This is the privacy notice (“Privacy Notice“) that governs how we, AmplioSpeech Ltd. and its subsidiary AmplioSpeech Inc. ( “AmplioSpeech”, “we“, “our” or “us“), use Personal Information (defined below) that we collect, receive and store about individuals in connection with the use of the websites, www.ampliospeech.com, their sub-domains and any other website that we operate (together with all sub-domains, content and services, the “Site“) and (ii) the AmplioSpeech software applications, which may be branded differently (the “App”). The Sites and the App are individually and collectively referred to herein as the “Services”.
- We have implemented this Privacy Notice because your privacy, and the privacy of other users, is important to us. This Privacy Notice explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Site. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information as well as health data which may be considered as sensitive data. In addition, Personal Information shall also include “protected health information” provided and/or made available by you to us or created by us, as a “Business Associate” on your behalf, and has the same meaning as the term “protected health information” as defined by 45 C.F.R. 160.103.
- Consent and Modification. By using the Site and the Services, you consent to the terms of this Privacy Notice and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Notice, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Notice at any time. Such change will be effective ten (10) days following posting of the revised Privacy Notice on the Site or Services, and your continued use of the Services thereafter means that you accept those changes.
- What Personal Information We Collect and How We Collect It. We do not currently require you to provide Personal Information in order to have access to GENERAL INFORMATION available on the Site But, we do receive and/or collect Personal Information from you in the ways set forth below:
- Account. In order to use the Services, you will be required to create an account (“Account”). You will register by completing and submitting an online registration form. You will be asked to provide us with certain mandatory information such as your name (or the name of your guardian), year of birth, country, language and email address, and a password that you will use for your Account, or by connecting the account to one of your existing Internet accounts, such as Google or Facebook. We may send an email to your nominated email address to instruct you how to confirm your registration.
- Information necessary for providing our Services. Such Information may include medical records (such as assessment, clinician notes, supervisor notes), voice and video recordings (during therapy and practice sessions), speech language qualities (SLQ), transcripts of speech, feedback (from Speech-Language Pathologist “SLP” and user) etc.
- ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available, by clicking “report” or “message”, or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name, telephone number and email address.
- Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.
- Cookies and Other Tracking Technologies. Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
- Device Data. We may collect limited information from your device in order to provide the Services. Such information may include your device type, device id, and date and time stamps of Services use. In addition, we may deploy tracking technologies within the Services to help us gather aggregate statistics, but we will not use Personal Information for such purposes.
- Additional Data. We may collect additional data through your device in order to provide the Services. Such information may include voice recordings, analysis of speech patterns, and usage of the mode application.
- The Way We Use Personal Information. If you submit or we collect Personal Information through the Services, then we may use such Personal Information in the following ways via any applicable communication channel, including e-mail, in-app messaging, SMS, etc.:
- We will use your Personal Information to provide and improve our Services, by providing decision support information to clinicians, based on real measurable and recorded data, to provide feedback to our users and/or guardians regarding performance and progress, communication with different caregivers (SLP, trainer, supervisor) etc.
- We will use your contact information to contact you in connection with the Services and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Services that you are authorized to access.
- We may collect your personal information in order for us to demonstrate compliance, performance and progress to authorized health providers (such as HMO, school etc.).
- We may use your designated email address to: (i) send you updates or news regarding the Services and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password) (iii) provide system notifications for events such as scheduling, messages and others.
- We, as a Business Associate, are permitted to use Information if necessary for our proper management and administration or to carry out our legal responsibilities. (Ref. 164.504(e)(4)(i)(A-B)).
- We may disclose your Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms and Conditions including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of our users, yourself or the public.
- International Transfers of your Personal Information. Any information we collect from you will initially be collected and stored in our cloud servers, hosted by Amazon Web Services or other vendors. If you are in the EU or EEA, we will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy notice.
- Use of Anonymous Information. We may use Anonymous Information (as defined below) or disclose it to third party service providers for research purposes and in order to improve our Services and enhance your experience with the Services. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Site.
- Opting Out. You may choose not to receive future promotional, advertising, or other Services-related emails from us by selecting an unsubscribe link at the bottom of bulk-emails that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Services.
At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Services, but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.
- Your Rights in Respect of your Personal Information.
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
- Right of access. You have the right to obtain:
- confirmation of whether, and where, we are processing your personal information;
- information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your personal information; and
- a copy of the personal information we hold about you.
- Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Notice. You may also review and edit the personal information you have submitted to us by logging into your account on the app.
You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority for European residents is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .
- Obligations. You shall:
- Immediately notify us of any limitation(s) in your notice of privacy practices of under 45 CFR 164.520, to the extent applicable and to the extent that such limitation may affect our use or disclosure of Information.
- Immediately notify us of any changes in, or revocation of, the permission by an individual to use or disclose his or her Personal Information, to the extent that such changes may affect our use or disclosure of Personal Information.
- Immediately notify us of any restriction on the use or disclosure of Information that you have either agreed or is required to abide by under 45 CFR 164.522, to the extent that such restriction may affect our use or disclosure of Personal Information.
- Not request us to use or disclose Personal Information in any manner that would not be permissible under Subpart E of 45 CFR Part 164 if done by you, except for uses or disclosures of Personal Information for data aggregation and our management and administration and legal responsibilities as set forth herein and under applicable law.
- Duration of storage of personal data. Your personal information will be deleted immediately as soon as you withdraw your consent – via email to email@example.com – or as soon as our purposes for storing your data have expired, unless we are legally bound to further store data according to Sec 6 Para 1 Page 1 lit. c GDPR.
- The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Services, you can contact us at firstname.lastname@example.org.
- OUR POLICY TOWARDS CHILDREN. Our Service is also directed to children but we do not knowingly collect personal information from children under 13 without the specific written consent of a parent/legal guardian. If your child is under the age of 13, and you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us. As the child’s parent/legal guardian, please be advised that:
- We will not require a child to disclose more information than is reasonably necessary to participate in an activity;
- you can review your child’s personal information, direct us to delete it, and refuse to allow any further collection or use of the child’s information;
- you can agree to the collection and use of your child’s information, but still not allow disclosure to third parties that are not part of the service providers; and
- If you wish to exercise any of your rights, please contact us at: email@example.com.
- Merger, Sale or Bankruptcy. In the event that we are acquired by or merged with a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Services to meet these demands. If you have any comments or questions regarding our Privacy Notice, or your Personal Information that we may be storing and using, please contact us at firstname.lastname@example.org.