Privacy Policy

 

(Effective as of November 6, 2018)

Datapult Inc. of 235-17 Industrial Parkway South, Aurora, Ontario, L4G 3V5 (“Datapult,” “we,” “our,” or “us”) believes in transparency and appreciates your trust in how we handle your personal information. Here we describe our privacy policy (“Policy”) for our website (www.achu.health), mobile applications, APIs, software, social media pages, products, and other Properties and services as it relates to the information we collect, how we use and keep your information safe, and the control that you retain over your information. We may change this Policy from time to time in order to address new issues and to reflect changes to the Properties, our data collection or use practices, or the applicable law.  We reserve the right to revise or make any changes to this Policy at our sole discretion, and your continued use of the Properties subsequent to any changes to this Policy shall be subject to any such revisions of this Policy, to which you will be bound.  Accordingly, please reread this Policy if the effective date posted on the top of this page has changed.

 

  1. INFORMATION COLLECTED
  2. INFORMATION THAT YOU PROVIDE: You are required to submit some basic information to create an account to use our Properties, such as your name, email address, password, date of birth, gender, height, weight, and when applicable, self-reported health conditions (e.g., colds, flus, or other symptoms). This is the only information you have to provide to create an account with us. You may also provide, at your own discretion, information concerning your medical history, risk factors, smoking status, medications, alcohol use, and other information that may increase the accuracy of our sickness prediction model for you. You may also choose to provide other types of information, such as a profile photo, biography, country information, and community username. If you contact us or provide feedback of any kind, we may collect information that you voluntarily submit such as your name, contact information, and the content of your message.
  3. PAYMENT INFORMATION: You may purchase services or items through the Properties, including payments and transactions with third parties. To make purchases through the Properties, you will need provide information sufficient for identification and verification, such as your name, credit, debit or other card number, card expiration date, and CVV code. This information is encrypted and sent to your card network for processing. Note that third-party payment processors may retain your information in accordance with their own privacy policies and terms.
  4. AUTOMATICALLY COLLECTED INFORMATION: We automatically obtain some information about you when you use our Properties, including information concerning your IP address, internet service provider, user preferences, device, operating system, preferences, geolocation information, and advertisements and responses thereto. We may use browser cookies, which are small files stored on your computer’s memory, in connection with the Properties. Cookies allow us to identify account holders and maximize your experience using the Properties. You may disable or refuse cookies, but you may lose certain functionality in your use of the Properties. We may collect GPS, hotspot, triangulation data through cell tower use, or other location information to provide better services and advertisements. You may disable or refuse to provide your location information, but may lose certain functionality in your use of the Properties.
  5. INFORMATION COLLECTED FOR AND FROM THIRD PARTIES: We may work with third-party services to collect data and other information concerning your use of the Properties for non-advertising purposes, such as helping us understand how visitors use our website, improving our technology, or other purposes. We may also use service providers, like Google Analytics, for digital analyses and search engine optimization. To learn more about how Google Analytics collects and processes data, you may visit their site at google.com/policies/partners. If you choose to connect to our Properties through a third party with whom you have an account, we may receive information from the third party. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friend list. You can stop sharing information from the third party by removing our access to that other service.
  6. HEALTH AND SPECIAL CATEGORIES OF PERSONAL DATA: Health data and other special categories of personal data are subject to the European Union’s General Data Protection Regulation (“GDPR”). We ask for your explicit consent to process this data, and obtain this consent from you prior to collecting the data. You can withdraw your consent at any time using your account settings, or by deleting your account. If you withdraw your consent, you may lose certain functionality in your use of the Products.

 

  1. HOW WE USE INFORMATION

 

  1. GENERAL INFORMATION: We may use information collected from or about you through our Properties for our business purposes including, for example, to:
    1. provide, maintain, and improve the performance of our Properties;
    2. optimize health benefits and help avoid recurrent illness in users;
    3. validate, improve, and personalize our sickness prediction technology;
    4. perform data analyses and research, including through third parties;
    5. troubleshoot against errors and debug our Properties;
    6. perform market research and new product development;
    7. track health data to determine sickness trends and data;
    8. provide relevant marketing, advertising, and deal notifications;
    9. provide you with sickness prediction, health tips, and other notifications; and
    10. facilitate secure payments and transactions.

 

  1. GDPR: For personal data subject to GDPR, we rely on several legal bases that allow us to process data, including:
    1. your consent which you may withdraw at any time;
    2. when processing is necessary to perform pursuant to our Agreement; and
    3. other legitimate business interests, such as in improving, personalizing, and developing the Properties, marketing new or improving existing features or products, and promoting safety and security for our users.

 

  1. HOW INFORMATION IS SHARED

 

  1. PERSONALLY IDENTIFYING INFORMATION: We do not share personal information that can reasonably identify you, or associate your identity with your health data. However, we reserve the right to disclose identifying information (i) to comply with a law, regulation, legal process, or governmental request; (ii) to assert legal rights or defend against legal claims; (iii) to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Properties or the physical safety of any person; or (iv) if we are involved in a merger, sale, acquisition, assignment, or transfer of all or part of our assets, affiliates, lines of business, or products, including at bankruptcy, in which case we will give affected users notice before transferring any personally-identifying information to a new entity.

 

  1. DE-INDENTIFIED INFORMATION: We do share aggregated and/or de-identified information including as provided below:

 

  1. GENERALLY: We may disclose and use aggregated and/or de-identified information such that it cannot reasonably be used to identify an individual.
  2. FOR EXTERNAL PROCESSING: We transfer aggregated and/or de-identified information to our corporate affiliates, subsidiaries, parent companies, service providers, vendors, consultants, agents, contractors, and other partners or service providers who process it in compliance with this Policy, and with any other appropriate confidentiality and security measures. These partners provide us with services, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.
  3. PUBLICLY: We may disclose aggregated and/or de-identified information publicly, such as in public reports about sickness trends, including in social media posts or sickness warnings, or as part of any service provided to users of our Properties.
  4. TO THIRD PARTIES: We may disclose or otherwise provide such aggregated and/or de-identified information to third party partners, affiliates, businesses, or other entities for their own use and legitimate business interests. Our Properties may also include links to third party websites and apps. We do not control third parties or their practices with respect to your information. This Policy does not apply to any information that either you or we provide to third parties.

 

  1. DATA RETENTION

We keep information needed to maintain your account with us – including your name, email address, and password – for as long as your account is active. We keep other information, including your sickness and health data, until you delete your account because we need this data to provide you with accurate and personalized daily sickness predictions and other services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests and legal reasons, including as provided in the HOW WE USE INFORMATION and HOW INFORMATION IS SHARED sections.

 

  1. YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA
  2. ACCESSING YOUR DATA: You may access and control to your personal data through your account settings. By accessing your account, you may view, save, download, or print your personal information, including your dashboard with your sickness prediction score and related health and activity statistics.
  3. EDITING OR DELETING YOUR DATA: You may edit or delete your personal data through your account settings, including without limitation your profile data or your account. If you delete your account, most of your information will be deleted within 90 days, however we reserve the right to preserve de-identified information, or information that was already used or shared. See the HOW WE USE INFORMATION and HOW INFORMATION IS SHARED sections for more information.
  4. OBJECTING TO OR LIMITING DATA USE: We provide options in account settings for you to control our data use. For example, you can limit (i) how your information is visible to other users of the Products; (ii) notifications you receive from us; and (iii) access of third party applications that you previously connected to your account with us. If you live in the European Economic Area, United Kingdom, or Switzerland, you can object to our processing of your information – including as described in the HOW WE USE INFORMATION section – and you have a general right to object to the use of your information for direct marketing purposes. Please also review our use of cookies for your options to control how we and our partners use cookies and similar technologies for advertising.

 

  1. CHILDREN’S PRIVACY POLICY (COPPA)

Our Properties are not directed to children under the age of 13 and children under the age of 13 should not use any of our Properties without parental consent. Datapult also does not knowingly collect or maintain information collected online from children under the age of 13 without such consent.

  1. This terms of this Policy apply to your child’s data, but for the following exceptions:
    1. LOCATION SERVICES: We will not collect location data of any kind, including GPS or triangulation data from cell towers, but will automatically collect and store information about account connectivity such as IP addresses, browser type, language, operating system, and app and mobile device information (including cookie and application identifiers).
    2. HOW WE USE INFORMATION: We use children’s information in the following ways: to provide, personalize, and improve our Properties and services, authenticate identities, to track sickness and health data, and to provide customer support. We also use the data we collect for internal purposes such as troubleshooting, protecting against errors, data analysis and testing, and to develop new features and services,.
    3. HOW INFORMATION IS SHARED: Information that we collect may be shared outside of Datapult in some limited circumstances. We do not share information that personally identifies children to companies, organizations, or individuals outside of Datapult unless one of the following applies:
      1. EXTERNAL PROCESSING: We provide personal information to our affiliates or other trusted businesses or persons for processing based on our instructions and subject to other appropriate confidentiality and security measures.
      2. OWNERSHIP CHANGES: If we are involved in a merger, acquisition, or sale of assets, we will give you notice before transferring any personal information to a new entity.
  • LEGAL REASONS: We may disclose information to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.

 

  1. DELETING YOUR CHILD’S ACCOUNT AND INFORMATION: As a parent, you maintain control of your child’s account. If at any time you wish to stop further collection or use of your child’s information, you can delete your child’s account.

 

  1. CHANGES TO THIS POLICY:

We may change this Policy from time to time at our sole discretion. We will inform you when we revise the Policy and post a new effective date on this website. We encourage you to review our Policy periodically to make sure you understand our practices with respect to your information.

 

  1. CONTACT

If you have any questions or comments regarding our Policy, you may contact us at [email protected][/vc_column_text][/vc_column][/vc_row]