Privacy Policy for Neiry Pulse

Effective date: June 24, 2026 Last updated: June 24, 2026

This Privacy Policy describes how the Neiry Pulse mobile application and related services (collectively, the “App”) access, collect, use, store, protect, and disclose information when you use Neiry Pulse together with compatible Neiry wristband devices.

The operator of the App and controller of your personal data depends on the channel through which you obtained the App:

If you downloaded the App from the Apple App Store, the operator is Konstantin Dvugroshev, a private individual using a personal Apple Developer account (hereinafter — “we”, “us”, or “our”) — full name: Konstantin Valeryevich Dvugroshev; email: hello.solomono@gmail.com; address: Moscow, Vysokaya str., bldg. 20, apt. 41, Russian Federation.
If you downloaded the App from Google Play, the operator is LLC “Neirotech” (ООО «Нейротех») — LLC NMF “Neirotech” (ООО НМФ «Нейротех»); OGRN 1026102573419, INN 6154082572; address: 347905, Rostov Region, Taganrog, Dzerzhinskogo str., 119-a, Russian Federation; email: privacy@neiry-bci.com.

Both operators apply the same data-handling practices described in this Privacy Policy.

Neiry Pulse is a wellness and fitness application. It is classified under the Health & Fitness category in both the Apple App Store and Google Play, not under Medical. The App is not a medical device. It does not diagnose, treat, cure, mitigate, monitor, or prevent any disease, injury, or medical condition, and it is not intended for clinical decision-making or for use by patients in clinical contexts. The App is designed for general wellness and fitness tracking by healthy adults who want to better understand their everyday wellbeing.

For any health-related questions or before making decisions that may affect your health, please consult a qualified healthcare professional.

The App requires compatible external hardware (Neiry wristband) to provide its core functionality.

By using the App, you agree to the practices described in this Privacy Policy.

Important Android permission notice: on some Android versions, Neiry Pulse may request approximate location and/or precise location permission solely to support Bluetooth Low Energy (BLE) scanning and connection to compatible Neiry wristband devices, as required by the operating system. Neiry Pulse does not use these permissions to determine, collect, store, or transmit a user’s physical location.

1. Information We Access and Collect

Depending on how you use the App, we may access or collect the following categories of data:

1.1 Account and profile information

We may collect and store:

your name;
your email address;
your unique user ID;
your date of birth or age group;
your sex/gender;
your height and weight (used to refine personal baseline calculations);
your wellness goals (e.g., recovery, stress management, fitness);
your preferred interface language;
your country or region, if you choose to provide it in your account settings or if it is derived from your language or locale settings rather than from your device geolocation.

We use this information to create and maintain your account, enable login, personalize your experience, send service-related notifications, and provide more relevant recommendations. We do not use device geolocation for these purposes.

1.2 Wellness and fitness data

When you use the App with a compatible Neiry wristband, the App may access and process wellness- and fitness-related data (used for informational purposes only and not for medical assessment), including:

heart rate (HR) and resting heart rate;
heart rate variability (HRV), including derived metrics such as RMSSD, SDNN, or pNN50;
raw R-R intervals (the time intervals between consecutive heartbeats);
inertial measurement unit (IMU) data: accelerometer and, where supported, gyroscope and magnetometer readings used to determine activity state and to filter heart-rate signal artifacts;
step count and physical activity summaries;
sleep phases (light, deep, REM, awake), total sleep duration, and overnight HRV trends;
SpO2 (blood oxygen saturation) readings, where the wristband model supports it;
calibration data — your personalized HRV baseline calculated during the first 36–48 hours of use;
training session records: duration, average and maximum heart rate, heart-rate zones, distance and route (GPS, where supported by the wristband model), estimated calories.

Important clarification about raw biometric data

Raw R-R intervals and IMU readings are transmitted from your Neiry wristband to the App over Bluetooth Low Energy (BLE), then sent to our servers for processing into derived health metrics (HRV, baseline, composite stress indicators). Raw biometric data is stored on our servers solely to enable retroactive recalculation in case our methodology changes, and is retained for limited periods (see Section 6).

We transmit and store the following derived wellness and fitness data on our servers:

aggregated daily, weekly, and monthly HRV values;
personal HRV baseline (your “personal norm”);
HRV deltas (deviation from your personal baseline);
composite stress metric (where applicable);
session results and training history;
sleep records and overnight metrics;
text-based recommendations generated for you based on your data.

We use this data to:

provide real-time and historical feedback in the App;
display your personal HRV baseline and deviations from it;
generate personalized recommendations and wellness insights;
support continuity across sessions and devices where applicable;
enable the Sharing functionality (see Section 4.3) when you explicitly choose to share your wellness metrics with a trusted contact;
improve and maintain the functionality of the App.

We may access or collect:

Bluetooth-related data needed to discover, connect to, and communicate with compatible Neiry wristband devices;
device identifiers associated with the wristband hardware;
wristband serial number;
wristband firmware version;
wristband model (VITRO, VANTA, VIGOR, or other supported Neiry models);
mobile device model, operating system version, and technical configuration.

We use this information to connect the App to the appropriate wristband, maintain stable operation, provide firmware-related notices, troubleshoot hardware/software issues, and improve compatibility.

1.4 Location information

On certain Android versions, the App may request approximate location and/or precise location permission solely because the Android operating system historically required location access for Bluetooth Low Energy (BLE) scanning and discovery of nearby external devices. Neiry Pulse does not use these permissions to determine, collect, track, or store a user’s physical location for advertising, profiling, analytics, or any location-based feature.

Device geolocation obtained through these permissions is not transmitted off-device by the App and is not stored on our servers (except as noted below for training GPS routes).

Exception for training mode: if your wristband supports GPS (VIGOR model) and you explicitly start a workout session with route tracking, the App will collect and store the GPS coordinates of your route for the duration of that workout. This GPS data is associated with the specific training session, displayed to you in session history, and stored on our servers as part of your training records. You can delete individual training sessions and their associated GPS data at any time from the in-app history screen.

If country or region information is associated with your account, it is provided by you or derived from language or locale settings rather than from device geolocation.

1.5 Analytics, diagnostics, and performance information

We may collect:

crash logs;
diagnostics data;
app performance information;
interaction events, such as screens viewed and buttons tapped;
installation attribution or source-related information;
device or other identifiers used for analytics and service performance.

We use this information to analyze product usage, fix bugs, monitor app performance, understand the user experience, improve the App, and measure the effectiveness of product changes. For clarity, analytics and diagnostics data collected through the App do not include the user’s physical device geolocation.

2. How We Use Information

We use the information described above to:

provide the core functionality of Neiry Pulse;
connect the App with compatible Neiry wristband hardware;
perform calibration of your personal HRV baseline;
calculate and display HRV, heart rate, sleep, and activity metrics;
generate personalized recommendations and wellness insights;
provide session history and progress tracking;
create and manage user accounts;
send essential service notifications (e.g., “Your personal baseline is ready”);
personalize parts of the user experience;
maintain security, integrity, and reliability of the App;
troubleshoot bugs, errors, and compatibility issues;
analyze usage and improve the App.

We do not use your data for selling data, cross-context behavioral advertising, or advertising-based profiling. When location permission is requested on supported Android versions, it is used solely to enable Bluetooth device discovery and connection as required by the operating system, and not to determine or use a user’s physical location.

3. Where Information Is Stored

3.1 Data stored locally on your device

The App stores certain data locally on your device in a local database (SQLite) to support offline functionality and reduce server roundtrips. This includes:

a buffer of recently received biometric data from the wristband, which is synchronized to our servers when network connectivity is available;
cached display values for current heart rate, recent HRV readings, and the current calibration progress;
your authentication tokens (JWT) for secure session management.

Locally stored biometric data is purged after successful synchronization with our servers.

3.2 Data stored on our servers

We store the following categories of data on our servers, located in the Russian Federation in compliance with Federal Law 152-FZ on personal data:

unique user ID;
name and email address;
date of birth or age group;
sex/gender;
height, weight, goals;
country or region, if provided by you;
preferred interface language;
wristband model and serial number;
raw R-R intervals (retained for the period specified in Section 6);
aggregated HRV and heart rate metrics;
personal HRV baseline value and history;
training session records, including GPS routes if collected;
sleep records;
composite stress metric values and recommendation history;
de-identified or pseudonymized interaction events used for analytics and product improvement.

Hosting infrastructure: Yandex Cloud (servers located in Moscow / St. Petersburg, Russian Federation).

We do not sell your personal data or health-related data.

We may share personal data or health-related data only in the following limited circumstances:

with service providers and processors acting on our behalf and only as necessary to provide, host, support, secure, and improve the App;
where required by applicable law, regulation, legal process, or enforceable governmental request;
to protect the rights, safety, security, or integrity of the operator, our users, or the public.

Wellness and fitness data are not shared with third parties for their own independent purposes, are never sold, and are not used for advertising or data-broker resale. Such data may be processed only by service providers acting on our behalf, or disclosed when required by law.

4.2 Third-party services and SDKs

We may use the following third-party tools and services:

Firebase (by Google LLC) — used for push notifications, crash reporting (Crashlytics), and analytics. Firebase may collect device identifiers, OS data, and interaction events. We do not use Firebase to collect or transmit device physical geolocation.
Sentry — used for crash and error reporting in the backend.
Yandex Cloud — used for hosting account data, settings, biometric data, session results, and related server-side information.
Veepoo SDK — used to enable communication between the App and Neiry wristband over Bluetooth. Communication with the wristband is local between your phone and the wristband; data is sent to our servers separately and not to Veepoo’s servers for independent use.

The App provides an opt-in feature that allows you to share your wellness and fitness metrics with a trusted contact (e.g., a family member or training partner) for informational purposes only. When you generate a QR code or invitation link for sharing, the recipient — once they scan or accept it — gains the ability to view your selected metrics inside their own Neiry Pulse app.

You retain full control:

you choose which metrics are shared;
you can revoke access at any time from in-app settings;
the recipient cannot modify your data or download it outside the App.

5. Security

We take reasonable technical and organizational measures to protect the information processed through the App. These measures include:

encryption in transit using TLS 1.3 for all client-server communication;
encryption at rest for data stored in our PostgreSQL databases hosted on Yandex Cloud;
role-based access controls;
audit logs for all access to wellness and fitness data;
pseudonymization of analytics events;
backups and infrastructure security measures provided by Yandex Cloud.

No method of electronic storage or transmission is completely secure. However, we take commercially reasonable steps designed to protect your information.

6. Data Retention

We retain data for as long as necessary to provide the App and its features, maintain your account, comply with legal obligations, resolve disputes, and enforce our agreements.

In general:

locally stored buffer data is purged after successful synchronization;
raw R-R intervals and IMU readings are retained on our servers for 90 days, after which they are aggregated into derived metrics and the raw data is deleted (this enables retroactive recalculation if our methodology changes within the retention window);
aggregated daily HRV values, baseline values, training sessions, sleep records, and recommendation history are retained while your account remains active;
analytics and diagnostics data may be retained as needed for product improvement, security, and operational purposes.

If your account is deactivated, we may retain your account data so that your account may be restored later if you choose to reactivate it.

If you request permanent deletion, we will permanently delete your account data and associated personal data within 30 days of receiving and verifying your request, except where retention is required by applicable law or necessary for security, fraud prevention, or similar legitimate purposes.

7. Account Deactivation and Permanent Deletion

7.1 Deactivation in the App

The App provides an in-app option to deactivate your account (Settings → Privacy → Deactivate Account). Deactivation is not the same as permanent deletion.

If you deactivate your account:

access to the account is disabled;
your data may remain stored so that the account can later be restored if you choose to reactivate it.

7.2 Permanent deletion request

If you want your personal data and associated account data to be permanently deleted, you may submit a deletion request:

In-app: Settings → Privacy → Delete Account Permanently
By email: privacy@neiry-bci.com

Subject line recommendation: Neiry Pulse — Permanent Data Deletion Request

Upon receiving and verifying your request, we will permanently delete your personal data and associated account data within 30 days, unless a longer retention period is required by law or for legitimate security or fraud-prevention reasons.

7.3 Deleting individual records

The App also allows you to delete specific records without deleting the entire account:

individual training sessions (with associated GPS data) — from the in-app history screen;
Health Sharing connections — from in-app Settings;
recommendation cards — from your in-app feed.

8. Your Choices

You may choose whether to:

create and use an account;
connect compatible Neiry wristband hardware;
grant permissions such as Bluetooth, notifications, and location access where required for core functionality;
enable or disable Health Sharing;
enable or disable training mode and GPS tracking;
deactivate your account in the App;
request permanent deletion of your account and associated data.

Please note that denying certain permissions or disconnecting compatible hardware may limit or prevent the App’s core functionality.

9. Permissions

Depending on your device and operating system version, the App may request permissions such as:

Bluetooth permissions (scan, connect, and related) to discover and communicate with Neiry wristband devices;
Approximate and/or precise location permissions on certain Android versions, solely where required by Android for Bluetooth scanning and discovery; these permissions are not used by the App to determine, collect, store, or transmit the user’s physical location (except in training mode with explicit user start);
Notification permissions to send service-related notifications (e.g., “Your personal baseline is ready”);
Health permissions (HealthKit on iOS, Google Fit on Android) — only if you explicitly opt in to sync your Pulse data with external health platforms (future release).

We request permissions only for functions relevant to the operation of the App.

10. Children’s Privacy

The App is intended for healthy adults aged 16 and older. The App is not intended for use by children under 16, by patients in clinical care, or for medical monitoring of any kind. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, please contact us immediately at the email provided in Section 12 and we will take steps to delete it.

11. International Processing

If you access the App from outside the Russian Federation, you understand that your information will be processed and stored on servers located in the Russian Federation in compliance with Federal Law 152-FZ on personal data.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated version on this page (https://pulse.neiry-bci.com/privacy-policy/) and update the “Last updated” date above. Your continued use of the App after the updated Privacy Policy becomes effective means that you accept the updated Policy.

13. Contact Us

If you have any questions about this Privacy Policy, our data practices, account deactivation, or permanent deletion requests, please contact us:

For App Store users (data controller — Konstantin Valeryevich Dvugroshev, private individual): Email: hello.solomono@gmail.com Address: Moscow, Vysokaya str., bldg. 20, apt. 41, Russian Federation

For Google Play users (data controller — LLC NMF “Neirotech” / ООО НМФ «Нейротех»): Email: privacy@neiry-bci.com Address: 347905, Rostov Region, Taganrog, Dzerzhinskogo str., 119-a, Russian Federation OGRN 1026102573419, INN 6154082572

General privacy inquiries: privacy@neiry-bci.com