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Cardiac Designs Inc. // Privacy Policy

Effective: August 1, 2018 (Rev1)

This Privacy Policy (“Policy”) describes how Cardiac Designs Inc. (“we,” “us,” or “our”) collects, uses, and discloses information that we obtain about your use of www.ecgcheck.com and www.cardiacdesigns.com (“the Site”) and the use of ECGCheck software (“the App”), collectively “the Service,” including information that we collect from the Cardiac Designs devices that you connect to a mobile device running the App.

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We are a worldwide company:  

  • If you are located in the United States or a country outside the European Union, your information is stored in the United States.  

  • If you are a European Union data subject, we store your information in the European Union.  

  • By using or downloading the Service, 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 Service, may be transferred to and stored in the United States and handled as described in this Policy. 

 
The Information We Collect About You. We collect information directly from you, automatically through your use of our Service. 

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When You Create, Update, or add information to Your Profile. When you register to use the Service, we collect the personal information you provide us, including your name, email address, password, gender, and birthdate. We also collect any additional information you choose to add to your profile, which may include: information related to your heath and activities, medications you are taking, patient ID, notes, etc.

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We collect additional information from Devices you connect to your App: 

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

  • You may use your mobile device to add notes and tags to ECG recordings you make. Many users use this feature to supplement ECG readings with information about their symptoms, activities, or diet related to their specific health conditions. Please note that we collect information provided through notes and tags, including any personal or sensitive information you choose to provide through this feature. 

  • When You Contact Us. When you contact us 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

We process your information, including your personal information, for the following purposes: 

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  • To provide our Service to you, to communicate with you about your use of our Service, 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 Service. 

  • 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 at any time as described below. 

  • To better understand how users access and use our Service, both on an aggregated and individualized basis, in order to improve our Service and respond to user desires and preferences, and for other analytical 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 Service. 

  • 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. 

 
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 Service with other third-party partners, including your personal information and data collected from your devices. 

  • Your Healthcare Providers Or Family. With your consent, we may share your information, including information collected from your connected devices, with your healthcare providers, a certified technician or cardiologist who would read your ECG/EKG and/or family members (e.g., immediate family or friends) that you designate to receive your information. 

  • Clinical Trial Studies. With your consent, physicians and staff of clinical trial programs may use the Service as a means of collecting data for the trial study. If the Service is used as part of a clinical trial study, we will use and share information about the clinical trial collected through the Service in accordance with our agreement with the clinical trial program and any privacy notices provided to you as part of the clinical trial program. 

  • 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 Service 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, 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, such as providers of hosting, email communication, customer support services, analytics, marketing, and advertising, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. 

  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding or reorganization, we will give affected users notice (using your registration e mail and or phone number) 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 Cardiac Designs is involved.

Cookies

Cookies are small text files stored on your device and used by web browsers to deliver personalized content and remember logins and account settings. In addition to improving user experience, we use cookies and similar technologies for analytic and advertising purposes. You can manage your cookies locally by adjusting your browser settings. Because there is not yet a common understanding of how to interpret 'Do Not Track' signals, we are unable to respond to 'Do Not Track' requests from browsers, however we are monitoring for updates and will revisit this policy once a common standard is established.

Third-Party Links

Our Service 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. 

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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

We acknowledge the right of EU and Swiss individuals to access their personal data pursuant to the Privacy Shield. 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 Service for a period of time. 

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We store information associated with your account until your account is deleted. You can delete your account at any time by contacting Customer Support at privacy@cardiacdesigns.com. 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.

What Choices Do I Have Regarding Notifications and Promotional Emails?

We may send periodic notifications or 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. We may still send you emails about your account or any services you have requested or received from us.

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.

GDPR – Rights For EEA Users and Cardiac Designs’ Capabilities for Worldwide Users 

What Rights Do I Have? Individuals located in the European Economic Area (EEA) have certain rights in respect of your personal information and Cardiac Designs will provide these capabilities to all our worldwide users, including: 

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  • The right of access to your personal data, to correct or rectify any inaccurate personal data, to restrict or oppose processing of personal data, to erase your personal data, and the right to personal data portability. 

  • We rely on your consent as a lawful basis processing personal data for the following purposes: 

  • Initial collection of personal data through the Service; 

  • Providing you with marketing or promotional communications. You may opt out of such communications at any time by clicking the “unsubscribe” link found within Cardiac Designs email updates and changing your contact preferences. 

  • We process personal data in order to perform our contract with you. 

  • Additionally, we process personal data based on our “legitimate interests” in providing you the Service as described in the section “How We Use Your Information”, including: 

  • To enable the Service to function as expected; 

  • To communicate with you in response to customer service inquiries, to deliver non-promotional, service-related emails, or to administer surveys and questionnaires; and 

  • To tailor your experience based on your general region. For example, we process Clinical Interpretation Service requests from EEA-based users through an EEA-based Clinical Interpretation Service partner. 

  • In some cases, we may process personal information pursuant to a legal obligation or to protect your vital interests or those of another person. 

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How May I Exercise My Individual Rights? Cardiac Designs users located worldwide may access and update their personal information as follows: 

  • Account holders may access and update personal information through their account settings in the Cardiac Designs platform; 

  • Account holders may exercise their rights to data deletion and data portability by contacting Cardiac Designs’ Data Controller Representative at privacy@cardiacdesigns.com. 

  • We do not retain any personal information from users who do not create Cardiac Designs accounts. 

  • Please note that we may request additional information from you to verify your identity before we disclose any personal or account information.

Contact Us

If you have questions about our privacy practices, please contact us at privacy@cardiacdesigns.com. 

 

Cardiac Designs Inc. 

695 Minnesota Street 

San Francisco, CA 94107. USA 

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If you are an EEA customer and are unable to reach us at the contact information provided above regarding your issue, you have the right to contact your local Data Protection Authority.

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 Service. 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.

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