required.
Understanding Privacy Policies: Each third-party website may have its own
privacy policies and procedures. We encourage you to familiarise yourself
with these policies before interacting with these sites. Look for information
about how they collect, use, and protect your personal data.
Trusted Partners: We strive to collaborate with trusted partners and
organisations that uphold similar privacy and ethical standards to ours.
While we cannot guarantee the practices of every linked site, we make efforts
to work with reputable entities that prioritise user privacy and security.
Exercise Caution: Exercise caution when clicking on links that redirect you
to external sites. Be mindful of sharing sensitive information and consider
the potential risks associated with interacting on third-party platforms.
Consent and Authorisation: Your consent plays a crucial role in data
sharing with third-party sites. Before providing any personal information or
authorising data transfer, ensure that you understand how your data will be
used and whether you are comfortable with the terms outlined by the third
party.
By staying informed about privacy policies, exercising caution, and being
mindful of consent, you can navigate third-party sites linked from our
platforms while safeguarding your privacy and security. If you have any
concerns or questions regarding data sharing practices, feel free to reach out
to us for assistance.
Please refer to our Terms of Use for further details on data
sharing and your rights and responsibilities as a user.
Account Closure
To close your account and ensure the deletion of your personal information,
please follow these steps:
Send a closure request: Simply email your request to close your account to
our Data Protection Officer at dpo@alulatechnologies.com
Account closure process: Upon receiving your request, we will promptly
initiate the closure process for your account. Your account and all
associated personal information will be deleted within 30 (thirty) days from
the receipt of your request.
Implications of account closure: Please be aware that the deletion of
personal information within our Services does not extend to any data
previously shared with third parties through our platform or any participation
in research studies to which you provided consent. For such cases, you must
directly contact the respective third parties to manage your information.
Handling of personal data post-closure: Rest assured that even after your
account is closed, we adhere to stringent protocols to safeguard your
personal data. We may retain certain information in accordance with legal
requirements or contractual obligations with third parties. This includes
retaining de-identified personal information and limited account registration
details necessary for accounting, audit, and compliance purposes.
By following these steps, you can effectively close your account while ensuring
that your personal information is handled responsibly and in compliance with
applicable laws and regulations. If you have any further questions or concerns,
please do not hesitate to reach out to our Data Protection Officer at dpo@alulatechnologies.com. Your
privacy and data security are our top priorities.
Other Important Information
We are committed to keeping you informed about any changes or events that may
affect your personal information.
Notifications: You will be notified in the event of a data breach impacting
your personal information, as required by law. We will provide instructions
on any further actions you may need to take. You will also be notified if there
is a Business Transfer involving your personal information, and if the
recipient intends to use your information differently from what is outlined in
this Privacy Policy. In such cases, you have the option to delete or export
your personal information as described above, or to close your account.
Data Retention: We ensure that identifiable information about you is
retained only for as long as necessary to fulfil our business purposes or to
meet legal requirements. This information is held for no longer than 24
(twenty-four) months. Should you close your account or request that your data
be deleted or de-authorised then the data retention period does not apply.
Children: We do not permit individuals under the age of 18 (eighteen) years
old to create accounts that grant access to our secure Site unless they
obtain prior consent from a parent or guardian.
Changes to this Privacy Policy: Our Privacy Policy may be updated in the
future. If changes are made, we will notify you by posting updates on our
Site and other relevant platforms. Each update will be accompanied by an
effective date. If you disagree with any changes, you have the option to delete
your account by contacting our Data Protection Officer at dpo@alulatechnologies.com
Concerns or Questions
Your feedback is valuable to us. If you have any questions or suggestions on
how we can enhance our privacy policy regarding personal information, please
feel free to email our Data Protection Officer at dpo@alulatechnologies.com . We are here to address any
concerns you may have and continuously improve our practices to better protect
your data.
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