Welcome to Alvio, a mobile application that, with the use of the accompanying respiratory device, helps children and adults like you to improve your respiratory system and track symptoms and training progress over time. We, at QoL Devices Ltd. (“Alvio”, “we”, “us”, “our”) respect your privacy.
It is your decision to provide us with your personal information. You are not legally obligated to provide us with this information, but we need it in order to provide you with the Alvio System’s functionality.
1. Information we collect. We collect information you provide us in the registration process. We also collect measurements of your respiratory motion while you use Sensor, play App games and practice your breathing – while the Sensor is turned on. These measurements will be sent through the App, to our cloud server every time conditions allow it (App is cloud connected).
2. Using the information we collect. We use the information we collect to operate the system and provide its features and functionalities.
3. Sharing the information we collect. We may share your information with third parties, mainly when you actively choose to share such information, by registering with your personal Alvio user account to third party apps, and with our licensors, contractors and service providers, allowing you to make the most of the Alvio system that help you improve your respiratory system when you regularly use the device over time.
4. Aggregated information. We may use the information we collect from you to create de-identified (anonymous), statistical or aggregated information, and make it available to others for any purpose.
5. Retention. We retain your information for as long as we deem necessary for the purpose it was first obtained. If you withdraw your consent to us processing your data, we will erase your personal data from our systems.
6. Security. We implement measures to reduce the risks of damage and unauthorized access or use of information, but these measures, just like any security measure, cannot provide absolute information security.
7. Children privacy. In case the Alvio system is being used by Children under the age of 16, we assume that you are the holder of the parental responsibility of the child. We do not knowingly or intentionally collect arbitrary information about children who are under 16 years of age.
Changes to the Policy. We may
change this Policy, in which case we will seek your consent to
those changes if they are material.
INFORMATION WE COLLECT
Registration. Only registered users may use the App. You may register using your email address and your name. Registered users must be adults over the age of 18.
Alvio Device Information. By using the App together with the accompanying respiratory device (the "Device"), we collect measurements of your respiratory system (“Measurements”) when you choose to transmit them from the Device via the App to our cloud server.
Inquiries. If you contact us for questions or complaints, or for technical support, we will collect the information related to your inquiry. This may include your mobile phone number and other contact information, depending on the nature of your inquiry.
Analytic Information. When you access or use the App as a registered user, we may use third party analytic tools to automatically collect information about your use of the App. This information includes your session durations, the content you accessed on the App, your interactions and user-interface clicks, and the frequency and scope of your use of the App.
Device information. We may collect information about your mobile device, including its model, its operating system, unique device identifiers, browser you use its version and language (i.e. locale) preferences, mobile network information and the Internet Protocol (IP) address through which you accessed the App.
In case the Alvio system is being used by Children under the age of 16, we assume that you (the registered user) are the holder of the parental responsibility of the child. We do not knowingly or intentionally collect arbitrary information about children who are under 16 years of age.
If you are under the age of 18 you may not use the APP in any way.
USING COLLECTED INFORMATION
Your consent serves as the legal basis for processing your information. You may withdraw consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.
We use the information we collect for the following purposes:
· Generating reports based on your Measurements, aimed at providing you with a better way to track your respiratory system performance and training progress over time;
· Operating the App and providing its features and functionalities;
· Sending you updates and other communications related to the App;
· Generating statistical and aggregated information about users of the App;
· Providing you with support, handling complaints and contacting you when we believe it is necessary.
· Enforcing the Terms and this Policy and preventing misuse of the App.
· Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified.
· Taking any action in any case of dispute involving you, with respect or in relation to the App.
Sharing information collected
We may share the information collected from you, as outlined in this Policy, with others, in any of the following instances:
· We may share anonymized information for research purposes only, to the benefit of public health in general and respiratory patient’s health specifically;
· We may use the information we collect from you to create de-identified (anonymous), statistical or aggregated information, and make it available to others for any purpose;
· We may share your data with our licensors, contractors and service providers, strictly for the purpose of helping us with the internal operation of the system;
· If we believe that you may have breached the Terms, abused your rights to use the App, or violated any applicable law: Your information may be shared with law enforcement agencies and other competent authorities and with our counsels and any third party as may be required to handle any result of your wrongdoing, if we believe it is necessary or justified;
· We may share your data to the extent required by law, or if we believe that sharing information is necessary to prevent imminent physical damage to body or property.
· We may share your data if the operation of the App is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided however, that those entities agree to be bound by the provisions of this Policy, with respective changes taken into consideration;
· We may share your data in any case of dispute, or legal proceeding of any kind between you and us, or between you and other users, with respect to the App or your use thereof.
In any case other than the above, your information will only be shared with others if you provide your explicit prior consent, and we will never share personal data with third parties for marketing purposes without your prior explicit consent.
Retaining and deleting collected information
We retain the information outlined above, for as long as you are using the App. We may delete your information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.
Please note that merely uninstalling the App won't delete your account and its details, including all the information maintained in it and information sent to Third Party Apps, which may still remain with us and with other Third Party Apps. If you wish to delete all information about you that is stored on our servers please contact us at: email@example.com. In order to process your request, we may require additional information or corroborative documents from you, to verify your account and confirm your identity.
Once we complete processing your request for deletion, we will delete your information from our systems. However, be advised that following such deletion, some information, though not accessible in the ordinary course of business, may still be retrievable from back-up copies or may still residually reside in our systems. You should also bear in mind that aggregated and analyzed information will not be deleted as it is merged with other information.
Transfer of data outside your territory
We may store and process information in the EU and in other countries throughout the world, such as the United States. We may also process information using cloud services. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services.
If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide your express and unambiguous consent to such cross-border transfer.
You may ask to access the personal information about you that is stored in our systems, or have us update, correct or delete such information. You may also be entitled to obtain from us the personal data you provided us (excluding data we obtained from other sources) in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact us at: firstname.lastname@example.org.
The following disclosures are made pursuant to the European General Data Protection Regulation (GDPR):
· You have the right to withdraw your consent at any time; and to submit a complaint to the relevant supervisory data protection authority.
· QoL Devices Ltd. is the data controller in respect of the processing activities outlined in this Policy.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. These measures do not provide absolute information security. Therefore, it is not guaranteed and you cannot expect that the App will be immune from information security risks.
The following disclosure is made pursuant to California Online Privacy Act (CA Civil Code § 22575): When you use our App, other parties, such as Google, may collect personally identifiable information about your activities over time and across different websites or online services.
You may contact us with any questions or comments, at: [email@example.com]
Effective date of the policy: November 13, 2018