LIFE Networks Privacy Policy

1. Introduction

The provider of LIFE Networks services, Grand Lux Industries LLC (DBA: Life Networks), hereinafter referred to as the “Company,” “we,” “us,” or “our,” is committed to respecting your privacy and protecting your personal information.

For the purposes of our services, LIFE Networks is the “Controller” of your personal data. Where we process data on behalf of our partners, we act as the “Processor” under their direction.

This Privacy Policy (the “Policy”) describes our policies and procedures on the collection, use, processing, disclosure, and protection of personal information gathered through all our services. The services to which this Policy applies include:

• Our website (lifenetworks.io) and affiliated websites (the “Platform”).
• Web and mobile applications (the “LIFE App”).
• Downloadable software applications.
• The LIFE NODE Application Programming Interface (“API”) and third-party applications authorized to use it.
• All related services we provide, including Node sales and Airdrop events (collectively, the “Services”).

This Policy outlines your rights regarding your personal information and provides instructions on how to contact us with any questions. By using our Services, you are deemed to have agreed to this Policy.

2. Acceptance of This Privacy Policy

By accessing our Platform, using our Services, submitting information to us, or registering for our products, you confirm that you have read and understood the entirety of this Privacy Policy and agree to be bound by its terms. This includes your express consent to the collection, use, processing, storage, and disclosure of your personal information by us or our authorized service providers in the manner described herein. If you do not agree with any part of this Policy, you must immediately cease using all of our Services.

3. What We Collect

In this Policy, “Personal Information” means any data that identifies or can be reasonably used to identify an individual. We collect your Personal Information through the following channels to provide and improve our Services and enhance security.

A. Information You Provide Directly or Consent to Integrate

This is information you provide when using our Services, linking external data, or participating in clinical trials:

• Basic Demographic Information: Age, gender, and race for fundamental research classification.
• Contact Information: Name, nickname, and email address for account creation and management.
• Medical and Health Information:
  • Routine Health Indicators: Standardized medical data such as blood pressure, blood glucose, and cholesterol levels from national health check-ups.
  • Medical Records and History: Electronic Medical Records (EMR) and prescription history from the diagnosis and treatment of specific diseases, as well as family medical history crucial for understanding genetic predispositions.
  • Genomic Data: Information for analyzing the genetic causes of diseases, such as Next-Generation Sequencing (NGS) data.
  • Sasang Constitutional Medicine Data: Diagnostic results of Sasang typology (Taeyang, Taeeum, Soyang, Soeum).
• Patient-Reported and Participant Data:
  • Qualitative data you directly input into the app, such as diet, supplement intake, symptom manifestation and improvement, and subjective experiences during treatment.
  • All data recorded during participation in clinical trials.
• Communication Records: Information generated from your interactions with us, such as customer support inquiries, feedback, and survey responses.
• Financial Information: Blockchain network details, cryptocurrency wallet addresses, and transaction history for processing transactions.

B. Information Collected Automatically During Service Use

When you use the LIFE App or our Platform, the following information may be collected automatically:

• Real-time Life Logs:
  • Daily life pattern data collected 24/7 via mobile phones and wearable devices like smartwatches, including step count, exercise records, sleep quality, and Heart Rate Variability (HRV).
• Online Identifiers and Usage Data:
  • IP address, geographic location, and device information (e.g., operating system, browser type).
  • Date and time of visits, clickstream data, and information on web pages visited immediately before and after using our Services.

C. Information Collected from Third Parties and Institutions

Within the scope permitted by applicable law and based on your consent, we may collect specialized data from our partner institutions:

• Clinical-Grade Medical Data:
  • Medical imaging data for stroke and cancer diagnosis provided by members of the Medical AI Alliance (MAA).
  • e.g., Real-time biometric data from environments like intensive care units.
• Clinical Trial Data:
  • e.g., Global Phase 3 clinical trial data, considered the 'gold standard' in new drug development.
• Social Media Information: If you post about Life Networks on our social media pages or other public platforms, we may collect your profile information and the content of your posts.

Note: We never collect or store sensitive authentication data such as your account password or private keys.

4. How We Use Personal Information

A. Our Guiding Principle: De-identification

Protecting your privacy is our highest priority. All Personal Information we collect, particularly sensitive data like medical and health information and life logs, undergoesde-identification immediately upon collectionto ensure it cannot be used to identify you.

• Data Segregation: Minimal identifying information required for account management and communication, such as your email address, is stored and managed in strict separation from your health data.
• Use of De-identified Data: The vast majority of our data utilization—including for service provision, research, and analysis—is performed exclusively with data from which personal identifiers have been removed. This allows us to leverage the utility of the data while robustly protecting the privacy of our users.

B. Purposes of Use

In accordance with our de-identification principle, we use the information we collect only for the following purposes and within the necessary scope:

• To Provide and Operate the Services:
  • Delivering personalized analysis reports based on de-identified health data.
  • Creating and updating user accounts.
  • Processing NFT orders and blockchain transactions.
  • Sending confirmations, technical support messages, and administrative notifications.
• For Research and Service Improvement:
  • Analyzing user trends and preferences using de-identified and aggregated data.
  • Improving the quality of our Services and developing new products, services, and features based on our findings.
  • Utilizing de-identified data for research aimed at developing disease prediction models and advancing medical technology.
• To Communicate with You:
  • Responding to your inquiries and requests.
  • Providing important information, including updates to our terms, conditions, and this Policy.
• For Marketing and Promotions:
  • Sending promotional and advertising materials related to products and services from us and our partners that we believe may be of interest to you.
  • Requesting feedback, conducting surveys, and improving our marketing activities.
  • You may opt out of receiving any promotional communications as described in Section 10, “Your Rights and Choices.”
• To Comply with Regulations and Legal Obligations:
  • Performing identity verification to comply with financial regulations.
  • Investigating or resolving claims and disputes related to the use of our Services.
  • Responding to official requests from regulatory bodies and government authorities.
• For Safety and Security:
  • Preventing, detecting, and investigating fraud, unauthorized access, and illegal activities.
  • Protecting our Services from malware and other security threats.
  • Resolving software bugs and other internal operational issues.

5. Information for European Residents (GDPR)

If you are in the European Economic Area (EEA), we will only process your Personal Information when we have a valid legal basis to do so:

• Consent: You have given us explicit consent to use your Personal Information for a specific purpose (e.g., for sending marketing communications).
• Contractual Necessity: The processing is necessary to perform a contract with you, such as providing our Services.
• Legal Obligation: The processing is necessary for us to comply with a legal obligation, such as a court order.
• Legitimate Interests: The processing is necessary for our legitimate interests, such as improving our Services and preventing fraud, provided that these interests are not overridden by your rights and interests.

6. How We Share Your Personal Information

Except as described in this Policy, we do not disclose your Personal Information without your consent. We may share or disclose information in the following circumstances:

• Service Providers and Partners: We share minimal necessary information with affiliates, vendors, and consultants who perform services on our behalf, such as web hosting, data analysis, customer service, and marketing.
• Legal Requirements and Regulatory Compliance: We may disclose information if required by law, legal process, or a valid request from public authorities, including to meet national security or law enforcement requirements.
• To Protect Rights and Safety: We may share information if we believe your actions are inconsistent with our agreements or policies, or to protect the rights, property, and safety of ourselves, our partners, the public, or others.
• Professional Advisors: We may share information with lawyers and other professional advisors to obtain legal advice or otherwise protect and manage our business interests.
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business, Personal Information may be transferred to another entity.
• Non-identifiable Information: We may share aggregated or de-identified information that cannot reasonably be used to identify you.

7. Data Security

We implement appropriate technical and organizational measures to protect your Personal Information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption of data at rest and in transit (e.g., AES, TLS).
• Hashing of critical information, such as API keys and passwords.
• Operating a system for monitoring security threats and responding to incidents.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.

8. Data Retention

We will retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected or until any legal retention periods expire. The specific retention period is determined by considering the type of service, the nature of our relationship with you, and any relevant legal obligations. When you close your account or our Services are terminated, your Personal Information will be promptly destroyed.

We may, however, retain some information as required by law or for legitimate business purposes, such as for legal compliance, dispute resolution, and fraud prevention.

9. International Data Transfers

As our Services are based on a global network, your Personal Information may be transferred to and processed on servers or cloud services located in countries outside of your own. In such cases, we will apply appropriate safeguards to ensure that your data is protected in accordance with the data protection laws of the relevant jurisdictions.

10. Your Rights and Choices

You have certain rights and choices regarding your Personal Information:

• Access, Correction, and Deletion: You may request to access, correct, or delete the Personal Information we hold about you at any time.
• Withdrawal of Consent: You may withdraw your consent to our collection and use of your Personal Information. However, this may limit your ability to use certain features of our Services.
• Opt-out of Marketing Communications: If you do not wish to receive marketing emails from us, you can opt out at any time by clicking the "Unsubscribe" link in the email or by contacting us directly.

To exercise any of these rights, please contact us using the contact information provided in Section 15, “Contact Information.”

11. Cookies and Tracking Technologies

We prioritize your privacy and do not use cookies to collect directly identifiable personal information. However, we may use minimal functional or analytical cookies to ensure the smooth operation of our Services and improve the user experience. You can refuse the use of cookies through your browser settings, but doing so may cause inconvenience when using some of our Services.

12. Use of Services by Minors

Our Services are not intended for use by individuals under the age of 19. If we become aware that we have collected Personal Information from a minor under 19 without parental consent, we will take immediate steps to delete that information and terminate the associated account.

13. Third-Party Websites and Services

Our Services may contain links to external websites or services operated by third parties. We have no control over and are not responsible for the content or privacy practices of these third-party sites. We strongly encourage you to review the privacy policies of any third-party site you visit.

14. Updates to this Privacy Policy

We may amend this Policy from time to time to reflect changes in the law or our Services. If we make material changes, we will notify you in advance through in-service notifications or by email. The "Last Updated" date at the top of this page indicates when the revised Policy takes effect. Your continued use of the Services after the changes become effective will be deemed your acceptance of the revised Policy.

15. Contact Information

If you have any questions about this Privacy Policy or our privacy practices in general, please contact us via email at:

• Email:contact@lifenetworks.io