Privacy Policy

Last updated: 18 DEC 2022

We value your privacy very highly. Please read this Privacy Policy carefully before using the Website (the “Website”) or Nomad Biometric App operated by both Belluscura, PLC, a(n) Public Limited Company formed in England, with a registration number of 09910883 and Belluscura LLC, a Delaware limited liability company (collectively, “us,” “we,” “our”) as this Privacy Policy contains important information regarding your privacy and how we may use the information we collect about you.

Website use

Your access to and use of the Website is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy applies to everyone, including, but not limited to: visitors, users, and others, who wish to access or use the Website.

By accessing or using the Website, you agree to be bound by this Privacy Policy. If you disagree with any part of the Privacy Policy, then you do not have our permission to access or use the Website.

What information we collect, where we get this information, how we use this information, what happens if we don’t have it, and the legal basis for processing this information. 

We collect any and all information that you enter on this Website. We collect the following information about you:

  • Name
  • Phone number
  • IP address
  • Email address
  • Internet or other electronic activity
  • Information regarding your interaction with our website or application.

With whom we share your information

We share your personal information with the following categories of third parties for the following reasons:

  • Government or law enforcement agencies
  • Email marketing vendors
  • Customer management systems
  • Data analytics providers.

How we protect your information

We have implemented the following measures to protect and safeguard your personal information:

  • Limiting the amount of personal information that we collect to strictly necessary only;
  • Using ssl or other secure connection technologies when receiving or sending personal information beyond internal networks;
  • Destroying the personal information that we no longer need;
  • Performing regular risk assessments;
  • Mitigating risks by following a risk treatment plan;
  • Having comprehensive security policies and procedures;
  • Screening all employees with access to personal information;
  • Training our employees;
  • Requiring our employees to sign confidentiality agreements;
  • Implementing and monitoring intrusion prevention and detection systems;
  • Maintaining up-to-date software and safeguards;
  • Performing regular due diligence of vendors;
  • Implementing physical security measures;
  • Physically and/or logically separating systems containing personal information from public networks such as the internet.

Sale of your information

We do not sell your personal information. Nevada residents – if you would like to opt out of future sales, please contact us at


A cookie is a small piece of data sent from a website and stored on your computer by your web browser. The file is added once you agree to store cookies on your computer or device, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow sites to respond to you as an individual. The Website can also tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

This Website collects cookies and may use cookies for reasons including, but not limited to:

  • Analyze our web traffic using an analytics package;
  • Identify if you are signed in to the Website;
  • Test content on the Website;
  • Store information about your preferences;
  • Recognize when you return to the Website.

Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This setting may prevent you from taking full advantage of the Website.

Children’s privacy

This Website is intended for use by a general audience and does not offer services to children. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond to that child to inform him or her that they cannot use this Website.

Analytics programs

This Website uses Google Analytics to collect information about you and your behaviors. If you would like to opt out of Google Analytics, please visit

Information retention

We retain all of the information that we collect until the dispute or product has reached its expected life.

Direct marketing

We use the information that we collect about you for direct marketing purposes. Direct marketing is the act of selling products or services directly to consumers rather than through retailers. You may, at any time, request that we cease to use your information for direct marketing purposes by emailing us at

Your rights

All visitors or users of this website have the following rights with regard to their personal information:

  1. The right to access your information.
  2. The right to say no to the sale of your personal information.
  3. The right to request that we delete all or some of the personal information that we have collected on you.
  4. The right to ask us to transmit your personal information that we have collected on you to another provider (where technically feasible).
  5. Rectification of information: the right to request that we amend any of the information that we have collected about you.
  6. The right to withdraw your consent to the processing of your data.
  7. The right to request that we restrict the processing of your data.
  8. The right to lodge a complaint regarding our collection, sharing and processing of data with competent authorities in the proper jurisdiction.
  9. The right to lodge a complaint regarding our collection, sharing and processing of data with the Information Commissioner’s Office or any other competent authority.
  10. The right to stop receiving unwarranted direct marketing.

Exercising your rights

You may exercise the rights specified above by submitting a consumer request to the person accountable for our privacy practices and policies, whose contact information is below.

We will need to verify your identity prior to effectuating your request. To verify your identity, you will need to provide us with the following information with your request:

  • Name;
  • Phone number;
  • Email address.

Please note that we may be unable to process your request if you do not provide us with the above information.

We will respond to most consumer requests within 30 days of receipt. However, some requests may take longer. We will notify you in writing if we need more time to respond (up to an additional 30 days). We have the ability to deny your request(s) if certain exceptions in the law apply. If we do deny your request(s), we will provide you with the reasons for such denials.


The following person is accountable and responsible for our privacy practices and procedures:

Paul Bray
Chief Compliance Officer
(214) 396-8313

You may lodge a complaint with us by contacting the person accountable and responsible for our privacy practices and procedures at the contact information above. You may also lodge a complaint with the Office of the Privacy Commissioner of Canada by filling out this form or calling 1-800-282-1376.

Location of data processing

All data processing activities undertaken by us take place in United States, United Kingdom.

Data Protection Officer

Paul Bray is our Data Protection Officer and may be reached via email at

Third-party websites

This Website may contain hyperlinks to websites operated by parties other than us. We provide such hyperlinks for your reference only. We do not control such websites and are not responsible for their contents or the privacy or other practices of such websites. It is up to you to read and fully understand their Privacy Policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.

Do Not Track

Do Not Track is a preference you can set on your browser to inform websites that you do not want to be tracked. We do not support Do Not Track (“DNT”). You can either enable or disable Do Not Track by visiting the Preferences or Settings page of your browser.

Transferring Data

We plan to transfer data to United States. This means that your information may be processed in a country outside of Canada and it may be accessible to law enforcement authorities and national security authorities of that country and jurisdiction.

NOMAD Biometrics App use

Belluscura provides this Privacy Notice to explain how we process personal data when you use the NOMAD BIOMETRIC™ mobile application and any of the data processing or storage features associated with this App (“services”). (“NOMAD”). Only patients who have downloaded and affirmatively agreed to the collection and management of data may authorize individual healthcare professionals to use the services. We use the term “personal data” or “personal information” to mean any information relating to an identified or identifiable natural person. This Privacy Notice also provides information about rights you may have under applicable privacy laws.

If you are located in the European Economic Area, United Kingdom, Switzerland or Turkey, “Belluscura” refers to Belluscura plc. If you are located in other jurisdictions, “Belluscura” refers to Belluscura LLC.

The Nomad Biometric App is not available yet in the European Economic Area, United Kingdom, Switzerland or Turkey. When it becomes available, please refer to the corresponding Jurisdiction-Specific Disclosures further below for additional information we are required to provide to you under your local laws.

If you are located in Singapore, Hong Kong or Japan, the NOMAD is not available yet.  When it becomes available please refer to the corresponding Jurisdiction-Specific Disclosures at the end of this General Privacy Notice

What types of personal data do we collect?

We collect the following types of personal information about patients who use the Nomad Biometric App, which we have grouped together as follows:

  • Registration Information: We ask you to provide information to register for and activate the Nomad Biometric App. This includes your name, phone number, email address, age, date of birth and gender.
  • Third-Party Contact Information: We may ask you to choose certain settings within Nomad Biometric App. This includes the names of third parties to whom you wish to disclose your information (g., healthcare professionals, friends, family, or any other third party you have designated to receive your data to help care for you) and their contact information (e.g., telephone numbers and email addresses).
  • Device Information: This is information collected from the Belluscura device and any other devices you connect with Nomad Biometric App, including information about your mobile device or computer (g., IP address, login credentials) and the type of Belluscura device used to capture your data.
  • Usage Information: This is information about how you use Nomad Biometric App when you are logged into Nomad Biometric App. With your consent as provided within the mobile application, we also collect your geolocation information.
  • Health Information: This is information about your physical activity and health (the categories of data collected depend on the type of device used to capture your data and may include oxygen saturation, respiration rate, perfusion index, pulse rate, Pleth Variability Index, temperature, and current/past trends regarding these metrics).

If you are a patient, please obtain the consent of your contacts before inputting their personal data into Nomad Biometric App.

We refer to the above groups of personal information by their respective sub-heading (e.g., Registration Information) throughout this Privacy Notice.

From what sources do we collect personal data?

If you are a patient, we collect Registration Information, Device Information, Usage Information and Third-Party Contact Information directly from you. We also collect Health Information from(i) medical devices that you connect with Nomad Biometric App, (ii) other applications such as Apple Health and FitBit that you connect with Nomad Biometric App, and (iii) hospitals and other healthcare providers if you have given them your consent to transfer your personal data to us.

For what purposes do we use personal data?

We use all of the categories of personal data we collect as necessary to:

  • Provide you with Nomad Biometric App and manage your relationship with us;
  • Respond to or fulfill your requests;
  • Ensure the security of our services;
  • Analyze the performance of, troubleshoot issues with our product and services;
  • Analysis of raw technical and hardware device data for research, development, algorithms and statistical purposes in order to improve user experience, services, usability and effectiveness, and to develop new features for both the Nomad Biometric App product and new products;
  • Exercise our legal rights, including to defend against claims and advance our legal interests, protect against fraudulent, harmful and illegal activity; and
  • Comply with applicable laws such as data protection and consumer laws.

In addition, if we take steps to enter into a reorganization, restructuring, merger, acquisition or transfer of assets (“Business Transfer”), we may also use your personal information to give effect to that Business Transfer.

To whom do we disclose, share or transfer personal data?

Personal data of patients who use Nomad Biometric App may be disclosed, shared or transferred to:

(i)       healthcare professionals whom your healthcare provider has authorized with your consent to access and download your personal data for the purposes of managing your care and conditions. Once authorized by you, these healthcare professionals and healthcare providers will have the option to locally download and access your personal data without the use of Nomad Biometric App; and

(ii)      third parties selected by you with whom you wish to share your personal data. If you designate a contact to receive your personal data, we may disclose your personal data to that contact until you remove them as a contact in the mobile application or deactivate your Nomad Biometric App account.

Personal data of healthcare professionals who use Nomad Biometric App may be disclosed to the hospital or other healthcare provider that supervises you for the purposes of administering your healthcare provider’s use of Nomad Biometric App.

Whether you are a patient or healthcare professional, your personal data may be disclosed, shared or transferred to employees and affiliated and unaffiliated processors (i.e., service providers) of Belluscura that develop, operate and support Nomad Biometric App.

In the event of a Business Transfer, we may transfer personal information to the acquiring or surviving entity in accordance with applicable law.

How long do we store personal data?

In general, we store personal data only as long as necessary to fulfil the purpose for which we collected it (the “General Retention Period”), except in the following situations: (1) where applicable laws require us to retain your personal data for a legally prescribed period beyond the General Retention Period. In these cases, we will keep that personal data for the legally prescribed time period before deleting it; (2) where your personal data is relevant to potential legal claim(s) by or against us. In these cases, we will keep that personal data for as long as the legal claim(s) can be made or, if it has been made, for as long as the personal data is relevant to the resolution of the claim(s) or any appeal thereto; (3) if we are instructed by a court order, subpoena, or other legal directive to retain your personal data; and (4) we will retain your personal data for a reasonable period of time necessary for us to verify the purposes for which we collected your data no longer apply and to delete the data following such verification.  If any of these exceptions apply to certain personal data, we will retain personal data for as long as the exception applies. For additional information about how long we retain your personal data specifically, please email

How do we protect personal data?

We have taken steps intended to protect the personal data we collect from loss, misuse, and unauthorized processing, including entering into data protection agreements with our service providers and encrypting personal data in transit and at rest. Please note, however, that while we have endeavored to create a secure and reliable online experience for users, the confidentiality or accuracy of any communication or material transmitted to or from us over the Internet cannot be guaranteed. It is your responsibility to safeguard the username and password that you use to access Nomad Biometric App, and to notify us immediately at the contact information below if you ever suspect that your username or password has been compromised.


We only collect personal data about children with the consent of their parent or legal guardian. You must be at least 18 years of age to use Nomad Biometric App. Children may only use Belluscura’s hardware products on the instructions, under the supervision, and with the consent, of their healthcare providers and parent or legal guardian.

Your Rights

You may have rights under applicable privacy laws, which may include to access, review, modify or delete the personal data we hold about you, and to access a copy of any privacy-related consent you have given to us.

To submit a request to exercise any rights you may have under applicable privacy laws, please contact us at and clearly describe your request. If you have rights under applicable privacy laws and your request complies with the requirements under such laws, we will give effect to your rights and respond within any mandatory timeframes as required by law.

Effect of this Privacy Notice; Changes

This Privacy Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may revise this Privacy Notice from time to time by making the revised document available through Nomad Biometric App and updating the “last updated” date above. We will also obtain consent from you where required by applicable law before processing your personal information for any purpose incompatible with the purposes set forth in prior versions of this Privacy Notice.

Contact Us

If you have any privacy-related inquiries or concerns, please contact our privacy department at

Changes to Privacy Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you of any changes to this Privacy Policy by posting the updated privacy policy to this website.


If you have any questions about this Privacy Policy, please contact us at