Last Updated: October 28, 2023
At CuesHub, PBC. (“CuesHub” or “we”), we care about the protection of your data. Our mission is to help you better manage your stress. This is primarily done by leveraging data to generate personalized alerts and automate adaptive messaging through various channels, such as mobile push notifications and in-app messaging.
CuesHub collects data through the CuesHub software that allow us to run the CuesHub smartphone and smartwatch application (“Mobile App”), www.cueshub.com website and CuesHub cloud services (“Website”) (which we collectively refer to in this Privacy Policy as the “Services”). Please review this Privacy Policy as well as our Terms and Conditions of Use (referred to throughout as our “Terms”), and End User License Agreement (referred to throughout as our “EULA”).
BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY.
CuesHub and all associated Services and systems is housed on servers in the United States. If you are located outside of the United States, please be aware that information we collect (including device data) will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws and principles, including your data subject rights, may not offer the same level of protection as those in the country/region where you reside, are a citizen, or travel to. By using our Services and providing information to us, you consent to the transfer to and processing of the information in the United States and, unless otherwise stated in this Privacy Policy, we use this consent as the legal ground for that data transfer. You may be asked for your explicit consent to this data transfer to access and use the Mobile App.
Please read this Privacy Policy carefully, as your access to and use of the Services signifies that you have read, understand and agree to all terms within this Privacy Policy. If you do not agree with any part of this Privacy Policy, our Terms, or our EULA, please do not access or continue to use any of the Services or otherwise submit your Personal Data (defined below) to us.
This Privacy Policy relates to data about you, your devices, and your interaction with our Services.
“Personal Data” is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number, device IDs, and network identifiers.
CuesHub collects, processes, uses, discloses, and stores Personal Data as outlined in this Privacy Policy, including to operate and improve the services to provide you with innovative stress management alerts, messages, and services.
We may create de-identified or anonymous data from your Personal Data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you, through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.
We collect your Data in a number of ways and for various purposes, including:
1. When you interact with our Services
CuesHub does not create, maintain, or store any user’s profile on its servers. Further, CuesHub does not ask for name, email, or phone number to set up or operate its Mobile App. However, as set out below, we may collect Personal Data automatically when you browse the content available on the Services. We use this data to provide the Services to you, including those related to push notifications.
2. When you use or interact with a wearable, smartphone, or other connected device
We collect data from motion and body sensors, and your interactions when you use devices or wearables that are connected to the Internet and integrate with the Services. We process sensor data to detect stressful moments, decide when to generate alerts, when to send notifications, and to calculate summaries. When you use a wearable or connected device or product, we may also access certain information about the device or product such as a randomly generated unique identifier, device type, and other device related information.
We collect self-reported stress ratings, reasons and contexts surrounding confirmed stress events when you use your smartphone that is connected to the Internet and integrate with the Services. We process self-reported data to present analytics of such data to better understand patterns in your stress and stressors.
When you download the Mobile App, we will ask for permission to provide push notifications and to use various hardware features, including Bluetooth connectivity, motion and body sensors, and access to your local network. Without such permission, you may not access certain key Mobile App’s features or functionality.
3. When you communicate with us
We collect Personal Data when you communicate with us at your own volition (“Messages”) via email. We may use your Personal Data to respond to and address your requests for technical support, questions or complaints about the Services, or any other communication you initiate.
Please note that because CuesHub does not store any user’s profile on its servers, we won’t be able to send you Messages pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to Services. Instead, we will notify you of such changes on our Website, or Mobile App.
4. When we leverage device IDs, Location, data from the environment, and other tracking technologies
We may automatically collect certain Personal Data using technologies such as device IDs, geolocation, and IP addresses for performance and analytics purposes (e.g., google analytics) when you visit the www.cueshub.com website.
5. When we aggregate or centralize data
We aggregate and centralize Personal Data for purposes of analytics, innovation, and to provide, enhance, and improve our Services and your experience, including to enable you to use the full range of our Services (e.g., processing of non-sensitive Personal Data related to your use or interaction with a wearable or other connected device that integrates with the Services; when we collect, use, or otherwise leverage device IDs, general location data, data from the environment, and other tracking technologies; when we aggregate and centralize data; and when we share Personal Data with our service providers and vendors).
6. When we provide you geographically relevant Services
We may use general location data to provide you with Services that are relevant to your general location.
7. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes
We may use and disclose Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms, EULA, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.
We may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy and in the following ways:
1. Operation and Improvement of Services and User Experience
For internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, administrative purposes, and above all, to provide and improve Services.
2. To Service Providers and Vendors
With business partners to provide and improve the Services. We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, or to perform Services-related services.
3. For Certain Analytics and Improvement
With certain companies for purposes of analytics and improvement of the Services. We may employ third party companies and individuals to assist us in analyzing how our Services are used.
4. In the event of an actual or contemplated sale
With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding Website and online data collection, your communication settings, and app preferences. Collection and use of Personal Data may be required for the Services to work. You may manage your preferences by contacting us at privacy@cueshub.com.
1. Cookie Use, Web Pixels or Beacons Use
We do not currently use Cookies, Web Pixels or Beacons.
2. IP Address Use
An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Privacy Policy, include “public” IP addresses, such as the IP address for a home router that is visible to the Internet, as well as “local” IP addresses, which are IP addresses assigned to computers and mobile devices “behind” a router (such as a home router). Our analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, and business development.
You may withdraw your consent for IP address use by following the instructions in the “Withdraw Your Consent for Use of Your Mobile Device IDs for Analytics” section below.
3. Mobile Sensor Data and In-Range Device Data Use
Our Services may transmit general location data and data from sensors to us and our partners.
4. Withdraw Your Consent for Use of Your Mobile Device IDs for Analytics
CuesHub does not use any user data for advertisement purposes.
5. Change Consent Settings for Communication Preferences
Mobile Notifications: CuesHub may use notifications to send you notifications. If you choose not to activate these functions, or to deactivate them later on, you may not be able to use the App's full scope of services.
You can manage the type of notifications you receive from CuesHub by modifying the app settings on the Device. You may also set your mobile device settings to not allow notifications from us.
The Personal Data CuesHub processes, and all associated Services and systems, including registration, is housed on servers in the United States. If you are located outside of the United States, please be aware that we may process your Personal Data in the United States (the data protection and laws in the United States may offer a lower level of protections than in your country/region).
By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the United States. Where and as required, we will seek your explicit consent.
We do not currently intend to serve users outside of the United States. If you reside or are temporarily traveling outside of the United States, please refrain from using the services.
Unless otherwise disclosed in this Privacy Policy, CuesHub does not retain your personal data on the Mobile App. All data is stored within your personal device or wearable that are connected to the Internet and integrate with the Services.
Data stored by CuesHub such as your body and motion sensor data, stress alerts, and summaries of historical data are not linked to any Personally Identiable Information such as Device ID, WearOS ID, and email, and hence can’t be identified for delection.
We implement technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the use, processing, and transfer of Personal Data.
If you become aware that a child has provided us with Personal Data without parental consent, please contact us at privacy@cueshub.com. If we become aware that a child has provided us with Personal Data without parental consent, we will take steps to remove the data.
In order to enhance our Services it might be necessary to change this Privacy Policy from time to time. We therefore reserve the right to modify this Privacy Policy in accordance with the applicable data protection laws. Please visit our Website from time to time for information on updates to this Privacy Policy.
We don’t sell Personal Data as defined by Nevada law.
If you are a resident of California, you have certain rights to the Personal Data that we may collect about you. Under California law, the exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., maintaining confidentiality when legally required). We will comply with your request as soon as reasonably practicable. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. To prevent unauthorized access to your Personal Data, we take steps to verify an individual’s right to the data - including requiring users to reach out to us directly from a verified email address, pass a challenge response, and/or confirm information associated with the account. Following verification of your identity, we will notify you if we are unable to fulfill your request and outline the reasons we are unable to honor your request at this time.
1. Your California Privacy Rights
You have the following rights:
2. How to Exercise Your Rights
Exercise your rights: To exercise your rights to your Personal Data, please contact us at privacy@cueshub.com or at the address listed below.
3. Additional California Rights
California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third party’s direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.
Under Section 1798.83, we currently do not share any Personal Data with third parties for their direct marketing purposes. If we do decide to share your Personal Data with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to privacy@cueshub.com or in writing to the address listed below.
It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes or for purposes of assisting us with our own marketing.
If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us at privacy@cueshub.com.
CuesHub, PBC.
1910 Madison Avenue #2026
Memphis, TN 38104