Privacy Policy

PupiLUX by R.Tej Health Analytics

Last updated: 23 March 2026

PupiLUX ("the App") is a smartphone-based pupillometry tool designed for use by qualified medical professionals. It is developed and published by R.Tej Health Analytics ("we," "us," or "our"), with its registered office at A-125 New Friends Colony, New Delhi 110025, India. We are committed to protecting your privacy. This policy explains what data we collect, how we use it, and your rights.

1. On-Device Processing

All pupil analysis — including video capture, pupil detection, metric computation, and report generation — happens entirely on your device. No images, video frames, or biometric data are ever transmitted to our servers or any third party. Camera frames are processed locally using Apple's Vision framework and on-device CoreML models, and are discarded after analysis is complete.

2. What Data We Collect

When you use PupiLUX with data sharing enabled, we collect only anonymized, non-identifiable metrics transmitted to our servers:

• Device hash — a one-way cryptographic hash of your device identifier used solely for credit management. We cannot reverse this to identify you or your device.
• Test metrics — numerical pupillometry measurements (e.g., constriction velocity, latency, dilation velocity, pupil diameters). These contain no patient-identifiable information.
• Device model and OS version — to ensure compatibility and quality across hardware.
• Credit balance and purchase records — to manage your prepaid test credits. Purchase transactions are processed by Apple through the App Store; we receive only a transaction receipt, not your payment details.

3. No Personally Identifiable Information (PII)

PupiLUX does not collect, transmit, or store:

• Patient names, dates of birth, or medical record numbers
• Biometric images or video (pupil recordings are processed on-device and never uploaded)
• GPS or precise location data
• IP addresses beyond what is incidentally logged by our hosting infrastructure
• Browsing history or activity outside the App
• Any data that could identify a specific patient or the administering clinician

4. How We Use Your Data

The anonymized data we collect is used exclusively for:

• Credit management — verifying and deducting test credits associated with your device.
• Normative reference ranges — aggregating anonymized measurements to build and improve population-level reference data for pupillometry.
• App improvement — understanding usage patterns to improve accuracy, reliability, and user experience.

We do not use any collected data for advertising, marketing, behavioural profiling, use-based data mining, or any purpose other than those listed above.

5. Third-Party Sharing

We do not share, sell, rent, or trade your data with any third party. We do not use any third-party analytics, advertising, or tracking SDKs.

Our servers are hosted on Vercel (infrastructure provider) with a Neon Postgres database. These providers process data on our behalf under data processing agreements and do not have independent access to or use of your data.

Anonymized, aggregated metrics may be used in peer-reviewed research publications, but individual data points are never disclosed in a way that could identify a device, clinician, or patient.

6. Apple and In-App Purchases

Credit purchases are processed by Apple through the App Store. Apple's privacy policy governs the data Apple collects during these transactions. We receive only a transaction receipt confirming your purchase — we do not receive your name, Apple ID, or payment information.

7. Data Retention

Server-side: Anonymized test metrics (sent only with your opt-in consent) are retained indefinitely for the purpose of building normative reference ranges. Device hashes and credit balances are retained as long as the device has an active credit account.

On-device: Test results, session recordings, reports, and any locally stored data are entirely under your control. You can delete them at any time through the App. Uninstalling the App removes all local data.

8. Your Rights and Data Deletion

You may exercise any of the following rights at any time by contacting us at info@pupilux.ai:

• Access: Request a copy of any data associated with your device hash.
• Deletion: Request deletion of all server-side data associated with your device, including credit balances and anonymized metrics. We will process deletion requests within 30 days.
• Opt out: Disable anonymized data sharing at any time through the App settings. Opting out does not affect credit functionality.
• Withdraw consent: Revoke any previously granted consent by contacting us. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

9. International Data Transfers

Our servers are located in the United States (Vercel / Neon). If you use the App from outside the United States, your anonymized data may be transferred to and processed in the United States. By using the App with data sharing enabled, you consent to this transfer. We ensure that all transferred data is protected by appropriate safeguards consistent with applicable data protection laws.

If you are located in the European Economic Area (EEA), United Kingdom, or any jurisdiction with data protection laws providing equivalent rights, you retain all rights described in Section 8 above and may lodge a complaint with your local data protection authority.

10. Children's Privacy

PupiLUX is intended for use by qualified medical professionals and is rated 17+ on the App Store. We do not knowingly collect data from individuals under the age of 17. If you believe that a minor has provided us with data, please contact us at info@pupilux.ai and we will promptly delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Your continued use of the App after any changes constitutes acceptance of the revised policy. We encourage you to review this page periodically.

12. Contact

If you have questions about this privacy policy or your data, please contact us:

Email: info@pupilux.ai
Company: R.Tej Health Analytics
Address: A-125 New Friends Colony, New Delhi 110025, India