Effective date: 18 December, 2014
Contact us: email@example.com
This document describes the policies and practices of Therapy Holdings, Inc (the “Company”) with regard to the personally identifiable information (“PII”) collected by the Company’s app (the “App”). Among other things, this document identifies what PII Therapy Holdings collects, how it uses that information, with whom it shares that information, its retention policies for PII, and the options users have to control and limit the Company’s use of that information.
The App is designed to collect biometric data from wearable fitness devices purchased from the Company or from its distributors, to forward that data to the Company’s servers and to display reports resulting from processing that data back to the user. (In this document, we refer to the foregoing collectively as the “Services”.) The App may be downloaded from Apple’s App Store or from Google Play.
1. Data Collection
Information Collected when using the App
Beyond the welcome screen and device setup, users are required to create an account to use the App and the Services. When you create an account, and when you use our Services, we collect information from you both actively and passively. When you create an account, we collect your email address. When you connect the Company’s wearable fitness device to your smart phone, the App also collects data on your exercise and workout sessions. The App uploads all of this information to our servers. The exercise and workout session data is associated with your account information, and in that manner becomes PII. We also collect information that identifies the particular Company wearable fitness device that you are using and information that identifies your smart phone.
The App connects to the Company's wearable fitness device using Bluetooth Low Energy (BLE). During this connection process the app performs a scan of nearby Bluetooth devices to determine if the Company's wearable fitness device is within range. During this scan, other Bluetooth devices may be discovered which could reveal a user's real-world location (for example if a Bluetooth device is discovered that has a known, fixed real-world location). The Company does not use or store the scan results for devices other than Company's wearable fitness devices. By using the App, the user gives permission to enable these required Location services on the user's smart phone and perform the Bluetooth scan.
The Company employs cookies to enhance our Services and the user experience. Cookies are small pieces of information that our servers send to your smart phone while you are using the App. We may use both session cookies, which expire when you cease using the App, and persistent cookies, which stay on your smart phone until you delete them, to provide you with a more personal and interactive experience.
Our technology allows you to monitor your activity through your movements. As our Service matures we will provide you with an increasing array of information about your physical performance and general health. All the data collected is associated with your user account.
The App and our services are not directed to, or intended to be used by, children under 18 years of age. The Company does not knowingly collect PII from persons under 18 years of age. If we become aware of the collection of such information, we will make every effort to remove that information and terminate the service to that individual. If you are aware of a user under the age of 18 using our Services, please contact us at firstname.lastname@example.org.
No Electronic Health Records
2. Transmission, Location and Storage of Data
This section of the document covers how we manage your data once we have uploaded it from your smart phone.
Transmission of Data Collected
After your biometric data is transferred from the wearable fitness device to your smart phone, our App analyzes it to provide you with insights on your performance, and uploads it to our servers. Your user name and password are required to authorize the transmission of the data to the App and then to our servers.
Location of Data
The information we collect, including your personal information and biometric data, is stored and processed on servers located in the United States of America. Therefore, this information may be subject to disclosure in accordance with the laws of the United States of America. If you are accessing The Company’s Services from outside the United States, please be advised that United States law may not offer the same privacy protections as the law of your jurisdiction. By using our Services, you consent to the transfer of your personal information to the United States.
If you do not want your personal information and data to be transferred, processed and stored in the United States of America, you should not use our products and Services.
Storage of Data
3. Data Sharing
This section of the document covers how you and we can share your data.
User Sharing with other Third Parties
Our Sharing Policies
Notwithstanding the foregoing, The Company may disclose your Information to third parties, without prior notice to you, if: (a) we are required to do so by any applicable law, regulation or directive of a governmental agency, or (b) we believe in good faith that such action is necessary to conform or comply with the provisions of any such applicable law, regulation or with legal proceedings, to protect the rights or property of The Company and/or to protect the personal safety of users of the Services or the public.
4. Data Use
This section of the document describes how The Company uses your data.
How The Company Uses Your Data
Subject to our policy under “Our Sharing Policies” above, The Company will use your data to provide you with the best experience possible and to improve our Services. Here are some examples:
- Personal information to calculate your exercise activity
- Contact information to send you account notifications and inform you about new features or products we think you would be interested in
- Personal information for research to improve our products and services
- Aggregate de-identified data to inform the health community about trends; for marketing and promotional use; or for sale to interested audiences.
The Company provides access to your data, including PII, to its employees and contractors for purposes of internal administration, maintenance and support of our platform and Services and to provide customer support. Each of our employees and contractors to whom we give access to your data has executed a confidentiality agreement obligating him or her to protect and safeguard that data. If The Company becomes aware of any misuse or misappropriation of your data by its employees or contractors, or any use of such data that conflicts with our policies as stated in this document, The Company will use its reasonable commercial efforts to terminate such misuse or conflicting activities. The foregoing notwithstanding, The Company has no obligation to inform you of such activities.
5. Opt Out Policy
At this time, The Company does not provide users of the App any options to selectively opt out of our collection, use, sharing or retention of any data. Each user has the option of using the Services as they are presently configured or terminating their use of the Services. Our policy on terminating users’ use of the Services is described below.
If we propose to use your PII for any purposes other than those described in this document, we will first revise this document and post it in the places where you found it, and we will also provide you with the ability to terminate your use of the Services.
6. Correcting and Updating your Data
This section of the document describes how you can update and delete your PII that The Company has collected and retained.
You can have access at any time to your user profile information by consulting your account / user profile. If you need to update or change that information, you may do so by editing your user profile. To update your user profile, click on the App, and log in to your account.
Deletion of Information
If you wish to cease using our Services, you may also wish to delete your user information. In order to delete your profile and other personal information you can contact The Company directly at email@example.com. We will delete your profile and any data associated with it, including the biometric data that you have uploaded to our servers. In order to delete backup data related to your profile there will be a time-lag. The Company will respond to your request to delete your account and biometric data within one week of receipt.
If your data has been included in a de-identified data set, we will not be able to remove it from the set; however, that information will not allow any user of the data set to identify you.
7. Data Retention Policy
The Company will retain your data indefinitely unless you send the company a written request to delete it.
8. International Users
The Company’s services are hosted and operated entirely in the United States and are subject to United States law. Any personal information that you provide to The Company is being provided to The Company solely in the United States and will be hosted on United States servers. You consent to the transfer of your personal information to the United States. If you are accessing The Company's Services from outside the United States, please be advised that United States law may not offer the same privacy protections as the law of your jurisdiction.
This section addresses specific items relating to The Company website
secure and private transactions
We utilize a third-party merchant service provider to process your payment and a third-party fulfillment center to ship your order. These third-parties only use your information to fulfill their services and operate under strict confidentiality contractual agreements. To ensure your security and privacy, your personal and private information is encrypted when communicated to these third-parties during a transaction.
We provide a mailing list to provide our customers with the latest company news, product tips, and exclusive offers. We never send unsolicited correspondence or provide third-party access. Subscription to our mailing list is voluntary and can be canceled at any time; to report unsolicited correspondence or to be removed from our mailing list, please contact customer service.
questions and concerns