Virufy
Privacy Policy
Last updated: September 30, 2025
The Covid Detection Foundation d.b.a. Virufy (“Virufy”, “we”, “us” or “our”), a California nonprofit corporation (Tax Identification Number: C4609035) located at 4546 El Camino Real B10 #614, Los Altos, California 94022, United States of America collects personal information to achieve our mission of offering respiratory disease pre-screening for patients, clinicians, and governments, especially in low-income countries.
This Privacy Policy (the “Privacy Policy”) sets out how we use, store, disclose, and process personal information you (“User”) provide to us when you participate in our research survey for the compilation of a dataset needed for the development of artificial intelligence (“AI”) algorithms for device-based COVID-19 and other respiratory disease detection (the “Dataset”) for the benefit of developing and developed countries, or that we obtain through or in connection with the use of our website at www.virufy.org (the “Website”), or when you otherwise interact with us via our other online or offline digital properties which link to, or are otherwise subject to this Privacy Policy (the “Services”).
Special Note to Virufy Users Interacting with our Contracted Clinical Care Providers: When you visit our website, mobile application, or inquire about or register for our Services, this Privacy Policy applies to the information we collect, use, and share identifying you and relating to your past, present, or future physical or mental health, treatment and services received, and payment for such treatment and services. If this information is collected, used, or shared as part of your treatment relationship with a clinical care provider, this information may be considered protected health information (“PHI”) protected by the Health Insurance Portability and Accountability Act of 1996 (as amended) and the Health Information Technology for Economic and Clinical Health Act (collectively, “HIPAA”) and subject to such clinical care provider’s privacy policies and HIPAA Notice of Privacy Practices describing how they use and disclose your PHI.
Special Note to Connecticut, Nevada, and Washington Virufy Users and Potential Users. For information on our processing of “consumer health data” subject to the Connecticut Data Privacy Act, as amended, Nevada Consumer Health Data Privacy Law, or Washington My Health My Data Act, please see Annex A – Supplemental U.S. Consumer Health Data Privacy Notice.
Special Note to Virufy Users Outside of the United States. If you are located in the European Union, and only if and to the extent the European General Data Protection Regulation 2016/679 (the “GDPR”) applies, Virufy is the “data controller” of, and responsible for, your personal information collected in accordance with this Privacy Policy.
- “PERSONAL INFORMATION” DEFINITION
- PERSONAL INFORMATION WE COLLECT
- HOW WE USE YOUR PERSONAL INFORMATION
- HOW WE SHARE YOUR PERSONAL INFORMATION
- STORAGE AND RETENTION
- INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
- SUPPLEMENTAL NOTICE FOR EU/UK GDPR
- YOUR PRIVACY CHOICES AND RIGHTS
- UPDATES TO THIS PRIVACY POLICY
- CHILDREN’S PERSONAL INFORMATION
- THIRD-PARTY WEBSITES/APPLICATIONS
- CONTACT US
1. “PERSONAL INFORMATION” DEFINITION
The term “personal information” as used in this Privacy Policy shall mean any information (including “personal data”, “sensitive data”, “health data”, “health information”, and “biometric information” as those terms may be defined in applicable data protection laws) that actually enables, or is capable of enabling us to identify you, directly or indirectly, by reference to an identifier such as your name, age, gender identity, postal address, email address, location data, online identifier or one or more factors specific to you.
2. PERSONAL INFORMATION WE COLLECT
We may collect personal information that are provided to us by you, collected automatically when you use the Services, and provided by third-party sources as described below.
- A. Personal Information You Provide to Us Directly
- Health Information. You provide us with your personal information by participating in the development of the Dataset and assisting us with promoting the research of coughs through AI algorithms. Such personal information may include, but is not limited to, current region (country and state), age group, biological sex, gender identity, smoking status, relevant medical conditions, relevant respiratory conditions, relevant active medications, flu or COVID-like symptoms and related medical symptoms and respiratory conditions, testing results, the timeframe of your tests taken and onset of symptoms, and cough sample recording.
- Donations. We may collect personal information and details associated with your donations, including, but not limited to, your name, email address, phone number, mailing address, and payment information (i.e., payment amount, payment date). Any donations made via our Website are processed by third-party payment processors (e.g., PayPal, GoFundMe). We do not directly collect or store any payment card information entered through our Website, but we may receive information associated with your payment card information (e.g., your billing details).
- Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email.
- Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
- Conferences and Other Events. We may collect personal information from individuals when we attend or host conferences and other events.
- Job / Volunteer Applications. If you apply for an employment, internship, or volunteer position with us, we will collect any personal information you provide in connection with your application, such as your contact information, employment information, and CV.
- B. Personal Information Collected Automatically
- Device Information. We may collect personal information about your device, such as your internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
- Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
- Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
- - Cookies. Cookies are small text files stored in device browsers.
- - Pixel Tags / Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
- C. Personal Information Collected from Third Parties
We may collect personal information automatically when you use the Services.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below. We may use and disclose anonymized information about our Users and information that does not identify any individual without restriction.
- A. Provide the Services
- managing your personal information;
- providing access to certain areas, functionalities, and features of the Services;
- communicating with you;
- answering requests;
- developing, training, and fine-tuning models, algorithms, and artificial intelligence technologies to analyze your cough audio recordings in order to better determine signs of COVID-19 and other disease detection;
- sharing personal information with third parties as needed to provide the Services;
- processing your financial information and other payment methods for donations; and
- allowing you to register for events.
- B. Operate Our Business
- providing the Services;
- pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- carrying out analytics;
- measuring interest and engagement in the Services;
- improving, upgrading, or enhancing the Services;
- analyzing, improving, upgrading, and/or enhancing the Services through the use of artificial intelligence and other methods;
- developing new products and services;
- creating de-identified and/or aggregated information to conduct anonymized demographic analysis of respiratory and related disease cases;
- running clinical research studies and other research activities;
- processing applications if you apply for a job we post on our Website;
- ensuring internal quality control and safety;
- authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
- debugging to identify and repair errors with the Services;
- auditing relating to interactions, transactions, and other compliance activities;
- enforcing our agreements and policies; and
- carrying out activities that are required to comply with our legal obligations.
- C. Marketing
- D. With Your Consent or Direction
- E. Automated Decision Making
Our Services are enabled by machine-learning tools fundamental to our ability to provide real-time engagement and inform disease type and progression. These machine-learning tools process natural language communications to support user experience and outcomes.
We may use your personal information to operate our business, such as:
We may use personal information to tailor and provide you with marketing and other content.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.
We may engage in automated decision making, including profiling. Our processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.
If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
4. HOW WE SHARE YOUR PERSONAL INFORMATION
- A. Disclosures to Provide the Services
- Service Providers. We may share personal information with third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, AI or machine learning services, analytics, marketing services, IT support, and related services.
- - Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.
- - Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.
- Third-Party Research Institutions. We may share your personal information with third parties for academic research, commercial, and non-profit purposes, such as to combine your personal information as part of the Dataset to be used globally to accelerate the development of technologies for the detection of respiratory diseases.
- Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).
Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
- Strategic Partners. We may share your personal information with strategic partners, including other non-profits, universities, companies, or organizations who support the mission of Virufy or collaborate with us, to provide you with a service you have requested. We may also share your personal information with strategic partners with whom we jointly offer services.
Once your personal information is shared with our strategic partner, it will also be subject to our strategic partner’s privacy policy. We are not responsible for the processing of personal information by our strategic partners. we recommend you to carefully review our strategic partners’ privacy policy to understand your privacy rights.
- Affiliates. We may share your personal information with our corporate affiliates.
- B. Disclosures to Protect Us or Others
- C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
Some of the service providers we may use include:
We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction. In the event that this occurs, we may require the provider to maintain a similar privacy policy or include such a requirement as a term of the corporate transaction.
5. STORAGE AND RETENTION
Personal information that is collected is stored in a secure third-party application with restricted access and controls (e.g. Amazon Web Services, Google Cloud, Google Drive, Google Mail, etc.). Your personal information will be stored with such a third-party application until it is downloaded by us. We will store the personal information with restricted access.
Information supplied for volunteer and employment applications will be stored in a secured cloud data server only accessible by Virufy recruitment staff.
We store your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights. We will store your personal information associated with your participation in our study in an anonymized form which cannot identify you for the purposes mentioned in the “How We Use Your Personal Information” section above.
We will store personal information associated with job and volunteer applications and email communications, in a form that permits us to identify you, for no longer than is necessary for the purpose for which the personal information is processed in accordance with the applicable laws. Otherwise, we will seek to delete your personal information within a reasonable timeframe upon request accordingly with your rights.
We will store your information data as needed to fulfill our legal obligations, resolve disputes, and enforce our agreements and rights. Otherwise, we will delete your personal information upon request, in accordance with your rights in Section 8 below.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
If you are visiting our Website, and/or assisting with our research, or otherwise providing personal information to us from outside the U.S., be aware that your personal information may be transferred to, stored, and processed by us outside of the jurisdiction within which you are based. Where personal information relating to individuals based in the European Economic Area (“EEA”), Switzerland, and/or the United Kingdom is shared with a third party located in a country that does not provide an adequate level of protection under applicable data protection laws, we rely upon appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses. Please contact dpo@virufy.org for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
7. SUPPLEMENTAL NOTICE FOR EU/UK GDPR
This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.
In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.
Virufy’s processing of your personal information may be supported by one or more of the following lawful bases:
| Privacy Policy Section | Lawful Basis: Performance of a Contract (i.e., to provide the Services to you) | Lawful Basis: Legitimate Interest | Lawful Basis: Consent | Lawful Basis: For Compliance with Legal Obligations |
|---|---|---|---|---|
| Section 3A: Provide the Services | ✔ | ✔ | ✔ | ✔ |
| Section 3B: Operate Our Business | ✔ | ✔ | ✔ | ✔ |
| Section 3C: Marketing | ✔ | ✔ | ||
| Section 3D: With Your Consent or Direction | ✔ | ✔ | ✔ | |
| Section 3F: Automated Decision Making | ✔ | ✔ | ✔ | ✔ |
If we process personal information that is considered a “special category of personal data”, then our processing of this personal information may be supported by one or more of the following conditions:
- Explicit Consent: You may have provided your explicit consent for our processing of your personal information.
- Necessary for Employment, Social Security, or Social Protection Law Purposes: Our processing of your personal information may be necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment, social security, and/or social protection law.
- Necessary to Protect Vital Interests: Our processing of your personal information may be necessary to protect your vital interests if you are physically or legally incapable of giving consent.
- In Connection with a Foundation, Association, Non-Profit Body or Other Partner Organization: Our processing of your personal information may be carried out in the course of our legitimate activities in connection with a foundation, association, non-profit body, or other partner organization.
- Publicly Available Personal Information: Our processing of your personal information may relate to personal information which has been manifestly made public by you.
- Necessary for the Establishment, Exercise or Defense of Legal Claims: Our processing of your personal information may be necessary for the establishment, exercise or defense of legal claims.
- Necessary for Substantial Public Interest: Our processing of your personal information may be necessary for reasons of substantial public interest.
- Necessary for Medical Purposes: Our processing of your personal information may be necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, or pursuant to contract with a health professional.
- Necessary for Substantial Interest in the Area of Public Health: Our processing of your personal information may be necessary for reasons of public interest in the area of public health.
- Necessary for Archiving, Research, or Statistical Purposes: Our processing of your personal information may be necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
If your personal information is subject to the applicable data protection laws of the European Economic Area, you may find the contact details of the competent authorities in the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
For the United Kingdom, you may lodge a complaint with the Information Commissioner’s Office (ICO) by clicking here: https://ico.org.uk/make-a-complaint/
8. YOUR PRIVACY CHOICES AND RIGHTS
- A. Your Privacy Choices.
- Email Communications: If you receive an unwanted marketing email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to this Privacy Policy).
- Text/SMS Messages: If you receive an unwanted promotional text/SMS message from us, you may opt out of receiving future text/SMS messages from us by following the instructions in the text/SMS message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
- Mobile Devices: We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services or contact us using the information set forth in “Contact Us” below.
- “Do Not Track”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies: You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.
- B. Your Privacy Rights.
- Request access to your personal information: You may have the right to request access to any personal information we hold about you as well as related data, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
- Request correction of your personal information: You may have the right to obtain without undue delay the rectification of any inaccurate or outdated personal information we hold about you.
- Request erasure of your personal information: You may have the right to request that personal information that was given with your consent is deleted.
- Request restriction of processing your personal information: You may have the right to prevent or restrict processing of your personal information.
- Request transfer of your personal information: You may have the right to request transfer of your personal information directly to a third party where this is technically feasible.
- Right to object: You may have the right to object to the processing of your personal information when you have legitimate reasons to do so.
- Right to withdraw consent: Where processing is based on consent, you may have the right to withdraw such consent.
- Request the anonymization, blockage or elimination of unnecessary, excessive and non-compliant processed data: You may have the right to have excessive, unnecessary or non-compliant processed data anonymized or excluded accordingly with the principle of necessity.
The privacy choices you may have about your personal information are described below.
Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.
The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.
Please note you must separately opt out in each browser and on each device.
In certain circumstances, you may have the following rights in relation to your personal information:
We will process such requests in accordance with applicable laws.
If you request deletion of essential information, such as cough recordings, for the management of your account with Virufy, this will result in the termination of your registration and participation in the research. If you need any assistance to exercise your rights, you may contact us as described in the “Contact Us” section below.
To exercise the above-mentioned rights, please send an email with an enclosed copy of the frontside of your identity card todpo@virufy.org. We reserve the right to request the provision of additional information necessary to confirm the identity of the enquirer.
9. UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time at our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy on our website, and/or we may also send other communications.
10. CHILDREN’S PERSONAL INFORMATION
The Services are not directed to children under 14 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in the “Contact Us” section below.
11. THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
12. CONTACT US
If you have any questions relating to the privacy of your personal information or to exercise your rights as detailed in this Privacy Notice, please contact us at dpo@virufy.org.
ANNEX A
SUPPLEMENTAL CONSUMER HEALTH DATA PRIVACY STATEMENT
This Supplemental Consumer Health Data Privacy Statement (“Consumer Health Data Privacy Statement”) supplements our Privacy Policy.
This Supplemental Consumer Health Data Privacy Statement only applies to personal information we process that is “consumer health data” subject to the Connecticut Data Privacy Act, as amended (“CTDPA”), Washington My Health My Data Act (“MHMDA”), Nevada’s Consumer Health Data Privacy Law (“NVCHDPL”), or other states with consumer health data privacy laws (as applicable).
Terms used in this Supplemental Consumer Health Data Privacy Statement that are defined in MHMDA, NVCHDPL, or CTDPA will have the meaning set forth in those laws to the extent such laws are applicable.
CONSUMER HEALTH DATA WE COLLECT
Under the MHMDA, “consumer health data” is defined as “personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status.”
Under NVCHDPL, “consumer health data” is defined as “personally identifiable information that is linked or reasonably capable of being linked to a consumer and that a regulated entity uses to identify the past, present or future health status of the consumer.”
Under CTDPA, “consumer health data” is defined as “any personal data that a controller uses to identify a consumer's physical or mental health condition or diagnosis, and includes, but is not limited to, gender-affirming health data and reproductive or sexual health data.”
Because consumer health data is defined very broadly, many of the categories of personal information that we collect under our Privacy Policy may also be considered consumer health data.
Examples of consumer health data that you may provide to us, or that we may otherwise collect, may include:
- Information about your health-related conditions, symptoms, status, diagnoses, disease, testing, or treatments.
- Information about use or purchase of prescribed medication.
- Information about measurements of bodily functions, vital signs, symptoms, or characteristics.
- Information about diagnoses or diagnostic testing, treatment, or medication.
- Information about surgeries or other health-related procedures.
- Biometric information.
- Information processed to associate or identify an individual with the data listed above that is derived or extrapolated from non-health information.
- Other information that may be used to infer or derive data related to the above or other consumer health data.
SOURCES OF CONSUMER HEALTH DATA
We collect consumer health data that you provide to us, consumer health data we collect automatically when you use the Sites, and consumer health data from third-party sources, as described in our Privacy Policy and below.
WHY WE COLLECT AND USE CONSUMER HEALTH DATA
We collect and use consumer health data for the purposes and in the manner described in the “How We Use Your Personal Information” section of our Privacy Policy.
Primarily, we collect and use consumer health data as reasonably necessary to provide you with the products or Services you have requested or authorized. This may include delivering and operating the products or Services and their features, personalization of certain product or Website features, ensuring the secure and reliable operation of the products or Services and the systems that support them, troubleshooting and improving the products and Services, and other essential business operations that support the provision of the products and Services (such as analyzing our performance and meeting our legal obligations).
We may also use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law.
SHARING OF CONSUMER HEALTH DATA
We may share each of the categories of consumer health data described above for the purposes described above and in the “How We Use Your Personal Information” section of our Privacy Policy.
We only share or disclose your consumer health data as needed to provide you with the products or Services that you request, or with your explicit consent. We may share or disclose any or all the above categories of consumer health data to the following entities, who shall use the data only as permitted for the purposes set forth above, and within the bounds of our contracts with them:
These general categories of third parties:
- research, academic, nonprofit, and business collaborators;
- product co-promotion partners;
- product co-development partners;
- service providers (including those hosting or analyzing data on our behalf, those assisting with fraud prevention, those assisting in program administration, those assisting in incident management and reporting, those administering our call center and websites, and those who assist with our information technology and security programs);
- emergency personnel;
- authorized/legal representatives, family members, and caregivers;
- third parties (including those with whom Virufy has joint marketing and similar arrangements, those who provide marketing and data analytics services, those who provide program enrollment or product fulfillment, payment, and authorization, other third parties as necessary to complete transactions and provide products or Services, or where required by law);
- lawyers, auditors, and consultants providing services to Virufy; and
- legal and regulatory bodies.
In addition, we may share or disclose consumer health data as permitted or required by law, such as (i) to an acquiring organization if we are involved in a sale or a transfer of our business, (ii) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, (v) as needed to support external auditing, compliance and corporate governance functions, (vi) as needed to preserve the integrity or security of our systems, or (vii) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or federal law.
HOW TO EXERCISE YOUR RIGHTS
The CTDPA, MHMDA, and NVCHDPL provide consumers with certain rights with respect to consumer health data.
Under MHMDA, consumers have the right to: (i) confirm whether Virufy is collecting, sharing, or selling consumer health data and to access such data; (ii) withdraw consent from Virufy’s collection and sharing of consumer health data; and (iii) request that Virufy delete consumer health data.
Under NVCHDPL, consumers have the right to: (i) confirm whether Virufy is collecting, sharing or selling consumer health data; (ii) have Virufy provide the consumer with a list of all third parties with whom Virufy has shared consumer health data relating to the consumer or to whom Virufy has sold such consumer health data; (iii) request that Virufy cease collecting, sharing, or selling consumer health data relating to the consumer; and (iv) request that Virufy delete consumer health data.
Under CTDPA, Virufy is required to obtain consumer consent prior to selling or offering to sell, consumer health data. Consumers have the right to: (i) confirm whether Virufy is collecting or sharing consumer health data; (ii) have Virufy provide the categories of consumer health data that it shares with third parties and the categories of third parties with which it shares consumer health data; and (iii) withdraw consent from Virufy’s selling of consumer health data.
The rights afforded to consumers under CTDPA, MHMDA, and NVCHDPL are subject to certain exceptions.
Subject to certain legal limitations and exceptions, you have the following rights with respect to any consumer health data we may collect about you:
- The right to confirm whether we are collecting, sharing, or selling your consumer health data and to access such data, including to receive a list of affiliates or specific third parties with whom we have shared or sold your information, along with contact information such as an active email address for each third party;
- The right to review and request corrections to your consumer health data;
- The right to withdraw consent from our collection or sharing of your consumer health data; and
- The right to request that we delete your consumer health data.
You may submit a request pursuant to any of these rights by contacting us as described in the “Contact Us” section.
Virufy will not discriminate against you for exercising any of your rights. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. Please allow 45 days for a response. We may, after receiving your request, require additional information from you to authenticate your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. If we deny your request, you have the right to appeal that denial by contacting us as described in the “Contact Us” section. We will process and respond to your appeal within the time permitted by applicable law.
If you are a Washington resident and your appeal is unsuccessful, you may file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
CHANGES TO OUR CONSUMER HEALTH DATA PRIVACY STATEMENT
We may update this Consumer Health Data Privacy Statement from time to time. When we do update it, for your convenience, we will make the updated statement available on this page. Our intention is to use consumer health data in accordance with the Consumer Health Data Privacy Statement in place at the time the consumer health data was collected.
ANNEX B
CONSUMER HEALTH DATA AUTHORIZATION
This Consumer Health Data Privacy Authorization (“Authorization”) supplements Virufy’s (“Virufy”, “we,” “us,” or “our”) Privacy Policy, Supplemental Consumer Health Data Privacy Statement, and the www.virufy.org cookie banner and applies only to “consumer health data” subject to the Connecticut Data Privacy Act, as amended (“CTDPA”), Washington My Health My Data Act (“MHMDA”), Nevada Consumer Health Data Privacy Law (“NVCHDPL”), or other states with consumer health data privacy laws (as applicable).
Terms used in this Authorization defined in CTDPA, MHMDA, NVCHDPL, or other applicable state consumer health data privacy laws will have the meaning set forth in those laws to the extent such laws are applicable.
If you opt-in to “personalized marketing” through the www.virufy.org cookie banner, you allow us to “sell” your consumer health data as described below:
- Specific consumer health data intended for “sale”: Consumer health data collected via cookies and similar technologies including but not limited to browsing activity on our website.
- Purpose of the “sale” of consumer health data: To tailor and deliver personalized advertisements to you.
- How consumer health data purchasers gather and use the data:Consumer health data purchasers will gather the data via cookies and other tracking technologies when you visit www.virufy.org. These purchasers may use the data to assist us to deliver personalized advertisements to you and in accordance with their privacy policies linked below.
- Consumer health data purchasers’ contact information:
- - Google: Privacy Policy
- - Microsoft: Privacy Statement
- - X Advertising: Privacy Policy
- - Facebook/Meta: Privacy Policy
- Contact information for Virufy: dpo@virufy.org
Please note:
- The provision of goods or services may not be conditioned upon you accepting the terms of this Authorization.
- Purchasers may redisclose the consumer health data sold under this authorization and such data may no longer be protected by the CTDPA, MHMDA, NVCHDPL, and/or applicable state consumer health data privacy laws.
- You may revoke this authorization at any time through the www.virufy.org cookie banner. To do so, please be sure the box next to “Personalize marketing” is unchecked and click “Save my choices.” You may also click “Decline all” to decline our use of all cookies not required to operate our website.
- A revocation will not impact previously sold consumer health data. In addition, if you use different browsers or devices, you must indicate your choices on each browser/device used to access www.virufy.org.
If you have any questions about how to revoke your authorization, please contact: dpo@virufy.org.
This authorization will expire one (1) year after accepting it.