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Kyruus Health Privacy Policy

Effective Date of Terms: January 9, 2024


This privacy policy (“Privacy Policy”) is designed to inform users of our website (the “Site”) about how we gather and use personal information collected by us in connection with the Site. We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this Privacy Policy and with applicable U.S. laws. In this Privacy Policy, “user,” “your” or “you” refers to any individual or entity using the Site, whether by browsing the Site, registering with us by creating an account, or participating in any other activities available through the Site.  “Kyruus Health,” “we,” “us,” and words of similar import refer to Kyruus, Inc. and its affiliates, dba Kyruus Health. 

This Privacy Policy does not apply to the data Kyruus Health processes on behalf of our customers (Customer Data) in our capacity as a processor. Your use of the Site as a customer of Kyruus Health, including use of our associated mobile applications (Mobile Apps), is covered under the agreements in place between such customer and Kyruus Health. Please remember that your use of and access to the Site is also subject to our Terms of Service, available at



You are free to explore our Site without providing any Personal Information about yourself. If you register for more information on our Site, we request that you provide Personal Information about yourself to enable the registration, and if you visit our Site, we may collect Navigational Information (as defined below).


This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Site, and information about you that is available on the internet, such as from LinkedIn, Meta, and Google, or information that we acquire from service providers. When providing information, please only provide your Personal Information.  Do not provide another individual’s Personal Information to us, unless you are the legally authorized proxy for that person and for this specific purpose.  You acknowledge that you are solely responsible for determining whether or not you have the right to provide any of this information. 


This Privacy Policy is applicable only to this Site.  From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites. We cannot and do not (1) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your Personal Information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on this Site. Any Personal Information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use.  If you are unsure whether a website is controlled, affiliated, or managed by Kyruus Health, you should review the privacy policy and practices applicable to each linked website.


We may collect web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs (collectively, “Web Tracking Technologies”) in order to operate the Site efficiently and to collect data related to your usage of and interaction with the Site. Such collected data (“Navigational  Information”) may include the address of the websites you visited before and after you visited the Site, your geographic location, the search terms you used, the date and time of your visit, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Site you visit and what links you clicked on, and whether you opened email communications we send to you. If you use a mobile device to access our Site, we may also collect information about the geographical location from which you accessed the Site. 

In order to collect Navigational Information and to make your use of the Site more efficient, we may store cookies on your computer. These cookies will be stored (1) until the user closes the browser, (2) until the user logs off the Site, or (3) until they expire.  For more information about cookies, visit

We may also use Web Tracking Technologies that are placed in web pages on the Site or in email communications to collect information about actions that users take when they interact with the Site or with such email communications. You may be able to modify your browser settings to alter which Web Tracking Technologies are permitted when you use the Site, but this may affect the performance of the Site. Likewise, most mobile devices allow you to disable the ability for geo-location to be collected from your mobile device, but this may also affect the performance of the Site. 



We will never sell your Personal Information to any third party without your express consent. 


We will use and store Personal Information for the purpose of delivering the Site content, and to analyze and enhance the operation of the Site.

We may use the Personal Information you provide or that we collect about you, as well as non-personally identifiable information, to fulfill your requests for our products, programs, and services, to respond to your inquiries about our offerings, and to offer you other products, programs or services that we believe may be of interest to you.  We sometimes use this information to communicate with you.


We use Navigational Information to administer the Site and to understand how well our Site is working, to store your user preferences, to develop statistical information on usage of the Site, and to analyze the productivity of users of the Site. This allows us to determine which features visitors like best to help us improve our Site, to personalize your user experience, and to measure overall effectiveness.

You may disable the collection and use of your location data through browser-, operating system- or device-level settings. Consent concerning location data may be withdrawn at any time by emailing:


Notwithstanding the above, we may in any event use Personal Information, and any other information collected through the Site to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Use) with you, or if in our reasonable discretion use as necessary to protect our legal rights or to protect third parties.


If you register and provide your email address, we will send you updates and promotional emails, including newsletters. If you wish to opt out of newsletters and promotional emails, you may do so by following the “unsubscribe” instructions in the email.



We will not disclose your Personal Information to any third parties except as follows:

(i) to third party contractors engaged to provide services on our behalf (“Contractors”), such as analyzing data and usage of the Site, operating the Site or providing support and maintenance services for the Site, performing marketing support, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us; and

(ii) when we have your consent to share the information.

Aggregated and De-identified Data:

As noted above, this Privacy Policy addresses the collection and sharing of Personal Information, that is, information that can reasonably be connected with a particular user.  We may occasionally de-identify and/or aggregate Personal Information – to the extent permitted by law – to the point that it can no longer be associated with a particular user.  When that occurs, such information is no longer Personal Information.

Use, Sharing, and/or Sale of Non-personal Information

We may aggregate data on user behavior with respect to the Site and/or Service.  This data does not enable identification of individual users and is not Personal Information as defined by this Privacy Policy.  As such, our use, sharing, and/or sale of non-personal information is not restricted by this Privacy Policy.


We disclose Navigational Information to Contractors, in order to analyze the performance of the Site and the behavior of users, and to operate and improve the Site. Certain Navigational Information that is not correlated to individual user Personal Information, such as the popularity ranking of certain pages of the Site, may be published on the Site and so disclosed to all users of the Site. Kyruus Health may disclose to its institutional and corporate subscribers how the users of the Site affiliated with the subscriber use the Site.


We may share information with businesses that are legally part of the same group as the Kyruus Health, or that become part of that group.  We reserve the right – in the event of a business transition such as a merger – to transfer Personal Information to a new business owner, on the condition that such Personal Information must be treated in accordance with this Privacy Policy. We reserve the right to disclose any information we collect in connection with the Site, including Personal Information to any successor to our business as a result of any merger, acquisition, asset sale or similar transaction.

We will also share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary and in our legitimate interests to:

  • comply with a legal obligation, process or request;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (i.e., exchanging information with other companies and organizations for the purposes of security and/or fraud protection).



If you would like your Personal Information or geographical location data permanently removed from our database, please contact us at We will delete your account and you will no longer receive marketing email from Kyruus Health. Your removal from the mailing list or database will not remove records of past transactions or delete information stored in our data backups and archives. If you opt-out of allowing Kyruus Health to collect geographical location data, the performance of the Site may be affected, and you may not be able to access certain functions within the Site.  Please note that this opt-out process may take some time to complete, consistent with applicable law.


Kyruus Health will allow you to review or amend your email address and/or contact details at any time. Please contact us by sending an email to:



This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the California Privacy Rights Act (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CPRA”).For purposes of this section, the term “Personal Information” means Personal Information under Cal. Civ. Code 1798.140(v).  To the extent that any other provision of this Privacy Policy conflicts with a provision of this section, the provision in this section controls as to California residents.

a) Categories of Information Collected, Disclosed, and Sold in the Past 12 Months

The below table discloses the categories of Personal Information and whether Kyruus Health has collected Personal Information from a category in the past 12 months from the effective date of this Privacy Policy.  For each category of Personal Information, the table identifies: (i) the category of Personal information, (ii) whether Kyruus Health has collected Personal Information from such category, (iii) whether Kyruus Health has, disclosed to a third party for a business purpose Personal Information from such category; and (iv) whether Kyruus Health sells to or shares Personal Information from such category with third parties. The table does not include Personal Information provided to us by customers or our customers’ authorized users in a business-to-business context. 

As stated in the chart below, we do not sell any Sensitive Personal Information to, or “share” any Sensitive Personal Information with, any third-party.  Under the CPRA, the term “share” specifically refers to the transfer of Personal Information to a third-party for cross-context behavioral advertising.  We will only sell Personal Information to, or “share” Personal Information with, third-parties upon obtaining explicit consent from the consumer through the Site.

Please note that we contract with each of the following service providers or contractors for data collection services: Amazon Web Services, Aptible, Google Cloud Platform, Looker, Mailgun, and Twilio.  As a result, these service providers or contractors are authorized to collect Personal Information and information about our business practices through our Site. 

Category of Personal Information Do We


Do We


(See “Disclosure of Personal Information” Section Below)

Do We

Sell to or “Share” with Third Parties?  (See “Disclosure of Personal Information” Section Below)

Sensitive Personal Information

Examples: Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation (within 1,850 feet of the consumer); racial or ethnic origin, religious or philosophical beliefs, or union membership; mail, email, or text message contents; or genetic data.  Sensitive personal information also includes the processing of biometric information for the purpose of uniquely identifying a consumer and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.

Yes Yes No

Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.

Yes Yes Yes
Categories of Personal

Information in Cal. Civ. Code Section 1798.80(e)

Examples: Name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, or debit card number (to the extent not already identified as Sensitive Personal Information), or any other financial information, medical information, or health insurance information.

Yes Yes Yes
Characteristics of 

Protected Classifications under California or Federal Law

Examples: To the extent not already identified as Sensitive Personal Information, race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

Yes Yes Yes
Commercial Information

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No No No
Biometric Information

Examples: To the extent not already identified as Sensitive Personal Information, physiological, biological, or behavioral characteristics, including information pertaining to DNA, that can be used, is, or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

No No No
Internet or Other Electric 

Network Activity Information

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

No No No
Geolocation Data

Examples: Physical
location (to the extent not already identified as Sensitive Personal Information).

No No No
Sensory Information

Examples: Audio, electronic, visual, thermal, olfactory, or similar information

No No No
Professional or 

employment-related information

Examples: If you apply for a job with us, job application or resume information, past and current job history, and job performance information.

No No No
Non-Public Information 

(as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)

Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.

No No No
Inferences Drawn from 

Personal Information

Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No No No

b) Categories of Sources

In the 12-month period that precedes the date this Privacy Policy is being viewed, we may have collected Personal Information from the following categories of sources: Our Site, you and/or your devices, business partners and affiliates, other third-parties, and publicly-available sources.

c) Use of Personal Information

Upon collection, we will typically retain each category of your Personal Information listed above for the amount of time necessary to fulfill the purposes for which it was collected, consistent with all applicable laws and our internal retention schedule.  In general, as permitted by the CPRA, Personal Information may be used in a manner that is reasonably necessary and proportionate for any of the specific business and commercial purposes listed below:

  1. Performing and providing regular services and goods.
  2. Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Personal Information.
  3. Resisting malicious, deceptive, fraudulent, or illegal actions and prosecuting those responsible for those actions.
  4. Ensuring the physical safety of natural persons.
  5. Short-term transient use, including non-personalized advertising shown as part of your current interaction with our customer (your provider) or with us, through the Site.
  6. Performing services on behalf of our customer, such as maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, providing analytic services, or providing storage.
  7. Verifying or maintaining the quality or safety of a service, product, or device that our customer owns, manufactures, or controls, or improving, upgrading, or enhancing any such service, product, or device.
  8. Collecting or processing Sensitive Personal Information where the collection or processing is not for the purpose of inferring characteristics about you.

To the extent that we collect Sensitive Personal Information from you, Sensitive Personal Information will only be used for purposes 1-8 listed above / may be used for any purpose listed above, subject to your Right to Limit the Use and Disclosure of Sensitive Personal Information.

d) Disclosure of Personal Information

In the 12-month period that precedes the date this Privacy Policy is being viewed, we may have disclosed each category of Personal Information to the following classifications of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics data storage, mailing, marketing, payment processing, Site administration, technical support); and (4) operating systems and platforms, (5) advertising networks (Internet or other electronic network activity information, geolocation data, and inferences only), (6) internet service providers, and (7) social networks (Internet or other electronic network activity information, geographical location data, and Inferences only).

e) Summary of California Residents’ CPRA Rights

California residents may:

  • Request that we delete their Personal Information (a “Request to Delete”).
  • Opt-out of the sale of their Personal Information (a “Request to Opt-Out”).
  • Request information about our collection, use, and sharing of their Personal Information (a “Request to Know”), including:
    • the categories and specific pieces of Personal Information we have collected about them;
    • the categories of sources from which we have collected their Personal Information;
    • the business or commercial purpose for collecting or selling their Personal Information;
    • the categories of their Personal Information that we have sold; and
    • the categories of third parties with whom we have shared, disclosed for a business purpose, or sold their Personal Information, and which categories of Personal Information we have sold to which categories of third parties.

California residents who share their Personal Information with Kyruus Health in their capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency have the right to submit a Request to Know but do not have the right to submit a Request to Delete.

f) Submitting “Requests to Know”

California residents may submit a Request to Know by filling out the form found here.

California residents may submit two types of Requests to Know: (1) a request for the specific pieces of Personal Information that Kyruus Health has collected about you in the past twelve months; or (2) a request for the categories of Personal Information that Kyruus Health has collected about you in the past twelve months.  Depending on the type of request you submit, we will need to verify your identity to a reasonable degree of certainty or a reasonably high degree of certainty. 

If you are not a Kyruus Health account holder, we will attempt to verify your identity by matching information that you provide to us with information that we have on file for you. This may include your name, email address, country and state of residence and photo.  For Requests to Know the specific pieces of information that Kyruus Health has collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the request. 

If Kyruus Health is able to verify your identity, we will respond to your Request to Know by:

(a) providing the requested information; or (b) explaining why the CPRA does not require us to provide the requested information.  If Kyruus Health is unable to verify your identity, Kyruus Health will respond by explaining why we cannot verify your identity.

We will confirm receipt of your Request to Know within 10 business days and will respond to your request within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.  If the CPRA requires us to provide the information requested, we will provide the information free of charge and in a readily useable, portable format.  We have no obligation to provide Personal Information to you more than twice in a 12-month period.  If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

g) Submitting “Requests to Opt-Out”

California residents may opt out of the sale of some or all of their Personal Information by clicking the “Do Not Sell” link in our cookie management tool located on our home page or you may fill out the form found here

Within 15 business days of receiving a Request to Opt-Out, Kyruus Health will:

  • Not sell your Personal Information unless and until you subsequently provide express authorization for the sale of your Personal Information.
  • Notify any third parties to whom we sold your Personal Information after we received your Request to Opt-Out but before we complied with the request, and instruct them not to sell your Personal Information.
  • Not ask for permission to sell your Personal Information for 12 months after receiving the Request.

California residents who have opted out of the sale of their Personal Information may opt back into the sale of their Personal Information by filling out the form found here.

h) Submitting “Requests to Delete”

California residents may submit a Request to Delete by filling out the form found here.  You may request that we delete all or some of your Personal Information.

We will confirm submission of your Request to Delete within 10 business days.  When you submit a request, we will need to verify your identity to a reasonable degree of certainty or a reasonably high degree of certainty depending on the type of Personal Information we have collected about you.

  • If you are not a Kyruus Health account-holder, we will attempt to verify your identity by matching information that you provide to us with information that we have on file for you.  This may include your name, email address, country and state of residence and photo ID.
  • If Kyruus Health is able to verify your identity, we will respond to your request by (a) deleting your Personal Information and, if applicable, directing any of our service providers to delete your Personal Information; or (b) explaining why the CPRA does not require us to delete your Personal Information.  Kyruus Health may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the information.  We will specify the manner in which we delete your Personal Information. 

If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

i) Authorized Agents

California residents may submit Requests to Know, Requests to Opt-Out, and Requests to Delete through an authorized agent.  Unless the agent provides Kyruus Health with a power of attorney executed by the California resident, Kyruus Health may require the California resident to verify their identity with Kyruus Health and/or to provide Kyruus Health with written confirmation of the agent’s authority to make the request.

j) CPRA Non-Discrimination

You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CPRA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CPRA rights. 

k) Minors

This Site is not directed to children, and Kyruus Health does not have actual knowledge that it collects or sells the Personal Information of minors under 16 years of age. If Kyruus Health discovers that a child under 16 has given it Personal Information, Kyruus Health will take steps to delete that information. If you believe that a child under the age of 16 has given us Personal Information, please contact us at


On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like Kyruus Health to disclose how they respond to “Do Not Track Signals”; and whether third parties collect personally identifiable information about users when they visit Kyruus Health.There is currently no accepted standard on how to respond to Do Not Track signals.

  • Kyruus Health does not respond to “do not track” signals.
  • Kyruus Health does not authorize the collection of personally identifiable information from Kyruus Health users for third party use through advertising technologies without separate member consent.


We do not market our services to residents in Europe, nor do we have a place of business in Europe.  We are thus not subject to Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of Personal Information and free movement of such Information, known as the General Data Protection Regulation (“GDPR”).

If you reside in the European Economic Area (EEA), please be aware that if you voluntarily provide us any Personal Information, that information will be transferred from the EU to data centers located in the United States for processing.

Although we are not subject to the GDPR, nevertheless we will honor your data privacy rights upon request.  If you are a resident of the EEA, you have the right, as applicable under the GDPR, to the following:

  • Request an accounting of Personal Information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
  • Request that we correct or update Personal Information that pertains to you.
  • Request that we delete Personal Information that pertains to you.
  • Fully or partially withdraw your consent to the collection, processing, and/or transfer of your Personal Information.

If you believe we are unlawfully possessing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find contact details here:

To request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information, please fill out the form found here. Once we have received notification that you withdraw your consent, we will no longer process your Personal Information for the purpose(s) to which you originally consented unless there are legitimate grounds for further processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.



We have put in place appropriate physical, electronic, and administrative procedures and security precautions to protect the security and integrity of your Personal Information in accordance with this Privacy Policy and applicable laws. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.


The Site may contain links to other websites, cookies or other materials from, or which may be operated by, parties other than Kyruus Health, whose information practices may be different than ours. Kyruus Health is not responsible for the privacy practices, the content or the actions of those third parties. This Privacy Policy applies solely to information collected by Kyruus Health in connection with the Site.  Please refer to the Kyruus Health Cookie Policy for further information about how Kyruus Health uses cookies.


We will retain your Personal Information in accordance with the appropriate statutory limitation periods as provided by local law, or in other cases, for as long as such personal data is needed for the following reasons:

  • as required by law or court order;
  • as needed to defend or pursue legal claims;
  • in line with industry codes of practice; and/or
  • as required for legitimate business purposes.


Kyruus Health may modify or amend this Privacy Policy from time to time. If we make any material changes, as determined by Kyruus Health, in the way in which Personal Information or Navigational Information is collected, used or transferred, you will be notified of these changes through the publication of the modified Privacy Policy on this Site. Notwithstanding any modifications we may make, any Personal Information and Navigational Information collected by Kyruus Health from you will be treated in accordance with the Privacy Policy in effect at the time information was collected, unless we obtain your consent otherwise. When you use this Site, you are agreeing to the most recent terms of this Privacy Policy.


In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance at and we will endeavor to accommodate your request as soon as possible. This is without prejudice to your right to raise a complaint with a relevant supervisory authority in the country in which you live or work, where you think we have infringed information protection laws.


Any person with a disability that prevents or restricts them from accessing this Privacy Policy through this Site may request a copy of the Privacy Policy in an alternative format by contacting Kyruus Health at or 617.419.2060.

Effective Date: January 1, 2024

Notwithstanding the Effective Date of this California Resident Privacy Notice, please note that the above chart that lists the categories of Personal Information that we have collected, sold, shared, or otherwise disclosed or used for business or commercial purposes is applicable to the 12-month period that precedes the Effective Date.