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Privacy Policy

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Table of contents
  1. Summary
  2. Section 1 - What Information do we Collect?
    1. Information we collect directly from you
    2. Information we collect about you indirectly or passively when you interact with us
  3. Section 2 - How do we Use your Information?
    1. Customer Support
    2. To Manage Byteflies Devices and Services
  4. Section 3 - When and How we Share your Information?
    1. Service Providers
    2. When Required or Permitted by Law
    3. Change in Business Ownership or Structure
  5. Section 4 - Consent
  6. Section 5 - Security
  7. Section 6 - Safety of Children
  8. Section 7 - Cookies
  9. Section 8 - Your Rights to Control What Happens to your Information
  10. Section 9 - How Long do we Retain your Data?
  11. Section 10 - Changes to this Privacy Policy

LATEST UPDATE: August 28, 2020

Summary

Privacy policies can be dense legal documents. We try to keep ours as straightforward and transparent as possible. If you have any questions or comments, please contact us.

What information do we collect?
When you use a Byteflies service, application, or device two types of information can be collected:
  • Information you give us directly, for instance your email address when you send us a direct question or register for an account
  • Health-related information as recorded by a Byteflies device
How do we use your information?
The collected information is used to:
  • Contact you and conduct our business
  • Provide you with our services
You always remain the owner of your data unless otherwise specified as part of a clinical study (see ).
When and how do we share your information?
Byteflies does not sell, rent, lease, give away, disclose, or share your information without your explicit consent. Situations where consent can be requested are clinical studies conducted in collaboration with a clinical or research partner (see ).
Your rights to control what happens with your information
Byteflies is a GDPR and HIPAA compliant company. This means that we are committed to protecting your privacy, conducting our business in a transparent manner, and making sure that you have full control over what happens with your data. More information is available here:
What if I participate in a clinical study?
It is possible that you were recruited to participate in a clinical or research study by one of our partners. In that case, you will have received an informed consent form that explains what data will be collected as part of the study and how it will be used. All studies Byteflies participates in or conducts follow the World Medical Association Declaration of Helsinki guidelines on medical research involving human subjects. Participating in a study that uses Byteflies devices in no way changes our commitment to safeguarding your privacy and data rights.

Section 1 - What Information do we Collect?

When you use a Byteflies service, application, or device we collect information relating to you and your use of our services from a variety of sources.

Information we collect directly from you

  1. Account Registration Information: You need a Byteflies account to use Byteflies services and products. When you register for an account, we collect your email address which may also disclose your name.
  2. Billing Information: If you make a payment to Byteflies, we require you to provide your billing details, such as a name, address, company, phone number, VAT number, email address and other relevant contact details. If you provide a billing address, we will regard that as the location of the account holder.
  3. Physiologic and Behavioral Data: Byteflies devices record physiologic* and behavioral** data and some of this data is processed into vital signs and other health-related measures. In addition, some information may be voluntarily entered into Byteflies’ software and applications. This information is transmitted to a Byteflies managed server (Byteflies Cloud) hosted on secure and compliant providers.

    UNDER NO CIRCUMSTANCES IS BYTEFLIES RESPONSIBLE FOR ANY PERSONALLY IDENTIFIABLE INFORMATION (PII) VOLUNTARILY SUBMITTED BY THE USER THROUGH A BYTEFLIES SERVICE, APPLICATION, OR ANY OTHER ROUTE. ALTHOUGH WE TAKE ALL REASONABLE MEASURES TO SECURE YOUR DATA, WE STRONGLY ADVISE AGAINST SUBMITTING ANY PII THROUGH OUR USER-FACING APPLICATIONS.

  4. Other Intentionally Shared Data: We may collect your personal information or data if you submit it to us in other contexts. For example when you subscribe to receive communications from us or contact us in any way.

*Physiologic Data: Byteflies devices can record biopotential signals, i.e. they measure electrical activity generated by physiologic processes such as the beating of your heart, brain activity, skeletal muscle contractions, and eye movement. Once that raw data is securely transmitted to the Byteflies Cloud, it can be automatically processed to derive vital signs and other health-related measures.

**Behavioral Data: Byteflies devices can record inertial signals which reflect movement of the device. Once that raw data is securely transmitted to the Byteflies Cloud, it can be automatically processed to derive activity and motion measurements.

Information we collect about you indirectly or passively when you interact with us

  1. Usage Data: We collect usage data about you whenever you interact with our services. This may include webpage visits, what you click on, when you performed those actions, and so on. Additionally, like most websites and applications today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system versions, and timestamps.
  2. Device Data: We collect data from the devices (including but not limited to Byteflies devices) and applications you use to access our services, such as your IP address, relevant device and experiment identifiers, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address. Some of our devices are capable of setting up a remote connection to Byteflies Servers which may expose more of the device’s surroundings (e.g. networks). Retrieving this information is only possible with explicit consent for each request.
  3. Referral Data: If you arrive at a Byteflies website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.

Section 2 - How do we Use your Information?

This section describes what we do with the collected information and why, and how it is managed during its lifetime.

Customer Support

In case you experience any issues with one of our products our services or have a question, we need to access your information to assist you.

To Manage Byteflies Devices and Services

We process the physiologic and behavioral data collected by Byteflies devices, as well as any other information you voluntarily provided through one of our applications, in order to derive relevant health and disease insights.

  • This information is never sold, rented, leased, given away, disclosed, or shared without your explicit consent.
  • This information is never aggregated unless you have given explicit consent as part of your participation in a clinical study.
  • You may choose to export information from our applications to 3rd party applications or websites. We do not own or operate these applications or websites. You are responsible for reviewing the privacy policies and statements of such applications or websites websites to ensure you are comfortable with the ways in which they use the information you share with them.

    BYTEFLIES DEVICES AND SERVICES CAN ONLY BE PRESCRIBED BY A CERTIFIED HEALTHCARE PROFESSIONAL. BYTEFLIES DOES NOT MAKE ANY DIAGNOSTIC OR PROGNOSTIC CLAIMS NOR IS BYTEFLIES RESPONSIBLE FOR ANY DIAGNOSTIC OR PROGNOSTIC CLAIMS BASED ON PERMITTED USAGE OF OUR DEVICES AND SERVICES.

Furthermore, we use your information for the following limited purposes:

  1. To monitor, maintain, and improve our services and features: We internally perform statistical and other analysis on information we collect to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or develop new features. We may use your information for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, marketing, research, and development purposes.
  2. To enforce our Terms of Service
  3. To respond to legal requests or prevent harm: If we receive a subpoena or other legal request, we may need to inspect the information we hold to determine how to respond and prevent potentially illegal activities
  4. To create new services, features, or content
  5. To contact you about your service or account: We can occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register).
  6. To contact you for marketing purposes: We may use your email address to inform you about a new feature, new product, or application. Anytime you would like to stop receiving these marketing messages, you can unsubscribe.

We are committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the Internet. If you have any questions about the security of your personal information, contact us.

Section 3 - When and How we Share your Information?

Byteflies does not sell, rent, lease, give away, disclose, or share your information in any way other than stated in our privacy policy (this document). If you participate in a clinical study, additional explicit consent to share or aggregate your data for clinical or scientific purposes may be requested by one of our clinical or research partners.

Service Providers

We use service providers who help us provide you with our services. We may give authorized persons working for some of these providers access to your information, but only to the extent necessary for them to perform their services for us. We also implement reasonable contractual and technical protections to ensure the confidentiality of your personal information and data is maintained, used only for the provision of their services to us, and handled in accordance with this privacy policy. Examples of service providers include payment processors, hosting services, email service providers, etc.

When Required or Permitted by Law

We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.

Change in Business Ownership or Structure

If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between Byteflies entities, you expressly consent to Byteflies transferring your information to the new owner or successor entity so that we can continue providing our services. If required, Byteflies will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.

When you provide us with personal information to register and use one of our services, complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we assume that you consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will ask you directly for your consent.

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, via the provided opt-out links or by contacting us directly.

Section 5 - Security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed.

Please note that we handle any event that might impact the availability, confidentiality, or integrity of personal data as a data breach and will act in accordance with the applicable data protection regulations and other laws for all impacted individuals, including but not limited to the EU General Data Privacy Regulation (GDPR) and US Health Insurance Portability and Accountability Act (HIPAA).

Byteflies NV, located at Borsbeeksebrug 22, 6th floor, 2600 Antwerp, Belgium is the data controller and processor for all data we collect from users in the EU and US.

Byteflies Cloud is hosted on Amazon Web Services (AWS), and unless mentioned otherwise, these are located in Ireland. More details about our commitment to safeguarding your information can be found in the Data Security section.

Section 6 - Safety of Children

Our services are not intended for and may not permissibly be used by individuals under certain age depending on the laws of the governing country. Byteflies does not knowingly collect personal data from persons under the age of 18 or allows them to register. If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact us.

A notable exception may be the participation of a minor in a clinical study. In that case, explicit informed consent will be requested from a parent or legal guardian.

Section 7 - Cookies

We and our partners use cookies and similar technologies on our websites. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:

  1. To make our websites easier to use: We may store your username in a cookie to make it quicker for you to sign in whenever you return to a Byteflies service or application.
  2. For security reasons: We use cookies to authenticate your identity, such as confirming whether you are currently logged into a Byteflies service or application.
  3. To provide you with personalized content: We may store user preferences, such as your default language, in cookies to personalize the content you see.
  4. To improve our services: We use cookies to measure your usage of our websites, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services and optimize the content we display to users.
  5. Google Analytics: In addition to the above, we have implemented on our websites and other services certain Google Analytics features to measure the performance of our products and services in order to improve them.
  6. Please be aware you can still choose to remove or disable cookies in your browser settings. Please note that doing this may adversely impact your ability to use our services. Enabling cookies ensures a smoother experience when using our websites. By using our websites and agreeing to this privacy policy, you expressly consent to the use of cookies as described in this policy.

Section 8 - Your Rights to Control What Happens to your Information

We implement the rights for individuals as stated in the GDPR worldwide, including:

  • The right to be informed about how and why we use the collected information
  • The right to access your personal information
  • The right to rectify your personal information
  • The right to be forgotten
  • The right to data portability

Note that participation in a clinical study may overrule some of these rights. If that is the case, you will be informed of this in the study’s informed consent form and you will need to give your express permission.

Specifically, you can:

  1. Access and correct your personal information: As an account holder, you may access and correct certain personal information that Byteflies holds about you. In all cases, requests to exercise these rights may be directed to our customer support team.
  2. Delete your data: Deleting data will not permanently delete data immediately. As long as you maintain an account with us, we may retain your deleted data for a limited time in case you delete something by accident and need to restore it (which you can request by contacting customer support). To the extent permitted by law, we will permanently delete your data if you request to cancel your account.
  3. Cancel your account: To cancel and delete your account, please contact customer support. We will respond to any such request, and any appropriate request to access, correct, update, or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).
  4. Take your data elsewhere: Taking into account that Byteflies services provide data in a structured, commonly used and machine-readable format, you as a user of our products and services, already have the right to transmit those data to another company’s application or service if desired.

Section 9 - How Long do we Retain your Data?

We generally retain your data for as long as you have an account with us, or to comply with our legal obligations, resolve disputes, or enforce our agreements. Data that is deleted from our servers may remain as residual copies on offsite backup media for up to approximately 6 months.

Section 10 - Changes to this Privacy Policy

We may modify this privacy policy at any time, but if we do so, we will notify you. If we determine the changes are material, we will provide you with an additional prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of these changes, you do not cancel your subscription and continue to use our services beyond the advance-notice period, you will be considered as having expressly consented to the changes in our privacy policy (this document). If you disagree with the terms of this privacy policy or any updated privacy policy, you may close your account at any time by contacting us.


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