Alvio – Privacy Policy
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.
This Privacy
Policy (the “Policy”) explains our privacy practices for the data
collected by the Alvio respiratory
device sensor (the “Sensor”)
and provided by you in the accompanying Alvio app (the “App”, which
together with the Sensor will be called the “Alvio System”). It
describes how we collect personally identifiable information, use it and share
it, and the rights and options available to you with respect to your
information.
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.
The following key points of the
Privacy Policy are only brought for your convenience. They are not a substitute
for the full Policy.
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.
8.
Changes to the Policy. We may
change this Policy, in which case we will seek your consent to
those changes if they are material.
Tempdrop – Privacy Policy
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.
Children's
Privacy
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: support@alv.io. 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: support@alv.io.
EUROPEAN CITIZENS
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.
Information
Security
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.
California
Residents
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.
Changes to
this Privacy Policy
Contact Us
You
may contact us with any questions or comments, at: [support@alv.io]
Effective
date of the policy:
November 13, 2018