Full Privacy Policy

We use privacy and security by design to build our services.

Effective date: January 6, 2025

juli Inc ("us", "we", or "our") operates the Mindful Patch mobile application on behalf of Noven Therapeutics, LLC (hereinafter referred to as the "Service").

juli Inc ("us", "we", or "our") operates the Mindful Patch mobile application on behalf of Noven Pharmaceuticals, LLC (“Noven”) (hereinafter referred to as the "Service"). 

Your use of the Service is intended to help you and your provider track and monitor your ADHD systems when you are using Xelstrym (dextroamphetamine) transdermal system, which is a Noven product. For more information regarding how Noven processes your Personal Information, please visit Noven’s Privacy Policy here. Use of Xelstrym or other Noven products is not a requirement for use of the Service. 

This Privacy Policy (“Policy”) describes how we collect, use and disclose Personal Information we receive when you use our Service or otherwise interact with us, whether online or offline, in relation to the Service. It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions, requests or concerns.

We use your data to provide and improve the Service. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Information Collection and Use

You may provide us with Personal Information, including when you:

  • register to receive the Service;

  • use our Service; and

  • communicate with us (whether through the app or by email) in relation to the Service.

Types of Data Collected

Personal Information

While using our Service, we may ask you to provide us with certain personal information that can be used to contact or identify you (“Personal Information”). Personal Information collected by Mindful Patch app may include:

  • Contact details, such as your name, username, password, email, and telephone number;

  • Basic profile information, such as demographic information including date of birth, and, should you choose to provide it, your gender and ethnicity.

Health Data

Health data is a special category of Personal Information. It may include information relating to your exercise regime, medication use, health, smoking, drinking, lifestyle and wellbeing, diet, sleep patterns, body metrics, health conditions, health symptoms, and any other information relating to your health, lifestyle and fitness you choose to share with Mindful Patch.

We may use your Health Data for our internal operations, which include administration, planning and various activities that assess and improve the quality and cost effectiveness of the Service that we deliver to you. We may also use your Health Data to contact you as a reminder to interact with or complete tasks relating to your use of our Service.

Usage Data

Identifiers and usage data, including your IP address, engagement metrics and information about your device, including model, version and operating system.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Certain Usage Data such as IP address may be considered Personal Information.

Correspondence Data

Correspondence and communications data, including any Personal Information contained in your correspondence and communications with us, including survey responses or customer service inquiries.

Third Party Data

We may obtain Personal Information about you from the following third parties:

Third party apps, devices and wearables. If you choose to connect Mindful Patch with a third-party health and fitness-related application (such as Apple HealthKit, Google Health Connect, FitBit, Garmin or others) or device, we will receive additional health and lifestyle data from the third-party providers of those apps or devices. The use of information received from Health Connect will adhere to the Health Connect Permissions Policy, including the limited use requirements.

Other Third Party services. We collect data from the environment based on your geolocation through third-party services should you choose to share your location with us. We do not share any personal information with such third parties except for geolocation data which we anonymize effectively by reducing the accuracy. Services we use are: getAmbee (https://www.getambee.com) and OpenWeatherMap (https://openweathermap.org).

Aggregate Data

We also collect, use and share aggregated data such as statistical or demographic data for our purposes and with our partner, Noven. Aggregated data may be derived from your Personal Information but is not Personal Information as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about your use of Mindful Patch to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will be used in accordance with this Policy. 

Use of Data

We use the Personal Information we collect for the following purposes:

  • To register you with Mindful Patch

  • To administer your Mindful account (including sending you information regarding changes to our policies, other terms and other administrative information)

  • To provide you with the Service

  • To conduct research and improve the Service and other offerings

  • To respond to queries and complaints and provide you with information and materials that you request or that may be of interest

  • To maintain accounts and records as required under applicable law

  • To maintain security, resolve technical issues, and troubleshoot

  • To conduct data analytics, testing and research

  • To respond to law enforcement requests or where required by applicable laws, court orders, or government regulations

  • To comply with legal requirements or to establish or exercise our legal rights to defend against legal claims

Retention of Data

juli Inc will retain your Personal Information and Usage Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. To the extent we collect your Personal Information through the Mindful App on behalf of Noven, we will retain such Personal Information only so long as directed by Noven.

juli Inc might also retain aggregated data for statistical purposes, but, as it is not considered Personal Information, the retention period for this kind of data would be unlimited.

Disclosure of Data

We only disclose Personal Information with the following recipients and in the following circumstances:

  • Vendors and service providers. We may share your Personal Information with third-party vendors and other service providers that perform services for us or on our behalf, which may include providing data hosting, customer relationship management, payment processing, health data analysis and analysis and analytics services. 

  • Fitness and health applications or devices. If you choose to integrate third-party applications (such as Apple HealthKit, FitBit, Garmin and others) and devices with Mindful Patch, we may share certain integration information with these third parties, including username, device information and ID, and inputs you enter into the Mindful Patch app. 

  • Healthcare professionals. We may share your Personal Information with healthcare professionals, such as qualified physicians, in certain circumstances, only if you explicitly request us to do so. We share certain contact information with these third parties, including name and contact information, and any data you explicitly choose to share.

  • Research partners. If you provide your explicit consent, we may share your Personal Information with third-party research partners, such as universities and research institutions, for the purposes of carrying out statistical and scientific research. 

  • Law enforcement, regulators, governmental authorities and other parties for legal reasons. We may share your Personal Information with third parties if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or our safety, or the safety of our users, a third party, or the public.

  • Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

  • Mixpanel. Mixpanel is a mobile application analytics service which tracks mobile usage. This data is used to help us make improvements to our service. For more information on Mixpanel’s privacy practices, please visit the Mixpanel Privacy Hub: https://mixpanel.com/legal/privacy-hub/

  • Noven. If certain conditions are met, your Personal Information may be released to, or shared with, Noven. Noven may also receive aggregated or anonymized data to comply with federal requirements and to evaluate Service and product usage.

Security of Data

All Personal Information you provide to us is sent in encrypted form and stored on secure servers with trusted third-party suppliers, Google Cloud Platform ('GCP') in the US. You can find out more about security policies and processes in the GCP Security Compliance page.

All traffic is transmitted securely via SSL by default.

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Your Rights

Depending on where you reside, you may have some or all of the privacy rights listed below with respect to the Personal Information we collect pursuant to this Privacy Policy. Please note that these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law. We will not discriminate against you for exercising any of these rights.

·       Right to Confirm/Access / Know. You may have the right to request access to Personal Information that we hold about you, including details relating to the ways in which we use and share your information. In some states, you may also have the right to obtain a list of the categories of third parties to whom we have disclosed your Personal Information. Residents of California have the right to know the categories of Personal Information we have collected about them, the categories of sources from which the Personal Information is collected, the categories of Personal Information sold, shared, or disclosed, the business or commercial purpose for selling, sharing, or disclosing the Personal Information, and the categories of third parties to whom we have sold, shared or disclosed their Personal Information. 

  • Right to Delete. You may have the right to request that we delete Personal Information we maintain about you.

  • Right to Correct. You may have the right to request that we correct inaccurate Personal Information we maintain about you.

  • Right of Portability. You may have the right to receive a copy of the Personal Information we maintain about you and to request that we transfer it to a third party.

  • Right to Withdraw Consent to Processing of Sensitive Personal Information. You may have the right to withdraw your consent to the collection, use and disclosure of your sensitive Personal Information (including health data). However, if you withdraw your consent, we may be unable to offer or provide you with the Service.

  • Right to Opt Out. You may have to opt out of certain uses of your Personal Information such as (i) targeted advertising, (ii) “sale” or “sharing” for cross-context behavioral advertising, or (iii) profiling or automated decision-making activities that result in a legal or similarly significant effect on you. Please note that we do not engage in any of these activities with the Personal Information collected pursuant to this Privacy Policy.

  • Right to Appeal. You may have a right to appeal our decision if we decline to process your request in part or in full. You can do so by replying directly to our denial. If you are not satisfied with our response to your appeal, you may contact your state Attorney General.

Requests to exercise these rights may be made using the contact information listed below. Only you, or as permitted by law, a person that you authorize to act on your behalf, may make a request related to your Personal Information. In the case of access, correction, and deletion, your request must be verified before we can fulfill the request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Information or that the requestor is authorized to act on your behalf. 

Additional Disclosures for California Residents

In addition to offering certain consumer rights (set forth in the section above), California law requires us to make the following additional disclosures to California residents regarding our information practices.

In the last twelve (12) months, the Personal Information we have collected falls into the following categories of Personal Information as defined under California law:

  • Identifiers and personal information categories listed in the California Customer Records statute, such as name, address, phone number, email address, online identifier, unique identifier, IP address, date of birth, payment card data, and medical information. We collect this category of information directly from you, or indirectly from you if you link the Service to third-party apps or devices. 

  • Protected classification characteristics, such as age. We collect this category of information directly from you. 

  • Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We collect this category of information directly from you, or indirectly from you if you link the Service to third-party apps or devices. 

  • Internet or other similar network activity, such as browsing history, search history, information on a consumer's interaction with a website or application. We collect this category of information automatically from your use of the Service.

  • Geolocation data, such as device location. We collect this category of information automatically from your use of the Service, if you allow it.

  • Sensitive personal information, such as precise geolocation and health data. We collect this category of information automatically from your use of the Service, if you allow it. We collect health data directly from you, or indirectly from you if you link the Service to third-party apps or devices. To the extent we collect sensitive Personal Information, we do not use it to infer characteristics about individuals. 

We use and disclose this Personal Information as described above in this Privacy Policy. In the past 12 months, we have disclosed each of the above categories of Personal Information to our service providers, but we have not disclosed Personal Information to other third parties. 

juli Inc does not sell information or share Personal Information collected pursuant to this Privacy Policy for cross-context behavioral advertising as defined under the California Consumer Privacy Act (CCPA).

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third-party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children's Privacy

Our Service is not intended for anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we will take the necessary steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Information, please contact us by email at privacy@juli.co or by using the contact forms on the juli website: https://www.juli.co.