Mobile Application Privacy Policy
Effective Date: July 13, 2026
Last Updated: July 14, 2026
This Privacy Policy explains how Veret Company, LLC, doing business as Onmetrica (“Onmetrica,” “Company,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects personal information when an individual downloads, accesses, activates, or uses the Onmetrica mobile application (the “App”).
The App incorporates the TenTwo Method and supports structured self-reflection, emotional and cognitive calibration, generated results and reports, authorized professional-support workflows, and non-commercial stage product and method-implementation improvement.
The App is not a medical device and is not intended to provide medical or psychological diagnosis, treatment, psychotherapy, crisis intervention, or emergency services.
Acknowledging this Privacy Policy does not constitute consent to every possible use of personal information. When applicable law or a particular App feature requires consent, Onmetrica will request that consent separately and explain the applicable purpose.
Please read this Privacy Policy together with the Onmetrica Mobile Application Terms and any additional notice or agreement presented in connection with a particular feature, professional workflow, Program activity, or other service.
1. Scope of This Privacy Policy
This Privacy Policy applies to personal information processed through:
• the App;
• App registration and onboarding;
• activation-code and invitation processes;
• account administration;
• App-related customer support;
• privacy and account-deletion requests; and
• directly related Program administration.
This Privacy Policy does not independently govern:
• general use of the Onmetrica website, which is governed by the applicable Website Privacy Policy and Website Terms of Use;
• optional participation in the Professional Program, which is additionally governed by the Participation & Feedback Agreement & Non-Disclosure Terms;
• a separately organized university, institutional, or regulated research study, which would require separate documentation and consent procedures;
• records independently maintained by a professional outside the App; or
• a separate written agreement between Onmetrica and a professional practice, institution, university, organization, or other entity.
Where a specific agreement expressly governs a particular activity, that agreement will control that activity. This Privacy Policy will continue to govern general. App data practices unless the specific agreement states otherwise.
2. Eligibility and User Roles
The App is intended only for individuals who are at least eighteen years old.
The App may support different authorized user roles, including:
• individual users using the App for structured reflection and calibration;
• professionals using authorized professional-support workflows;
• clients or participants invited by an authorized professional;
• optional Program participants; and
• authorized account or support administrators.
References to “you” or “user” generally mean the individual whose personal information is processed through the App.
3. Onmetrica’s Role in Professional Workflows
For information that you provide directly to Onmetrica to create, activate, secure, or support your App account, Onmetrica generally determines the purposes and means of processing that information.
When a professional or organization:
• invites a client or participant;
• assigns or recommends an App activity;
• determines how App results will be used;
• communicates with a client about App results; or
• maintains an independent professional record,
that professional or organization may separately determine the purposes and means of processing information within its own practice or operations.
The professional or organization may have its own privacy notice, confidentiality obligations, professional responsibilities, and data-retention requirements.
A deletion request submitted to Onmetrica may not delete copies of information independently retained by a professional or organization outside the App. Users should contact the applicable professional or organization regarding information independently controlled or maintained by that professional or organization.
4. Information We Collect
We collect information reasonably necessary to provide, secure, administer, support, and improve the App and the implementation of the TenTwo Method within the App.
4.1 Account and Contact Information
Depending on the account structure and enabled features, we may collect:
• name;
• email address;
• profile photo, if provided;
• password or authentication credentials in protected form;
• Apple ID or Google sign-in association;
• user, account, or profile identifier;
• communication preferences;
• account status; and
• support contact information.
4.2 Access, Invitation, and Role Information
Because access to the App may require an invitation or activation code during the non-commercial stage, we may process:
• activation or access codes;
• invitation links and invitation details;
• professional or client role information;
• professional-client account associations;
• participant identifiers;
• account-verification information;
• onboarding status;
• activation or deactivation status; and
• records showing acceptance of applicable terms, privacy notices, program agreements, or confidentiality obligations.
4.3 Calibration, Reflection, and Generated App Data
When you use the App’s calibration, reflection, evaluation, report, or related functions, you may provide or generate:
• present-state, past-state, desired-state, or other structured calibration inputs;
• responses to guided questions and internal App flows;
• point-based selections;
• body-reflection or body-awareness responses;
• self-reflection entries;
• notes, progress logs, and timestamps;
• information about perceived patterns, relationships, emotional states, or personal experiences;
• results, visualizations, summaries, scores, or reports generated from your inputs; and
• changes in results or progress history over time, where that feature is enabled.
This information may reveal or permit inferences concerning emotions, mental state, personal experiences, relationships, or health-related concerns.
We therefore treat this information as sensitive information and, where applicable, consumer health data or special-category personal data.
Terms such as “diagnostic,” “evaluation,” “assessment,” “calibration,” “result,” “report,” or similar expressions describe method-related, reflective, informational, or product functions. They do not represent medical, psychiatric, or psychological diagnoses.
4.4 Professional and Client Workflow Information
When the App is used as part of an authorized professional-support workflow, we may process:
• the identity and contact information of the authorized professional;
• the association between a professional and a client or participant;
• invitations, assignments, status information, and workflow permissions;
• App results, reports, or content made visible within the authorized workflow;
• professional notes or comments entered through an enabled App feature; and
• records of professional-client interactions within the App, where such functionality is enabled.
A user must not enter information about another person unless the user has a lawful basis and appropriate authority to do so.
4.5 Participation and Feedback Information
If you voluntarily participate in the Program, we may collect:
• Program eligibility and onboarding information;
• records of acceptance of the Participation & Feedback Agreement & Non-Disclosure Terms;
• product-related comments and suggestions;
• usability observations;
• technical or workflow error reports;
• responses to optional surveys or interviews;
• information concerning selected feedback discussions; and
• records reasonably necessary to administer Program participation and confidentiality obligations.
Program participation is optional.
Downloading or using the App, receiving an access code, purchasing a professional membership, or acknowledging this Privacy Policy does not automatically enroll a person in the Program.
4.6 Communications and Support Information
When you contact Onmetrica, we may collect:
• the content of your communication;
• your contact information;
• support history;
• screenshots or files that you choose to provide;
• device or account information relevant to the issue; and
• information necessary to investigate and respond to your request.
Do not send medical records, psychotherapy notes, emergency information, or identifiable client files through ordinary support email unless Onmetrica expressly provides an authorized method for submitting that information.
4.7 Device, Usage, and Diagnostic Information
The App or its service providers may automatically collect limited technical information, including:
• IP address;
• general region inferred from an IP address;
• device type and device model;
• operating system;
• language and time zone;
• App version and installation information;
• device or App identifiers used for authentication, security, analytics, diagnostics, or functionality;
• login and session information;
• screens viewed;
• feature interactions and general usage activity;
• crash reports;
• error logs;
• latency and performance information; and
• security or fraud-prevention events.
The App is not designed to collect precise GPS location for advertising or profiling.
We do not use advertising identifiers to track users across unrelated third-party apps or websites for behavioral advertising.
4.8 Payment Information
App access is currently separate from Onmetrica’s paid professional memberships and may be provided without an in-App purchase, subject to authorization and an access code.
If subscriptions or purchases are later enabled through Apple or Google, the applicable application store will process payment credentials. Onmetrica would ordinarily receive only limited transaction-related information, such as:
• purchase status;
• product identifier;
• transaction identifier;
• renewal status; or
• subscription status.
Onmetrica does not ordinarily receive or store complete payment-card details processed by Apple, Google, or another payment processor.
Payments made through the Onmetrica website or another third-party processor are governed by the applicable website privacy notice and the processor’s terms and privacy policy.
4.9 Information Users Should Not Submit
Unless a specific authorized workflow and written agreement expressly permit it, do not submit through the App or ordinary support channels:
• medical or insurance records;
• psychotherapy notes;
• protected health information requiring a Business Associate Agreement;
• emergency or crisis information;
• information concerning a minor;
• government identification numbers not requested by the App;
• financial-account credentials;
• confidential client files; or
• information about another person that you are not authorized to disclose.
5. Sources of Information
We may obtain information from:
• you directly through the App, onboarding, support, surveys, or privacy requests;
• an authorized professional or organization that invites or administers your access;
• another user when an App feature is intentionally designed to connect authorized accounts;
• your device and your interactions with the App;
• service providers supporting hosting, authentication, security, communications, analytics, or diagnostics;
• Apple, Google, or another authorized application-distribution provider; and
• Onmetrica website, customer-relationship management, demonstration, or onboarding records used to issue or manage App access.
6. How We Use Information
6.1 Providing and Operating the App
We may use information to:
• create, authenticate, and maintain accounts;
• issue and validate access codes;
• provide calibration, reflection, reporting, progress-history, and other enabled functions;
• save user progress and settings;
• connect authorized professional and client accounts;
• display information according to user permissions;
• maintain account security; and
• provide customer support and respond to requests.
6.2 Improving the Product and Method Implementation
We may use information to:
• identify technical problems and improve reliability;
• evaluate feature usage and workflow usability;
• improve navigation, presentation, reports, and App-guided flows;
• improve implementation of the TenTwo Method within the App;
• develop, test, and validate App improvements;
• evaluate how users interact with enabled App functions;
• improve professional and client workflows; and
• generate internal statistics and quality-assurance information.
Where reasonably possible, we use aggregated, anonymized, or de-identified information for analytics and product improvement.
We do not use identifiable sensitive App content for an unrelated purpose without an appropriate legal basis and, where required, consent.
6.3 Administering Optional Program Participation
We may use information to:
• confirm eligibility and agreement acceptance;
• organize optional feedback activities;
• review product-related feedback;
• communicate about Program activities;
• maintain participation and confidentiality records; and
• protect non-commercial stage materials and App integrity.
6.4 Security, Fraud Prevention, and Enforcement
We may use information to:
• detect, prevent, and investigate unauthorized access, misuse, fraud, and security incidents;
• maintain account and system integrity;
• protect users, professionals, Onmetrica, and third parties;
• enforce applicable terms, agreements, access rules, and intellectual-property rights; and
• maintain security and audit records where appropriate.
6.5 Communications
We may use information to:
• send account, access, security, support, and service notices;
• provide legal or policy updates;
• send Program-related communications to voluntary participants;
• deliver App notifications enabled by a user; and
• send optional, non-essential communications where permitted and subject to available opt-out rights.
Users may opt out of non-essential promotional communications. Users may continue to receive communications reasonably necessary for account administration, access, billing, security, support, legal compliance, or requested services.
6.6 Legal and Business Purposes
We may use information to:
• comply with applicable law and legal process;
• respond to lawful requests;
• establish, exercise, or defend legal claims;
• maintain corporate, tax, accounting, and transaction records; and
• evaluate or complete a merger, financing, restructuring, acquisition, or sale of assets.
7. Product Improvement Is Not Automatic Research Enrollment
The current Professional Program is intended primarily to support:
• product improvement;
• method-implementation improvement;
• usability review;
• quality assurance; and
• structured feedback.
Downloading or using the App, receiving an access code, purchasing a professional membership, or acknowledging this Privacy Policy does not automatically enroll a person in a regulated human-subject research study.
Onmetrica may separately collaborate with universities, research institutions, public agencies, or funding partners.
Any separately organized research activity will use separate:
• documentation;
• eligibility criteria;
• consent procedures;
• data-use disclosures; and
• institutional or regulatory processes, as applicable.
We will not publish identifiable App content in an external research paper, public presentation, case study, testimonial, or marketing material without separate authorization.
Aggregated or properly de-identified information may be used for internal analysis and may be described externally where individuals cannot reasonably be identified, subject to applicable law.
8. Automated Processing And Generated Results
The App processes user inputs according to its configured logic to generate visualizations, summaries, results, reports, or other outputs.
These outputs are intended for:
• structured reflection;
• calibration;
• informational use;
• product-supported professional discussion; and
• authorized professional-support workflows.
Generated outputs are not medical, psychiatric, or psychological diagnoses.
They are not intended to serve as the sole basis for decisions producing legal or similarly significant effects.
Professional users remain responsible for exercising independent professional judgment.
Individual users should seek appropriately qualified assistance for medical, psychological, psychiatric, therapeutic, or emergency concerns.
9. Consumer Health Data Notice
Certain App information may qualify as consumer health data, health-related data, or a similar category under applicable law because it identifies or may reasonably be linked to a user and concerns or permits inferences about emotional, mental, or health-related status.
9.1 Categories of Consumer Health Data
Depending on how the App is used, consumer health data may include:
• emotional-calibration inputs;
• self-reflection inputs;
• body-reflection responses;
• responses to structured App flows;
• information about perceived emotional states, patterns, relationships, or experiences;
• generated reports, visualizations, results, and progress history;
• inferences generated from App inputs;
• professional-client workflow information associated with App results; and
• communications containing emotional, mental, or health-related information.
9.2 Sources of Consumer Health Data
We may collect consumer health data from:
• the user;
• an authorized professional or connected account;
• the user’s interactions with the App; and
• service providers that host or process information on our behalf.
9.3 Purposes for Collecting and Using Consumer Health Data
We collect and use consumer health data only:
• to provide an App function requested by the user;
• to maintain an authorized professional-client workflow requested or enabled by the user;
• to save and display user progress where enabled;
• for security, integrity, support, and legal compliance;
• for an additional purpose to which the user has consented; or
• in aggregated, anonymized, or de-identified form for product and method-implementation improvement where permitted by law.
9.4 Categories of Recipients
We may disclose relevant consumer health data only as reasonably necessary to:
• an authorized professional, client, participant, or administrator within a user-directed workflow;
• service providers processing information for hosting, database management, authentication, security, analytics, diagnostics, communications, customer support, or similar operational purposes;
• legal, compliance, security, or professional advisers where reasonably necessary;
• government authorities or other parties when disclosure is required or permitted by law; or
• a successor or transaction participant in a merger, financing, restructuring, acquisition, or asset transfer, subject to appropriate protections.
Onmetrica currently has no affiliate to which it discloses consumer health data for that affiliate’s independent marketing purposes.
9.5 No Sale, Targeted Advertising, or Healthcare Geofencing
We do not sell consumer health data.
We do not disclose consumer health data for cross-context behavioral advertising or targeted advertising based on activity across unrelated third-party apps or websites.
We do not use geofencing around healthcare facilities or similar locations to identify, track, collect, or infer consumer health data.
9.6 Consumer Health Data Rights
Where applicable law provides these rights, a user may request to:
• confirm whether we collect, use, or disclose the user’s consumer health data;
• access consumer health data;
• obtain information about third parties or affiliates to which consumer health data was disclosed;
• withdraw consent for collection or disclosure based on consent;
• delete consumer health data;
• correct inaccurate information where applicable; and
• appeal a denial of a request.
Requests may be submitted to support@onmetrica.com with the subject line “Consumer Health Data Request.”
We may verify the requester’s identity, authority, and account ownership before acting on a request.
10. How We Disclose Information
We do not sell personal information.
We do not disclose personal information for cross-context behavioral advertising.
We may disclose information in the limited circumstances described below.
10.1 At Your Direction or Within an Authorized Workflow
Information may be made available to an authorized professional, client, participant, or administrator when you:
• intentionally connect accounts;
• accept an invitation;
• submit information through a shared workflow;
• authorize access through an enabled function; or
• otherwise direct the disclosure.
Before using a shared workflow, review the applicable screens, permissions, and notices.
Disconnecting a workflow may stop future App disclosures but may not delete information already received or independently retained by another authorized user.
10.2 Service Providers and Processors
We may engage service providers to support:
• cloud hosting, storage, and databases;
• authentication and account security;
• App performance, diagnostics, and crash reporting;
• limited analytics and usage measurement;
• email, notification, and customer-support services;
• customer-relationship management, onboarding, and access-code administration;
• fraud prevention and security monitoring;
• incident response;
• legal, accounting, and compliance support; and
• application distribution and transaction confirmation through Apple, Google, or another authorized platform.
These providers may process information only for authorized purposes and are subject to contractual or legal confidentiality, security, and data-protection obligations appropriate to their services.
10.3 Legal, Safety, and Rights Protection
We may preserve, use, or disclose information where we reasonably believe it is necessary to:
• comply with applicable law, regulation, court order, subpoena, or lawful government request;
• protect the rights, safety, property, or security of Onmetrica, users, professionals, participants, or others;
• investigate fraud, misuse, unauthorized access, or a security incident;
• enforce agreements, policies, and access restrictions; or
• establish, exercise, or defend legal claims.
10.4 Business Transactions
Information may be disclosed or transferred as part of due diligence or a completed:
• merger;
• acquisition;
• financing;
• restructuring;
• reorganization;
• bankruptcy;
• sale of assets; or
• similar transaction.
We will use reasonable measures to require the recipient to handle personal information consistently with applicable law and the commitments applicable at the time of transfer.
10.5 De-identified and Aggregated Information
We may use or disclose information that has been aggregated, anonymized, or de-identified so that it cannot reasonably be linked to an individual, where permitted by law.
We will not attempt to re-identify information maintained as de-identified except:
• to test whether de-identification measures are effective;
• to protect against improper re-identification; or
• as otherwise permitted by law.
11. No Sale, Behavioral Advertising, or Third-Party Advertising Tracking
Onmetrica does not:
• sell personal information or consumer health data;
• rent personal information to data brokers;
• use App content for third-party behavioral advertising;
• track users across unrelated third-party apps or websites for advertising purposes;
• disclose sensitive App content to advertisers; or
• use emotional-calibration inputs to select third-party advertisements.
If these practices materially change, we will update this Privacy Policy and provide consent or opt-out rights where required before applying the change to previously collected sensitive information.
12. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:
• provide requested App functions;
• administer accounts and authorized workflows;
• maintain security;
• document permissions and agreements;
• resolve disputes;
• enforce legal rights; and
• comply with legal, accounting, tax, or reporting obligations.
Retention periods depend on the type of information and the context in which it was collected.
For example:
• account and access information may be retained while an account is active and for a reasonable period after closure to complete deletion, prevent fraud, or resolve account issues;
• user content, reports, and progress history may be retained until the user deletes them, requests deletion, or closes the account, subject to applicable exceptions;
• Program agreement and confidentiality records may be retained as reasonably necessary to document permissions, obligations, and legal compliance;
• support communications may be retained for service quality, security, dispute resolution, and legal compliance;
• technical, security, and audit logs may be retained for a limited period appropriate to security and operational needs;
• transaction records may be retained for tax, accounting, fraud-prevention, and legal requirements; and
• properly de-identified or aggregated information may be retained for a longer period where it no longer reasonably identifies an individual.
When information is deleted from active systems, residual copies may remain for a limited period in protected backups, disaster-recovery systems, or immutable security logs until they are overwritten, isolated, or no longer required.
13. Data Security
We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized:
• access;
• acquisition;
• use;
• alteration;
• disclosure; or
• destruction.
Depending on the system and context, safeguards may include:
• access controls and role-based permissions;
• authentication and credential-management measures;
• encryption in transit where supported and appropriate;
• secure hosting and storage configurations;
• logging, monitoring, and incident-response procedures;
• data minimization;
• internal access limitations;
• vendor diligence;
• contractual protections; and
• periodic review of security and privacy practices.
No method of electronic transmission, storage, or processing is completely secure. We cannot guarantee absolute security.
Users are responsible for protecting their passwords, devices, access codes, and account credentials and for notifying Onmetrica promptly of suspected unauthorized access.
14. Security Incidents and Breach Notifications
If we become aware of unauthorized acquisition, access, disclosure, or use of personal information, we will investigate and take reasonable steps to contain and address the incident.
We will provide notices to affected individuals, regulators, service providers, organizational customers, or other parties when and as required by applicable law.
Depending on the nature of the information and the App’s legal classification, notification obligations may arise under:
• state data-breach laws;
• consumer health-data laws;
• contractual requirements; or
• the Federal Trade Commission’s Health Breach Notification Rule.
15. HIPAA And Professional Confidentiality
The fact that the App may contain emotional, mental, or health-related information does not automatically mean that all App information constitutes protected health information under the Health Insurance Portability and Accountability Act (“HIPAA”).
HIPAA applies only in specified circumstances involving covered entities, business associates, and protected health information.
Unless Onmetrica has entered into a separate written Business Associate Agreement expressly covering a particular professional or organizational workflow, Onmetrica does not agree, through this Privacy Policy, ordinary App use, or issuance of an access code, to act as a HIPAA business associate.
Professionals and organizations must not use the App to transmit or maintain protected health information requiring a Business Associate Agreement unless:
• Onmetrica has expressly authorized that use in writing; and
• the required Business Associate Agreement is in effect.
Even where HIPAA does not apply, App information may remain protected by:
• this Privacy Policy;
• consumer-protection laws;
• state consumer health-data laws;
• contractual duties;
• professional confidentiality obligations; and
• other applicable privacy laws.
16. Your Choices and Controls
Depending on enabled App features and applicable law, you may be able to:
• review or update account information;
• manage notification preferences;
• choose whether to enter optional reflection or profile information;
• choose whether to accept or continue an authorized professional-client connection;
• withdraw from optional Program activities in accordance with the applicable agreement;
• request correction or export of information;
• delete individual information where the App provides that function;
• delete or request deletion of your account;
• withdraw consent for future processing where processing is based on consent; and
• contact us regarding privacy concerns.
Withdrawing consent does not affect processing that occurred lawfully before withdrawal.
Certain information may continue to be processed where reasonably necessary to:
• complete a requested action;
• protect security;
• prevent fraud;
• comply with law;
• document an agreement or legal obligation; or
• establish, exercise, or defend legal claims.
17. Account and Data Deletion
You may delete your Onmetrica account and associated App data through the App or request deletion without having access to the App.
Detailed instructions are available at:
https://onmetrica.com/account-and-data-deletion.html
17.1 Deleting an Account Through the App
To delete your account through the App:
1. Open the Onmetrica App and sign in.
2. Go to Profile.
3. Select Account.
4. Select Delete Account.
5. Confirm the deletion request.
In-App account deletion is immediate and cannot be undone.
17.2 Requesting Deletion Without the App
If you no longer have the App installed or cannot access your account, you may request deletion by emailing:
support@onmetrica.com
Send the request from the email address registered to your Onmetrica account and use the subject line: Account Deletion Request
We may verify your identity and account ownership before processing the request.
Following verification, we will delete the account within thirty days and confirm completion by email.
17.3 Information Deleted with the Account
Subject to applicable legal exceptions, account deletion includes deletion of the account and associated information maintained in active Onmetrica systems, including:
• profile name;
• email address;
• profile photo;
• account and sign-in credentials;
• Apple ID or Google sign-in association;
• user and account identifiers;
• access or activation codes;
• invitation links;
• professional-client account associations maintained within the App;
• emotional-calibration inputs;
• body-reflection responses;
• self-reflection entries;
• structured App responses;
• notes;
• generated results and reports;
• progress logs; and
• App history associated with the account.
17.4 Information That May Be Retained
Certain limited information may be retained where reasonably necessary to:
• comply with legal, tax, accounting, regulatory, or reporting obligations;
• document acceptance of binding terms, confidentiality obligations, or other agreements;
• prevent fraud or unauthorized access;
• protect the security and integrity of the App;
• resolve disputes;
• enforce legal rights; or
• establish, exercise, or defend legal claims.
Information that has already been properly aggregated, anonymized, or irreversibly de-identified so that it cannot reasonably be linked back to you may also be retained and used for lawful product, security, statistical, and method-implementation improvement purposes.
Residual copies may remain temporarily in protected backups, disaster-recovery systems, or immutable security logs until they are overwritten, isolated, or no longer required.
17.5 Information Held by Professionals or Organizations
Deleting your Onmetrica account may not delete:
• records independently maintained by a professional;
• information exported or downloaded by an authorized professional before deletion;
• professional notes maintained outside the App;
• records maintained by an organization under its own legal obligations; or
• information controlled by an unrelated third party.
Contact the applicable professional or organization regarding information it independently controls.
17.6 Effect on Professional Memberships
Deleting an App account does not automatically cancel a separately purchased professional membership or recurring subscription obtained through the Onmetrica website.
Professional memberships must be canceled separately in accordance with the applicable checkout terms and Website Terms of Use.
17.7 Effect on Program Participation
Deleting an account terminates access to the App and may make continued Program participation impossible.
Any confidentiality, intellectual-property, or other obligations that are stated to survive withdrawal or termination will continue in accordance with the
Participation & Feedback Agreement & Non-Disclosure Terms.
18. Privacy Rights
Depending on your location and applicable law, you may have the right to:
• confirm whether we process your personal information;
• access personal information we maintain about you;
• correct inaccurate personal information;
• request deletion;
• obtain a portable copy of certain information;
• restrict or object to certain processing;
• withdraw consent where processing is based on consent;
• opt out of sale, targeted advertising, or qualifying profiling, although Onmetrica does not currently engage in those practices;
• receive information about categories of information, purposes, sources, and recipients;
• use an authorized agent where permitted; and
• appeal a denial of a privacy request.
To exercise a privacy right, you may:
• use an available in-App privacy or account-deletion function; or
• email support@onmetrica.com with the subject line “Privacy Request.”
Please describe the right you wish to exercise and identify the account or email address involved.
We may request information reasonably necessary to verify:
• identity;
• authority;
• account ownership; and
• the validity of the request.
We will respond within the period required by applicable law.
If we deny a request, we will provide an explanation and appeal instructions where required.
We will not discriminate against a user for exercising a privacy right.
Certain rights are subject to legal exceptions, including where retention is necessary for:
• security;
• fraud prevention;
• legal compliance;
• completion of a requested transaction;
• exercise of free-speech or other legal rights; or
• establishment, exercise, or defense of legal claims.
19. Additional Notice for U.S. State Residents
Residents of certain U.S. states may have additional rights concerning personal information or consumer health data.
These rights may include the right to:
• access;
• correct;
• delete;
• obtain a copy;
• opt out of certain processing;
• withdraw consent;
• obtain information about disclosures; and
• appeal a privacy decision.
Onmetrica does not sell personal information.
Onmetrica does not process personal information for cross-context behavioral advertising.
Onmetrica does not use sensitive App content to make decisions producing legal or similarly significant effects.
Where state law provides a right to appeal, submit the appeal to:
support@onmetrica.com
Use the subject line: Privacy Appeal
Identify the original request and explain why you believe the decision should be reconsidered.
If an appeal is denied, we will provide information about any further complaint mechanism required by applicable law.
20. EEA, United Kingdom, and Switzerland
If European Economic Area, United Kingdom, or Swiss data-protection laws apply, Veret Company, LLC is generally the controller for information processed directly for:
• App accounts;
• activation and access;
• security;
• product operations;
• direct support;
• product improvement; and
• privacy-request administration.
A professional or organization may be a separate controller for information that it independently determines to collect and use within its practice or operations.
20.1 Legal Bases
Depending on the processing activity, we may rely on one or more of the following legal bases:
• performance of a contract or steps requested before entering a contract;
• consent, including for optional features, sensitive information, Program activities, or non-essential communications where required;
• legitimate interests, including security, fraud prevention, support, service improvement, and protection of legal rights, where those interests are not overridden by individual rights;
• compliance with a legal obligation; and
• establishment, exercise, or defense of legal claims.
Where App information qualifies as special-category personal data, we will rely on explicit consent or another condition permitted by applicable law.
20.2 Additional Rights
Applicable rights may include:
• access;
• rectification;
• erasure;
• restriction;
• objection;
• portability;
• withdrawal of consent; and
• the right to lodge a complaint with a competent supervisory authority.
Users may contact support@onmetrica.com to exercise these rights or request information concerning the applicable supervisory authority.
21. International Data Transfers
Onmetrica is based in the United States.
Personal information may be processed in the United States and in other countries where service providers operate.
Where required for an international transfer, we use appropriate safeguards, which may include:
• contractual protections;
• transfer mechanisms recognized by applicable law;
• technical and organizational security measures; and
• assessments of the transfer context.
22. Children’s Privacy
The App is intended only for individuals eighteen years of age or older.
We do not knowingly collect personal information from individuals under eighteen through the App.
If we learn that an individual under eighteen has provided personal information, we will take reasonable steps to delete or restrict that information, subject to applicable law.
A parent or guardian who believes that a minor has used the App should contact:
support@onmetrica.com
23. App Permissions And Third-Party Platforms
The App may request device permissions only when needed for an enabled function.
The applicable permission prompt or in-App disclosure will explain the requested access.
Users may manage permissions through their device settings. Disabling a permission necessary for a particular function may limit or prevent use of that function.
The App may contain links to or rely on services provided by:
• Apple;
• Google;
• authentication providers;
• hosting providers;
• analytics providers;
• diagnostic or crash-reporting providers; or
• other operational service providers.
Those third parties may process information under their own privacy policies and terms.
Onmetrica is not responsible for an unrelated third party’s independent privacy practices.
The Apple App Store privacy label and Google Play Data Safety section are summaries of App data practices. They should be read together with this Privacy Policy.
Onmetrica is responsible for maintaining those disclosures so that they reasonably reflect the App’s actual data practices, including the practices of third-party software development kits integrated into the App.
24. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in:
• App functionality;
• account-deletion procedures;
• data practices;
• professional workflows;
• service providers;
• security practices;
• applicable laws; or
• the Onmetrica non-commercial stage framework.
When we update this Privacy Policy, we will revise the “Last Updated” date.
We may provide additional notice through:
• the App;
• email;
• the Onmetrica website;
• an account notice; or
• another reasonable method,
when a change is material.
Where required, we will obtain consent before using previously collected sensitive information for a materially different purpose.
25. Contact Information
Questions, privacy requests, consumer health-data requests, account-deletion requests, appeals, and complaints may be directed to:
Veret Company, LLC, DBA Onmetrica
700 S. Rosemary Avenue, Suite 204
West Palm Beach, Florida 33401
United States
Email: support@onmetrica.com
Support: https://onmetrica.com/support
For faster routing, use one of the following email subject lines:
• Privacy Request
• Consumer Health Data Request
• Account Deletion Request
• Privacy Appeal