January 1, 2022
RAIsonance, Inc. and AudibleHealthAI Inc (“RAIsonance”, “AudibleHealth AI”, “we”, “us”, or “our”) wants you to use our AudibleHealth Dx mobile application (the “App”) secure in the knowledge that we have implemented fair and transparent information policies and practices designed to protect your privacy.
- Information We Collect
- How We Use Your Information
- How We Share Your Information with Others
- Protection of Your Information
- Retention of Information
- Your Privacy Choices
- Contact Information
- Privacy Rights of California Residents
1. INFORMATION WE COLLECT
When you use our App, we may collect the following types of information:
- Contact Information. We collect the contact information you provide when you initially log into our App, including your name, email address, home address, and phone number. We also request contact information about your healthcare provider; however, this information is optional.
- Demographic Information. We collect certain demographic information you provide, such as your age, gender, race, ethnicity, and status as a smoker.
- Application Account Credentials: When you register an AudibleHealth Dx account, we will collect your account credentials, including a username (email address) and password.
- Cough Sound Signature. We collect your forced cough vocalization when you provide it to us, which may require you to grant permission for our App to temporarily access your device’s microphone.
- Submitted Content. Additionally, where we provide the functionality within our App, you may choose to submit additional information to us, such as a photograph. Submissions of photographs may require you to grant permission for our App to temporarily access your device’s camera or photo library.
- Usage Data. When you use our App, we may automatically receive certain information about your use of the App and your mobile device, including device type, operating system and version, precise location data, the time, date, and duration of your use of the Apps, information about your interactions with the Apps, and diagnostic or performance information.
- Test Result. When you use our App, we will provide you with a test result which is available to you through a secure, encrypted Patient Portal. To retrieve this result, we will email you a link as soon as the analysis for your test has been completed.
Please note that we may supplement the information we collect through the App with information we receive from third parties and information we collect through other means, such as offline or through our website.
2. HOW WE USE YOUR INFORMATION.
We may use the above-mentioned information for the following purposes:
- To Provide the Services. We use the above information in order to provide our services to our users.
- To Maintain and Improve Our App. We use the information we collect to maintain and improve the App, as well as to develop new apps, products, or services. For example, we may use usage data to troubleshoot and protect against errors; to assist you if you contact us for technical support; to perform data analysis and testing; to improve the functioning and operation of our App; and develop new features for our App.
- To Communicate with You. We may use your contact information to communicate with you, including to provide technical support concerning our App and related services, to market and promote our products and services, or to otherwise respond to you when you contact us.
- To Comply with the Law. We may use the information to comply with our legal obligations. For example, we may use the information to provide reports to regulators, including applicable public health authorities.
- Anonymized and Aggregated Data. We may aggregate and anonymize the data we collect so that it cannot reasonably be used to identify an individual, and we may use such anonymized and aggregated data for a number of purposes, such as to generate and/or publish reports about our products and services, or as part of the benchmarking information we provide to authorized partners, researchers, or public health authorities.
- To Promote Safety and Security. We use the data we collect and receive to promote the safety and security of our App and our services, our users, and other parties. For example, we may use the above data to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
3. HOW WE SHARE YOUR INFORMATION WITH OTHERS
- Healthcare Providers. If a healthcare provider ordered your test, or if you provide your healthcare provider’s contact information, the provider will receive your test results by accessing a third party, encrypted Laboratory Information System. As required by law, if your test is positive, we will report that result to the appropriate public health authority for your state or territory, as well as to the Centers for Disease Control (CDC), via a third-party test results reporting partner.
- Service Providers. We use service providers that perform functions on our behalf, including, for example, our cloud infrastructure and hosting service provider, our Laboratory Information Services provider, our public health reporting partner, and our patient portal information services partner.
- Anonymized and Aggregated Data. We may share information that has been anonymized and aggregated with third parties, including, for example, as part of the benchmarking information we provide to authorized partners, researchers, and public health authorities.
- Change of Control. We may share your information if we are involved in a merger, acquisition, or sale of assets, but we will continue to take measures to protect the confidentiality of such information.
- Law Enforcement / Protection. We reserve the right to share information about you and your use of the App where we believe that such disclosure is necessary to comply with a legal requirement, such as a subpoena or court order, or to protect our rights or property, or the rights or property of others.
- Consent. We may share your information in any other manner to which you consent, including, for example, if you use the App to provide a third party with your test results, in which case we will only share the results of such test, the date and time such self-check was initiated, your name, your photo, and a unique identifier generated by the App.
- Other Parties: If you received your test from your employer, educational institution, insurer, health care provider, or other entity with whom you have a relationship, you acknowledge that they will be able to view your test results without further notification to you.
4. PROTECTION OF YOUR INFORMATION
We and our service provider partners make reasonable efforts to guard the information we collect from and about you against accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, however, we cannot guarantee the security of information provided over the Internet or stored in our databases. Any transmission of information is at your own risk. You agree that we are not liable for the unauthorized release of your information unless such release was the result of our gross negligence or willful misconduct.
The safety and security of your information also depends on you. You are responsible for maintaining the confidentiality of your account and are responsible for all activities that occur under your account. Please notify us immediately of any unauthorized access or use of the App, or the loss or unauthorized use of your account information (e.g., username or password).
5. RETENTION OF INFORMATION
We will retain the information we collect for the length of time needed to fulfill our business and legal purposes outlined in the section titled “How We Use Your Information” above unless a longer retention period is required or permitted by law.
6. YOUR PRIVACY CHOICES
You can control the information we collect and use in the following ways:
Location Data: You can disable location-based services on your mobile device by adjusting the settings on your device. This will prevent our App from accessing your location information. Note that some services may not be available if you disable location-based services.
Email Communications: You can unsubscribe from our marketing emails by clicking the unsubscribe link in the footer of such email, or by submitting your request to opt-out here firstname.lastname@example.org
AudibleHealth Dx Accounts: You can keep your contact information accurate and up to date by logging into your account on our App. If you wish to cancel your account, email us at email@example.com
If you are a California resident, you can learn more about your privacy rights below in section titled “Privacy Rights of California Residents”.
We do not knowingly collect personal information from children under the age of 13 unless we obtain parental consent first. If we learn that we have collected personal information from children under the age of 13, then unless we obtain parental consent to use or maintain that information, we will delete it.
8. CONTACT INFORMATION
6400 S. Fiddlers Green Circle, Ste 350
Greenwood Village CO 80111
10. PRIVACY RIGHTS OF CALIFORNIA RESIDENTS
As a resident of California, you have rights under the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”) relevant to your Personal Information (as defined under the CCPA), as well as other laws. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.
California Consumer Rights Under the CCPA: If your Personal Information is subject to the CCPA, you may have certain privacy rights with regard to that information. You may have the right to:
- Request that we provide you access to the following no more than twice in a 12-month period:
o the categories and specific pieces of Personal Information that we have collected about you;
o the categories of sources from which the Personal Information is collected;
o the business or commercial purpose for collecting or sharing your Personal Information;
o the categories of third parties with whom we share your Personal Information; and
o the categories of Personal Information that are sold (as defined under the CCPA) and the categories of third parties to whom the Personal Information was sold.
- Request that we delete your Personal Information, subject to exceptions under the CCPA or other applicable law; and
- Request that we not “sell” your Personal Information by opting out of the sale of your Personal Information.
California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CCPA, as described in this section. We will not discriminate against you because you have exercised any of your rights under the CCPA.
How to Submit a Request Access to or Deletion of Your Personal Information:
If you wish to exercise your right to request access to your Personal Information or deletion of your Personal Information please submit your request through our toll free number: 888-285-4943 or by email firstname.lastname@example.org To ensure we can verify your identity and help us respond to your request please provide us with your full name, email, and home address, and clearly indicate which of the rights conferred by the CCPA you wish to exercise.
We are required to provide you with access to your Personal Information or delete your Personal Information only in response to verifiable consumer requests. We will compare the information you have provided as part of submitting the request to any information we may have in our possession in order to verify your request. We may also contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used only for verification purposes and responding to your request.
How to Opt Out of the Sale of Your Personal Information:
We do not sell your Personal Information; however, we are required to let you know that you have the right to opt out of the sale of your Personal Information if we ever engage in such activity.
Requests Made Through Agents:
Please note that you may authorize an agent to exercise any of these rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of you and your agent’s identity and authorization.
Categories of Personal Information Disclosed for a Business Purpose:
We share Personal Information about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the products and services you seek from us. For more information about the business purposes for which we disclose Personal Information, see the section titled “How We Share Information with Others” and see the section titled “Information We Collect” for what types of information may be shared.
Additional California Privacy Rights:
California residents may also ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make one request per calendar year.
To make this request, you may contact us at email@example.com. In your request, please include a subject line that states “CA Shine the Light Request”, state that you are a California resident, and provide a current California address for our response.