Privacy Policy

No Guru LTD, 7, Dositheou Street, Para Building, Block B, Office B101, 1071 Nicosia, Cyprus 398069 (“we,” “us,” “our,” and “Company”) recognizes that the privacy of your information is important. This Privacy Policy (“Privacy Policy”) describes our practices in connection with information we collect through the NoGuru application (the “App”). Our App is designed to give you access to a library of practical techniques to reach your psychological and mental well-being through a self-help system.

If you are visiting us from the European Union or European Economic Area, please see the section entitled “Additional Information for European Union Users” for information on how we comply with privacy laws applicable to you.

By using the App, you consent to our collection, use, disclosure, and storage of information as described in this Privacy Policy.

Our Privacy Policy explains:

What information we collect from you (“Information”)
How we use, share, manage and protect that Information
Additional rights for California residents
Additional rights for European Union Users
How to contact us

What Information We Collect

We will be collecting personally identifiable information such as: your e-mail address and your password for the App.

We will be collecting non-personally identifiable information such as: demographic information; language requirements, time zone, mood; goals; assessments and questionnaires; usage data; device and system data such as type of phone, operating system and network information.

We will collect other Information described in this Privacy Policy.

When you use the App, you may provide certain information directly to us, including when you allow us to obtain information about you from other sources.

We may also obtain automatically-collected information through the App. We may use common technologies that can collect data from a mobile device. The automatically-collected information may include demographic, de-identified, aggregated, or certain information collected automatically through your device such as technical information about your device, web browser information, and server log files collected by us or provided by you. Our App may also collect information specific to use of your mobile device, such as a unique device identifier and precise geolocation information.

Certain features of the App may actively record information about you as you use the App. We use this information solely for the purpose of providing you with health-related feedback and self-care suggestions.

You may limit the Information you provide or make available to us if you want to; however, that may limit your ability to access or use certain functions of the App or to request certain services or information.

All payment processing for our subscriptions is handled directly by the app stores (and any information you provide to the provider is governed by its privacy policy). We do not have access to payment information.

Our App operates on computer servers in the European Union; therefore, any Information you provide will be processed by a computer server located within the European Union.

How We Use Information

We may use the Information for a number of purposes such as: to respond to an e-mail or particular request from you; to communicate with you; to provide you with content through our App; to authenticate you on any portion of our App and with vendors acting on our behalf; to administer surveys and promotions; to personalize your experience on our App; to provide you with informational or promotional offers, as permitted by law, that we believe may be useful to you, such as information about products or services provided by us or other businesses; to perform analytics and to improve our products, our App, and advertising; to comply with applicable laws, regulations, and legal process; to protect someone’s health, safety, or welfare; to protect our rights, the rights of affiliates or related third parties, or take appropriate legal action, such as to enforce our Terms of Use; to conduct health and behavioral research, including with research partners; and as otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law or for any other purpose with your consent.

We may use Information to contact you through any contact information you provide through our App, including any e-mail address, telephone number, or cell phone number.

We may, when permitted, combine your Information with other information, maintained or available to us from you or from other sources, such as from our vendors, and we may use and disclose combined data as described herein. We may use and disclose de-identified and aggregated data for any purpose, which may include, without limitation, disclosures to third parties for analytics purposes such as evaluating the App and providing additional benefits, programs, and services.

How We Share Information

We will only share your Information with third parties as outlined in this Privacy Policy and as otherwise permitted by law or as permitted with your consent, including as follows:

if all or part of the Company is sold, merged, dissolved, acquired, or disbanded to any extent in a similar transaction, or in connection with steps that may need to be taken in anticipation of such events.
in response to a court order, subpoena, search warrant, or to comply with law or regulation.
with our affiliates and other third party companies that we have a business relationship with or hire to perform services on our behalf. For example, we may hire a company to help us send and manage e-mail, and we might provide that company with your e-mail address and certain other information in order for them to send you an e-mail message on our behalf.

We may share Information with other third party companies conducting health or behavioral research, including your personally identifiable information. However, we will require that such companies and their vendors not disclose any such Information that is personally identifiable, that they and their vendors use such Information only for such research purposes, and that they and their vendors not use any such personally identifiable Information to direct any advertising to you or evaluate you for any third party product or service or for any employment opportunity.

Posting Messages, Comments, and Content

Our App may have collaboration areas, including bulletin boards or chat capabilities that permit users to have collaborative discussions and/or share information. Please note, any information you submit or post to these collaboration areas, including your display name or image, may be visible by other users of the App, and such users may share with others. Therefore, please be thoughtful in what you write and understand that this information may become public.

How to Manage Your Information

Our App may permit you to view your profile, if applicable, and access related Information about you and to request changes to, or deletion of, such Information. Please note that if we have already disclosed some of this Information to third parties, we may not have access to that disclosed information and may not be able to force the deletion or modification of any information by the third parties to whom we have made those disclosures.

If you need additional assistance in opting-out of a communication, please contact us at info@noguru.com. Please be aware that opt-outs may not apply to certain types of communications, such as account status and App updates.

Information Collecting and Tracking

The Company may use various technologies to automatically collect information and may aggregate this information from our App or to enable certain features of our App. This Information may include demographic data, technical information about the technology (e.g. phone, computer) used to connect to the App, your IP address, operating system, camera use, use of screen, patterns of application usage, and browsing behavior such as pages visited and how often they are visited (“Activity Information”). We may also use third party analytics companies to provide these services.

We gather Activity Information about you in order to improve the quality of our services, such as the best method and time to contact you. Without limiting the other ways in which we may use Information as described herein, we may otherwise use and disclose your Activity Information unless restricted by this Policy or by law. Some examples of the ways we use your Activity Information include:

Customizing your experiences, including managing and recording your preferences;

Authenticating your account information;

Marketing, product development, and research purposes;

Developing reports regarding usage, activity, and statistics;

Assisting users experiencing problems with our services;

Updating and servicing our App;
Enabling certain functions and tools on the App; and
Tracking paths of visitors within the App.

As described above, we may use tracking technologies that allow us to recognize your device when you return to our App within a period of time, as determined by us, and to support automatic login to the App. To maintain your privacy, you should affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our App has “timed out” – i.e. we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). Unless you affirmatively log out of your account, you may be automatically logged back in the next time you or any user of your devices visits the App.

How We Protect Information

We maintain administrative, technical, and physical safeguards designed to protect the Information that you provide on our App. These safeguards vary based on the sensitivity of the Information that is being collected, used and stored. However, no security system is impenetrable and we cannot guarantee the security of our App, nor can we guarantee the security of the Information you transmit to us over the Internet, including your use of e-mail. We are not liable for the illegal acts of third parties such as criminal hackers.

It is your responsibility to safeguard the devices you use to access our App, and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal Information using those devices. If you log into the App using a device of another person, you should affirmatively log out of your account (i) prior to ending your session, or (ii) if you will be inactive on the App for more than a few minutes, otherwise, the next user of that device may be able to access your account and the Information in your account if your session has not ended.

You agree that we are not responsible for any harm that may result from someone accessing your account or personal Information on a lost, stolen or misplaced device or on a device where you do not take the necessary steps to log out.

Our App allows us to communicate with you through push notifications. You may be able to turn off push notifications in your mobile phone settings. You may also be able to control preview settings in your e-mail applications. Please note, choosing to disable certain functionality of the App may impact the functionality of other areas of the App.

We retain Information for as long as necessary for the purpose for which it is collected, subject to a longer period if the Information is relevant to a legal challenge.

This privacy policy does not cover APIs and other services available on domains other than ours.

Children under 13

We will not intentionally collect any personal information (as that term is defined in the Children’s Online Privacy Protection Act) from children under the age of 13 through our App without receiving parental consent. If you think that we have collected such personal information from a child under the age of 13, please contact us immediately at info@noguru.com.

California Shine the Light Law

California residents may request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes. If we have disclosed any personal information to third parties for direct marketing purposes, we will provide a list of the categories of personal information, along with the names and addresses of these third parties to you at your request. To make such a request, contact us at the e-mail address found in the “Contact Us” section of this Privacy Policy.

This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the specified e-mail or postal address. You should put “California Privacy Rights” in the e-mail subject line and in the body of your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.

California Consumer Privacy Act

California residents have the right to request any of the following information about the Information that we collect:

What Information we collect;
Where and from whom we collect such Information;
The business purpose for collecting Information;
Who we share that Information with and the types of Information disclosed; and
The categories of third parties to whom we disclosed your Information

This information will be provided free of charge, by mail or electronically; and in a portable and readily useable format, to the extent possible.

You have the right to request that we delete any of your personal information. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why.

You will not be denied services, provided a different quality of services or penalized or charged different pricing or rates for exercising these rights.

To make such a request, contact us at the postal or e-mail address found in the “Contact Us” section of this Privacy Policy. We may request specific information from you to help us confirm your identity and process your request. We will not use that information for any other purpose.

California Minors Under 18

If you are a California resident under the age of 18 and are a registered user of our App, you may request that we remove from our App any content you post that can be accessed by any other user (whether registered or not). Please note that any content that is removed from visibility on our App may still remain on our servers and in our systems. To request removal of content under this provision, please write or e-mail us at the postal or e-mail address found in the Contact Us section of this Privacy Policy. When you write us, provide us with a description of the content and the location of the content on our App.

When this Privacy Policy Applies

This Privacy Policy applies to any Information collected through the App only. Our Policy does not apply to the practices of other companies or other websites or software applications that may be linked from or made available through our App. The inclusion of a link on our App or the ability to utilize a third party website or software application through our App does not imply that we endorse, or otherwise monitor the privacy or security practices of that third party website or software application or the accuracy of its content and your use of the third party website or software application is governed by the third party’s privacy policy. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Rights of European Union Residents

The following sections apply only if you a resident in the European Union or European Economic Area using our App (an “EU User”):

Personal Information- References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller and Data Protection Officer NoGuru is the controller of your personal information for purposes of European data protection legislation. You can contact our Data Protection Officer at info@noguru.com.
European Union and United Kingdom Residents under 16 - The App may not be used by any European Union and United Kingdom residents under the age of 16.

Lawful Basis for Data Processing

We will only collect, store, and process the personal information of EU Users where a lawful basis for such processing exists, which will typically fall under one of the following scenarios:

You have given consent to the processing of your personal information for one or more specific purposes, for example by consenting to receiving electronic marketing, in which case you may withdraw your consent subsequently at any time (by emailing info@noguru.com) without affecting the lawfulness of processing based on consent before its withdrawal;
Processing is necessary for the performance of a contract to which you, the Data Subject, are party;
Processing is necessary for compliance with a legal obligation to which NoGuru as a Controller is subject;
Processing is necessary for the purposes of the legitimate interests pursued by us as the Controller, or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you, the Data Subject, which require protection of your personal information.

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. However, we will not share Personal Information of EU Users with a third party for research purposes (i.e., research not related to improving our products or services) without obtaining your prior consent to do so as required by applicable law in the European Union.

Retention

If you are an EU User, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for or as required by applicable law. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your Rights

European data protection laws gives EU Users certain rights regarding your personal information. EU Users may ask us to take the following actions in relation to your personal information that we hold:

Opt-Out - Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
Provide you with information about our processing of your personal information and give you access to your personal information.
Update or correct inaccuracies in your personal information.
Delete your personal information.
Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to info@noguru.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described below or submit a complaint to the data protection regulator in your jurisdiction.

You may contact us at info@noguru.com or at Dositheou, 7, PARA BUILDING, BLOCK B, FLAT/Office B101, 1071, Nicosia, Cyprus.

Effective Date

September 21, 2020