Privacy Policy

This Privacy Policy applies to your use of WatchRx smartwatch with Watch App (the “Watch”) , a Caregiver Mobile Application (the “App”) and related web interface (the “Site”) owned by WtachRx Inc. (“we” or “us”). The Watch, App and the Site are referred to together as the “Application”. ‘You’ refers to any user of the Watch,Application, including individuals who use the Application to track medication compliance of themselves or on behalf of their care recipients, healthcare providers who use the Application to monitor compliance of usersunder their supervision. If you do not agree to the terms of this Privacy Policy, including with respect to (a) thecollection and processing of Health Information (as defined below), (b) the collection and processing of yourgeolocation data (c) our cookies policy, (d) crossborder transfer of data and (e) marketing, please do not click “ Login ” or “ Register ” and do not use the Application.

We have the highest regard for your privacy and personal information and realize that the success of our servicedepends on the trust that users have in the way we handle their personal information. This policy sets out ourcommitments and explains the rights that you have with respect to your personal information.

INFORMATION COLLECTION AND USE

WatchRx respects your right to privacy. While you may use some of the functionality of the Site withoutregistration, use of the Application and certain tools of the Site require registration. If you use our Site withoutregistering, we only collect information through the use of cookies, web beacons and navigational datacollection. While we cannot directly identify you, in some jurisdictions, this information is still subject toapplicable data protection laws and requires your consent to our cookies policy as described below. If youchoose to register with us, you will be asked to provide Personal Information (as defined below) and may also beasked to input your personal information and/or your care recipient Personal Health Information. It is yourvoluntary decision whether to provide us with any such Personal Information or Health Information, but if yourefuse to provide such information we may not be able to register you to use the Application or your use of theApplication may be limited.

Collecting and Using Your and/or your care recipient Personal Information and Health Information(Actively Provided Information)

Whenever you submit information via our App or Site, or otherwise in connection with your use of theApplication, including, but not limited to, by telephone or email with customer service, you consent to thecollection and processing of your Health Information and geolocation data and other personal information you provide to us, our cookies policy, crossborder transfer of data, and the use of your data for marketing purposes,all in accordance with this Privacy Policy. WatchRx respects your right to privacy. Please read this PrivacyPolicy for more information about collection, storage, use, processing, combination, deletion and disclosure ofyour Personal Information.

“Personal Information” means information that can be directly associated with a specific perso
n (and includesHealth Information). When you register or update your information on our Site or through our App, we collectfollowing information:
 
first and last name, email address, phone number, address, Date of birth, Geo-Location, patient image,emergency contacts etc.
 
If you are a healthcare provider, during registration you will be asked to provide Personal Information includingqualification, title etc.
 
During registration or subsequently, you may choose to use certain features of the Watch and the Applicationthat will allow you to input other Personal Information with respect to your or your care recipient health, such asthe medications taken, the date of the prescription, the number of refills, medication regimen , (“Heal th Information”). We will send reminders to the watch to take medications in accordance with this information.
 
As a caregiver using the caregiver application or Site, you may also send family members or friends aninvitation to be secondary caregivers, so that such caregivers will receive alerts regarding the care recipient
scompliance with medication regime. By sending such invitation, you represent that you have the right to contactother caregivers and that you consent to our sending Personal Information about your care recipient medicationsand compliance with medication regime to the caregivers. Sharing of your and or your care recipient PersonalInformation in this manner is solely your responsibility.
 
You may use the Watch and the Application in order to share your Personal Information or other informationwith your doctor or healthcare providers. Such sharing may be enabled by inviting your healthcare provider tomonitor your Personal Information, by accepting an invitation from your healthcare provider to download anduse the Application, or otherwise using the Application settings to share your information with your healthcare
 provider; in these cases you consent to our sending Personal Information about yo
ur medications and yourcompliance with your medication regime with your healthcare providers. Confirm with your healthcare providerthat they have sent you an invitation to download WatchRx Application. Such sharing of your information is atyour discretion and is solely your responsibility.
 
If you are a healthcare provider using the Application to invite individuals to monitor patients under yoursupervision to use the Application, you agree not to include any Personal Information about you or your professional qualifications in the text of these invitations. We may also use your Personal Information in orderto provide you with personalized third party content or links to third party sites that might interest you, as part ofthe feed on the Application. We provide this third party content and/or links to third party sites for information purposes only and are not liable for such content or sites. For more information see the “Links to other Websitesor Apps” section below.
 
We may also use the Personal Information (1) to identify your account for purposes of providing you withcustomer services and to respond to your requests, (2) to provide you the specific services you select (includingthe requested reminders), (3) to help diagnose problems with our servers, to make the Application more useful, for other internal purposes or to customize the Application and personalize its content for you; and (4) to send you texts, emails or other communications regarding general adherence information, Application maintenance,updates, or changes to this Privacy Policy or any other relevant agreements. Please note that we reserve the rightto send you such service related communications without offering you the opportunity to opt out of receivingthem unless you cancel your account.
 
While we take great care to keep your Personal Information confidential and secure, when you share your healthor medication information with others or provide feedback regarding health matters, medications and otherwise,including by means of social media sites, or when you participate in a forum on the Application, any informationdisclosed that may be automatically made public, and such information will not be considered PersonalInformation by us. You should exercise caution when disclosing any information (including PersonalInformation) in such ways, as you do not know who will access or use such information and for what purposes.Your Personal Information will not be combined with other information and will not be used for other purposes,except as explained in this policy. Please note that we are not subject to medical secrecy obligations.
 
Ensuring the accuracy and completeness of the Personal Information and any other information that you providein connection with your use of the Application is important. Inaccurate or incomplete information will affect thefunctioning of the Application, as well as the information you receive from us and our ability to contact you.
 
Automatic Data Collection
 
Site: We collect information about your use of the Site (IP address, type of computing or mobile device you use,language of your operating system, the Internet browser you are using, geolocation and use of the Site) throughthe use of various technologies, such as cookies, web beacons and navigational data collection (log files, serverlogs, clickstream). For more information on our cookies policy, please see below.
 
The App may automatically collect certain information about you when you use the App, such as the type of computing or mobile device you use, your device’s IP address and/or unique device ID, your device’s operating system, the language of your operating system and the Internet browser you are using. We may use third partyservice providers to collect such information, in order to assist us with the following: pseudonymizedinstallation tracking, social media recommendations, anonymized crash tracking, anonymized behavior trackingand testing (including in real time) and anonymized A/B testing. We collect such information in order tofacilitate use and ensure technical functioning of the App, dynamically generate and deliver targeted content, statistically monitor usage of the App, and improve the overall quality of our users’ experiences.
 
Data collected automatically on the Site or App may be used, for example, to help diagnose problems with ourservers, to make WatchRx more useful, to customize WatchRx and personalize its content for you.
 
The App might access a list of installed apps on your device. This is done only to ensure proper quality ofservice, as some apps might interfere with the App functionality, such as blocking notifications, and in suchcases we will notify you. Information about installed apps is not transmitted and not shared with anyone.
 
Cookies
 
A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the
device of the originating visitor when this visitor returns. We use cookies to help personalize your experience. A
“persistent”
cookie may be used to help save your settings and customizations. Also, if you log in to the Site,such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use theSite. Most Web browsers automatically accept cookies, but allow you to modify security settings so that you canapprove or reject cookies on a casebycase basis or reject all cookies. You can configure your web browser to
remove cookies by following the directions provided in your Internet browser’s “help” section.
 
  • Safari
  • Opera
  • Firefox
  • Google Chrome
  • Internet Explorer

Also, you are free to delete any existing cookies at any time. If you delete or disable cookies from our Site, some parts or functions of the Site may not work properly for you.

Sharing of Your Personal Information with Third Parties and Service Providers

We will not publish your Personal Information without your explicit consent. However, we might share yourPersonal Information, as is reasonably necessary, without your consent with: (1) our contractors or consultantswho are bound by an obligation of confidentiality, provided that we will only share Personal Information to the
extent necessary with such contractors or consultants; and 2) affiliates of our company for the purposes of
improving our marketing strategies, for research purposes and for entering into commercial contracts in order to provide our users with our services. We also require that such contractors and consultants agree to protect the privacy of your Personal Information and agree not to use or disclose Personal Information for any purposeother than providing us with products and services and as required by law.
 
Additionally, you may choose to share your Personal Information with pharmacies with which we partner and/orthird party coupon companies, in order that we may send you coupons and/or provide you with reminders to getyour prescription refilled. If you choose to share your Personal Information in this manner, please note that suchinformation may be disclosed to the coupon companies and/or pharmacies and will be subject to their privacy practices.
 
We may share your Personal Information with third parties, such as research institutes, healthcare systems ordoctors, for research purposes and so that they can crosscheck such information with other information thatthey have about you, for research purposes and for improvement of our services. We will first obtain yourconsent for the same. Please note that we may share your deidentified data with such third parties withoutobtaining such consent.
 
From time to time, we may also ask whether you would like us to share your Personal Information with anothercompany that may want to send you information about their products or services. If you consent to such transfer by us of your Personal Information to another company, please note that the information provided will be
subject to such company’s pr 
ivacy practices and shall not be within our control.
 
In addition we may share your personal data with third parties, such as law enforcement authorities, courts and tribunals, to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree.
 
We may also share your Personal Information with legal advisors, consultants, or courts in order to protect and defend our rights and property or those of Application users. We may also transfer your Personal Information in the event of a merger, acquisition or sale of all or a portion of our assets.
 
Use of Aggregated Data
 
We may analyze all information we receive and/or combine your Personal Information, including HealthInformation and information regarding your use of the Application, with information from other users to createaggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction,on commercial terms that we can determine in our sole discretion for purposes of content marketing, for research purposes, in order to understand behavior patterns and in order to increase adherence to medication regimens.We also use
“Google Analytics” to collect information about the use of the Application. Google Analytics collects information such as how often users visit the Application, what pages they visit when they do so, and what other sites they used prior to coming to the Application. Google Analytics collects only the IP address assigned to you on the date you use the Application, as well as information regarding your operating system,language and information regarding your use of the Application, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal

Information.

We use the information we get from Google Analytics only to improve the Application. Google’s
ability to use and share information collected by Google Analytics about your use of the Application is restricted by the Google Analytics Terms of Use located at
http://www.google.com/analytics/terms/us.html and theGoogle Privacy Policy located at http://www.google.com/policies/privacy/.
 
DISABLING THE SERVICE, ACCESS, CORRECTIONS AND DELETION
 
At any time, you can stop the collection of your information by canceling the subscription and uninstalling theApp and refraining from using the Site. You may also request that your Personal Information be deleted fromour active databases. We cannot restore information that we have deleted. You are responsible for backing upthe data that you store on the Application. We may retain any data in nonidentified form, subject to applicablelaw.
 
You may contact us as specified below under “How to Contact Us” to access information th
at we keep aboutyou or update or correct such information or ask for its deletion. We will retain your information for as long asyou continue to use our Site or App and for a reasonable period of time afterwards.
 
You have the right to object to direct marketing.
 
LINKS TO OTHER WEBSITES OR APPS
 
Our Application may link to or refer to websites or mobile device applications that we do not control. AnyPersonal Information you provide on the linked pages is provided directly to this third party and is subject to this
third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or
applications, and we are not responsible for the privacy practices or content of any website or application notcontrolled by us. If you have any concerns, we urge you to review the terms of those other websites orapplications for more information about their applicable policies.
 
SECURITY
 
We take reasonable steps to protect Personal Information as you transmit it to us and to protect such informationfrom loss, misuse and unauthorized access, disclosure, alteration or destruction. However, you should keep inmind that no Internet transmission is ever completely secure or errorfree.
 
If you use and/or access the Application on or from an Android device which you or someone else rooted or onor from an iOS device which you or someone else jail broke, WatchRx shall not be responsible for the securityof your data, including your Personal Information, and you shall bear all responsibility for any breach, illegalaccess, loss and/or corruption of such data.
 
CHILDREN
 
Our Application is intended for use by persons 18 years of age and older. Under no circumstances should theApplication be used by children under 18 years of age, and we will not knowingly collect Personal Informationfrom any person we know to be in this age group. If you are using the Application for the benefit of a child, please do not provide information relating to such child unless you have obtained the child’s parents’ orguardians’ con sent, including their consent to this Privacy Policy. If you discover that your child has been usingthe Application without your consent, or that someone has been using the Application for or on behalf of yourchild without your consent, please contact us using the information below under “How to Contact Us,” and wewill take reasonable steps to delete the child’s information from our active databases.
 
INTERNATIONAL TRANSFERS
 
We store your Personal information on servers located in the United States. Additionally, we may usesubcontractors that are located in countries other than your own, and send them or provide them with access toinformation we receive. All our subcontractors will be subject to nondisclosure and nonuse obligations. Nevertheless, some countries may have levels of protection of personal and other information which are not ashigh as in your country of residence or business.
 
We may transfer our databases containing your Personal Information if we sell our business or part of it.
 
HOW TO CONTACT US
 
If you have any questions, comments, requests, or concerns related to this Privacy Policy or the privacy practicesfor our Application, please contact us at:
 
ATTN: WatchRx Inc.10 Barker Road,Acton, MA 01720
info@WatchRx.io
 
CHANGES TO PRIVACY POLICY
 
From time to time we may need to change this Privacy Policy. You will be informed of such change in advance,and you will always have the possibility to stop using the service as explained above.
 
This Privacy Policy was last updated in August 2020.