PRIVACY POLICY

Vave Health, Inc.
Last Updated: November 8, 2019

Thank you for visiting this website (the “Site”), owned and operated by Vave Health, Inc. (referred to in this statement as the “Company,” “we,” “our”, or “us”). We are a medical device company headquartered in California, U.S. and we develop as well as commercialize products, mobile applications and related services for users of ultrasound devices; our products and services include a series of hand-held ultrasound probes enabled via a mobile application downloadable from the internet (e.g. for iOS, Android and via the web), as well as cloud storage services, and, in future, an e-commerce platform for purposes of product purchase and subscription services (collectively the “Services”). The Company runs all of its operations in the U.S., and our website is hosted in the U.S. At present, we comply with U.S. law.

This Privacy Statement describes our practices in connection with information that we collect from you by accessing this website or using our mobile application(s) (“App” or “Application”), via publicly available social media sites (“Social Media”), or by face-to-face interactions (“Directly”). The Services are intended for U.S. residents only.

We need to collect Personal Information to provide you the Services.  If you do not provide the information we require, we may not be able to provide you the Services or an optimal level of Services. If you disclose any Personal Information relating to other people in connection with provisioning and use of the Services, you represent that you have all necessary permissions to do so.

Vave does not knowingly collect Personal information from individuals under the age of 13. Use of our website to create accounts or to perform any other type of activity is not permitted by individuals under the age of 13.

1.     The Personal Information We Collect

 “Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  Personal Information Vave may collect through the Services includes:

  • Name
  • Organization or employer
  • Occupation or medical specialty
  • Username, password
  • Email address
  • Postal address
  • Phone numbers
  • Credit and/or debit card payment information
  • Health information, including records of medical treatment or diagnosis

2.     How We Collect Personal Information:

Personal Information is collected in several ways, including:

  • Via the Services, e.g., when signing up for a newsletter, registering an account, purchasing Services, or interacting with this website or via an App.
  • Through Direct channels, e.g. from interacting at a trade show, ordering by phone, contacting customer service, or participating in a feedback survey or a study.
  • Via Social Media Pages.

3.     Use of the Personal Information We Collect

We and our service providers may use Personal Information for any of the following purposes:

  • Registering an account
  • Providing, improving, maintaining or repairing the Services
  • Responding to inquiries and fulfilling requests.
  • Verifying your identity to complete transactions or provide customer service.
  • Undertaking quality and safety assurance measures.
  • Conducting internal compliance audits and/or for fraud and security monitoring.
  • Exchanging messages with and among users.
  • Identifying usage trends; assessing effectiveness of our promotional campaigns.
  • Developing new products or services.
  • With permission, sending promotional materials.

3.     Disclosures of Personal Information

In the ordinary course of business, we will share, as necessary, Personal Information and/or Non-Personal Information (defined below) with companies that we hire to perform services or functions on our behalf. By way of non-limiting example, we may use vendors for order-fulfillment, billing, platform support. In all cases when we provide Personal Information with a third-party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide. We will not sell, share, or publish Personal Information, except as provided in this Privacy Statement or in conjunction with a corporate sale, merger, dissolution, or acquisition.

Note: if you make a payment for Services, your Personal Information will be collected by a third-party service provider and not by us, and as such subject to the third party’s privacy policy.  We have no control over, and are not responsible for, a third party’s collection, use and disclosure of your Personal Information. This Privacy Statement does not address, and we are not responsible for, any third party terms linked on our website and the inclusion of any such link is as a courtesy and does not imply endorsement of the linked site or service by us. In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or Products or our Social Media Pages.

We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).

We may disclose your personal information to third parties if we feel that the disclosure is necessary to:

  • enforce this Privacy Statement and the other rules about your use of this website
  • protect our rights or property
  • protect someone’s health, safety or welfare
  • comply with a law or regulation, court order or other legal process
  • We may also keep, disclose, and use personally identifiable information that you give us through this website in ways that we believe are consistent with FDA and other governmental guidance, directions, regulations, and laws, including by aggregating and/or anonymizing Personal Information so that it will no longer be considered Personal Information.

4.     Collection of Non-Personal Information

If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information about you from your computer. This may include:

  • the type of web browser software you use (for example, Internet Explorer)
  • the name of the domain from which you access the Internet
  • the Internet protocol (“IP”) address of the website from which you linked into our website
  • dates and times that you have accessed our website
  • the geographic location of the server you use to access our website
  • pages you have visited on our website
  • search terms you use
  • links on which you click
  • location (based on enabling location based services)

5.     How We Collect Non-Personal Information

  • To enable the Services, users must enable location-based services.
  • We further collect browser or device information, e.g. we may collect and/or track IP addresses, browsers, operating systems, locations from which you accessed the Services, Uniform Resource Locators (URLs), user interactions (keypresses, and mouse events such as movement, location, and clicks), domain names, landing pages, page views, dates and times you used the Services, error logs, device IDs and other information about your mobile phone or other mobile device(s).
  • We may collect information about your use of the Services or App (including workflow information, log files, buttons pressed, boot logs, usage statistics, support requests and results).
  • We use Cookies. Cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We, and our service providers, use cookies for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.   If, however, you do not accept cookies, you may experience inconvenience in your use of the Services.
  • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
  • We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

6.     Uses and Disclosures of Non-Personal Information

We may use and disclose Non-Personal Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Non-Personal Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Statement. In some instances, we may combine Non-Personal Information with Personal Information. If we do that, we will treat the combined information as Personal Information as long as it is combined.

7.     Opt-Out

We give you choices regarding our use of your Personal Information for marketing purposes.  You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by using the unsubscribe link within each email, updating your email preferences within your Services account settings (for registered users), or by contacting us to have your contact information removed from our promotional email list or registration database. We also may send you mobile text messages (SMS) for account authentication purposes when you register with the Services. You may opt-out of receiving such text messages by emailing us or modifying your account settings within the App.

We will try to comply with your request(s) in a timely manner. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. We have no obligation to honor opt-out requests you make to any third party regardless whether you were connected or linked via the Services.

8.     Other Requests Related to Personal Information

You may request to access, correct, update, suppress, restrict or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us by referring to “Contact Information” below.  We will respond to your request in a manner consistent with applicable law. You may also exercise some of the requests above by logging into the Services (for registered users) and using settings available within your account.

Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).  In addition, we retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

9.     Retaining Your Personal Information

We have put in place commercially reasonable physical, electronic, and organizational procedures to protect Personal Information within our organization. Although we take appropriate measures to safeguard against unauthorized disclosures of information, these measures cannot be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Information” section below.

10.  Where Information May Otherwise be Transferred and Stored

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

11.    Sensitive Information

At times, certain users may allow Vave with access to sensitive Personal Information, e.g. medical records, diagnosis or treatment information, or other health information of a user’s patients.  Vave will maintain and protect such information according to applicable law and our agreements in place with our users. If you are a patient and you have questions or requests regarding your medical information that is handled by Vave, please contact your healthcare provider. Do not disclose non-relevant sensitive Personal Information such as social security numbers, racial or ethnic origin, political opinions, religion or other beliefs, or criminal background.

12.    CONTACT INFORMATION

We welcome any questions, comments, or concerns regarding our Privacy Statement or practices. Please send an email to info@vavehealth.com to the attention of our Privacy Officer. You may also contact us at our address:

Vave Health, Inc.

2350 Mission College Blvd., Suite 1200

Santa Clara, CA 95054

+1 (877) VAVE-HELP (toll free)

www.vavehealth.com

Because email communications are not always secure, please do not include payment information, health information, or other sensitive information in your emails to us.

The “Last Updated” legend at the top of this Privacy Statement indicates when this Privacy Statement was last revised.  Privacy laws and regulations are evolving. We reserve the right to revise this Privacy Statement as we see appropriate. Review this Privacy Statement from time to time as you return to our website so that you are familiar with any changes. Our use of your Personal Information is in accordance with the privacy statement that was in effect at the time the information was collected. We will notify you of updates to this Privacy Statement by posting a notice on our website. Use of the Services following changes made to this Privacy Statement means that you accept the revised Privacy Statement.

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