CVAid Ltd. Privacy Policy

Last Updated: August 1st, 2024

 

This Privacy Policy applies to CVAid’s subscription services, including the associated CVAid mobile applications (collectively, the “Services”), www.cvaidmedical.com and other CVAid websites (collectively, the  “Websites”), and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with CVAid. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of CVAid’s business. 

This Privacy Policy does not apply to any third party applications or software that integrate with the CVAid Services (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any personal data, video recordings, messages, files or other content submitted through use of the Services (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls certain aspects of their instance of the Services (their “Deployment”). 

 

Information We Collect And Receive 

CVAid may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways.

Customer Data Deployments are configured to send Customer Data to CVAid for processing using the Services. For example, video recordings may be sent to CVAid through the Services in order for a stroke specialist or certified medical teams to review the video recordings of a neurological examination. Customers or individuals granted access to a Deployment by a Customer (“Authorized Users”) routinely submit Customer Data to CVAid when using the Services. For example, Authorized Users may submit messages through the mobile application component of the Services to coordinate care for a patient. Customer Data includes “Protected Health Information” as defined in the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Protected Health Information is governed by the HIPAA Business Associate Agreement between the Customer and CVAid and not by this Privacy Policy.

 

Other Information CVAid collects, generates and/or receives the following types of Other Information:

- General Contact Information. We collect personal data such as general contact information (including name, email address, phone number, and address) and any other information included in messages submitted through the contact us form on our Website.

- Deployment and Account Information. To create or update an Authorized User account, you or the Customer (e.g., your employer) supply CVAid with personal data such as an email address, phone number, password, role or title, and other similar account details. In addition, Customers provide CVAid (or its payment processors) with billing details such as banking information and a billing address.
- Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users use the Services. For example, CVAid logs when an Authorized User logs in to the Services, what videos recordings are accessed by an Authorized User, and other Authorized User activity within the Services.

- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data. Note that IP address is considered personal data.

- Device information. CVAid collects information about devices accessing the Services or Websites, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this information often depends on the type of device used and its settings.

- Location information. We may receive location information from you, the Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. CVAid may also collect location information from devices in accordance with the consent process provided by your device. Note that location information is considered personal data.

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CVAid collects the above categories of Other Information from the following sources:

- Information Collected via Cookies. CVAid uses cookies and similar technologies in our Websites and Services. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect information about you via the Websites and Services and across other websites and online services. See the section below regarding Cookies and Tracking Technologies for more information.

- Information Collected via Integration with Third Party Services. The provider of a Third Party Service may share certain information with CVAid. For example, if a cloud storage application is enabled to permit files to be imported to a Deployment, we may receive username and email address of Authorized Users, along with additional information that the application has elected to make available to CVAid to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to CVAid. We do not receive or store passwords for any of these Third Party Services when connecting them to the Services.

- Information You Import into the Services. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.

- Affiliates and Business Partners. CVAid may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional Information Provided to CVAid. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with CVAid. If you make a request through our Trust Center Website, you will be asked to provide your full name, email address, phone number (for 2 factor authentication), institution name, and job position. You may also provide free text information to CVAid through our Websites, including our Trust Center.

Generally, no one is under a statutory or contractual obligation to provide us with any Customer Data or Other Information. However, as discussed above, certain Other Information is collected automatically and, some Other Information, such as contact information, is required in order for us to be able to provide the Services.
 

Cookies and Tracking Technologies

We and our third party partners and service providers (such as advertising networks and analytics providers) may use cookies and similar tracking technologies such as tracking pixels and web beacons to collect user activity information when you use our Website or Services. This information includes IP address, location, browser and device characteristics, operating system, language preferences, referring URLs, information about how and when you use the Website or Services, and other technical details. We use the following types of cookies:

• Necessary cookies. These are cookies that are required for the operation of the Website or Services.

• Functionality cookies. These cookies remember choices you make and are used to recognize you when you return to the Website or Services.

• Analytics cookies. These cookies collect information about how you use the Website or Services. They allow us to recognize and count the number of visitors and to see how visitors move around within the Website or Services.

• Advertising cookies. These cookies are used to track your online activity and deliver personalized advertisements.

Our website uses third parties to assist us in analyzing data regarding visitors to our Website and delivering personalized advertising, such as Google. For example, we use Google Analytics to collect information such as the number of visitors to a site, the webpage that referred visitors to a site, and the pages visitors view within a site. You can opt-out of Google Analytics by downloading Google’s Opt-Out Browser Add-on. Third parties may use cookies to track you across websites and serve you advertisements for CVAid while you are visiting other websites (i.e., retargeting).

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. If you use your browser settings to block all cookies, you may not be able to access all or parts of our Website.

Some internet browsers have “Do Not Track” or “DNT” features which, when turned on, send a signal to the website that the individual visiting the website does not wish to be tracked. Our Website does not honor DNT signals, but you can adjust your cookies settings as described above.

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How We Use Information

Customer Data will be used by CVAid in accordance with applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. CVAid is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to an Authorized User, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services. As noted above, CVAid’s use of Customer Data is governed by the Customer Agreement.
 

CVAid uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, CVAid uses Other Information:

- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.

- As required by applicable law, legal process or regulation. We may use Other Information in order to comply with applicable law, legal process, or regulation.

- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond. For example, we will use the information you provide to us to respond to Trust Center requests.

- To develop and provide algorithms, tools and additional features. CVAid tries to make the Services as useful as possible for specific Deployments and Authorized Users. For example, we may improve the way we present video recordings and images to Authorized Users by using Other Information to help determine and rank the relevance of information, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new features and products. Please note that after obtaining your consent, CVAid may use Customer Data and Other Information we obtain from your Deployment to train and improve our artificial intelligence models. CVAid may also access Customer Data and Other Information including messages within the mobile application to better understand how Authorized Users use and engage with the Services.
- To send emails and other communications, including marketing communications. We send you alerts through the mobile application when we identify a suspected condition and if you are “on call” within the mobile application. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about CVAid. These are marketing messages so you can control whether you receive them. 

- For billing, account management and other administrative matters. CVAid may need to contact you for account management and similar reasons and we use account data to administer accounts.

- To investigate and help prevent security issues and abuse. We may use Other Information to maintain the security and integrity of our Services, Websites, and business.

If Customer Data or Other Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, CVAid may use it for any business purpose. As discussed above, Protected Health Information is governed by the HIPAA Business Associate Agreement between the Customer and CVAid and not by this Privacy Policy.
 

Data Retention
CVAid will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Typically, CVAid will retain Customer Data and Other Information for the duration of a Customer’s subscription term in the Customer Agreement. CVAid may retain Other
Information after you have deactivated your account for the period of time needed for CVAid to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements. CVAid may retain aggregated or de-identified Customer Data indefinitely.
 

How We Share And Disclose Information

This section describes how CVAid may share and disclose Customer Data and Other Information.

- Customer’s Instructions. CVAid will solely share and disclose Customer Data in accordance with the Customer Agreement, and in compliance with applicable law and legal process.

- Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users. For example, an Authorized User’s email address or phone number may be displayed with their Deployment profile in order to use the Services, for example to enable rapid communication between the stroke team and the emergency department of a referring hospital in connection with the care of patients.
- Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Deployment activity, or accessing or modifying your profile details.
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Customer Data and Other Information and support our business. These third parties may, for example, provide virtual computing and storage services.
- Corporate Affiliates. CVAid may share Customer Data and Other Information with its corporate affiliates and subsidiaries. 
- During a Change to CVAid’s Business. If CVAid engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of CVAid’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Customer Data and Other Information may be shared or transferred, subject to standard confidentiality arrangements.

- Aggregated or De-identified Data. Subject to the Customer Agreement, we may disclose or use aggregated or de-identified Customer Data and Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective CVAid customer the average response time to alerts within a typical Deployment. 
- To Comply with Laws. If we receive a request for information, we may disclose Customer Data and Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of CVAid or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. CVAid may share Customer Data and Other Information with third parties when we have consent to do so.
 

Security
CVAid takes security of data very seriously. CVAid works hard to protect Customer Data and Other Information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. 
 

Age Limitations
To the extent not prohibited by applicable law, CVAid does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information. 
 

Changes To This Privacy Policy

CVAid may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and indicate the “last updated” date above. We encourage you to review our Privacy Policy to stay informed. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account.
 

Contact the Customer if you wish to request the removal of personal data under their control or have any inquiries related to your Protected Health Information.
 

To communicate with our Data Protection Officer, please email oren@CVAidmedical.com.
 

Contacting CVAid
Please also feel free to contact CVAid if you have any questions about this Privacy Policy or CVAid’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at privacy@CVAidmedical.com