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.
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
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
Blvd., Suite 500
Newport Beach, CA
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
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
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
For your convenience, we have summarized the key points from our
ProMedix Health as Responsible Entity/Controller
(“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
link to a third party, we are no longer the controller, and you will be subject
our Data Protection Officer at firstname.lastname@example.org
What information do We collect and why?
“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
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
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
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
· 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
Where is your Personal Data stored, transmitted
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?
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
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
· 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
Blvd., Suite 500
Newport Beach, CA
Please note that email communications are not
always secure; so please do not include sensitive information in your emails to