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Last Modified: September 10, 2018

Bardy Diagnostics, Inc. (“BardyDx,” “we,” “our,” or “us“) understands that privacy is important to you. We provide this Privacy Policy to inform you about the manner in which we collect, use, process, share, and safeguard Personal Information gathered related to the use of our website at www.bardydx.com (the “Site”).

All capitalized terms that are not defined herein have the definitions given them in our Terms of Service.

PERSONAL INFORMATION WE COLLECT

In this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. We may collect Personal Information about you from various sources described below.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Site if that information is necessary to provide you with it or if we are legally required to collect it.

Personal Information Provided by You

  • Communications. If you contact us directly via email, we collect the content of your message, the date and time of your message, our response and any other Personal Information you provide in that context.
  • Website. If you fill out information on our website (e.g., to contact us), we may collect your name, town/state or province, email address, phone, facility, age, as well as other information you may directly provide to us.

Personal Information Collected via Automated Means

We and our third party partners may collect certain types information via cookies and similar technologies when you visit our Site.

  • Cookies. When you visit our website and mobile applications, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the website and mobile applications. A cookie may also convey information to us about how you use our website and mobile applications (e.g., the pages you view, the links you click, how frequently you access our website and mobile applications, and other actions you take), and allow us to track your usage of our website and mobile applications over time.
  • Log files. We may collect log file information about your browser or mobile device each time you access our website and mobile applications. Log file information may include information such as your web request, Internet Protocol (“IP“) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on our website and mobile applications, domain names, landing pages, pages viewed, and other such information.
  • Clear gifs. We may employ clear gifs (also known as web beacons) which are used to track online usage patterns. In addition, we may also use clear gifs in HTML-based emails we send to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our Site.
  • Mobile devices. When you access our website and mobile applications by or through a mobile device, we may receive or collect and store a unique identification number associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA“), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
  • Analytics. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our website and mobile applications. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving our website and mobile applications. We also work with analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about the use of our website and mobile applications, and report on activities and trends. You can learn about Google’s practices by going to https://www.google.com/policies/privacypartners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

HOW WE USE INFORMATION ABOUT YOU

BardyDx collects and uses your Personal Information as described below.

  • Communications. We may send emails to an email address or place calls to phone numbers you provide to us (i) to response to your contact submission form[, or (ii) to send you information about topics or content that we think may interest you; updates about the latest developments or features of our products and services; or updates regarding your order].
  • Analytics. We use Personal Information, such as your interactions with our Site (including information collected via automated means), to perform benchmarking, to monitor and analyze usage of our Site, and to improve and enhance the Site. We may also anonymize your Personal Information.
  • Legal. We may use your Personal Information to defend our legal rights, and to comply with our legal obligations and internal policies.

WHEN WE USE INFORMATION ABOUT YOU

If you are located in the European Economic Area (“EEA”), we only process your Personal Information based on a valid legal ground, including when:

  • Consent. You have consented to the use of your Personal Information, for example to reply to your contact submission request.
  • Legal obligation. We have a legal obligation to use your Personal Information.
  • Legitimate interest. We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for Site development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Site. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

We may share your Personal Information in the instances described below or as otherwise disclosed to you at the time of the collection.

  • Affiliates and subsidiaries. We may disclose Personal Information about you to our affiliates and subsidiaries.
  • Service Providers. We may share Personal Information about you with third-party vendors and other service providers that perform services on our behalf, in order to carry out their work for us, which may web hosting or providing analytic services. We provide only as much Personal Information to them as is reasonably necessary to perform the services on our behalf.
  • Merger. To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
  • Legal. If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

YOUR RIGHTS AND CHOICES

Your choices. You have the following choices with regard to your Personal Information.

  • Communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests.
  • Cookies. To “opt out” of the collection of information through cookies or other tracking technology, you can manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies and how you may opt-out of some of this tracking, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org). Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.

Rights in the EEA. If you are located in the European Economic Area, you may have additional rights described below. These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us as indicated at the bottom of this Privacy Policy.

  • Request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
  • Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

DATA TRANSFERS

We may transfer your Personal Information to countries other than the country where you are located, including to the U.S. or any other country in which BardyDx or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer your Personal Information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of your Personal Information outside of your country. We may also transfer your Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information, or rely on third parties’ Privacy Shield certifications, where applicable. If you are located in the European Economic Area, you may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the European Economic Area.

DATA SECURITY

BardyDx cares about the security of your Personal Information, and uses certain physical, managerial, and technical safeguards that are designed to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%.

DATA RETENTION

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.

CHILDREN’S PRIVACY

BardyDx does not knowingly collect or solicit any information from anyone under the age of 16 or knowingly allow such persons to register. In the event that we learn that we have collected Personal Information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 16, please contact us at info@bardydx.com.

LINKS TO OTHER WEB SITES AND SERVICES

Our Site may integrate with or contain links to other third party sites and services. We are not responsible for the practices employed by third party websites or services embedded in, linked to, linked from, or connected with the our Site and your interactions with any third-party website or service are subject to that third party’s own rules and policies.

CHANGES TO OUR PRIVACY POLICY

BardyDx may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy we will update the “last modified” date at the top of this page.

HOW TO CONTACT US

Bardy Diagnostics, Inc. is the entity responsible for the processing of your Personal Information covered by this Privacy Policy. Please contact BardyDx with any questions or comments about this Privacy Policy or our privacy practices, or to exercise your rights at info@bardydx.com. You may also write to us at:

Bardy Diagnostics, Inc.

220 120th Avenue NE Suite 100

Bellevue, WA 98005

United States