PInCH Medical Systems Ltd

Privacy Notice

Revision: 11 June 2015

LifeCourse is a product owned and operated by PInCH Medical Systems Ltd (collectively "LifeCourse", "PInCH," "we," "us"). This Privacy Notice describes how PInCH collects, processes, uses, discloses, and secures information through its mobile apps (the "Apps") and its websites, including http://lifecour.se (the "Sites") (collectively the "Services").

There are many different ways you can use our Services - to back-up, store and synchronise data from any of our apps, including AFinity, which may include personal wellbeing diary entries, prescriptions, and measurements, to bringing in data from external third-party apps and sources including ECG providers, to generate wellbeing summary reports for GPs and specialist consultants. In order to deliver the Services to you, we require you to consent to the collection and processing of your personal information when you initially begin using them. Your information is stored in two locations in order to provide you with the Services: your mobile device and the LifeCourse secure, encrypted cloud server. As you use our Services, we want you to be clear about how we are using information and the ways in which you can protect your privacy.

Our Privacy Notice explains:

• What information we collect and why we collect it.
• How we use that information.
• The choices we offer regarding our use of the information.
• The measures we take to protect the security of the information.

Your privacy of utmost importance to us, as we believe that you, the individual, should be in complete and total control of your health information on and off-line. So your opinion, concerns, and questions are important to us; please contact us at support@lifecour.se if you have any questions.

Information We Collect

We may collect the following types of personal information from users of our Services, and store it on your mobile device and in the the LifeCourse secure, encrypted cloud server:

• Contact information (such as name, postal address, email address, and mobile or other telephone number) of individuals such as medical professionals, human patients and/or their parents or guardians, caretakers of veterinary patients and other visitors;
• Username and password;
• Information in customer support inquiries;
• Human patient demographics such as date of birth and gender;
• Human patient medical data such as medications and ailments, medication prescriptions, and treatments undertaken, name of GP, and detailed particulars of the kinds of medical conditions that the user has, including any specific variants;
• Human wellbeing and activity data, including personal diary entries about perceptions of wellbeing, routine activities, and medications taken;
• Information about your device, such as its model and operating system version; and
• Detailed usage information about how our Services are used, including the local time(s) our Services are used, duration of use, feature(s) of our Services used, time zone and geographic location(s) it is used in, and notifications generated and dismissed).

Cookies

When you visit our Services or open our emails, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, language preferences, referring URLs, information on actions taken on our Services, and dates and times of website visits. The information does not identify you. If you continue to use our Services, we will assume that you permit this collection.

A 'cookie' is a file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A 'web beacon' also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain 'clickstream data,' which is a log of the links and other content on which a visitor clicks while browsing a website and identifies the prior website used to access the Services. As the visitor clicks through the Services, a record of the action may be collected and stored. We may link certain data elements we have collected through automated means with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you.

We use cookies, web beacons, web server logs and other automated means for purposes such as (i) customising users' visits to our Sites, (ii) delivering content tailored to users' interests and the manner in which users browse our Sites, and (iii) managing our Sites and other aspects of our business.

We may use third-party web analytics services on our Services, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons collect usage information matched to an IP address, but not your personal information, to help us analyse how visitors use the Sites and improve the overall experience of the Sites. The analytics providers may also collect information about your use of other websites over time, if those websites also use the same analytics providers. To learn more about Google Analytics and how to opt out, please visit http://www.google.com/analytics/learn/privacy.html.

We may use third-party services on our Services, such as MixPanel, to collect usage data in order to understand and continue improving our products and services. To learn more about MixPanel, please visit https://mixpanel.com/privacy/.

How We Use the Information We Collect

We may use the information we collect to:

• Create and manage accounts;
• Provide products and services, and give access to the ECG analysis service;
• Deliver and manage customer support and respond to inquiries;
• Process payments;
• Send promotional materials or other communications, communicate about, and administer participation in, special events, programs, offers, surveys and market research;
• Perform data analyses (including deidentification and aggregation of personal information);
• Operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analysing our products; and performing accounting, auditing and other internal functions);
• Aggregate and anonymise information and images and use and share the resulting data for business purposes (for example, to provide beneficial health-related data not limited to statistics, trending and services to LifeCourse and PInCH Medical Systems Limited affiliates);
• Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities; and
• Comply with and enforce applicable legal requirements, relevant industry standards and our policies.

We will retain your personal information even if you cease using the Services until such time as you notify us, as indicated in the 'How to Contact Us' section of this Privacy Notice, of your intention to cease using the Services indefinitely. Even after you notify us of your intention to cease using the Services, we will retain and continue to use aggregated and anonymised information and images.

Information We Share

We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice. We do not rent, sell, or share personal information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.

We share your information with other users (such as healthcare providers) if you explicitly give permission for them to access your data through the Services or you choose to email them your information.

In addition, we may access, preserve, and disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity, and (iv) to protect your, our, or others' rights, property or safety.

In the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation), such assets likely will include the data we retain. We will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that personal information.

Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you, such as how we use the personal information and how we communicate with you. To update your email preferences, ask us to remove your personal information from our mailing lists or submit a request, please contact us as indicated in the 'How to Contact Us' section of this Privacy Notice.

Users with online accounts may be able to update or delete certain personal information using the Services. You may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below by submitting a request via the 'How to Contact Us' section of this Privacy Notice. Any access request may be subject to a fee of £10 ($15 USD) to meet our costs in providing you with details of the personal information we hold about you. You may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. To exercise any of these rights, please submit a request via the 'How to Contact Us' section of this Privacy Notice.

Data Protection

PInCH Medical Systems Limited complies with international data protection laws by hosting your data locally within the primary country where you reside. For example, if you are located in the United Kingdom or EU, your data will be maintained and processed in the United Kingdom, in accordance with UK and EU Data Protection Laws. If you are located in the United States, your data will be maintained and processed in the United States. If you move from one country to the other, you may contact us to have the data we store about you transferred to our data centre in your new country of residence. If you move to a country that we do not yet have data centres, you may elect to have your data stored in any of our existing servers, or removed entirely. Regardless of where your data is stored, PInCH Medical Systems Limited services all use the same high standards of data protection to ensure that your data remains secure (meeting or exceeding all regional data protection requirements), and that your personal information as described in this Privacy Notice is protected at the same level as would be required were it processed in the country in which the personal information was originally collected.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

Links to Other Websites and Applications

The Services may provide links to other websites and applications for your convenience and information. These websites and applications may operate independently from us. Linked sites and applications may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or applications are not owned or controlled by us, we are not responsible for the sites' or applications' content, any use of the sites or applications, or the privacy practices of the sites or applications.

Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes to our information practices. We will post a prominent notice on our Services to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. Where required by law, we will seek your explicit consent to specific changes. You agree that PInCH Medical Systems Limited will reserve the right to occasionally notify you via email of any important changes to this Privacy Notice and/or Service agreements.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at support@lifecour.se. You also may write to:

PInCH Medical Systems Limited,
54 Welbeck Street
London
W1G 9XS
United Kingdom