Select Page

USA PRIVACY POLICY

EFFECTIVE DATE: 1 July 2018

1. PURPOSE OF POLICY

We are committed to protecting your privacy. We created this Privacy Policy (“Policy”) to give you confidence as you visit and use the rewellio website and mobile application, and any other related services provided by us (collectively, the “Service”). This Policy covers how we collect, use, store, and share your information when you use our Service. The provisions of our Terms of Use [link einfügen] apply to this Policy as well. All references to “we”, “us”, “our”, or “rewellio” refer to rewellio Inc., a [Recht der Gesellschaft einfügen, zB Delaware]company. All references to “you”, “your”, “user”, “Therapist”, and “Patient” shall have the meanings ascribed to them in our Terms of Use. Any capitalized terms not defined herein shall have the definition ascribed or attributed thereto in ourTerms of Use.Do not hesitate to contact us at info@rewellio.com if you have any questions or want to discuss this Policy.

 

2.  HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”)

Our Service is fully HIPAA-compliant, meaning that our Service meets the standards set for protecting sensitive patient data as directed by HIPAA. By agreeing to access the Service, the Therapist agrees to the terms of the Business Associate Agreement found here [link einfügen], which are hereby incorporated into the Terms and Policy.

 

3. INFORMATION WE COLLECT AND HOW WE USE IT

Required Information You Voluntarily Provide Us. 

When you sign up for an account through the Service, you will be required to provide us with various information that is, or may be, considered personally identifiable information.

For Patients, this information may include: 

–      your first and last name; 

–      your telephone number;

–      your date of birth;

–      your sex;

–      your preferred language;

–      your email address;

–      your physical or mailing address; 

–      your therapist / therapy institution and

–      certain medical information, including any diagnosis you have been given and any existing course of therapy to treat such diagnosis.

For Therapists, this information may include:

–      your first and last name and name of the therapy institution you work at; 

–      your address;

–      your telephone number;

–      your date of birth;

–      your preferred language; and

–      your email address.

Information We Collect With Your Permission as You Use the Service.

In addition to the information you voluntarily provide us, if Patient gives his or her permission, we will collect certain of Patient’s medical information relating to Patient’s use of the Service (referred to herein and in the Terms of Use as the “Data”), including signals from the Patient’s brain to the Patient’s hand, and Patient’s improvement over time as a result of using the Service. Data may be collected from either Patients or Therapists, and is collected for the purpose of providing and improving the Service. While the Data is provided to us only with your permission, some aspects of the Service may not be available if you choose not to provide us with the Data. 

How We Use Your Information

We use this information for the purposes described in this Policy and in our Terms of Use andin furtherance of providing you with the core aspects of the Service. Additionally, by registering for an account via the Service, you agree that we may use this information, including your email address, to send to you information regarding Updates to the Service, problems with the Service, and any other communications pertaining to the functionality of the Service.

Cookies.

We use cookies to remember you as a user of the Service and to streamline the functionality of the Service. These are first party cookies, not third party cookies, meaning that the cookies are only used to track your activity on the Service, and not on third party sites or services. 

We automatically collect certain information about you as you use the Service, including, without limitation, through cookies on the rewellio website and in-app tracking when you use our App. This may include information about the way you use the Services, the parts of our Services you use.

Other Anonymous Data We Collect. 

When you use and visit the Service, we may also use third-party services, such as Google Analytics and Unity3d Analytics, which use cookies to collect generic, anonymous information that does not identify you. We use this information to better understand how users interact with the Service and to improve your user experience while using the Service. You may be able to opt out of such third-party services by contacting such third parties. 

Do Not Track Signals.

To the extent that we receive any Do-Not-Track signals, we will not comply with them.

 

4. HOW WE SHARE YOUR INFORMATION

Information Shared By You Through The Service.

Patients may share their personal information, including the Data, with Therapists. Likewise, Therapists may share their personal information with Patients. 

Our Personnel And Vendors. 

To be able to effectively provide you with the Service, and to improve the functionality of the Service, we may disclose your information to our personnel, including our employees, contractors, agents, vendors, and other similar persons or entities, to the extent that such persons or entities have a need-to-know such information in furtherance of the Service. In the event we charge a Subscription Fee, we may also share information with our vendor who provides payment processing.

Sale of Company or Assets. 

In the event that we sell all or substantially all of our company or its assets, including the user information collected through our Service, we may transfer your information to the acquiring company. However, we will notify you before we do so.

Other Third Parties.

In addition to our practices described above, we may share your information if we have a good-faith belief that such action is necessary to (1) comply with the law (see the section below on “Government Requests”), (2) protect and defend the rights or property of rewellio, or (3) prevent an emergency involving danger of death or serious physical injury to any person. We will notify you prior to disclosing your information pursuant to this section.

Aggregated and Anonymized Information.

At times, we may share Patients’ aggregated and anonymized information with third parties.  

 

5.STORING YOUR INFORMATION

Storage, Modifications, and Retention of Your Information. 

We use state-of-the-art administrative, technical, personnel and physical measures to safeguard your personal information against loss, theft or unauthorized use, disclosure or modification. 

We will securely store your personally identifiable information on third-party servers, and will do so for as long as it is needed to provide the Service. We may not know if you have stopped using the Service so we encourage you to contact us if you are no longer using the Service. You can change some of your information through the account settings provided on the Service. If required by applicable law, we may retain your information for such period as may be required by such law. To continue to provide an effective service, we may store non-personally identifiable information perpetually and may anonymize your personally identifiable information and store that anonymized information perpetually. Additionally, we use third party services and do not control their practices related to storage and retention of your information.

Security. 

We use reasonable efforts to secure your information and to attempt to prevent the loss, misuse, and alteration of the information that we obtain from you. For example, we have implemented a strict data security policy, we train our personnel on privacy issues, we communicate only via https, and we review the privacy practices of new products and services that we integrate into our Service. Relatedly, we require our personnel to sign confidentiality agreements that extend to your personal information. In addition, we store your personal information in locked rooms. We also use reasonable technical safeguards such as secure hosting provided by industry leading third party vendors, to secure your personal information. However, loss, misuse, and alteration may occur despite our efforts to protect your information. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration.

Review and Deletion of Your Information. 

If you would like to review what personal information is collected from you, request that such information not be collected, request that such information be changed, or request that such information be deleted, please contact us at info@rewellio.com.

 

6. GOVERNMENT REQUESTS

From time to time, we may receive requests from government agencies to obtain information about our users. In handling such government requests, we greatly value the privacy of your information, however, we may turn over your information in accordance with such requests if we believe such action is warranted. We will notify you prior to disclosing your information pursuant to this section.

 

7. THIRD PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL

Our Service utilizes third party services as part of the functionality of the Service. We may share your information with third parties as explained in this Policy. We have no control over such third parties. We encourage you to review the privacy practices of such third parties. We make no guarantees about, and assume no responsibility for, the information, services, or data/privacy practices of third parties.

 

8. CHANGES TO THIS POLICY

We reserve the right to change this Policy from time to time, with or without notice to you. If you continue to use the Service, you consent to the new Policy. We will always have the latest Policy posted on the Service.

 

9. PLEASE REACH OUT TO US WITH ANY QUESTIONS OR FEEDBACK

If you have any questions or comments about this Policy or our Service, please feel free to contact us by email at info@rewellio.com.