OMRON CONNECT POWERED BY ALIVECOR Privacy Policy

EFFECTIVE DATE: March 26, 2018

Omron Connect is provided by Omron and AliveCor, two separate companies. Your personal information collected by this App is jointly and independently used by both companies as described in this Policy. All other websites, apps, or products made available by either Omron or AliveCor will be governed by those respective privacy policies, not this one.

In this joint Omron-AliveCor Connect Privacy Policy (“Policy”), we describe how Omron and AliveCor (“we,” “us,” or “our”) collect, use, and disclose information that we obtain about your use of Omron Connect powered by AliveCor (“the App”), which includes information that we collect from the AliveCor and Omron devices that you connect to the mobile App.

By using or downloading the App, you agree that your personal information, including any information about your health that you provide directly to us or that we collect through your use of the App, will be transferred to and stored in the United States and handled as described in this Policy and in the Omron Connect powered by AliveCor Terms of Service.

The Information We Collect About You

We collect information directly from you, from devices, and from certain services with which you connect, such as Apple Health and Google Fit, as well as automatically through your use of our App.

When You Create, Update, or add information to Your Profile. When you register to use the App or create an Omron Connect account, we collect the personal information you provide us, including your name, email address, password, gender, height, and birthdate. We also collect any additional information you choose to add to your profile, including: address, weight, body mass index (BMI), whether you are a smoker or non-smoker, medical conditions, information related to medications you are taking, patient ID, and activity levels.

When You Connect a Device to your App: We collect additional information from Devices you connect to your App:

When you Use a Kardia Device. We collect your raw electrocardiogram (“ECG,” “EKG”) measurement data, average heart rate, and location on the body where the ECG recording was taken (e.g. body or chest) when you use a Kardia device. We collect additional information from your mobile device at the time of recording, including accelerometer data, local time, local time zone, and, with your consent, geographic location.

You may choose to use your mobile device to add notes, tags, or voice memos to recordings you make with any connected device. Many users use this feature to supplement ECG measurements with information about their symptoms, activities, or diet related to their specific health conditions. We collect and store the notes, tags, or voice memos you record, including any personal or sensitive information you choose to provide through this feature. You may opt out of this feature at the time you record your ECG or by changing your settings in the App.

When You Use a Connected [Blood Pressure Monitor] Device. When you use a connected [blood pressure monitor], we collect testing results, information about the specific [blood pressure monitor] device, and information from your mobile device. Testing results include: blood pressure readings, pulse rate, dates and times of tests, [Blood Pressure Monitor] cuff position, and TruRead average blood pressure results. Information collected about the specific device includes device identifiers (device model, serial number, and any identifiers you assign to your device) and when your [Blood Pressure Monitor] is near your mobile device. Information collected from your mobile device at the time of recording includes accelerometer data, local time, local time zone, and geographic location.

Information Collected From Your Phone or Watch. In addition to the collection described above, we collect basic information from your mobile device, including device model and OS version, device ID, device language, activities within the App and how long the App is open.

If you choose to connect your mobile device to a compatible third party service, such as Apple Health or Google Fit, with your permission, we collect information from your user profile which may include: username and email address, heart rate BPM, step count and distance traveled, activity sample, glucose and oxygen saturation levels, active and resting energy levels, sleep analysis, blood pressure readings, and workout history.

When You Use A Premium Feature. When you choose to participate in a premium service, we collect additional information from you related to those services.

Some premium features are paid services. When you make payments through the App, you may need to provide your shipping address and financial account information, such as your credit card number, to our third-party service providers. We do not collect or store financial account information, though we may receive transaction identifiers and summary information that does not include credit card or bank account numbers.

When You Use The Kardia Pro Service. When you enroll in the Kardia Pro service as a provider, we ask you to provide your National Provider Identifier (NPI) number. When a health care provider submits patient information through the Kardia Pro service, based on permissions from both the patient and the health care provider, we receive patient profile information including: name, email address, telephone number, birthdate, gender, medical record number, and any notes, tags, or voice memos submitted by the health care provider.

When You Use The Clinical Interpretation Service. If you choose to use the AliveCor Clinical Interpretation Service, as defined in the AliveCor Terms of Service, we will receive the results of your clinical analysis and deliver those results to you through the App.

When You Contact Us. When you contact Omron or AliveCor directly, such as when you contact our Customer Support team, we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.

How We Use Your Information

As permitted by applicable law, we use your information, including your personal information, for the following purposes:

To provide our services to you, to communicate with you about your use of our services, to respond to your inquiries, and for other customer service purposes.
To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the App.
To research and develop new products and features.
For marketing and promotional purposes, to the extent permitted by law and, where required, with your consent. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving marketing emails at any time as described below.
To better understand how users access and use our App and services, both on an aggregated and individualized basis, in order to improve our App and respond to user desires and preferences, and for other analytical purposes.
To administer surveys and questionnaires.
To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy.
To authenticate your identity.
To monitor your compliance with any of your agreements with us.
To manage or transfer our assets or liabilities, for example, in the case of an actual or potential acquisition, disposition, or merger.

How We Share Your Information

We may share your information, including personal information, as follows:

With Your Consent. With your prior consent, we may share information from the App with other third party partners, including your personal information and data collected from your Devices.

Your Healthcare Providers. With your consent, we may share your information, including information collected from your connected devices, with your health care providers that you designate to receive your information.
Clinical Trial Studies. With your consent, physicians and staff of clinical trial programs may use the App as a means of collecting data for the trial study. If the App is used as part of a clinical trial study, we will use and share information about the clinical trial collected through the App in accordance with our agreement with the clinical trial program and any privacy notices provided to you as part of the clinical trial program.
Other Health-focused Mobile Apps. With your consent, we may share your profile information and data collected from your connected devices with other health-focused mobile applications installed on your mobile device to help you track your health and wellness information. If you share your information with these apps, your personal information, including your health information, will be used in accordance with those apps own privacy policies, not this one.

Aggregate and De-Identified Information: We may share aggregate or de-identified information so that it cannot reasonably be used to identify an individual with third parties for marketing, advertising, research or similar purposes.

Health Researchers. We may share data collected through the App with healthcare researchers and other research organizations, including de-identified profile information and data collected from your connected devices. For example, we may share information such as your gender, height, weight, information about medications you have provided, and data from your connected devices, but we will not share your name or other information that could identify you.

Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.

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 based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures.

Business Transfers. If we are, or may be, acquired by or merged with another company, if substantially all of our assets are or may be transferred to another company, or as part of a bankruptcy proceeding or reorganization, we will give affected users notice before transferring any personal information to a new entity.

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 court order or a subpoena.

Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.

To Protect Us and Others. We also may disclose the information we collect from you 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 either Omron or AliveCor is involved.

Information Crossing Borders

For our Canadian users, please note that we may transfer your personal information across provincial or national borders to fulfill any of the purposes described above, including to service providers located in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure laws in those jurisdictions. You may contact us at the contact information is provided below to obtain information about our policies and practices regarding our transfer of data or use of service providers outside of Canada, or to ask questions about the collection, use, processing, disclosure or storage of personal information outside of Canada.

Additional Information:

Third Party Analytics.

We use automated devices and applications, such as Google Analytics and Mixpanel, to evaluate usage of our App. We also may use other analytic means to evaluate our App. We use these tools to help us improve our App, services, performance, and user experiences. Users may opt-out of Mixpanel’s analytics tracking by visiting https://mixpanel.com/optout. If you choose to use the Mixpanel opt-out, you will need to access the opt-out on each device you use.

Do-Not-Track.

Currently, our systems do not recognize “do-not-track” requests.

Third-Party Links

Our App 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 reasonable precautions 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 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 and Deleting 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 App for a period of time.

For our Canadian users, upon written request and authentication of identity, we will provide you with your other personal information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed.

In some situations we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information. When an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

We store information associated with your account until your account is deleted. You can delete your account at any time by contacting Customer Support. Please note that it may take a bit of time to delete your account information, and we may preserve it for legal reasons or to prevent harm, including as described in the How Information Is Shared section.

Accuracy

We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete. In most cases, we rely on you to ensure that your information is current, complete and accurate.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under its control with a note that the correction was requested but not made.

What Choices Do I Have Regarding Promotional Emails or other Uses of My Personal Information?

As permitted by law and where required, with your consent, we may send periodic promotional emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, please understand that your opt-out will apply to the respective company that sent you the promotional email. We may still send you emails about your account or any services you have requested or received from us.

You may also withdraw your consent to our collections, uses and disclosures of your information at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of your withdrawal of consent. When we receive notice of withdrawal of consent, we will inform you of the likely consequences of that withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.

Users Under 18

Our services are not designed for users under 18. If we discover that a user under 18 has provided us with personal information, we will delete such information from our systems.

Special Information for California Consumers

California residents may request a list of certain third parties to which we have disclosed personal information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at: omronhealthcare@speedymail.com and privacy@alivecor.com. Please allow up to thirty (30) days for a response.

If you have questions about the privacy aspects of our App or would like to make a complaint, please contact Omron at our Call Center at 866.216.1333 or email us at omronhealthcare@speedymail.com; or AliveCor at privacy@alivecor.com.

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 App. 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