Sense.ly Privacy Policy

Effective Date: October 1st, 2013 PLEASE NOTE THAT THE SITE, MOBILE APP AND SERVICES ARE IN BETA RELEASE AND, THUS, THEIR FEATURES ARE SUBJECT TO CHANGE. WE MAY REVISE AND CHANGE THIS PRIVACY POLICY AND THE WAYS IN WHICH WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION AS WE AMEND THE SITE, MOBILE APP AND SERVICE. PLEASE CHECK BACK HERE FREQUENTLY TO REVIEW THE LATEST VERSION OF THIS PRIVACY POLICY. Sense.ly Inc. (“Sense.ly,” 'we' or 'us') values your privacy. Sense.ly offers avatar-based, speech enabled monitoring of chronic diseases and other conditions (the 'Services'). This Privacy Policy applies to our website the www.sense.ly (the 'Site') and the Services, which are accessible through the Sense.ly portal at https://beta.sense.ly, the Sense.ly mobile applications (collectively, the 'App'), and via other mobile devices (e.g., tablets and smartphones). Our Services are intended to give medical professionals and health care staff (“Clinicians”) the ability monitor, assess and collect certain medical information about their clients and patients ('Patients'). In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our Site, users of our mobile Application, and other users of our Services. By visiting the Site, using or downloading the App, or using our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site, App and Services, and any dispute over privacy, is subject to this Policy and our Terms of Service[link to], including its applicable limitations on damages and the resolution of disputes. The Sense.ly Terms of Service are incorporated by reference into this Policy. What Information Do We Collect About You and Why? How We Use Your Information How We Share Your Information Our Use of Cookies and Other Tracking Mechanisms Third-Party Links Security of My Personal Information Marketing Emails Children Under 13 Contact Us Changes to this Policy What Information Do We Collect About You and Why? We may collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services. Information We Collect Directly From You. Registration. Certain areas and features of our Site and Services may require registration. To register you must provide your name, email, phone number, user name and password. We also may collect additional optional information from you. Patient Assessments. When you use the Sense.ly Services, we collect information about you, including your responses to assessments and your interaction with the Sense.ly avatar (the 'Assessments'). We may collect this information via a number of methods, including through web forms and questionnaires, as well as by recording audio and/or video records of your interactions with the Sense.ly avatar, using your device's microphone, camera or similar device. If available and approved by your healthcare provider, we may also collect as part of your Assessments, at your request, readings and information from medical devices, such as glucose meters, blood pressure monitors, pulse oximeters, pedometer, ECGs and other approved devices. Information We Collect Automatically. We may automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site, and the following: access time and browser type. We also may collect the following information about your use of the Application: mobile device ID; location and language information; device name and model; operating system type, name, and version; your activities within the Application; and the length of time that you are logged into our Application. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information about our use of cookies and other tracking mechanisms. How We Use Your Information We use the information that we gather about you for the following purposes: To provide our Services. To communicate with you about your use of our Services, to respond to your inquiries, to provide technical support and assistance and for other customer service purposes. To tailor the content and information that we may send or display, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services. To send offers and other promotional communications to Clinicians; we do not market to Patients. To display advertising on our Site. To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes. How We Share Your Information We may share the information that we collect about you, including personally identifiable information, as follows: Services and Management. We may share your information in the course of providing Services to you and Clinicians, and for our own management purposes. Clinicians. As directed and consented to by you, our Services make your Assessments and related information available to your Clinician. This information will not be available to Clinicians other than those with whom you have requested that we share your Assessments. This Policy does not address how Clinicians will use and disclose information obtained using Sense.ly. If you would like this information, you should ask your Clinician directly for a copy of his/her Notice of Privacy Practices. Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other Company. In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena in compliance with applicable privacy laws. To Protect Us and Others. We also may disclose the information we collect from you, to the extent permitted by law, where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which Sense.ly is involved. Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes. Our Use of Cookies and Other Tracking Mechanisms We use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other information we collect from you. Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse public areas of the Site, but the Services will not function. Clear GIFs (a.k.a. web beacons, web bugs or pixel tags). Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and, to the extent permitted, our Application. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties. User Generated Content We may invite you to post content on our Site, including your comments, pictures, and any other information that you would like to be available on our Site. If you post content to our Site, all of the information that you post will be available to other users of the Services. If you post your own content on our Site or Services, your posting may become public and Sense.ly cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. As a result, you should never post any sensitive information to our Site that you are not comfortable sharing publically. Sense.ly is not liable to you or any other person for any content or information you post to our Site or the use or disclosure of such content or information by other users or third parties. Third-Party Links Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites. Security of My Personal Information We have implemented commercially reasonable precautions and safeguards, including, where appropriate, password protection, encryption, SSL, firewalls, and internal restrictions on who may access the personal information Sense.ly maintains, in order to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. Access To My Personal Information You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Application for a period of time Marketing Emails We may send periodic promotional or informational emails to Clinicians. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us. Children Under 13 Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. Contact Us If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at info@sense.ly. Changes to this Policy This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, at https://beta.sense.ly/privacypolicy. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site, or emailing the email address of record for your account.