True Angle Medical Technologies Inc.
Effective upon: February 24, 2022
Last updated: February 24, 2022
We collect two basic types of information from you when you provide it to us or when you use or interact with our Services: personal information and non-personal information.
Personal information includes all information that relates to you personally and either identifies or may be used to identify you personally (collectively, “personal information”). We may collect various types of Personal Information from you depending upon how you interact with us or use or interact with our Services.
Non-personal information includes information that does not personally identify you (i.e. aggregated information) or information that has been anonymized (collectively, “non-personal information”). When we combine non-personal information with personal information, we treat the combined information as personal information.
You can always refuse to provide us with your information, except that it may prevent you from using our Services or receiving responses to your inquiries or other information of interest.
Information directly from you. We collect personal information you give to us directly. For example, when you create an Account or place an order for products or services with us you will give us information like your email address, first and last name, payment information, and your username and password. You may also provide us with other optional information as part of your Account profile, such as avatars or profile images, and other contact information, including your mailing address, and telephone number. We may also collect information directly from you for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for Services to determine if, and how much, tax we need to collect from you. We will normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
Payment processing information. If you have made a purchase through us, or if you make a financial transaction using our Services, we and any third-party payment processors we use will collect information about the purchase or transaction. This includes billing details, credit card information, account, and authentication information.
- Remind us who you are when you access our Services which helps us to provide you with services tailored to your specific needs and interests;
- Determine the browser you are using so our Services work properly;
- Assist us with sending you notifications;
- Generate analytics regarding your use of our Services; and
- Estimate our audience size by determining whether your visit is your first.
You can set your browser or device to refuse all cookies or to indicate a cookie is being sent. Some cookies remain stored on your device until you delete them. If you delete your cookies or if you set your browser or device to decline these technologies, some Services may not function properly. Our website does not currently change the way it operates upon detection of Do Not Track or similar signal.
We also collect personal information about you such as your geographic location, your browser type and settings, log data, your device information (for example, if you’re using a tablet, mobile phone, or desktop computer and the operating system), information about your browser configuration and plug-ins, your language preferences, unique identifiers, information about how you interact with the Website and Services, the information we collect when you complete a transaction with us through the Services, information you provide in the App to use its functions and features, information you provide in the Platform to use its functions and features, and usage data you may provide to us through the communication and help and support systems through the Website and our Services.
Social Media Integration. Our Services may, from time to time, contain links to and from social media
platforms. You may choose to connect to us through a social media platform, such as Facebook or Twitter, and when you do, we may collect additional information from you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We do not have control over the collection, use and sharing practices of social media platforms and encourage you to review their usage and disclosure policies and practices, including the data security practices, before using the social media platforms.
Marketing, Surveys and Promotions. We collect personal information you include in your marketing preferences with us. We may also collect personal information we get from our partners to support our marketing initiatives, improve our Services, and better monitor, manage, and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
Communications. We collect personal information you include in your communications with us, such as information you include in SMS or RCS (text) messages, form submissions on the Website, communication means in the Services, and other electronic messages between you and us (collectively, “Electronic Messages“) or by phone or mail.
Sensitive Personal Information. We collect sensitive personal information from you with your consent and for the purposes we identify at the time we collect the information, which includes providing our Services to you. The sensitive personal information we collect includes genetic or biometric data for the purpose of uniquely identifying you (including facial images or fingerprints), information about your health, your birth date, and other sensitive personal information we identify at the time we collect it from you.
How We Use Information
We may use personal information to:
- Provide you with information about us, our Mobili-T® device (which is a portable swallowing exercise unit to capture, filter and process physiological signals from muscles used in swallowing, with the capacity to wirelessly connect to electronic mobile monitors, tablet computers, and smart phones), the Website, or the Services.
- Facilitate your interactions and transactions with us.
- Respond to your communications, suggestions, comments, inquiries, and requests (including your feedback about our Services), including to send you Electronic Messages and other communications about the Services and your relationship with us.
- To verify your identity.
- Administer our relationship with you, including creating and managing your Account.
- Measure the performance of our Services.
- Develop new services or products.
- Sell and distribute our Mobili-T® device including obtaining payment for our Mobili-T® device and other products and services.
- Better understand the preferences of our customers, including customer management and analysis.
- Provide personalized Services, including content and ads. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for an Account or follow us, and we may choose to serve you a particular advertisement based on your service choices with us or what we think may interest you based on other information we hold about you.
- Provide you with, and improve, relevant marketing offers or information from us or relevant third parties. We may use your information to send you tailored marketing communications about products, services, offers, programs, and promotions of ours and those of our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on what we think may interest you based on other information we hold about you.
- Enhance the security and/or performance of the Website (and related systems) and the Services, such as when we use your personal information to verify your identity and access credentials.
- Respond to legally binding requests from law enforcement, regulatory authorities, or other third parties, including to protect others’ interests, rights, and property.
- Defend, protect, or enforce our rights or applicable terms of service.
- Prevent fraud or the recurrence of fraud.
- Assist in the event of an emergency.
- Comply with applicable law.
We may also combine your personal information collected through various sources, including information collected through our Services, and develop of a customer profile that will be used for the purposes above, including to reflect your preferences, characteristics, behavior, and other similar characteristics.
We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose.
When We Use Your information
Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
Performance of a contract. We need your personal information to provide you with services and products requested by you or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we use your personal information to deliver our Services to you through our Platform or App.
To protect vital interests. We may process your personal information when necessary to protect your vital interests or those of another person.
Legal obligation. We have a legal obligation to use your personal information at times, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
- To operate our business and provide you with tailored advertising and communications to develop and promote our business.
- To create and use performance reporting and analytics to improve our Website and Services.
- To analyze and improve the safety and security of our Website and Services, which is necessary to pursue our legitimate interests in ensuring our Website, Services, and assets are secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
- To provide and improve the Website and Services, including any personalized services. We do this to pursue our legitimate interests of providing an innovative and tailored offering to our users, to provide you with troubleshooting and support services, and to answer your questions about our business.
- To share your personal information with other companies that help us to provide and improve the Website and Services.
- To anonymize and subsequently use anonymized information. Personal information does not include information that has been anonymized or aggregated in such a way that it can no longer be used to identify a specific natural person, whether on its own or in combination with other information. We may use your personal information to create this kind of anonymized or aggregated data.
How We Disclose Information
The following are particular circumstances in which we may disclose personal information:
- to our third party service providers, contractors, suppliers, distributors, and partners to help us with the uses described in the How We Use Information section above;
- to our payment processor, if you make a credit card payment;
- to our employees or contractors who need access to your Personal Information as part of their job functions to provide you with our Services or to help us with the uses described in the How We Use Information section above;
- to insurance companies, banks, and service providers with respect to entering into and fulfilling contracts related to our Services, or to help us with the uses described in the How We Use Information section above;
- to law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:
- responding to a subpoena, court order or other legal processes;
- defending, protecting or enforcing our rights;
- assisting in the event of an emergency; and
- complying with applicable law.
- where we believe in good faith that disclosure is necessary:
- to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies or investigative bodies in that regard;
- to collect a debt owed to us or to repay any money owed to you;
- to investigate and defend us from and against any third party claims or allegations;
- to protect the security or integrity of the Services; and/or
- to exercise or protect the rights, property or our personal safety, and that of our clients and users, employees, independent contractors, or others;
- to comply with your directions or any additional consent you have provided us;
- as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation; and
- if we are involved in asserting or defending a legal claim, we may disclose information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.
We share non-personal information with third parties as reasonably necessary to meet our business needs.
Protecting and Retaining Information
We have taken industry standard measures to ensure the security and confidentiality of personal information. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your information, please contact us immediately.
We may retain personal information for as long as we have a legal requirement or business need to do so, including, for backup, archival, accounting, and/or audit purposes. We may retain non-personal information for as long as we have a business need to do so.
Our Services are not for children under the age of 13. We do not knowingly collect personal information from children under 13 years of age. Individuals under the age of 13 should only use our Services with the permission and under the supervision of a parent or guardian. Individuals under the age of 13 should not attempt to provide us with any personal information. If you think we have received personal information from children under the age of 13, please contact us immediately.
Your Rights and Choices
We offer you certain choices in connection with our Services:
Updating your information and exercising your other rights. The accuracy of the information we have about you is very important. You may request that we update your personal information by contacting our Privacy Officer. In certain jurisdictions, you may also have the right to have your personal information deleted, transferred to another service provider or processor or otherwise made portable for you, to not be subjected to automated decision making, or otherwise restrict how your personal information is processed.
You can exercise your other rights (including deleting your Account) by contacting our Privacy Officer. Please note that we may need to verify your identity in connection with your requests, and such verification process may require you to provide us with additional information (e.g., government identification). Even if you have access to your Account, we may request additional information if we
believe it’s necessary to verify your identity. If we are unable to verify your identity or request, we may not, in accordance with applicable law, be able to fulfill your request. Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it. We also will retain personal information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
Electronic communications. You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your e-mail address or phone number in order to receive Electronic Messages, you can opt-out of marketing messages at any time by following the instructions in our messages and adjusting your communication preferences. Please note that certain Electronic Messages may be necessary for the operation of our Services. You will continue to receive these messages, if appropriate, even if you unsubscribe from our optional communications.
Cookies. If you wish to minimize information collected by cookie or beacon, you can adjust the settings of your device or browser. You can also set your device or browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some Services may not work properly. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
Do Not Track. Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Our website does not currently change the way it operates upon detection of Do Not Track or similar signal. Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.
Withdrawal of Consent. If we rely on consent for the use or processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the use or processing of your personal information before your withdrawal of consent. If you wish to withdraw consent, please contact our Privacy Officer, or follow the instructions on opting-out of collection and use of your personal information through the Service or Account. Please note that if you withdraw consent, certain features of the Service or your Account may not have full functionality because certain features rely on your personal information to work as intended.
Third Party Websites and Apps
European Union and General Data Protection Regulation (GDPR)
Rights under European Union laws and GDPR. If you are located in the European Union, you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, port to another service provider, object to and restrict certain uses of your personal data, to not have your personal information be subjected to automated decision making or profiling, and to opt-out of direct marketing.
This section is only applicable to you if you are a resident of the state of California in the United States (“California Residents“) and only applies to personal information for which we are a “business” and you a “consumer” (as defined in the California Consumer Privacy Act, or “CCPA“). This section applies to personal information we collect from California Residents on or through our Website or Services and through other means (such as information collected offline or in person).
- Identifiers, such as your name, username or alias, postal address, unique personal identifiers (such as your account number or other online identifier), Internet Protocol (IP) address and other electronic network information, email address, and other similar identifiers.
- Customer records information, such as signatures, e-signatures, passwords, and other sign-on details, and any similar or related customer records information we identify at the time we collect it from you and which you choose to give to us.
- Commercial information, such as records of products you have purchased or considered, or other purchasing or consuming histories and tendencies.
- Biometric information, such as fingerprints or facial recognition for login purposes, and other biometric data we identify at the time of collection.
- Internet or other electronic network activity information, such as your browsing history, search history, and your interaction with the Website or Services.
- Geolocation information.
- Audio, visual, thermal, olfactory, or similar sensory information.
- Professional or employment-related information, such as your occupation, education, employment, and similar information.
- Inferences as we describe in the sections above entitled Collection and How We Use Information.
Sources, purposes, and third parties. California law requires us to disclose the categories of sources of the information we collect about you, the purposes for collecting, sharing, and disclosing that information, and the categories of third parties with whom we may share your information. For each of the categories we listed above, the sources of the information are described in the section above entitled Collection. The purposes for collecting, sharing, and disclosing the information are described in the section above entitled How We Use Information. The categories of third parties with whom we share your personal information are described in the section above entitled How We Disclose Information.
Financial incentives. In some circumstances, we may provide financial incentives as allowed by the CCPA for collecting and using your personal information. Any such incentives will be described to you at the time of collection or otherwise communicated to you before the incentives become applicable.
Your requests. Subject to certain exceptions and restrictions, the CCPA provides California Residents the right to submit requests to a business which has collected their personal information: (i) to provide them with access to the specific pieces and categories of personal information collected by the business about such California Resident, the categories of sources for such information, the business or commercial purposes for collecting such information (including any sale of personal information), and the categories of third parties with which such information was shared; and (ii) to delete such personal information (each, a “California Request“). We need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services. If you are a California Resident, please follow the instructions in the Your Rights and Choices section above to submit California Requests and please make sure you note that you are a California Resident when you do so. California Residents may designate an authorized agent to make California Requests on their behalf. In order to designate an authorized agent to make a California Request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification. We may use any relevant categories of personal information we outline in this section to verify your identity when you make a California Request.
We do not discriminate against you. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. We do not discriminate against California Residents for exercising their rights.
Public Areas of the Services
You may be able to post or make public communications on certain areas of our Website or Services, such as comments and questions fields, discussion forums, in-App communication functions, and other public discussion mechanisms. These kinds of communications are made at your own risk. Although we may monitor or even control these types of public posts, we are under no obligation to do so. We also cannot control the actions of other users of the Website or Services, including how they will use your public posts and any personal information you include in them. We cannot and do not guarantee that unauthorized persons will not view your public posts or respect your privacy.
Where We Store Personal Information
Automated Decision-Making and Your Personal Information
We may use machine learning algorithms and forms of automated decision-making. For example, we use automated decision-making to prevent risk and fraud, to personalize your experience and make it more efficient, and to determine eligibility for certain services or features we offer on our Website and Services. We may also use such technologies to provide and improve the Website and Services and how we deliver them to you.
We welcome questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have questions, concerns, or feedback, you can always contact our Privacy Officer below. For your protection, we may need to verify your identity before assisting with your request.