Privacy Policy

Effective Date: 8.19.2022

This Privacy Policy for the HeartScan mobile application ("HeartScan," "we," "us," or "our"), describes our privacy practices as well as how and why we might collect, store, use, and/or share ("process") your information when you use our mobile application HeartScan (the "App").

This Policy applies only to information we collect in the App, email, text, and other e-communications sent by you through or in connection with the App.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using the App, you agree to this privacy policy.

Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our App. If you still have any questions or concerns, please contact us at support@heartscan.app.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics in the relevant section below.

What Personal Data do we process? When you visit and use our App, we may process Personal Data depending on how you interact with the App, the choices you make, and the products and features you use.
Do we process any sensitive Personal Data? We process sensitive Personal Data related to health with full compliance with the law.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our App, conduct medical research, communicate with you, for security issues, and to comply with the applicable law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share Personal Data? We may share information in specific situations and with specific third parties.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your Personal Data. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, and or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your Personal Data.
How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

We collect information from and about users of the App:

directly from you when you provide it to us;
automatically when you use the App;
from third parties, for example, our scientific and research partners such as medical universities and institutions, and other third parties that help us provide our products and services to you.

The Personal Data You Provide to Us

In Short: We collect Personal Data that you provide to us.

We collect Personal Data that you voluntarily provide to us when you register on the App, express an interest in obtaining information about us or our apps, when you participate in activities on the App, or otherwise when you contact us.

Contact Information. The Personal Data that we collect depends on the context of your interactions with us and the App, the choices you make, and the products and features you use. The Personal Data we collect may include the following:

user name
email address

Sensitive Information Related to Health. We process sensitive information in strict compliance with data protection laws. This information is processed by our service to produce results and recommendations. Without the processing of this information, our in-app services will not be available. This information includes heart activity measurements on your device. This data is stored locally and can only be transmitted for further processing with your consent.

Automatic Information Collection and Tracking

When you download, access, and use the App, it may use technology to automatically collect:

Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, logs, and other communication data, date/time stamps associated with your usage, device event information (such as system activity, error reports, hardware settings), and features that you access and use on or through the App.
Device Information. We may collect information about your mobile device and internet connection, including the device's unique identifier, IP address, operating system, and network information.
Location Information. This App does not collect real-time information about the location of your device. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. This information is processed for the purpose of determining service availability in your location and applicable laws.

Aggregated and De-identified Data

Subject to applicable law, including but not limited to our obligations under the GDPR, we may license, sell, or otherwise share aggregated, de-identified versions of your data and other data ("De-identified Information") with our subsidiaries, affiliates, partners, customers, investors, providers, and contractors for any purpose. You agree and acknowledge that HeartScan is the sole and exclusive owner of any De-identified Information created by HeartScan and that you have no ownership or other intellectual property rights in or to such De-identified Information. This De-identified Information can also be included in the machine learning model on the basis of which our service operates.

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

analytics companies;
your mobile device manufacturer;
your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal data or they may collect information, including sensitive data, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Third-party Applications/Websites

We do not control the privacy practices of websites or applications that we do not own. Users are encouraged to read the privacy policy of those properties to make an informed decision regarding their use of them.

Google Analytics: https://policies.google.com/privacy
Firebase: https://policies.google.com/privacy
RevenueCat: https://www.revenuecat.com/privacy/

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our App, communicate with you, for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your Personal Data for a variety of reasons, depending on how you interact with our App, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To conduct scientific research. We may process or share with medical institutions your depersonalized (fully anonymized) information for conducting scientific research, building data sets, and machine learning models.
To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To request feedback. We may process your information when necessary to request feedback and contact you about your use of our App.
To protect our App. We may process your information as part of our efforts to keep our App safe and secure, including fraud monitoring and prevention.
To evaluate and improve our App, products, services, and your experience. We may process your information when we believe it is necessary to identify usage trends and evaluate and improve our App, products, services, and your experience.
To identify usage trends. We may process information about how you use our App to better understand how they are being used so we can improve them.
Notify you when App updates are available, and of changes to any products or services we offer or provide through it.
To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

Our legal basis for processing

Our legal basis for processing your Personal Data will typically be one of the following:

Consent. You have actively consented for us to process data, including sensitive personal data, by completing a form on the App, or have indicated your consent with another affirmative act.
Legitimate interests. We have a Legitimate Interest in processing your personal data, and our reasons for it do not override your data protection rights. Our Legitimate Interests in processing your Personal Data are:
- to ensure our services meet the high standard of usability and security you would expect;
- to help us identify areas for improvement;
- to enable us to communicate effectively regarding our services; and
- to enable us to process queries or complaints.
Legal obligation. It is necessary for us to process your Personal Data for us to comply with our legal or regulatory obligations.
Contractual obligation. It is necessary for us to process your Personal Data to perform the tasks associated with a contract to which you are a party, or to take steps at your request prior to you entering into a contract.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may share your information with selected third parties including but not limited to:

Business partners, suppliers, service providers, and sub-contractors for the performance of any contract we enter into with you.
Local councils and clinics with which we collaborate to advise and support them in the delivery of their public health function, but only in an anonymized manner with your consent. This transfer of your data is subject to an obligation of secrecy under applicable law or rules established by national competent bodies.
Analytics and research medical institutions that assist us in the improvement and optimization of our App and that conduct medical research.

We may disclose your Personal Data to third parties:

If HeartScan or substantially all of its assets are transferred to a third-party organization, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of HeartScan, our customers, or others.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. This section describes our use of these technologies and how you can manage your preferences.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your Personal Data through a system of organizational and technical security measures.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your Personal Data at any time.

8. MINORS

In Short: We do not knowingly use children's Personal Data in any manner.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

In Short: We currently do not honor do-not-track signals sent by some browsers.

10. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

In Short: Yes, we will update this Privacy Policy as necessary to stay compliant with relevant laws.

11. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If you have questions or comments about this Privacy Policy, you may email us at support@heartscan.app

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the Personal Data we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your Personal Data, please email us at support@heartscan.app or use app features (if available).