Priming Labs LLC
Privacy Policy
1. Who we are
Priming Labs LLC ("Priming Labs," "we," "us") operates the Neuro Progress Tracker application (the "App"). Priming Labs LLC is a Maryland limited liability company and is the controller of the information described in this policy.
Contact: [email protected]
2. What this policy covers
This policy explains what information the App collects, why we collect it, who can see it, how long we keep it, and what rights you have over it.
The App records information about your physical symptoms, your sleep, your training, and your performance on brief cognitive tests. That is health information about you, and we treat it accordingly.
3. What the App is, and what it is not
The App produces a daily readiness indicator from what you report and how you perform on its tests. That indicator is informational.
The App is not a medical device, does not diagnose any condition, and does not provide medical advice. It is not a medical record. It does not replace the judgment of your clinician. Nothing the App shows you should be acted on in place of professional advice, and using the App does not create a clinician-patient relationship with Priming Labs.
4. Information we collect
4.1 Information about you
- Your first and last name
- Your date of birth
- An account code that identifies your record in the App
Where a date of birth was estimated from an age recorded before the App collected dates of birth, that record is marked as estimated.
4.2 Health and symptom information you provide
- Your answers to the daily self-check questions covering focus and attention, anxiety and stress, and body fatigue, including each individual answer
- The number of hours you slept and your rating of your sleep quality
- Body areas you mark on the body map, whether you mark each as pain, tightness, or good, and the 0 to 10 intensity you assign
- Labels you or your clinician create for specific pain sites
- Training sessions you log, including session type, duration, perceived physical and mental exertion, and any notes entered
4.3 Performance information the App measures
- Completion times, error counts, and related measures from the Trail Making Test and the continuous performance tests
- Which version of each test you took and how many times you retried within a session
4.4 Information the App derives
- Daily readiness scores, component scores, and the resulting tier
- Comparisons against your own history and against published age-group reference values
- The daily guidance text shown to you
4.5 Information we do not collect
We do not collect payment information, precise location, contacts, photos, advertising identifiers, or biometric identifiers. We do not use tracking technologies for advertising and we do not sell information about you.
5. Why we use your information
We use your information only to:
- Provide the App and produce your readiness indicators and trends
- Show your history and progress over time
- Make your information available to the clinician associated with your record
- Diagnose and fix technical problems
- Improve the App using aggregated, de-identified information as described in section 8
We do not use your information for advertising, for profiling unrelated to the App's function, or for any purpose beyond those listed, without asking you first.
6. Who can see your information
6.1 You
You can see all information the App holds about you, and you can download a complete copy at any time from within the App.
6.2 Your clinician
Each record in the App is associated with a clinician. That clinician can see the information listed in section 4 for records associated with them. This is the intended function of the App and the reason it exists.
Clinicians access your information in their own professional capacity. Their handling of it is governed by their own professional and legal obligations, which are separate from this policy.
6.3 Service providers
We use the following providers to operate the App:
| Provider | Purpose | What they receive |
|---|---|---|
| Supabase | Database hosting and storage | All information described in section 4 |
If we add a provider, we will update this policy and this table before that provider receives any information about you.
6.4 Automated summaries
The App may generate written summaries of your trends using an automated language model provided by a third party.
Where this feature is used, the model receives only de-identified numeric measures. It does not receive your name, your date of birth, your account code, any identifier, any absolute date, or any free text you or your clinician have written. This restriction is enforced in our software rather than left to practice.
6.5 Everyone else
We do not disclose your information to anyone else, except where we are legally required to do so, or in connection with a sale or transfer of the business, in which case the acquirer would be bound by this policy or you would be notified before any change.
7. Where your information is stored
Your information is stored in the United States on infrastructure operated by Supabase. Access to production data is limited to those who need it to operate the App.
8. How long we keep it
- While your account is active, and for 24 months after your last activity, after which the record is deleted.
- If you request deletion, your record is immediately hidden from the App and permanently erased within 30 days. During that 30-day window the deletion can be reversed if it was made in error, by contacting your clinician or us.
- Aggregated, de-identified information that cannot reasonably be linked back to you may be kept indefinitely to develop reference values and improve the App. Once information is aggregated and de-identified in this way, it is no longer information about you and is not covered by the deletion above.
9. Your rights
You may:
- Access everything the App holds about you, at any time, in the App
- Export a complete copy of your information as a file, from within the App
- Correct information that is wrong, by asking us or your clinician
- Delete your account and all information associated with it, from within the App
- Withdraw consent by deleting your account. The App cannot function without the information described in section 4.
We respond to requests within 30 days.
Depending on where you live, you may have additional rights under state law, including the right to know what information is held, the right to correction and deletion, and the right not to be discriminated against for exercising those rights. We honor these requests regardless of where you live.
10. Security
We protect your information using access controls at the database level that restrict each record to you and the clinician associated with it, encryption in transit, and encryption at rest as provided by our hosting provider.
No system is completely secure. If a breach affects your information, we will notify you and any required authority without undue delay and no later than 72 hours after we become aware of it, describing what happened, what information was involved, and what we are doing about it.
11. Children
The App is not intended for anyone under 13, and we do not knowingly collect information from anyone under 13. If you believe a child under 13 has provided information to us, contact us and we will delete it.
Where the App is used by a minor aged 13 to 17, it must be used with the involvement of a parent or guardian and the clinician responsible for their care.
12. Changes to this policy
If we change this policy in a way that materially affects how your information is used, we will notify you in the App and ask you to agree to the updated version before continuing. We record which version you agreed to and when.
13. Contact
Questions, requests, or complaints:
Priming Labs LLC [email protected] 17610 Zullo Dr, Poolesville, MD 20837
This document is a draft prepared for review. It has not been reviewed by an attorney and should not be published as the live policy until it has been.