Effective date: April 1, 2021
THIS PRIVACY POLICY CONTAINS IMPORTANT INFORMATION REGARDING HOW KOYA MEDICAL, INC. MAY COLLECT, USE, AND SHARE YOUR INFORMATION WHEN YOU VISIT OUR WEBSITE AND ALL RELATED WEB PAGES HOSTED UNDER THE URL WWW.KOYAMEDICAL.COM (KOYA MEDICAL WEBSITE) OR IN CONNECTION WITH THE KOYA MOBILE APPLICATION (THE “APP”) OR ANY OTHER KOYA RELATED PRODUCT OR SERVICE. PLEASE READ THIS POLICY BEFORE USING THE WEBSITE, APP, OR SUBMITTING ANY PERSONAL INFORMATION. BY CONTINUING TO USE THE WEBSITE , APP OR OTHER PRODUCT/SERVICE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
KOYA MEDICAL WEBSITE:
Personal Information Collection and Use
When you use Koya Medical's product and services, we or our service providers acting on our behalf may collect the following information to provide and improve our services to you.
Types of Data Collected
Personal Information
We may ask you to provide us with certain information that can be used to contact or identify you ("Personal Information"). This may include, but is not limited to your:
We may use your Personal Information to tailor your website experience to you (for example, by matching you with products or packages that may be of interest to you.) We may also use your Personal Information to contact you or send you information, for example, to send you our newsletters, marketing or promotional materials, and other information that we think 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 the instructions provided in any email we send.
Usage Data
We may also collect information that your browser sends whenever you visit the Koya Medical Website or when you access the Koya Medical Website 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 the Koya Medical Website 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 Koya Medical Website with 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 Technologies
In addition to information you submit through the Koya Medical Website, we may collect certain information using automated tools or tracking technologies. Tracking technologies allow us to improve the Koya Medical Website. The types of information we collect automatically when you use the Koya Medical Website may include IP addresses, device identifiers, device advertising identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, anonymous traffic data, and pages viewed.
We may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from third parties.
We or our service providers may collect Personal Information about your online activities over time and across different online services when you use the Koya Medical Website. More information about how specific providers of tracking technologies use Personal Information is discussed below in the “Analytics” section.
Information from other sources
We may obtain information from other sources and combine that with information we collect through the Koya Medical Website. For example, we may collect Personal Information from our commerce partner. The categories of information we collect from other sources include:
Use of Personal Information
We may use Personal Information we obtain for various purposes, including:
Disclosure of Data
Koya Medical does not sell your Personal Information to anyone. We may share Personal Information for the purposes described below.
Service Providers
We may share personal information with third party service providers, who will process it on behalf of us for the purposes described in this Privacy Policy and our Terms of Use (“Service Providers”). Service Providers include, but are not limited to, IT service providers, banks, credit card companies, brokers, suppliers of Durable Medical Equipment, shipping and logistics providers, training providers, survey service providers, investigators, and data hosting providers and custodians. We do not share, sell, rent, or trade personal information with third parties for their commercial purposes.
These Service Providers have access to your Personal Information 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 Service Providers to monitor and analyze the use of the Koya Medical Website.
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 the Koya Medical Website. 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: https://policies.google.com/privacy?hl=en
Behavioral Remarketing
Koya Medical may use remarketing services to advertise on third party websites to you after you visited the Koya Medical Website. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to the Koya Medical Website.
Google Ads (AdWords)
Google Ads (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
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Facebook remarketing service is provided by Facebook, Inc.. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/business/ads/ad-targeting
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
KOYA MEDICAL APP:
Koya collects personal information that you provide when you register for and use an account through the App. You cannot use the App without providing the information required to create an account. You do not have to use the App in order to use your Koya Dayspring system (the “Device”).
Legal Rights and Protection of Personal Information
Koya is not a “covered entity” under the federal Health Insurance Portability and Accountability Act (“HIPAA”), and the information collected by the App is not protected by HIPAA. However, Koya is required to abide by this Privacy Policy, as may be amended from time to time, and your information may be protected by other state and/or federal law.
Collection and Use of Personal Information
In order to establish an account with Koya, you will need to provide your name and email address. [You may provide your telephone number if you want to receive texts to remind you to use your Device and for other purposes to which you agree.] Koya uses this information to establish your account. It also collects information about your use of the App and the Device once connected to the App. For example, Koya collects information about the amount of time that you spend on the App, using your Device and when you do so. This information is then summarized and presented on the App for your review so that you may track your use of the Device over time. It is up to you to share this information with your health care provider if you want to. Koya will maintain your personal information until you cancel your account.
If you have opted-in to marketing communications, Koya may email [or text] information to you. You have the right to opt-out of such communications at any time. Koya may aggregate information and use it to improve the App, track Device utilization data or for other internal purposes. Aggregated data does not identify you as an individual.
Koya does not independently collect browser data, device data (other than the Device) or geolocation data and, further, does not utilize any third-party services that track App users.
"Do Not Track” Signals under California Online Privacy Protection Act (CALOPPA)
The App does not track you over time or across third-party websites. Therefore, it does not respond to Do Not Track signals.
Spyware
Koya values your privacy. The App does not use any spyware or any software that can gather information about you without your knowledge and consent and send it to another entity without your consent.
Business Transactions
Koya does not sell your personal information to anyone. Koya may share your information with third parties in limited circumstances as outlined under Disclosure of Data for the Koya Medical Website.
For example, Koya may share your information (subject to a confidentiality and non-disclosure agreement) in order to participate in a corporate transaction, in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company. Koya may also disclose information when necessary to respond to complaints or to comply with legal requirements.
Disclosure for Law Enforcement
We may share your personal information as required or permitted by law, including sharing with law enforcement, government agencies, or authorized third parties in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other party to legal liability.
Your Choices
If you do not wish to receive marketing emails from us, you can opt out of future marketing emails by following the instructions provided in the marketing emails. Opting out of marketing emails will not affect our administrative emails to you (e.g., emails about your transactions or policy changes).
Your Personal Information Rights
You may make certain requests regarding our use of your personal information by emailing us at compliance@koyamedical.com. We are under no obligation to provide a specific response to any such request, however, we agree to make commercially reasonable efforts to respond to any request we receive, subject to local laws. For your protection, we may need to verify your identity before acting on your request.
Security of Data
Koya uses a variety of security measures to protect your personal information from unauthorized access or disclosure. Although we implement reasonable security measures on the Koya Medical Website, we cannot guarantee the security of your information transmitted via the Internet.
When you create an account with the App, the App syncs to Koya servers using the https protocol that automatically encrypts the information. When you sync your Device with the App on your phone, the connection is secured through a BLE secure connection. Koya stores all personal information in a secured network. However, no method of protecting information sent over the Internet is perfect, and Koya cannot guarantee that your information is absolutely secure.
All information collected on the Website and App is maintained in the United States and its protection is subject to the laws of the United States.
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click an outside link, you will be directed to that outside site. We strongly advise you to review the Privacy Policy of every site you visit. We are not responsible for the privacy practices or the content of any outside sites or services.
Children's Privacy
Koya’s Website and App are not directed to children and Koya does not knowingly collect personally identifiable information from anyone under the age of 18. Parents, guardians or anyone with legal custody of a child may establish an account on the child’s behalf or register the child to use the App in conjunction with the child’s use of the Device.
Changes to This Privacy Policy
Koya reserves the right to change this Privacy Policy at any time without notice except for the posting of the revised Privacy Policy on this page. Any changes will be effective upon posting and will apply only to information collected after the posting date. It is your responsibility to review this policy from time to time to ensure that you continue to agree with all of its terms.
Contact Us
If you have questions about this policy, our privacy practices or how to change the information on your Koya Medical account, please contact our Privacy Officer at compliance@koyamedical.com.
