1. Introduction
We, Accurate, provide this Privacy Notice to explain how we process personal data when you use the Accurate's mobile application or the Accurate's clinical portal designed to help healthcare providers to remotely manage patient’s care and conditions, and any of the data processing or storage features associated with these services. Only patients who have been authorized by their healthcare provider to use ACCHEALTHY may do so, and only healthcare providers who have signed up with us to use ACCHEALTHY may authorize individual healthcare professionals they supervise to use the services. We use the term “personal data” or “personal information” to mean any information relating to an identified or identifiable natural person. This Privacy Notice also provides information about rights you may have under applicable privacy laws.

2. What types of personal data do we collect?
We collect the following types of personal information about patients who use ACCHEALTHY, which we have grouped together as follows:
● Registration Information: We ask you to provide information to register for and activate ACCHEALTHY. This includes your age, date of birth and gender.
● Device Information: This is information collected from any devices you connect with ACCHEALTHY, including information about your mobile device or computer (e.g., IP address, login credentials) and the type of Accurate's device used to capture your data.
● Usage Information: This is information about how you use ACCHEALTHY when you are logged into ACCHEALTHY. With your consent as provided within the mobile application, we also collect your geolocation information.
● Health Information: This is information about your physical activity and health (the categories of data collected depend on the type of device used to capture your data and may include oxygen saturation, respiration rate, perfusion index, pulse rate, Pleth Variability Index, temperature, and current/past trends regarding these metrics).

3. From what sources do we collect personal data?
If you are a patient, we collect Registration Information, Device Information, Usage Information and Third-Party Contact Information directly from you. We also collect Health Information from medical devices that you connect with ACCHEALTHY. 

4. For what purposes do we use personal data?
We use all of the categories of personal data we collect as necessary to:
● Provide you with ACCHEALTHY and manage your relationship with us;
● Respond to or fulfill your requests;
● Ensure the security of our services;
● Analyze the performance of, troubleshoot issues with our product and services;
● Analysis of raw technical and hardware device data for research, development, algorithms and statistical purposes in order to improve user experience, services, usability and effectiveness, and to develop new features for both the ACCHEALTHY product and new products;
● Exercise our legal rights, including to defend against claims and advance our legal interests, protect against fraudulent, harmful and illegal activity; and
● Comply with applicable laws such as data protection and consumer laws.  

5. To whom do we disclose, share or transfer personal data?
Personal data of patients who use ACCHEALTHY may be disclosed, shared or transferred to:
(i) healthcare professionals whom your healthcare provider has authorized with your consent to access and download your personal data for the purposes of managing your care and conditions. Once authorized by you, these healthcare professionals and healthcare providers will have the option to locally download and access your personal data without the use of ACCHEALTHY; and
(ii)  third parties selected by you with whom you wish to share your personal data. If you designate a contact to receive your personal data, we may disclose your personal data to that contact until you remove them as a contact in the mobile application or deactivate your ACCHEALTHY account.

Personal data of healthcare professionals who use ACCHEALTHY may be disclosed to the hospital or other healthcare provider that supervises you for the purposes of administering your healthcare provider’s use of ACCHEALTHY.

In the event of a Business Transfer, we may transfer personal information to the acquiring or surviving entity in accordance with applicable law.  

6. How long do we store personal data?
In general, we store personal data only as long as necessary to fulfil the purpose for which we collected it (the “General Retention Period”), except in the following situations:
(1) where applicable laws require us to retain your personal data for a legally prescribed period beyond the General Retention Period. In these cases, we will keep that personal data for the legally prescribed time period before deleting it;
(2) where your personal data is relevant to potential legal claim(s) by or against us. In these cases, we will keep that personal data for as long as the legal claim(s) can be made or, if it has been made, for as long as the personal data is relevant to the resolution of the claim(s) or any appeal thereto;
(3) if we are instructed by a court order, subpoena, or other legal directive to retain your personal data; and
(4) we will retain your personal data for a reasonable period of time necessary for us to verify the purposes for which we collected your data no longer apply and to delete the data following such verification.  If any of these exceptions apply to certain personal data, we will retain personal data for as long as the exception applies. 

7. How do we protect personal data?
We have taken steps intended to protect the personal data we collect from loss, misuse, and unauthorized processing, including entering into data protection agreements with our service providers and encrypting personal data in transit and at rest. Please note, however, that while we have endeavored to create a secure and reliable online experience for users, the confidentiality or accuracy of any communication or material transmitted to or from us over the Internet cannot be guaranteed. It is your responsibility to safeguard the username and password that you use to access ACCHEALTHY, and to notify us immediately at the contact information below if you ever suspect that your username or password has been compromised.

8. Your Rights
You may have rights under applicable privacy laws, which may include to access, review, modify or delete the personal data we hold about you, and to access a copy of any privacy-related consent you have given to us.

To submit a request to exercise any rights you may have under applicable privacy laws, please contact us using the contact details under “Contact Us” below and clearly describe your request. If you have rights under applicable privacy laws and your request complies with the requirements under such laws, we will give effect to your rights and respond within any mandatory timeframes as required by law.  

10. Effect of this Privacy Notice; Changes
This Privacy Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may revise this Privacy Notice from time to time by making the revised document available through ACCHEALTHY and updating the “last updated” date above. We will also obtain consent from you where required by applicable law before processing your personal information for any purpose incompatible with the purposes set forth in prior versions of this Privacy Notice.

11. Contact Us
If you have any privacy-related inquiries or concerns, please contact our privacy department at privacy@accbiomed.com.