CLEERLY PRIVACY NOTICE
This privacy notice describes how Cleerly, Inc. (‘we’, ‘us’), collects and processes information about you on our website at cleerlyhealth.com or any other of our websites or mobile applications that link to this policy; how we use and protect this information, and your rights in relation to this information.
This privacy notice applies to the personal information we collect or process about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.
Personal Information We Collect
We collect personal information about you from a variety of sources, including information we collect from you directly when you provide it to us through the website as well as information we collect automatically when you visit the website. We may collect information about you over time and across websites following your visit to our website.
The categories of information that we may collect include the following:
- Identifiers (e.g. name, phone number, email address, postal address or mobile number);
- Information you may upload to our site related to the use of one of our medical devices;
- Information you may provide to us about your interest in our devices or other products or services;
- Internet or other electronic network activity information that we collect automatically (e.g. data relating to your browsing of our site or other sites that is collected through various technologies such as pixel tags and cookies);
The following additional categories of information that we may collect are only applicable for users interested in Cleerly’s services and partnership with Heartbeat Health, Inc (“Heartbeat Health”).
- Information you may upload or provide to us regarding your status of medical insurance coverage
For more information about how Heartbeat Health uses information that is shared or provided, please click here.
We also may supplement the personal information we have about you with information from third party sources. We also use third-party online analytics services, including Google Analytics and Showpad, to collect information about your usage. For more information about how Google uses information from sites or apps that use Google Analytics, click here. For more information about how Showpad uses information from sites or apps accessed by Showpad, click here.
How We Use Your Personal Information
We use your personal information for various purposes associated with running our business, including to:
- contact you to address questions you may have;
- to send you information regarding our services, including updates and newsletters;
- if you are a job applicant submitting your information to us, to consider your application for employment with us;
- provide information to service providers and business partners regarding your interest in Cleerly’s services; and
- comply with legal obligations to which we are subject.
In some countries, we may be required to have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
- to respond to your requests for more information about our products and services, for example, when you contact us through our website;
- to fulfill our contractual obligations to you, for example to ensure that our invoices are issued correctly, and for ensuring you are able to access our services as appropriate;
- to comply with our legal obligations to you; and
- to meet our legitimate interests in operating our business, for example to ensure that our services are appropriate to the needs of users of our devices.
Your Rights and Options Regarding Your Personal Information
You may have certain rights regarding your personal information, subject to local (i.e., certain country or state) laws. These may include the following rights to:
- access your personal information, including the categories and sources of personal information we have collected about you and with whom we have shared them;
- correct the information we hold about you;
- erase your personal information;
- restrict our use of your personal information;
- object to our use of your personal information;
- receive an explanation of the business or commercial purpose for collecting personal information;
- receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
- lodge a complaint with your local data protection authority (i.e. a country-specific privacy regulatory agency).
Please note that we may require additional information from you to honor your requests.
If you would like to discuss or exercise such rights, please contact us as described in the “Contact Us” section below.
We do not currently respond to “do not track” signals from browsers. If you block cookies, certain features on our sites may not work.
We may share your personal information with third parties under the following circumstances:
- Service providers and business partners. We may share your personal information with our service providers and business partners that perform services on our behalf or in support of our operations.
- Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
We do not share information as described in Cal. Civ. Code § 1798.140(t), but we may share all of the categories of personal information that we collect as described in section 1 above for business purposes, as described in Cal. Civ. Code § 1798.140(d).
Information Security and Storage
We implement technical and organizational measures to protect the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing, however we cannot guarantee security for data collected over the Internet.
International Data Transfer
If you are the resident of a country of a jurisdiction such as the United Kingdom or the European Union, please note that your personal information may be transferred to, stored, and processed in a country that your home country does not regard as ensuring an adequate level of protection for personal information.
We have, as applicable, put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements so that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
Where applicable, Cleerly, Inc. is the controller responsible for the personal information we collect and process.
If you have questions or concerns regarding the way in which your personal information has been used, please contact us at firstname.lastname@example.org.
Changes to the Policy
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date below. Changes and additions to this privacy notice are effective from the date on which they are posted.
Effective: Oct 28, 2022