Last modified date: March 5, 2018
Akili Interactive Labs, Inc. (“Akili” or “we”) develops cognitive platforms (including the Project: EVO™ platform) and mobile applications (“apps”) which enable multiple clinical products for remote data-capture and intervention. Our proprietary adaptive mechanics allow the software (including embedded software and third party software) to automatically personalize to the patient's ability level with no clinician input required.
Akili is committed to protecting the confidentiality, privacy and security of the data of its mobile app and website visitors (“you”, “your”). We want you to understand how we collect and use information, including personally identifiable data, so you can interact with Akili with confidence. Personally identifiable data (“Personal Data”) is data that includes a personal identifier like your name, address, email address, , and other similar information that can be used to identify you.
Information We Collect
When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below.
When You Contact Us for Help
If you are a Study Participant, please contact your Researcher for help. You should not contact us through our Services or social media pages for help.
If you are a visitor to our Services, you should contact email@example.com for help. Whenever you contact us for help, we collect your name and email address along with additional information you provide in your request so that we can provide you with assistance.
When You Visit or Use our Services
When you use or access our Services, we may collect and use Personal Data, about you, as well as other information, such as:.
- Users may provide information such as an email address, phone number, and password to create and log into an account. In order to facilitate your use of our Services, and to make it easier to log your child’s behaviors, Akili will permit you to remain logged into the Services for a 30-day period. At the end of each 30-day period, you will be prompted to re-enter your login credentials. If you prefer, you may manually log out each time you use the Services.
- Information provided to us when you communicate with us for any reason, including information you provide in emails you send us, or submissions you may make to our blog or content you post through our social media pages.
Other Information We Collect:
When you interact with Akili through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Akili may store such information itself or such information may be included in databases owned and maintained by Akili affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process. 
Information from Other Sources
We do not collect any information about you from other sources outside your interaction with the Services.
Use of Your Information
- De-identified data, including data you provide to us via our Services, may be used to inform the health community about trends, for publication in scientific journals, for product development, in commercial transactions, for marketing and promotional use, or for sale to interested audiences. See “Sharing of De-identified Data That Does Not Identify You” to learn more.
- To provide you, including via your email address, with information relating to the Services; and
- To administer our Services, including by monitoring and analyzing traffic and usage patterns on our Services.
- Akili and its affiliates may use your information to contact you in the future to tell you about services or products we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us at firstname.lastname@example.org
Sharing Your Information
We don’t sell any data that could identify you, and we only share data about you when it is necessary to provide the Services. We may sell data, but only when the data is de-identified and aggregated.
Data That Could Identify You
We do not sell or rent Personal Data collected through Akili’s Services to anyone. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, under the following circumstances:
- With companies that are contractually engaged in providing us with services, such as order fulfillment, email management, credit card processing, and compiling statistics and reports regarding our audience and the users of the Services. These companies are obligated by contract to safeguard any Personal Data they receive from us.
Such third parties have access to personal information as needed to perform their functions, but they are not allowed to use it for other purposes.
Data That Does Not Identify You (De-identified Data)
Akili may sell or share aggregated, de-identified data, including data you provide to us through our Services, with third party partners and with the public in a variety of ways, such as, but not limited to, by providing research or reports about health and fitness, publishing in scientific journals, using it in product development, and in commercial transactions. This research may be compiled and analyzed on an aggregate basis, and Akili may share this aggregate data with its affiliates, agents and business partners. When we provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from re-identifying it back to you. Akili may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Technologies We Use
A “cookie” is a small computer file that is sent to your computer when you visit a website or mobile app. When you visit the site or app again, the cookie allows that site or app to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Keep in mind, however, that some website features or services may not function properly without cookies.
A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.
“Do Not Track” Requests
Although we would like to honor the browsers set with a “Do Not Track” signal, our Services do not currently respond to a DNT or similar signal as Akili awaits the results of efforts by the policy and legal community to determine the meaning of DNT and the proper way to respond. However, we believe that consumers should exercise choice regarding the collection of this type of data, which is why we disclose the cookies used and provide links to opt-out of those collection practices below. You can also visit our Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain of our Services.
We use the following third-party data analytics platforms to improve the Services in a variety of ways:
Third Party Websites and Social Media Features
How Long We Save your Data
We may store your information indefinitely.
Akili takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These procedures include, but are not limited to, firewalls, encryption, intrusion detection, and monitoring. We also limit access to any Personal Data we receive to employees who need access to that information in order to do their jobs. However, no data protection procedures are entirely infallible. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Akili via the Internet. As a result, while we strive to protect your Personal Data, we cannot guarantee that it will be 100% secure. Your transmission of your data to our Services thus is done entirely at your own risk.
Backups of data that you provide to us through the Services, such as your email address, will remain in our archive servers.
Email & Other Communications
We may need to contact you about your use of the Services. These communications are part of the Services and you may not opt out from receiving them. You can opt out from receiving other communications from us by contacting email@example.com. Further, you acknowledge that features of the Services may, now or in the future, enable your tablet, mobile phone or other similar device to receive text message (SMS) alerts (the “Text Message Service”). You will be required to opt-in to the Text Message Service if you want the Text Message Service activated. Akili will not charge you for the text message (SMS) alerts you may receive from the Services. However, message and data rates may apply from your mobile carrier in accordance with your wireless customer agreement with your carrier and you are responsible for any such charges. You should consult your wireless service provider regarding its pricing plans.
Akili’s Services are hosted and operated in the United States (“US”). By using the Services, you are consenting to the transfer of your personal information to the US. If you are accessing the Services from outside the US, please be advised that US law may not offer the same privacy protections as the law of your jurisdiction.
California Privacy Rights
California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes. Akili does not share any California consumer personal information with third parties for marketing purposes without consent.
California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.
Users Only of Legal Age of Majority
Other Terms and Conditions
Your access to and use of the Services is subject to the Terms of Service at [link].
Access to Information
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
Akili Interactive Labs, Inc.
125 Broad Street, 4th floor
Boston, MA 02110
Attn: Legal Affairs
Copyright© 2018, Akili Interactive Labs, Inc. All rights reserved.