Effective Date: 8.19.2022
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.
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.
We collect information from and about users of the App:
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:
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.
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.
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.
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:
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.
We do not control these third parties tracking technologies or how they may be used and we do not monitor your interactions with third parties. Any interactions you have with third parties are solely your responsibility. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers.
We process your Personal Data for a variety of reasons, depending on how you interact with our App, including:
While using the App, we do not make any automated decisions about you. The App and our services can analyze your data received from device sensors and build on it the definitions of the data that you manage on your own. This data is not transferred to third parties; you can do so by voluntarily sharing your data with such a third party.
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:
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.
Our service may use machine learning to process De-identified Information such as records with results of measurements, RAW sensor data, errors, crashes, reports, and other data to provide and improve the App and available service, including improving forecasting and optimization models and models recommendations accuracy provided by the App.
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:
We may disclose your Personal Data to third parties:
If we use or share your data differently than we have listed above, we will ask your permission when we collect the Personal Data.
HeartScan are for users located within the European Economic Area (EEA). If you choose to use the App from outside the EEA, you may also be transferring your Personal Data outside the EEA. This means that the laws around data collection may be different from EEA laws. We may also transfer your Personal Data from the EEA to other countries or regions. By giving any information on our App, including your Personal Data, you consent to these actions.
The technologies we use for automatic information collection may include:
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize such information or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your Personal Data through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Data we process. However, despite our safeguards and efforts to secure your information, 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, or modify your information. Although we will do our best to protect your Personal Data, the transmission of Personal Data to and from our App is at your own risk. You should only access the App within a secure environment (mobile device).
All information you provide to us is stored on secure servers held in both the European Economic Area (EEA) and GDPR-compliant international data processors only. Where international data processors are used, all appropriate technical and legal safeguards will be put in place to ensure that you are afforded the same level of protection as within the EEA.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
In Short: You may review, change, or terminate your Personal Data at any time.
If you are located in the EEA or UK and you believe we are unlawfully processing your Personal Data, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Applicable data protection laws may provide you with certain rights with regard to our processing of your Personal Data.
Access and Update. You can review and change your Personal Data by logging into the App and visiting the edit profile page (if applicable). You may also request access and notify us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. Please note that we may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have retained it as permitted by law.
Portability. To the extent the Personal Data you provide HeartScan is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used, and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account and deleting the App. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data. Please note, that the De-identified Information used to train and build the machine learning model will indirectly use the De-identified Information you gave us. We can exclude them only to the extent technically possible.
Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups and machine learning models.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods below and through the live chat feature of our Websites. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
If you would at any time like to review or change the information in your account or terminate your account, you can delete your account via the App or contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at email@example.com.
Access to information
The data protection legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the applicable laws.
In Short: We do not knowingly use children’s Personal Data in any manner.
The App is not intended for persons under 18 years of age, and we do not knowingly collect information from persons under 18 without verification of parental consent. If we learn we have collected or received information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at firstname.lastname@example.org.
In Short: We currently do not honor do-not-track signals sent by some browsers.
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 email@example.com or use app features (if available).
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