Effective date: May 12, 2018
Geritrak, Inc. (“us”, “we”, or “our”) operates the http://Geritrak.com website and the Geritrak App mobile application (collectively, the “Services”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING ANY SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE COLLECTION, USE AND PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT VISIT, INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS ANY SERVICES.
Definitions
Service
Services means the http://Geritrak.com website and the Geritrak App mobile application operated by Geritrak, Inc.
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Services and is the subject of Personal Data.
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personal Data may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
- Health information
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Usage Data
We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Services by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Services and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
- Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
Mobile Data
We use mobile analytics software to allow us to better understand the functionality of our mobile application on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
We may send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. The mobile application may also ask for your permission to access your camera and your photos. If you no longer wish to receive these types of communications, or if you’ve initially agreed for the application to access your camera and photos and you would like to stop the app from accessing them, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We do not ask for, access or track any location-based (precise location) information from your mobile device at any time while downloading or using our Mobile Apps or Services.
Use of Data
Geritrak, Inc. uses the collected data for various purposes, including, but not limited to:
- To provide and maintain our Service
- To administer your account
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Services when you choose to do so
- To provide customer support
- To provide you with access to particular tools or features
- To respond to your inquiries and send you administrative communications
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- Obtain your feedback on our sites and our offerings
- Conduct research and measurement activities
- To detect, prevent and address technical issues
- Provide you and people with similar demographic characteristics and interests with more relevant content and advertisements
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
We may combine information that we collect about you with information from external sources. We may use this information to provide services to you such as personalized content and advertising. Third parties may also use this information in order to display interest-based advertising to you.
To enhance our services, we may share your information with third parties who provide services on our behalf to help with our business activities such as email service providers, data analyzers and business intelligence providers for the purpose of enhancing our products and services. These companies are authorized to use your personal information only as necessary to provide these services to us.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Geritrak, Inc. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Geritrak, Inc. may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- To comply with the law
Retention of Data
Geritrak, Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Geritrak, Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Geritrak, Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure Of Data
Disclosure for Law Enforcement
Under certain circumstances, Geritrak, Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Geritrak, Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Geritrak, Inc.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Services or the public
- o protect against legal liability
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We have put in place technical, physical, and administrative safeguards to protect the Personal Information that we collect.
We take reasonable security measures to protect the security of your Personal Information. Despite Geritrak’s efforts to protect your Personal Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.
The security of your Personal Information is important to us. When you enter Personal Information (including personal health information in various tools on our website), we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology.
If you have any questions about the security of your personal information, you can contact us at privacy@geritrak.com.
Data Protection Officer
Geritrak has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer may be reached at the following address:
Geritrak
ATTN: Data Protection Officer
19 West 34th Street,
Suite 1018,
New York, NY 10001
dataprotectionofficer@geritrak.com
“Do Not Track” Signals
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Geritrak, Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Geritrak, Inc. relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Service Providers
We may employ third party companies and individuals to facilitate our Services (“Service Providers”), to provide the Services on our behalf, to perform Service-related services or to assist us in analyzing how our Services are used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Advertising
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
Google AdSense DoubleClick Cookie
Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Services or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
AdMob by Google
AdMob by Google is provided by Google Inc.
You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
For more information on how Google uses the collected information, please visit the “How Google uses data when you use our partners’ sites or app” page: http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of Google: http://www.google.com/policies/privacy/
Behavioral Remarketing
Geritrak, Inc. uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
Google AdWords
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Links To Other Sites
Our Services may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children’s Privacy
Our Services does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes To This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
- By email: privacy@geritrak.com
- By visiting this page on our website: http://www.geritrak.com/privacy-policy
- By mail: Geritrac Inc 19 West 34th Street, Suite 1018, New York, NY 10001.