PART ONE: INTRODUCTION
PROMEDIX HEALTH OPERATES THE THAD CONNECT APP. WE VALUE YOUR PRIVACY AND WE ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF HELPING YOU IMPROVE YOUR HEALTH OR HELPING YOU IMPROVE THE HEALTH OF ANOTHER BY OFFERING A CONVENIENT AND SECURE MOBILE APP AND WEB SITE WITH TOOLS THAT ALLOW USERS TO MONITOR AND REMOTELY TRANSMIT PATIENT-GENERATED HEALTH DATA.
THIS PRIVACY POLICY APPLIES TO PERSONAL DATA THAT PROMEDIX HEALTH COLLECTS FROM USERS OF PROMEDIX HEALTH’S APP AND WEB SITE (COLLECTIVELY, THE “APP”)]. “PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR IN COMBINATION WITH OTHER INFORMATION TO IDENTIFY OR CONTACT ONE OF OUR USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL DATA IS OF UTMOST IMPORTANCE. IN THIS PRIVACY POLICY (THE “POLICY”), WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL DATA.
Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. For the purposes of Applicable Data Protection Laws, including the European Economic Area data protection law, (the “Data Protection Law”), the data controller is:
ProMedix Health.
4590 MacArthur
Blvd., Suite 500
Newport Beach, CA
92660
BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS APP, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE APP AND PLEASE DO NOT SUBMIT ANY PERSONAL DATA TO US.
PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE POLICY, WE WILL POST THE UPDATED POLICY ON OUR WEBSITE. YOU MAY STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT THE POLICY, OR SAVE IT. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE APP FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.PART TWO: PRIVACY POLICY SUMMARY
For your convenience, we have summarized the key points from our Privacy Policy below.
ProMedix Health as Responsible Entity/Controller
ProMedix Health. (“We”, “Us”, “the Company”, or “ProMedix Health”) is the controller of your Personal Data (as defined below), and we may process this data in accordance with our Privacy Policy. If we are processing Personal Data on behalf of a third party, the terms of this Privacy Policy do not apply; instead, the terms of that third party’s privacy policy will apply. If you leave our App via a link to a third party, we are no longer the controller, and you will be subject to that party’s Privacy Policy. You may contact us with any questions about our Privacy Policy at compliance@promedixhealth.com. You may reach our Data Protection Officer at compliance@promedixhealth.com
What information do We collect and why?
We collect “PERSONAL DATA”, which includes any information that can be used on its own or in combination with other information to identify or contact one of our users. For a description of the types of personal data we collect, please review this section in the full Privacy Policy. In some cases, this Personal Data may be or may include “protected health information”. Personal Data does not include any information posted or shared via a public forum.
We may use Personal Data to (1) communicate with you about and manage your User Account; (2) store data; (3) comply with the law; (4) respond to requests from public and government authorities; (5) enforce our terms and conditions; (6) manage and improve our operations and App; (7) provide additional functionality; (7) protect our rights, privacy, safety or property, and/or that of you or others; and (8) allow us to pursue available remedies or limit the damages that we may sustain.
We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described above (and in the full Privacy Policy). Where required by law, we will ask for your prior consent before doing so.
Failure to Provide Data. Providing your Personal Data is not statutorily or contractually mandated. However, if you choose not to provide this information, we cannot create a User Account, and you will be unable to use our Services.
Will We share your Personal Data with anyone else?
· Yes, with any individual with whom you choose to connect via the App (e.g., a caregiver or spouse)
· Yes, with third parties that help us power our App
· Yes, with third parties and the government when legal or enforcement issues arise
· Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of ProMedix Health’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We may, from time to time, rent or sell aggregated data and/or other information that does not contain any personal identifiers (i.e., if the information has been anonymized by stripping out identifiers such as name, address, phone number, etc.). The purpose of this type of disclosure is to provide healthcare professionals, research institutions, and other interested parties (e.g., pharmaceutical and/or device manufacturers) real world information about the usefulness of the data.
Where is your Personal Data stored, transmitted and/or maintained?
Personal Data that ProMedix Health collects through the App will be stored on secure third-party cloud servers. Personal Data may be transmitted to third parties; those third parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the United States.
How long will We maintain your information?
We store your Personal Data for as long as you maintain a User Account and up to 30 days after the account is closed.
How do We protect your Personal Data?
ProMedix Health uses a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot absolutely ensure the security of information you transmit to us. By using the App, you are assuming this risk. For more information on the safeguards
Your Rights
You have certain rights relating to your Personal Data, subject to local data protection laws. These rights may include the right to:
· access your Personal Data held by us
· erase/delete your Personal Data, to the extent permitted by applicable data protection laws
· receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;
· restrict the processing of your Personal Data to the extent permitted by law (while we verify or investigate your concerns with this information, for example);
· object to the further processing of your Personal Data, including the right to object to marketing;
· request that your Personal Data be transferred to a third party, if possible;
· receive your Personal Data in a structured, commonly used and machine-readable format
· lodge a complaint with a supervisory authority
· rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete
· not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”); and
· withdraw your consent at any time (to the extent we base the collection, processing and sharing of your Personal Data on your consent) without affecting the lawfulness of the processing based on such consent before its withdrawal.
How can you contact us with questions or concerns?
If you have any questions about this Privacy Policy, please contact us by email at compliance@promedixhealth.com or please write to:
ProMedix Health.
4590 MacArthur
Blvd., Suite 500
Newport Beach, CA
92660
Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.