BEWELL CONNECT PRIVACY POLICY
Effective Date: December 1st ,2016

Bewell Connect Corp. (“BewellConnect”, “we” or “us”) offers health monitoring devices (the “Devices”) designed for use in connection with BewellConnect’s suite of mobile applications (including without limitation BewellConnect™, BewellCheckup™, MyTENS™ and MyDoc™, the “Apps”). This Privacy Policy applies to the data collected through the Apps and the Devices, as well as through the BewellConnect website and other websites or other digital services on or to which this Privacy Policy is linked or referenced (such websites and digital services, collectively, the “Website”). The Devices, Apps and Website, as well as any services and content provided to you by or on behalf of BewellConnect in connection with the Devices, Apps and Website are collectively referred to in this Privacy Policy as the “BewellConnect Platform.” By using the BewellConnect Platform, you consent that we may process the data that we collect from you in accordance with this Privacy Policy.

 

This Privacy Policy is incorporated into and made part of our Terms of Service. We encourage you to review our Terms of Service, because they contain important limitations on our liability to you when you use the BewellConnect Platform.

Please note that this Privacy Policy describes how we protect your privacy as a general user of the BewellConnect Platform.

 

  • This Privacy Policy does not describe how we protect and use your data as a patient using the BewellConnect Platform at the direction of a health care provider. If you are a patient and use the BewellConnect Platform at the direction of a healthcare provider, you have other rights with respect to the access, use, and disclosure of your Protected Health Information (“PHI”). For a more complete description of your patient rights under the Health Insurance Portability and Accountability Act (“HIPAA”), please refer to the Notice of Privacy Practices provided to you by your health care provider.
  • The name BewellConnect is also used by our affiliates, including Visiomed Group SA, for provision of similar platforms outside of the United States. Please note such similar platforms are not provided by BewellConnect, and this Privacy Policy does not apply to the data collected by such other platforms. Please consult the provider of the platform to determine its privacy practices.

When you use the BewellConnect Platform, we may ask you to provide certain “Personal Data”, which means any data that can be used alone or in combination with other data to identify you (such as your name, email address and photograph). We also may collect “Non-Personal Data”, which means data that we collect automatically about your use of the BewellConnect Platform but does not identify you (such as your IP Address, device ID, browser type and pages visited). Finally, we may collect “Health Data”, which means data that does not necessarily identify you but we recognize may be more private to you than other data.

We may collect your data when you:

Create an Account. To view the data collected by your Device, you must create a BewellConnect account. When you create a BewellConnect account, we ask for some Personal Data and Non-Personal Data, including your name, email address, birthdate, weight, height, waist size, and step length. You can further customize your experience by adding other types of data to your account, such as a photograph or medical history, or defining objectives for your health goals. Whenever you add this type of data, we collect it and store it in your account. Your email address will be your BewellConnect username, which you will use to log into and access your account.

You may also create a user profile for a family member. You may only enter your family member’s Personal Data with that family member’s permission, unless you are the parent or guardian of a child under 13 years old. Please refer to our Terms of Service for the rules that apply to creating an account and building a user profile for yourself and your family member(s).

Activate and use an App or Device. You may need to download one or more Apps to access certain features of the U.S. Platform or to activate a Device. In such event, you may be asked and enter information about yourself, such as your gender, birth date, height, weight etc… We use this Personal Data to personalize your health statistics. For example, by tracking your weight over time, we are able to tell you where you stand on your goals and if you have reached your objectives. When you use a Device through an App, data recorded on your Device is transferred from your Device to our servers located in the U.S. This data is then uploaded from our servers to your account. Each time a Device syncs with our servers, we log Non-Personal Data about the transmission, such as the sync time and date, Device battery level, and the IP Address used when syncing. The type of data collected by each Device will be Device specific. To find out more information about the type of data each Device collects, visit our Connected Devices page. Note that you may use an App without connecting a Device, and we may still collect data about your usage of the App.

Use the Website. When you use the Website through your computer or mobile device, we automatically collect Non-Personal Data about your visit through the use of cookies, web beacons, and other data collection technologies. To learn more about our data collection technologies and how we use them, see the “Data Collection Technologies” section below.

Purchase a Product. When you purchase a product from our online store, we will collect Personal Data that allows us to fulfill your order. We do not view or store your credit card information, as such credit card information is sent directly to and is handled by our third-party payment processor. We store your shipping address so we can process your order through our fulfillment partner. If you are logged into your account when you purchase something on the BewellConnect Platform, we associate that order with your account.

Subscribe to our Newsletter. If you subscribe to our email newsletter, we will collect your email address to send you latest updates about our products and services. You can always unsubscribe to receiving our newsletter by using the unsubscribe link at the bottom of any newsletter you receive or by emailing us at bewellconnect@bewell-connect.com.

Contact Us. We may collect your Personal Data, including your name, phone number, and email address, if you contact us with questions, concerns, or feedback via our online form, through email, or by other means such as a survey. When you contact us, we will only use your Personal Data to respond to your communication and fulfil your request.

We use your data to provide you with customer service that we hope makes you feel supported, motivated and reassured. Here are some examples:

  • measure and monitor your Health Data through the Apps, set objectives, access and analyze results, and to customize your use of the BewellConnect Platform so that it is responsive to your physical and physiological needs.
  • We may use your Personal Data to send you administrative announcements, newsletters, and information about new features and products we think you would be interested in. You can always unsubscribe to receiving our promotional and marketing emails by using the unsubscribe link at the bottom of any promotional or marketing email you receive or by emailing us at support@bewell-connect.com
  • Non-Personal Data is used for our internal business purposes so that we can understand and improve the BewellConnect Platform, troubleshoot Devices, and detect and protect against fraud and criminal activity.
  • We may aggregate or de-identify your Personal Data for marketing and promotional use, and for clinical trials. Such aggregated or de-identified data does not and cannot be used to identify you.

We only share your data with third parties in accordance with this Privacy Policy and under the following circumstances:

  • At Your Direction. You can direct us to share your data with your contacts, relatives, and third parties. For example, you might authorize us to send your Health Data to your contacts or to your medical provider. If you direct us to share your data with a third party, that data is governed by the third-party’s privacy policy. You can revoke your consent to share with the third party at any time by writing to bewell@bewell-connect.com specifying the purpose of your request.
  • With Notice at the Time of Collection. If we collect your data and intend to disclose it in a way not already disclosed in this Privacy Policy, we will notify you of such intended disclosure at the time of collection.
  • Service Providers. We may share your data with companies that we contract with to help us deliver the BewellConnect Platform, such as email management, credit card processing, order fulfillment, technology hosting, and website analytics. These companies are obligated by contract to use your Personal Data and Health Data only on our behalf and at our direction.
  • We may transfer your data to subsidiaries of BewellConnect if appropriate.
  • Business Transaction. We may sell, transfer or otherwise share some or all of our assets to a third party in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. In such event, your Personal Data and Health Data may be transferred to that third party.
  • As Required or Permitted by Law. We may disclose your data as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to protect the property and rights of BewellConnect or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity, and to otherwise to comply with law.

We may share aggregated data with third parties in a variety of ways, such as by providing health research or reports or using the data for promotional purposes. When we disclose this aggregate data, we perform appropriate procedures aimed to eliminate certain data elements it so that third parties cannot identify you.

We and third parties acting on our behalf use various technologies that help us to manage the operations of the BewellConnect Platform and track usage behavior so that we can tailor information to make your visits more enjoyable and meaningful. For example, we use Google Analytics to collect information about how often users visit the Website, what pages they visit when they do, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to improve the BewellConnect Platform. For more information about Google’s ability to use and share information collected by Google Analytics about your visits to the Website, please see the Google Analytics Terms of Service and the Google Privacy Policy.

Our data collection technologies include:

  • Cookies: Cookies are text files containing small amounts of information that are stored on your computer or mobile device’s browser directory. Cookies are created when you visit a website that uses cookies to keep track of your movements within the website. Cookies are useful because they allow us to recognize your device, remember your preferences, automatically log you in to your account, and provide us with information that we can use to further personalize your user experience. You can find more information about cookies at allaboutcookies.org.
  • Web beacons and GIFs: Certain pages on the BewellConnect Platform contain web beacons (also known as web bugs, pixel tags and clear GIFs), which we use to monitor how users use the Website. We use web beacons in combination with Cookies to understand how our users navigate through and process the content contained on our Website.
  • Local Storage and Local Shared Objects: We use local shared objects (LSOs) such as Flash Cookies and local storage, such as HTML5 Local Storage, to enhance user experience by, for example, storing your user preferences and settings (e.g., volume/mute) in connection with animated content on the BewellConnect Platform. Local storage is similar to browser cookies but can store data more complex than simple text. By itself, local storage cannot do anything to or with the data stored on your device. Like cookies, local storage can only access personal data that you have provided on the BewellConnect Platform. Third parties with whom we partner to provide certain features on the BewellConnect Platform or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here.

Your browser may allow you to manage your cookies and local storage. Because each browser is a little different, we encourage you to check your browsers’ “Help” feature to learn how to block cookies, how to receive notification of new cookies, and how to disable existing cookies. For more information about managing cookies, please visit www.allaboutcookies.org/manage-cookies/.

Some web browsers incorporate a “do-not-track” (“DNT”) or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his/her online activity tracked.  If a website receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, BewellConnect (along with many other website operators) do not currently respond to DNT signals.  For more information about DNT signals, visit allaboutdnt.com.

Some components of the BewellConnect Platform may include a geo-tracking feature that allows us to offer you location-based services, such as access to the contact details of healthcare professionals (including a doctor, pharmacy, hospital or clinic) in your immediate vicinity. You can change your preferences on your mobile device and/or browser to deny us access to your geolocation. Please note that if you disable geolocation tracking, certain features of the BewellConnect Platform may not be available to you.

Personal Data that you provide to us may be modified by accessing your account and profile and changing the data stored within. Please note that if you remove data from your account, it will no longer be visible to you. If you have any questions about accessing, modifying or deleting your data, please contact us at support@bewell-connect.com.

The BewellConnect Platform is not directed to children under the age of 13, and BewellConnect does not knowingly collect any Personal Data from children under 13 without the verifiable consent of that child’s parent or guardian. If you are aware of a child providing his or her Personal Data without parental consent, please contact us at support@bewell-connect.com. We will endeavor to delete all data we collected from a child under 13 if we discover we collected it without that child’s parental consent.

We employ reasonable security measures designed to safeguard the Personal Data under our control from unauthorized access, use, and disclosure. Despite these measures, the confidentiality of your Personal Data cannot be guaranteed. We encourage you to take appropriate steps to protect your Personal Data, such as using a password that is not easy to guess. If you have a security related question or concern, please contact us at support@bewell-connect.com.

Under California Civil Code §1798.83, BewellConnect is required, once per calendar year and upon request, to disclose to California residents: (i) the identity of any third party to whom we disclosed  Personal Data within the previous calendar year for the third party’s direct marketing purposes; and (ii) the type of Personal Data disclosed. To request such information, please send an email to contact@bewell-connect.com with the subject line “California Privacy Rights” or write us at the following address:

BewellConnect
Attn: California Privacy Rights
185 Alewife Brook Parkway
02138 Cambridge MA

The BewellConnect Platform is hosted in the United States and subject to U.S. law. If you are accessing the BewellConnect Platform from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the law of your jurisdiction. By accessing and using the BewellConnect Platform, you consent to the transfer to and processing of your Personal Data in the United States.

The Effective Date of this Privacy Policy is set forth at the top of this page. Because we are always looking for innovative ways to help you monitor your health, this Privacy Policy may change over time. If any modifications materially change your rights, we will notify you of these changes either by posting notice on the BewellConnect Platform or by sending you an email to the email address we have on file for you. By continuing to access or use the BewellConnect Platform after such changes take effect, you agree to be bound by the modified Privacy Policy.

You can email or write to us with any questions or comments at the following contact information:

BewellConnect
Attn: Customer Care
185 Alewife Brook Parkway
02138 Cambridge MA

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