Privacy Policy

Last Updated: March 10, 2021   

 

1. INTRODUCTION

VitalTracer Ltd., (VitalTracer, we, us”) has created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information collected through https://vitaltracer.com/including its subpages (the “Website”) and in the course of providing our personalized medical smartwatches that monitor vital signs and other products and services offered by us from time to time through our website (see furtherTerms of Service) or by other means.  This Privacy Policy also applies to personal information collected through any mobile applications or other sites offered by us that display this Privacy Policy and to information we collect when you engage with us on social media, or otherwise interact with us (collectively with use of the Website, the “Services”). Please review this Privacy Policy carefully.

By using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

 

2. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information which can be used to identify an individual (“Personal Information”).  We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

  • Contact Data includes name, billing address, delivery address, email address and telephone numbers.
  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us and orders you have placed.
  • Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Usage Data includes information about how you use our Website and Services, such as the buttons, controls, products and ads you click on, pages of our Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website, App and the webpage and app(s) you go to next.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

This Privacy Policy does not apply to the practices of companies that we do not own or control, including third parties that may resell VitalTracer products. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy.

3.COLLECTION AND USE OF PERSONAL INFORMATION

3.1 Profile and Transactional Information

In order to make purchases through the Website, you will need to provide certain contact and payment information to us such as your name, email address, phone number, shipping address, and payment information as well as any other personal information requested on our purchase/transactional pages. We use this Personal Information to process your purchase requests and deliver your purchases. Purchase information such as shipping address and billing address is used to process and deliver your purchase. VitalTracer may also keep a record of and store your past purchases and pending purchases.

3.2 Use of Personal Information

 VitalTracer uses Personal Information to:

  • provide, operate, maintain and improve the Services;
  • provide and deliver the Services, process and complete transactions, and send you related information, including confirmations and invoices;
  • respond to comments, questions, and requests and provide customer service and support;
  • communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partners;
  • investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
  • monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes;
  • link or combine with other information we receive from third parties to help understand your needs and provide you with better service; and
  • for other purposes which we will notify you about and seek your consent.

4.COOKIES & INFORMATION COLLECTED AUTOMATICALLY

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this automatically-collected information as “Device Information”.

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies: 

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.

The Website uses “cookies” to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your email address or identity.

We may use “persistent cookies” to save your registration ID and login password for future logins to our service. We may use “session cookies” to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. We also use session cookies to verify your age, keep track of items you have viewed and store such items in your cart while you are browsing.

The Website may also use technologies such as beacons, scripts, and tags. These technologies may be used for analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base as a whole. Various browsers may offer their own management tools for removing these types of tracking technologies. We may also use third-party ad companies to help provide some of our advertising services. These third parties may place cookies on your computer and collect data about your online activities across websites or online services when you are logged into the third-party service, including for targeted advertising.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

 You can opt out of targeted advertising by using the links below: 

  • Facebook: https://www.facebook.com/settings/?tab=ads
  • Google: https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

4. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

 VitalTracer processes and stores its data, including Personal Information, on servers located in Canada and the United States. VitalTracer also transfers data to the following third-party service providers. By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.

6. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

6.1 Service Providers and Business Partners

We may from time to time employ third parties to perform tasks on our behalf and we may need to share Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage includes third party companies and individuals employed by us to facilitate our Services, including the provision of database management, payment processing and customer relationship management tools.

6.2 Business Transfers

If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law. 

6.3 With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

6.4 As Required by Law

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

  • satisfy any applicable law, regulation, legal process or governmental request; enforce our contracts or user agreement, including investigation of potential violations hereof; and
  • detect, prevent, or otherwise address fraud, security or technical issues.

The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

7. RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

8.  INTERNATIONAL USERS

If you are visiting the Website from outside of Canada, please note that you are agreeing to the transfer of your information to Canada and the United States and for it to be processed globally by our third-party service providers. By providing your information you consent to any transfer and processing in accordance with this Policy.

9. ACCESS, CORRECTION AND ACCURACY

 You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

 

10. CALIFORNIA PRIVACY RIGHTS 

This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act(the CCPA).

 For more details about the Personal Information VitalTracer has collected over the last 12 months, please see the section “Information you provide us” above. We collect this Personal Information for commercial purposes described above. VitalTracer does not sell (as that term is defined in the CCPA) the Personal Information we collect.  

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” or “sharing” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

11. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.

12. ADDITIONAL INFORMATION 

Questions regarding this Privacy Policy or VitalTracer’s privacy practices should be directed to us at:

 

Privacy Officer at VitalTracer

804-5740 Av Rembrandt, Côte-Saint-Luc, QC H4W 2Z2, Canada

Email: [email protected] / Phone: 613-276-1413