Destroke US Privacy Notice
Effective: January, 2023
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Overview
Destroke, Inc. (Destroke) and each of its affiliates (collectively, “Destroke,” “we,” “us,” “our”) respect your privacy and are committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us.
This Privacy Notice explains our practices with respect to personal data we collect and process about you. This includes information we collect through, or in association with, the Destroke application (the “App”), our website with a home page located at https://www.de-stroke.com (the “Website”), our products and services that we may offer from time to time via our website, our related social media sites, or otherwise through your interactions with us (the app, website, products, services, and social media pages, collectively, the “Services”).
The App educates individuals on performance of the National Institute of Health stroke scale, which is a bedside clinical assessment of signs of stroke (e.g. facial droop, numbness, trouble speaking, and weakness). The App is solely intended as an educational aid for stroke detection and not for medical decision-making or in the place of a medical professional. As such, if you reply to one of our marketing emails or otherwise send a communication to us, such communication does not create a doctor-patient relationship with us. Therefore, please do not send any information that you consider confidential unless you agree to its use as described in this Privacy Notice.
Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.
Categories of Personal Data We Collect
How We Obtain Your Personal Data
How We Use Your Personal Data
Who We Share Your Personal Data With
Other Important Information About Personal Data and the Services
Collection of Personal Data from Children
Third-Party Websites and Services
Business Transfer
Do Not Track
Modifications and Updates to this Privacy Notice
Applicability of this Privacy Notice
Additional Information and Assistance
2. Personal Data We Collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.
You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services. In addition, as noted below in the section captioned “Your Choices”, it is possible to change your browser settings to block the automatic collection of certain information.
a. Categories of Personal Data We Collect
The types of personal data we collect about you depends on your interactions with us and your use of the Services. In the past twelve (12) months, we collected the below categories of personal data from our users:
1. Identifiers such as a real name, postal address, internet protocol address, email address, username, telephone number, date of birth, login details, your (gender, race, ethnicity) if you choose to give this to us, or other similar identifiers.
2. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and
information regarding a consumer’s interaction with an app, internet website or advertisement.
3. Payment card information such as credit/debit card information.
4. Biometric information, including, physiological, biological or behavioral characteristics, such as face imagery, voice patterns, and gestures/motion.
5. Health/Medical information including information about medical conditions, treatments, diagnoses, disability, billing, past
medical history, past surgical history, medications, emergency contact (name, email, phone number), and primary care
provider (name, email, phone number) and other medical records.
6. Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We will not collect additional categories of personal data other than those categories listed above. If we intend to collect additional categories of personal data, we will provide you with a new notice at or before the time of collection.
b. How We Use Your Personal Data
We collect and process your personal data for the following purposes:
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Operational Uses. We make use of your personal and non-personal data for our general business operations, including communicating with you, providing the Services, providing information about our Services, improving the Services, research purposes including conducting publishable research, and complying with applicable legal requirements.
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Third Party Uses. We may disclose personal data to our service providers to allow them to provide services to you, to assist in carrying out your requests and in connection with our marketing efforts.
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Legal Uses. We may disclose information we maintain, including personal data, (1) when permitted or required to do so by law; (2) in response to a request from a law enforcement agency or authority or any regulatory authority; and/or (3) to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.
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Marketing Uses. Marketing our services to you, including sending you messages about the services we offer. We also may contact you about other Destroke activities or news, or about opportunities to support Destroke.
We will not use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.
c. Who We Share Your Personal Data With
We share personal data with the following categories of third parties:
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Our affiliated entities.
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Our partners or prospective partners.
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Service providers we use to help us run our business and deliver our services to you, e.g. third party email providers, storage hosts, website hosts, credit card processing companies and website analytics providers.
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Our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.
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Government agencies or regulations when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.
We do not sell or share your personal information to third parties. We will not share your biometric personal data with third parties unless you have consented to that sharing within the App or we are required to do so by applicable law.
3. Protecting Personal Data
Because security is important to both Destroke and you, we employ reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. If you suspect unauthorized access to your information, you should contact Destroke immediately as provided in the section captioned "Additional Information and Assistance" below.
No method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit to us through the Internet is or will be secure.
4. Retention of Personal Data
We retain personal data for as long as is necessary to fulfil the purpose for which it was collected, as well as to the extent we deem necessary to carry out the processing activities described above, including compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties. For details on the retention periods applicable to specific elements of your personal data, please contact us as provided in the section captioned "Additional Information and Assistance" below.
5. Your Choices
You have choices about certain information we collect about you, how we communicate with you, and how we process certain personal data. When you are asked to provide information, you may decline to do so; if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.
6. Other Important Information About Personal Data and the Services.
a. Collection of Personal Data from Children. We are committed to protecting the privacy of children. The Services are not designed or intended to attract children under the age of 16. The Services do not collect personal information from any person we actually know is under the age of 16. By using the Services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental or guardian consent to do so. A parent or guardian, however, may use the services to establish use of the App for a minor. The parent or guardian is solely responsible for providing supervision of the minor's use of the App. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the use of any information or suggestions provided through the App for the minor.
b. Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies for such third-party services for information about how they collect, use, and process personal data.
c. Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
d. Do Not Track. We use analytics systems that process personal data about your online activities over time and across third-party websites or online services, and these systems may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.
7. Modifications and Updates to this Privacy Notice
This Privacy Notice replaces all previous US disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. Your continued use of the Services following our posting and/or your acknowledgement of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.
8. Applicability of this Privacy Notice
This Privacy Notice governs your use of the Services within the US. This Privacy Notice applies regardless of the means used to access or provide information through the Services.
This Privacy Notice does not apply to information from or about you processed by third parties for their own needs acting as data controllers (including via their services, applications, websites or advertisements) as part of or associated with the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices and under no circumstances are we responsible or liable for any third party’s compliance therewith.
9. Additional Information and Assistance
If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please contact us at: info@de-stroke.com.
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