PRIVACY POLICY

Last updated: March 31, 2020
This GaitReady Service Privacy Policy (the “Policy”) describes how Ducere Technologies Inc. and AARP Services, Inc. (collectively, “we,” “our,” or “us”) collect, use, and share information, including Personal Information, received in connection with your access to and use of the GaitReady Service. The “GaitReady Service” includes the mobile application (the “GaitReady App”) and Lechal Insoles (from Ducere Technologies Inc.), along with associated firmware, applications, accessories, software, websites, APIs, products, services, and visit us at www.gaitready.com/aarpmedsupp/, or +1-844-526-8298.

In this Policy, “Personal Information” means any information that directly or indirectly identifies, describes, or can reasonably link to you or your household. For instance, this could include, among other things: an identifier, such as your name, email address, online identifier, or IP address; biometric information, such as information about your gait, health, exercise habits, or other physical patterns or characteristics; geolocation information; and internet or similar network activity.

To the extent that information we collect is health data or another special category of Personal Information, we ask for your explicit consent to process this information. We obtain this consent separately when you take actions leading to our obtaining the information.

Please read this Policy carefully. By using or accessing the GaitReady Service, or by providing Personal Information to us on or through the GaitReady Service, you acknowledge that you have read, understand, and agree to the terms and conditions of this Policy. If you do not agree, your choice is not to use the GaitReady Service.

This Policy addresses the following:
  • How to contact us
  • Information we collect
  • Cookies
  • How we use information
  • How information is shared
  • Your rights to access and control your personal information
  • Data retention
  • Analytic services provided by others
  • Information Security
  • Additional Information
  • Changes to this policy

How to Contact Us

If you have questions, suggestions, or concerns about this Policy, or about our use of your information, visit us at www.gaitready.com/aarpmedsupp/, or +1-844-526-8298.

Information we collect

When you use the GaitReady Service, we may collect Personal Information from you in a variety of ways, including when you provide it to us voluntarily, automatically when you use the GaitReady Service, or when we receive it from other sources. This section lists the types of information we may collect.

INFORMATION YOU PROVIDE US

You may provide Personal Information to us voluntarily when you:

  • Register for a GaitReady account. Some information is required to create an account with the GaitReady Service, including your first and last name, phone number, and email address, as well as a strong password. This is the only information you must provide to create an account.
  • Use additional GaitReady account features. To help improve your experience or enable certain features of the GaitReady Service, you may choose to provide us with additional information, such as your age, gender, height, weight, and information about your experience with falls or unsteadiness.
  • Contact us. If you contact us, we collect the information you submit such as your name, contact information, and message.


INFORMATION WE RECEIVE AUTOMATICALLY

We and our third-party service providers may collect information from you automatically as you use the GaitReady Service, including information from your use of the Lechal Insoles as well as information about your online activities over time and across third party websites or other online services.

We automatically collect the following information when you access the GaitReady Service:
  • Lechal Insole information. Any time you wear the Lechal Insoles, embedded sensors automatically collect gait and balance information and provide that data to the GaitReady App to estimate a variety of metrics including gait, balance, activity level, and walking patterns. When the GaitReady App syncs with our software, data recorded on the app and the Lechal Insoles is securely synched with our servers.
  • Usage information. When you access or use the GaitReady Service, we receive certain usage data through cookies or other automated data collection technologies (collectively referred to as “cookies”). This includes information about your interaction with the GaitReady Service, for example, when you view or search content, install applications or software, create or log into your GaitReady account, pair your mobile device to your account, or open or interact with the GaitReady App.
  • Device information. We also may collect data through cookies about the devices and computers you may use to access the GaitReady Service, including IP addresses, browser type, language, operating system, mobile device information, the referring web page, pages visited, and cookie information.
See the section on "Cookies" below for more information about the automatic data collection technologies we use and the choices you have for opting out.

INFORMATION WE RECEIVE FROM THIRD PARTIES

We may work with third parties, such as employers and insurance companies that offer the GaitReady Service to their employees and customers. In such cases, those companies may provide us with your name, email address, or similar information (like a telephone number or subscriber ID) so that we can invite you to participate or determine your eligibility for particular benefits, such as discounts or free services. Such information is not considered protected health information under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

Cookies

The automatic collection of data (such as device or usage information) is a common practice that supports digital services, and is used to provide customized digital experiences, as well as for analytics and system administration purposes.

A “cookie” is a small data file that a website sends to and stores on your device that allows the site to recognize your browser or store information or settings. The cookie itself does not contain personal data, but can be read by the entity that placed the cookie and may allow it to associate your device to personal data. We may use “persistent” and/or “session” cookies. Persistent cookies are stored on your computer and used for various purposes by your browser on subsequent website visits. Session cookies are held temporarily in your computer’s memory and erased after you end a browser session or shut off your computer.

HOW TO CONTROL COOKIES

Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Consult the “Help” feature of your browser for specific instructions.

Third parties that perform services for us also may use their own cookies or other automated data collection technologies. We do not control use of these cookies used by such third parties and expressly disclaim responsibility for information collected through them.

How we use information

We use the information we collect for the following purposes.

PROVIDE AND MAINTAIN THE GAITREADY SERVICE

Using the information we collect, we are able to deliver the GaitReady Service to you and honor our Terms of Service with you. For example, we need to use your information to provide you with your dashboard tracking your exercise, activity, and other trends and to provide you customer support.

IMPROVE, PERSONALIZE, AND DEVELOP THE GAITREADY SERVICE

We use the information we collect to improve and personalize the GaitReady Service and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services.

We also use your information to make inferences and show you more relevant content. Here are some examples:
  • Information like age, gender, height and weight are used to compare your assessment results to the normative population of users, and allows us to improve the accuracy of the data and statistics collected like gait and balance metrics.
  • Based on your assessments and monitoring of your data (exercise activity, gait and balance metrics), we personalize your exercises to help you improve your mobility, strength and balance.
  • For the purposes of providing relevant information to you; such as, notification of goals you achieved, trends in your activity, reminders about recommended exercise and assessments, changes in gait and balance, and useful content and information.
COMMUNICATE WITH YOU

We use your information when needed to send you notifications and respond to you when you contact us.

PROMOTE SAFETY AND SECURITY

We use the information we collect to promote the safety and security of the GaitReady Service, users of the GaitReady Service, and other parties. For example, we may use the information to authenticate users, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

We use cookies and similar technologies for the purposes described above.

How information is shared

We may share non-Personal Information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, or to parties under agreement with us.

We do not share your Personal Information except in the limited circumstances described below.

WHEN YOU AGREE OR DIRECT US TO SHARE

You may also authorize us to share your information with others. For example, you may authorize us to share information regarding your use of the GaitReady Service with third parties that you designate or with an employer or insurer when you opt to participate in their wellness programs. Remember that when your information is shared with such third parties, their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with such third parties by writing us at support@lechal.com or calling us at +1-703-955-4805.

FOR EXTERNAL PROCESSING

We transfer information to our corporate affiliates, service providers, and other authorized vendors who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These authorized vendors provide us with services for customer support, information technology, data analysis, research, and surveys.

FOR LEGAL REASONS OR TO PREVENT HARM

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the GaitReady Service or the physical safety of any person.

Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.

If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of Personal Information and give affected users notice before transferring any Personal Information to a new entity.

Your rights to access and control your personal information

We give you profile settings to access and control your Personal Information, as described below.

Accessing Historical Data. You can access your assessment reports from the profile section of the app. This information is shared with you via an email provided by you.

Editing and Deleting Data. Your profile settings let you change and delete your Personal Information. For instance, you can edit or delete the profile data you provide and delete your account if you wish by writing us to at support@lechal.com.

If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm, including as described in the “How Information is Shared” section above.

Objecting to Data Use. We give you tools to control our data use. For example, using the notification settings on your mobile device, you can limit the notifications you receive from the GaitReady Service. You can choose to share your assessment results with your friends and family by emailing them the report. This email address is not stored on our systems.

Please note this Privacy Policy and the GaitReady Service are governed by the laws of the United States. The GaitReady Service is to be used only in the United States. The GaitReady Service is not be used by a resident of the European Union.

Data retention

We keep your GaitReady account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the GaitReady Service, we delete the data after it is no longer needed for the feature. We keep other information, like your exercise or activity data, and we use this data to provide you with your personal statistics and other aspects of the GaitReady Service. We also keep information about you and your use of the GaitReady Service for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the “How We Use Information” and “How Information Is Shared” sections.

Analytic services provided by others

We use tools of and might work with authorized vendors who provide us with analytics services. This includes helping us understand how users interact with the GaitReady Service. These companies may use cookies and similar technologies to collect information about your interactions with the GaitReady Service and other websites and applications.

Information security

We work hard to keep your data safe. We use a combination of commercially reasonable technical, administrative, and physical controls to maintain the security of your data. This includes using Advanced Encryption Standard (AES) to encrypt many of our Services. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact UnitedHealthcare Helpline at 1-844-526-8298. Despite our safeguards, however, no website, app, or information system can ever be completely safe or secure. You acknowledge that [texts/emails] containing your protected health information will be sent unencrypted and there is a risk of interception or disclosure of the contents of [texts/emails].

Additional information

Do Not Track Disclosure. The GaitReady Service does not respond to “do not track” signals at this time. For a description of “Do Not Track” information for browsers and mobile devices, and information about opt out programs that third party advertising companies participate in, please visit https://allaboutdnt.com/.

Privacy of Children. The GaitReady Service is not intended for users under the age of 21 and we do not knowingly collect Personal Information from people under 21. If we learn we have collected or received Personal Information from a person under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us using the contact information at the top of this Policy.

Changes to this policy

We may make changes to this Policy from time to time. We will notify you through the GaitReady App before we make material changes to this Policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the GaitReady Service. Your continued use of the GaitReady Service following the posting of any changes to this Policy indicates your acceptance of the new terms.



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