Nervana legal

Nervana Privacy Notice

Last Updated: July 31, 2026

Who We Are

Nervana Health, Inc. (“Nervana,” “we,” “our,” or “us”) is a consumer educational and coaching platform, and we value your privacy and the protection of your Personal Data. This Privacy Notice (“Notice”) explains how we collect, store, use, share, transfer, delete, and process information collected from or about you known as Personal Data (defined further below in this Notice), and how you may exercise any rights you may have regarding our processing of your Personal Data. Nervana, or any of its subsidiaries or affiliates, will be responsible for the collection and processing of your Personal Data (known in some jurisdictions as the data controller).

Purpose and Reach of this Privacy Notice

This Notice describes the types of Personal Data that Nervana may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding our processing of your Personal Data.

This Notice applies to Personal Data collected or processed by us:

Through online activities and services we offer (through websites, web surveys, newsletters, applications, email, online messaging services/channels, and otherwise) (“Online Services”);

When we provide products and services directly to you, or when we facilitate optional services provided to you by an independent Coach, and in other situations where you interact with us, including but not limited to interacting with us by telephone, through email or SMS/text messages, or by visiting our sites and offices or our events (e.g., tradeshows and conferences) (such products and services, together with Online Services, are collectively, the "Products and Services");

When we undertake employment recruiting activities; or

Anywhere this Notice is posted or referenced.

Nervana may provide you with a different privacy notice in certain specific situations, in which case that privacy notice or policy will apply to the Personal Data collected or processed in that specific situation, rather than this one.

If you provide us with Personal Data of anyone other than yourself (such as a friend or family member), please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to Nervana (including obtaining consent, if required).

Please review this Notice carefully. To the extent permitted by applicable law, by providing us with your Personal Data or otherwise interacting with us, you are agreeing to this Notice.

Information Collected

What is Personal Data?

“Personal Data” is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link to or associate with a specific individual.

Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license, state identification card, passport number, and other similar information. Data that could be considered Sensitive Personal Data is highlighted with an asterisk (*) in the chart below.

We will process any Personal Data we collect in accordance with applicable law and as described in this Notice (unless, as explained above, a separate policy or notice governs). In some circumstances, if you do not provide us with your Personal Data, certain Products and Services may be unavailable to you.

The below table is a high-level summary of the types of Personal Data we may collect from you. Following that high-level summary is additional detail and information on how we collect, process, and use Personal Data and the potential recipients of your Personal Data, now and in the preceding 12 months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which are included below, but please note that not all jurisdictions may recognize all legal bases. The types of Personal Data we collect and disclose depends on your relationship with Nervana. Not all of the categories listed in the following charts may apply to you. If the nature of your relationship with Nervana changes, additional categories of Personal Data may also apply.

	Identity and contact information	Other personal information	Visual and audio information	Technical information	Wellness and symptom information	Commercial and financial information	Professional and educational information	Inferences	De-identified data
	This may include name, email, phone number, etc.	This may include age, gender, date of birth, etc.	This may include still images, video, call recordings, etc.	This may include Internet Protocol (IP) address, browser, device type, etc.	This may include journal entries, session insights, symptom trends, etc.	This may include request documentation, financial transaction history, etc.	This may include job title or position, employer, etc.	Drawn from your Personal Data used to create a profile about you.	Data for which your individual personal characteristics have been removed****
Users of Online Services, Visitors to Our Websites, and Senders of Inquiries	X	X*	X	X*	X*			X	X
Users of Our Products and Services	X	X*	X*	X*	X*	X*		X	X
Business Partners and Their Employees, Agents, and Contractors	X	X*	X	X*		X*			X
Employment and Apprenticeship Candidates	X	X*		X*			X	X	X

Personal Data that may be considered sensitive is noted with a “*”.

Users of Online Services, Visitors to Our Websites, and Senders of Inquiries
We may process your Personal Data when you: (1) visit our websites and applications; (2) submit inquiries to us both online (e.g., via email) or offline (e.g., by written letters); and/or (3) sign up for our newsletters or other informational or marketing materials.
Examples of the types of data we process (Personal Data that may be considered sensitive is noted with a “”)*
Identity and contact information, such as:	first and last name or unique pseudonym honorifics and titles, preferred form of address email address postal address phone number customer number company ID number such as account number
Other personal information, such as:	age gender disability* date of birth
Visual and audio information, such as:	still images video recordings of your calls with our customer service representatives voicemails
Technical Information, such as:	Internet Protocol (IP) addresses (which may identify your general geographic location or company) browser type and browser language device type advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) date and time you use our Products and Services Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services activity on our Products and Services and referring websites or applications data collected from cookies or other similar technologies***
De-identified Data:	De-identified data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws****
Where do we get the data?
you directly those authorized to provide on your behalf such as an authorized representative your devices our security systems third parties that provide access to information you make publicly available, such as social media
Why do we process the data? (Purposes for the processing of Personal Data that may be considered sensitive are noted with a “”)*
to provide you with our Products and Services* to communicate with you and respond to your requests to administer our relationship with your organization* to send you information about our Products and Services, including press releases, product news and updates* to notify you of new Nervana Products and Services to respond to reports about our Products and Services to identify and authenticate you* to ensure we have up-to-date contact information to customize content for you* to detect security incidents* to protect against malicious or illegal activity* to ensure the appropriate use of our Products and Services* to monitor the safety of our Products and Services to improve our Products and Services* to improve our Online Services, including digital design or content* for short-term, transient use* for administrative purposes * to monitor and analyze trends, usage and activities in connection with our Products and Services* for marketing, internal research, data analysis, and development* for quality assurance and to assist in training and development of our representatives* to operate our business, including for auditing advertising and product promotion, including to contact you regarding programs, events, products, services, and topics that may be of interest or useful to you* to comply with legal and regulatory obligations*
Who receives the data? (Parties that may receive Personal Data that may be considered sensitive are noted with a “”)*
Nervana, our affiliates, and related companies third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programs and our loss prevention programs partners that assist us in providing the Products and Services or help us improve our marketing or administration** Nervana’s lawyers, auditors and consultants

Business Partners and Their Employees, Agents, and Contractors
We may process your Personal Data if you are a current Nervana business partner, employee of a Nervana business partner, agent or contractor.
Examples of the types of data we process (Personal Data that may be considered sensitive is noted with a “”)*
Identity and contact information, such as:	first and last name or unique pseudonym honorifics and titles, preferred form of address company/employer email address postal address phone number customer number company ID number such as account number records of collaborations with Nervana
Other personal information, such as:	age gender date of birth
Technical Information, such as:	Internet Protocol (IP) addresses (which may identify your general geographic location or company) browser type and browser language device type advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) date and time you use our Products and Services Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services activity on our Products and Services and referring websites or applications data collected from cookies or other similar technologies***
Commercial and financial information, such as:	Products and Services purchased, obtained, or considered bank account number and details* request documentation customer service records financial transaction history financial account number*
Professional and educational information, such as:	job title or position employer working location National Provider Identifier number state medical license number work skills employment history graduate degrees certifications specialized training responses to surveys and questionnaires enrollment history for our education and training events
De-identified Data:	De-identified data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws****
Where do we get the data?
you directly your devices our business partners and other third parties that provide access to information you make publicly available, such as social media platforms your employer or principal
Why do we process the data? (Purposes for the processing of Personal Data that may be considered sensitive are noted with a “”)*
to communicate with you and respond to your requests to administer our relationship with your organization* to administer and manage your registration and participation at events* to send you information about our Products and Services, including press releases, product news and updates* to fulfill business relationships with you, including processing payments and notifying you of your order status or any associate order status issues to notify you of new Nervana Products and Services to respond to reports about our Products and Services to identify and authenticate you* to ensure we have up-to-date contact information to customize content for you* to detect security incidents* to protect against malicious or illegal activity* to ensure the appropriate use of our Products and Services* to monitor the safety of our Products and Services to improve our Products and Services* to improve our Online Services, including digital design or content* for short-term, transient use* for administrative purposes* to monitor and analyze trends, usage and activities in connection with our Products and Services for marketing, internal research, data analysis, and development* for quality assurance and to assist in training and development of our representatives* to operate our business, including for auditing to procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations* advertising and product promotion, including to contact you regarding programs, events, products, services, and topics that may be of interest or useful to you* to comply with legal and regulatory obligations*
Who receives the data? (Parties that may receive Personal Data that may be considered sensitive are noted with a “”)*
Nervana, our affiliates, and related companies* third parties who assist with fraud prevention, detection and mitigation* third parties who assist with our information technology and security programs* Nervana’s lawyers, auditors and consultants* partners that assist us in providing the Products and Services or help us improve our marketing or administration* **

Users of Our Products and Services
We may process your Personal Data when you use Nervana Products and Services, including AI-enabled coaching interactions, and when you browse or book optional services provided by an independent Coach.
Examples of the types of data we process (Personal Data that may be considered sensitive is noted with a “”)*
Identity and contact information, such as:	first and last name or unique pseudonym honorifics and titles, preferred form of address email address postal address phone number customer number company ID number such as account number
Other personal information, such as:	age gender disability* ethnicity* date of birth
Technical Information, such as:	Internet Protocol (IP) addresses (which may identify your general geographic location or company) browser type and browser language device type advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) date and time you use our Products and Services Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services activity on our Products and Services and referring websites or applications data collected from cookies or other similar technologies***
Wellness and symptom information, such as:	self-reported symptoms, including severity and triggers * goals and journal entries* exercises completed* symptom trends* user-reported information (e.g., responses to questionnaires, feedback, survey responses, messages to coaches)* health integration information, when authorized (e.g., steps, sleep) care team exports information you choose to log* Nervana does not routinely receive or store independent human Coach session notes, and human-coaching sessions are not recorded or transcribed through the Services.
Commercial and financial information, such as:	Products and Services purchased, obtained, or considered bank account number and details* request documentation customer service records financial transaction history financial account number* Coaching booking, payment, refund, dispute, and Coach payout records*
De-identified Data:	De-identified data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws****
Where do we get the data?
you directly your devices our business partners and other third parties those authorized to provide on your behalf such as your authorized representative Independent Coaches, but only for limited booking, support, safety, privacy, or dispute information
Why do we process the data? (Purposes for the processing of Personal Data that may be considered sensitive are noted with a “”)*
to provide you with our Products and Services* to communicate with you and respond to your requests to administer our relationship with you* to generate reports or exports at your request to administer and manage your registration and participation at events* to send you information about our Products and Services, including press releases, product news and updates* to fulfill business relationships with you, including processing payments and notifying you of your order status or any associate order status issues to notify you of new Nervana Products and Services to respond to reports about our Products and Services to identify and authenticate you* to ensure we have up-to-date contact information to customize content for you* to detect security incidents* to protect against malicious or illegal activity* to ensure the appropriate use of our Products and Services* to monitor the safety of our Products and Services to improve our Products and Services* to improve our Online Services, including digital design or content* for short-term, transient use* for administrative purposes* to monitor and analyze trends, usage and activities in connection with our Products and Services to determine and verify program, product, and service eligibility and coverage* for marketing, internal research, data analysis, and development* for quality assurance and to assist in training and development of our representatives* to operate our business, including for auditing to procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations* advertising and product promotion, including to contact you regarding programs, events, products, services, and topics that may be of interest or useful to you* to comply with legal and regulatory obligations* To display Coaches and availability and facilitate optional coaching bookings* To process one-time coaching payments, refunds, disputes, and Coach payouts* Human-coaching session content is not collected for or used to train AI models.
Who receives the data? (Parties that may receive Personal Data that may be considered sensitive are noted with a “”)*
Nervana, our affiliates, and related companies* service providers and partners that assist us in providing the Products and Services or help us improve our marketing or administration* ** third parties who assist with fraud prevention, detection and mitigation* third parties who assist with our information technology and security programs* Nervana’s lawyers, auditors, and consultants* other third-party recipients at your request The independent Coach you select, for the information reasonably needed to provide the booked service* Payment, calendar, video-meeting, transactional-email, fraud, security, and support providers involved in the booking*

Optional Human Coaching

Human coaching is an optional service provided by an independent Coach and purchased separately from a Nervana subscription. If you browse or book a Coach, Nervana may process your account identifier and email address; the Coach selected; session date, time, duration, and time zone; price and currency; booking, payment, refund, dispute, and payout status; the terms and privacy versions accepted; calendar and meeting identifiers; and limited support, safety, privacy, fraud-prevention, or operational records.

Nervana uses this information to display Coaches and availability, schedule and support the session, collect payment, pay the Coach, process refunds and disputes, prevent fraud, maintain required records, and operate the booking platform. Nervana shares only the information reasonably needed for these purposes with the selected Coach and relevant service providers.

Nervana does not automatically give a Coach access to your Nervana AI conversations, journal entries, symptom history, app session history, or medical records. Neither Nervana nor the Coach records or transcribes the human-coaching session through the Services, and Nervana does not routinely collect Coach session notes. Session content is between you and the Coach unless you or the Coach provides limited information needed for support, safety, privacy, a dispute, or a legal obligation.

You may choose to export a PDF from Nervana and share it yourself. Nervana does not automatically export or send the PDF to a Coach. If you share a downloaded PDF, the sharing occurs at your direction, and Nervana cannot control or revoke a copy held outside Nervana.

Employment and Apprenticeship Candidates
We may process your Personal Data when you apply or are a candidate for employment or apprenticeship at Nervana.
Examples of the types of data we process (Personal Data that may be considered sensitive is noted with a “”)*
Identity and contact information, such as:	first and last name or unique pseudonym honorifics and titles, preferred form of address company/employer email address postal address phone number username or code and password
Other personal information, such as:	age gender disability* social security number* date of birth
Technical Information, such as:	Internet Protocol (IP) addresses (which may identify your general geographic location or company) browser type and browser language device type advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) date and time you use our Products and Services Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services activity on our Products and Services and referring websites or applications data collected from cookies or other similar technologies***
Professional and educational information, such as:	job title or position employer work skills employment history graduate degrees certifications specialized training responses to surveys and questionnaires
De-identified Data:	De-identified data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws****
Where do we get the data?
you directly your employer or principal your devices our business partners and other third parties
Why do we process the data? (Purposes for the processing of Personal Data that may be considered sensitive are noted with a “”)*
to communicate with you to identify and authenticate you* to detect security incidents* to protect against malicious or illegal activity* for short-term, transient use* for administrative purposes* for marketing, internal research, data analysis, and development* to comply with legal and regulatory obligations*
Who receives the data? (Parties that may receive Personal Data that may be considered sensitive are noted with a “”)*
Nervana, our affiliates, and related companies* partners that assist us in providing the Products and Services or help us improve our marketing or administration* ** third parties who provide benefit verification and program enrollment* third parties who assist with fraud prevention, detection and mitigation* third parties who assist with our information technology and security programs* Nervana’s lawyers, auditors, and consultants*

Children
Nervana does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 18 without the permission of such minor’s parents or legal guardians.

**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, merger, consolidation, corporate reorganization, or transfer, to the buyer, assignee, or transferee; and (2) government or regulatory officials, law enforcement, courts, public authorities, or others when permitted by this Notice or required by law.

***Please see the Marketing, Cookies & Tracking section below for more information on how we use cookies and similar technologies.

****We will not attempt to reidentify you or anyone else from this de-identified data, and if we disclose it to third parties, we will require that they commit to not attempting to reidentify you or anyone else from the de-identified data.

We collect and use certain Personal Data for the purpose of helping us develop and improve our Products and Services. We do not sell or use Personal Data for the purpose of training large language models. Human-coaching session content is not collected for or used to train large language models or other AI models.

Consumer Health Data

The law of the state in which you reside or in which your Personal Data is collected may make specific requirements in connection with Personal Data that is linked or is reasonably capable of being linked to you and that identifies your past, present, or future physical or mental health status (“Consumer Health Data”).

To the extent your Personal Data constitutes “Consumer Health Data,” the categories of Consumer Health Data being collected; the manner in which it will be used; the categories of sources from which it is collected; the categories of third parties and affiliates with whom it is being shared; the purposes of collecting, using and sharing it; and the manner in which it will be processed are all provided in the Information Collected section of this Notice (primarily as “Information regarding your treatment”). Additional information about Nervana’s activities can be found in the Marketing, Cookies & Tracking and Third Parties sections of this Notice.

To the extent that the state in which you live requires us to provide certain rights to you in connection with your Consumer Health Data, we will provide the following rights to you based on your state’s law:

To request our confirmation that we are collecting, sharing, or selling your Consumer Health Data;

To request to review and to make changes to any of your Consumer Health Data;

To request that we delete your Consumer Health Data;

To request a list of all third parties with whom we have shared or sold your Consumer Health Data;

To request that we stop collecting, sharing, or selling your Consumer Health Data;

To exercise any of these rights, follow the procedure explained in the Your Rights Regarding Your Personal Data section of this Notice.

A third party may collect Consumer Health Data over time and across different websites or online services when you use any of our websites or Online Services. For more information, see the Marketing, Cookies & Tracking and Third Parties sections of this Notice.

This section (and the Notice more generally) is effective as of the “Last Updated” date above. We will notify you of changes to this section (and the Notice more generally) as described in the Changes to This Privacy Notice section.

Marketing, Cookies, and Tracking

Marketing Uses, Cookies, and Other Activities

To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, we may engage in the following activities:

We may use your contact details to contact you to determine whether you would like to initiate a business relationship with us or to send you marketing emails. If you do not wish to receive such marketing emails, you may opt-out by declining to receive such emails when registering or in our subsequent communications by following opt-out or unsubscribe instructions included in the email or at other information collection points on the Online Services.

We may display advertisements to you regarding Products and Services that we believe are relevant to you based on your activities on the Online Services or on other web or digital properties. Such advertisements may be shown on our Online Services or the online services of others. We may achieve this by using, and allowing third parties (e.g., Facebook, LinkedIn) to use certain cookies, eTags, pixels, web beacons, and other tracking technologies to track your activities over time on our Online Services and other online services. For more information about these activities and how to manage or opt-out of them, please see the below sections.

We may make offers to you based on your activities across different Online Services, including activities on other web or digital properties or your other interactions with Nervana that are not via the Online Services (e.g., regional offers based on your location).

We also perform statistical analyses of the users of our Online Services to improve the functionality, content, design, and navigation of the Online Services.

Do-Not-Track Signals

Certain web browsers and other programs may transmit “opt-out” signals, also called a Global Privacy Control (or GPC) signal (we refer to these as “GPC Signals”), to websites with which the browser communicates. We currently do not recognize GPC Signals.

Behavioral Advertising

Where allowed by law, as described above, we use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. In some states, you may have the right to opt-out of these types of targeted advertisements. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page by going to http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Opt-out of Sale, Sharing, Targeted Advertising, or Limit the Use of Sensitive Data

Certain of Nervana’s practices may be considered the sharing of Personal Data under certain applicable laws. You may have the right to opt-out. To exercise these rights, please see the Your Rights Regarding Your Personal Data section below.

Third Parties

Service Providers

Service providers acting on our behalf must execute agreements requiring them to maintain confidentiality and to process Personal Data as necessary to perform their functions in a manner consistent with this Notice, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations.

Independent Coaches

An independent Coach is not merely a service provider acting on Nervana's behalf with respect to the coaching service or session content. You choose the Coach, and the Coach receives the limited information needed to provide the booked service. Nervana's agreement with the Coach restricts the Coach's use and disclosure of member information and requires confidentiality, security, deletion, and incident reporting.

Combination of Data with Data Received from Third Parties

We may combine information we collect, including Personal Data, with Personal Data that we may obtain from third parties.

Links to Other Websites

Our Products and Services may contain links to other websites, applications, products, or services that are not owned or operated by Nervana, such as social media websites and applications like Facebook and X. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products, and services.

Your Rights Regarding Your Personal Data

Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Data about you (e.g., your contact information).

Under your jurisdiction’s data protection law, you may be able to exercise the following rights with respect to some or all of your Personal Data:

to request access to and a copy or representative summary your Personal Data (including under GDPR Article 15);

to request that we rectify or erase your Personal Data (including under GDPR Articles 16 and 17);

to request that we restrict or block the processing of your Personal Data (including under GDPR Articles 18, 21 and 22 and to object to the sale or sharing of your Personal Data under other relevant laws);

This includes the right to opt out of solicitations and to opt-out of sharing your Personal Data for cross-context behavioural or targeted advertising;

to provide your Personal Data directly to another organization, i.e., a right to data portability (including under GDPR Article 20);

when we previously obtained your consent, to withdraw consent to processing (including under GDPR Article 21);

to request that we limit the processing of your Sensitive Personal Data;

to appeal the denial of a request; and

To lodge a complaint with the data protection authority in your area (including under GDPR Article 77).

To exercise these rights, please contact us at support@trynervana.com or founders@trynervana.com

To learn if you have the other above rights in the state in which you live, to exercise any of these rights with respect to your Personal Data, or to revoke any consent you have previously provided, please contact us using the contact information provided above. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you Products and Services or it may otherwise affect the way we are able to interact with you. To appeal our decision on a request you have submitted, you may respond directly to our decision communication.

We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor 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.

In the event you wish to make a complaint about how we process your Personal Data, please contact us at support@trynervana.com and we will handle your request as soon as possible. Even if you make a complaint to us, you may always lodge a complaint with the relevant authority in your location.

Transfer of Personal Data Across National Borders

If you provide us with your Personal Data, you acknowledge that such Personal Data may be transferred from your current location to the offices and servers of Nervana and the authorized third parties referred to herein, which may be located in the United States.

Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction, where the privacy laws may differ to those in your location, including the United States. Nervana has put in place safeguards in accordance with applicable legal requirements, to protect your Personal Data irrespective of the standards in the country where your Personal Data may be transferred. This includes entering into agreements with third parties, such as service providers, to require them to adopt standards that ensure an equivalent level of protection for data as those we adopt.

Safeguarding Information

Consistent with applicable laws and requirements, Nervana has put in place physical, technical, and administrative safeguards designed to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services. In addition, it is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Products and Services.

How Long Your Personal Data Will Be Retained

We generally retain Personal Data for as long as needed for the specific business purpose or purposes for which it was collected or obtained, and as outlined in this Notice. In some cases, we may be required to retain Personal Data for a longer period of time by law or for other necessary business purposes. Whenever possible, we aim to de-identify the information or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the Personal Data; and (iii) whether retention is determined to be necessary or advisable for Nervana due to applicable statutes of limitations, litigation, or other legal or regulatory obligations. Nervana takes reasonable steps to dispose of Personal Data upon the expiration of retention periods taking into consideration these litigation, legal, or regulatory obligations.

Changes to This Privacy Notice

We reserve the right to change this Notice from time to time. We will alert you when changes have been made by indicating the date this Notice was last updated as the date the Notice became effective or as otherwise may be required by law. It is recommended that you periodically revisit this Notice to learn of any changes.

Contact Us

Controller: Nervana Health, Inc (we also conduct business under the following assumed business name(s): Nervana

If you have questions or comments about this Notice or about how your Personal Data is processed, please contact us by one of the methods below:

Email: support@trynervana.com

Phone: 9167614259