What personal information we collect from you and for which purpose (Section 3 and 4); The measures to safeguard the access to and the security of your Personal Data (Section 5); Your rights to access, rectify, erase your Personal Data and object to the processing of your Personal Data (Section 8).
Precordior Ltd. provides Precordior CardioSignal Application, a service with a primarily focus on the detection of atrial fibrillation. Precordior CardioSignal Application consists of the Precordior Platform and the Precordior CardioSignal Mobile Application (each as defined hereinafter and collectively the "Application"). The Precordior Platform is the engine core of the Application and interacts with and exchanges data with the Precordior CardioSignal Mobile Application. In addition, the Precordior Platform also analyses and stores data. The recordings via the Precordior CardioSignal Mobile Application are performed by placing the mobile device on the chest of the User. It thereby detecting chest motions using the motion sensors of the mobile device.
Precordior is committed to protecting the privacy of all of its Users Personal Data and providing a secure, user-controlled environment for the use of the Products in accordance with Regulation (EU) 2016/679, the European Union's General Data Protection Regulation ("GDPR"). At the same time, you also share responsibility for maintaining privacy and security for example, by not allowing any third party to use your personal account on the Precordior CardioSignal Mobile Application. Precordior requires all Users to be responsible for safeguarding any authentication information and to immediately notify Precordior of any unauthorized use of your personal Account.
"Account" means your account registered through the registration process on the Precordior CardioSignal Mobile Application;
"Application" means the (I) Precordior Platform and (II) Precordior CardioSignal Mobile Application;
"Precordior CardioSignal Mobile Application" means the mobile application (I) which the User has to download toon its mobile device and (II) is intended to record, display, store and transmit chest motion data;
"Precordior Platform" means the cloud based platform to which the Precordior CardioSignal Mobile Application is connected and with which it collectively functions.
"Product" means the Application;
"Results" means the results of the analysis by the Precordior Platform of the chest motion data recorded by the User through the Precordior CardioSignal Mobile Application;
"Third Parties" means any natural or legal person or entity other than Precordior or the primary User;
"Our website" means the website available at http://www.precordior.com.
3. Information we collect
We may collect several types of personal information from the Users of our Products, and store it on your mobile device and/or our server such as:
Contact information (e.g. your name, postal address, e-mail address, and mobile or other telephone number); The profile data provided by you on your account such as your name and profile picture; Information in helpdesk support inquiries; Patient demographics such as date of birth and gender; Information about your health conditions relevant to the risk of atrial fibrillation, and other health related information (e.g. medicine usage); Information about your device, such as its model, unique device identifier and operating system version; Information collected by the Application, such as measurement of your heart rhythm itself, average heart rate, the local time and geographic location of the measurement; Notifications and tags you may add to your measurements, including information such as symptoms and activities; Payment information such as transaction identifiers and summary information that does not include credit card or bank account numbers (we do not collect or store financial account information); and Web behavior information such as information related to how the Users use the Products (e.g. browser type, domains, page views) collected through cookies and other automated technology (cfr. Section 6 "Cookies").
Hereinafter collectively "Personal Data".
We shall store your Personal Data on our servers located in the European Economic Area (AWS - Frankfurt - Germany).
We would like to draw your attention to the fact that Personal Data consisting of patient medical data is also protected by medical secrecy rules.
4. How do we use your Personal Data
Precordior (I) collects, (II) uses, (III) maintains and (IV) may share your Personal Data provided by you or collected by us with its affiliates, parent companies or other related companies for all purposes necessary to ensure the proper functioning and operation of the User accounts and/or the proper functioning of the Products. These purposes may include (collectively the "Purpose"):
Creating and managing your Account to use the Application; Providing information and allowing the Users to access to the Products; Diagnosing technical problems and managing technical support and processing inquiries concerning the Products; Contacting the Users by phone, email, text message or push notifications (if they are enabled) to (I) verify your account (II) for information and operational purposes such as account management, instructions, alerts, reminders, customer service, system maintenance and others; Contacting the Users to (I) communicate about, and organize your participation in market research or (II) obtaining testimonials; Commercializing the Application; Performing data analyses (including anonymization and aggregation of Personal Data) and using and sharing the resulting anonymized data to third parties for commercialization purposes; The operation, evaluation and improvement of the Products (including the development of additional products and/or services, enhancing and improving the current Products, analysis of our Products, quality control activities and performing internal business functions such as accounting and auditing);
Furthermore, you agree that Precordior is free to access, retain, and disclose Personal Data in the following events:
By using the Application, you acknowledge and explicitly agree that we may disclose certain information to vendors and service providers who help us provide the Products. Examples of these vendors and service providers include entities that process credit or debit card payments and provide analytics and web hosting services.
You furthermore understand and agree that the technical processing and transmission of the Products, including your Personal Data, may involve (I) transmissions over various networks; and (II) modifications to conform and adapt to technical requirements of connecting networks, or devices.
Precordior shall take appropriate administrative, technical and organizational measures against unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use. Upon written request, Precordior can provide you with a list of people of Precordior that may have access to your Personal Data. These people have entered into confidentiality agreements prior to having been granted access to your Personal Data.
In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, Precordior is required by law to notify the User if the breach is likely to affect your privacy.
The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Products (such as usage, activity logs and click-throughs), and dates and times of visits. Log data is promptly deleted on a regular basis.
7. Disclosure to Third Parties
We may also share Personal Data with Third Party service providers who help us to provide, understand, commercialize and improve our Products. We do not authorize these Third Party service providers to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such Third Party service provider with only the Personal Data they need to perform their specific function.
Precordior holds the right to use the collected fully anonymized data for commercial purposes. In fully anonymized data no personal details are left, such as name, addresses or phone numbers or any other data from which person identification could be possible.
8. Your rights
Right of access. If you are concerned or have any questions about your Personal Data, you have the right to request access to the Personal Data which we hold or process about you. We will then provide you with information about the data that are being processed and on the source of those data.
Right of rectification and right of erasure. You have the right to request us free of charge to correct, erase or block any inaccuracies in your Personal Data if such Personal Data would be incomplete, inaccurate or processed unlawfully.
9. Data retention and deletion
Please note that we retain your Personal Data even if you temporarily stop using the Application until you permanently delete the Application on your mobile device and notify us thereof. Precordior will store your personal data one year from the termination of the latest contract. Upon notification, we may retain and continue to use and disclosure your Personal Data to Third Parties exclusively on a fully anonymized basis.
10. Third Party websites or applications
You acknowledge and agree that certain content or services provided by Third Parties may be made available to you through the Products. You agree that such linked content or services may have their own privacy policies for which Precordior cannot be held responsible. Precordior does not in any way review or endorse the privacy practices of such Third Parties.
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