Atlas App Consent & Data Practices

1. What Atlas Is

Atlas is a wellness and behavior tracking application developed by Nira Health to help parents and caregivers observe, log, and understand patterns in their child's behavior, mood, sleep, and focus over time.

Atlas is not a medical service and does not constitute clinical care. It does not provide diagnoses, prescribe treatments, or replace consultation with a licensed healthcare provider. Use of Atlas does not create a patient-provider relationship between the user and Nira Health or any of its clinical staff.

Atlas is designed as a tool to help families gather meaningful observations before and during engagement with clinical care — not as a substitute for it. If you have concerns about your child's health or safety, please contact a qualified healthcare provider.

2. Data Collected by Atlas

The Atlas application may collect the following categories of data, all of which are entered or approved by a parent or guardian:

• Behavior patterns: Parent-reported observations about mood, emotional regulation, social interactions, and behavioral events
• Sleep data: Duration, quality ratings, and sleep schedule information reported by the parent or caregiver
• Focus tracking: Observations about attention span, task completion, and concentration logged during school or home activities
• Parent-reported observations: Free-form notes, daily logs, and responses to structured check-in prompts
• Account and contact information: Parent or guardian name, email address, and child's first name and date of birth

Atlas does not collect biometric data directly from the child and does not interface with wearable devices or third-party health sensors.

3. COPPA Compliance — Children Under 13

Atlas complies with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information directly from children under the age of 13. All data entered into Atlas about a child is entered by and under the control of a parent or legal guardian.

If you believe we have inadvertently collected personal information directly from a child under 13 without proper parental consent, please contact us immediately at info@nira-health.com and we will promptly delete such information.

4. Parental Consent Required for All Minor Users Ages 5–17

Consistent with our clinical services, parental or legal guardian consent is required for all Atlas users between the ages of 5 and 17. By creating an Atlas account for a minor, the consenting adult confirms that they are the child's parent or legal guardian and have authority to consent to the collection and use of data about the minor as described in this policy.

Minors may not create Atlas accounts independently. If you become aware that a minor has accessed or enrolled in Atlas without parental consent, contact us at info@nira-health.com.

5. How Atlas Data May Be Used If Transitioning to Nira Clinical Care

If you choose to enroll your child in Nira Health's clinical services after using Atlas, your Atlas data may potentially be used to inform your child's clinical care — but only under the following conditions:

• You provide explicit, written authorization during the clinical enrollment process
• The clinical care team reviews and determines the data is clinically relevant
• The data is incorporated into your child's clinical record only with your documented consent

You may choose not to share Atlas data with your Nira Health care team. This choice will not affect your child's eligibility for clinical services. Enrollment in Atlas does not automatically enroll your child in clinical care, and a separate clinical intake and consent process is required.

6. Data Sharing

Nira Health does not sell your child's Atlas data to third parties under any circumstances.

Atlas data may be shared only in the following limited circumstances:

• With your Nira Health care team: Only with your explicit written consent, as described in Section 5
• With service providers: Technology vendors who operate the Atlas platform infrastructure under contractual data protection obligations (e.g., hosting, analytics). These vendors are prohibited from using the data for their own purposes.
• As required by law: If compelled by a valid legal process, court order, or to protect the safety of a child

Atlas data is never shared with advertisers, insurance companies, employers, or data brokers.

7. Your Rights

As the parent or legal guardian of an Atlas user, you have the following rights regarding data collected through the app:

• Right to Access: You may request a copy of all data collected about your child through Atlas
• Right to Correct: You may request correction of any inaccurate data in your child's Atlas record
• Right to Delete: You may request deletion of your child's Atlas data at any time
• Right to Withdraw Consent: You may withdraw consent to data collection at any time by deleting your account or contacting us

8. How to Withdraw Consent and Request Data Deletion

You may withdraw your consent to the collection and use of your child's Atlas data at any time. To do so:

• Delete your Atlas account through the app settings, or
• Email info@nira-health.com with the subject line "Atlas Data Deletion Request" and include your name and your child's first name

Upon receiving a valid deletion request, Nira Health will delete your child's Atlas data within 30 days, except where retention is required by applicable law or to protect legitimate legal interests. We will confirm in writing when deletion is complete.

Please note: if your child is currently enrolled in Nira Health clinical services, deletion of Atlas data does not affect separately maintained clinical health records, which are governed by our Privacy Policy and applicable healthcare law.