OMRON HEALTHCARE, INC.
CANADA PRIVACY POLICY

EFFECTIVE DATE: December 20, 2023

This OMRON Healthcare, Inc. Canada Privacy Policy (this “Policy”) explains how OMRON Healthcare, Inc. (“OMRON”, “we,” “us,” or “our”) collects, uses, and discloses information that we obtain about you.

We will only use your personal information in accordance with this Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This Policy applies when you use our website located at https://omronhealthcare.ca/ (the “Site”), as well as our mobile application(s) and other online products and services that link to this Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

This Policy DOES NOT apply to information that:

  • We collect offline.
  • You provide to or is collected by any third party (including our affiliates and subsidiaries).

Some OMRON affiliates’ sites and services (e.g. Omron.com, automation.omron.com and components.omron.com) are governed by that OMRON affiliate’s own separate privacy policies and practices. All other websites, services, or products made available by OMRON or any third party will be governed by those respective privacy policies. Additionally, https://omronhealthcare.com/ is our website in the United States and is governed by a separate privacy policy as shown in that website, not this one.

Your personal information may be transferred to and stored in a third-party server outside of Canada (see Transferring Your Personal Information).

This Policy may change from time to time (see Changes to this Policy). Your continued use of this Site and any Services after we make changes indicates that you accept and consent to those changes, so please check the Policy periodically for updates. We will notify you in advance of any material changes to this Policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download, register with, or use this Site or any Services. By using this Site or downloading any mobile application, you indicate that you understand, accept and consent to our use and collection of your personal information, including any information about your health that you provide directly to us or that we collect through your use of the Site or any Services as described in this Policy.

The Information We Collect About You

We collect information directly from you, from devices, and from third party and certain services with which you connect, such as Apple Health, Samsung Health and Google Fit or any other application(s) that may contain your information and automatically through your use of our Services.

When you visit our Site, use our Services, register to use our mobile application, create an account, update, or add information to your profile, fill out a form, sign up to receive our newsletter or other email communications from us, use a connected OMRON device, OMRON Complete or Alivecor Kardia Mobile Device (collectively referred to as “OMRON Device”) or otherwise communicate with us, we may collect the following categories of personal information:

  • Personal and Account Information. Your name, date of birth, age, email address(es), password, postal code and address. It is also at your discretion to add additional information to your account. You may choose to include details such as your profile image or picture, biography, race, ethnicity or any other contact information or third-party email address(es) that you may want to share your reports with.
  • OMRON Device Information. Information collected about the specific OMRON device includes but not limited to, device identifiers (user ID(s), device model, serial number, and any identifiers you assign to your device) and when your OMRON device is near your mobile device.
  • Mobile Device and Usage Information. Bluetooth functionality is required when connecting to your Omron device. During the course of the Services we provide to you, we collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, application version, device language, and accelerometer data (when using the mobile application). We also collect information about your activity on our Services using analytics tools (see below Advertising and Analytics), such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
  • Location Information. Your precise geographic location (i.e. GPS signals) and we collect this type of data if you grant us explicit access to your location through your mobile device settings. You can always remove our access using your mobile device settings.
  • Activity Information. Your activity information, such as your blood pressure, heart rate, blood pressure monitor, cuff position, movement error and location on the body where the electrocardiogram (“EKG” or “ECG”) recording was taken (e.g. finger tips, chest, limbs, etc.)
  • Health History and Information. At your discretion, we also collect health information that you choose to provide through your use of our mobile applications. This may include any of you and your family prior or current medical conditions, diseases, diagnoses and testing result (e.g., diagnosis of an irregular heart rhythm), raw ECG measurement data and readings, average heart rate, blood pressure readings, pulse rate, irregular heartbeat, TruRead average blood pressure results, medication you take and any images of your medication or medication bottles, and any notes, tags or voice memos to ECG recordings you make. You may also choose to provide us with the information about whether you have any disease or disorder for Cardiovascular (“CVD”) or presence of CVD in relatives.
  • Fitness and Behavioral Information. With your consent and permission, we collect your height, weight, body mass index, skeletal muscle percentage, resting metabolism, body fat percentage, visceral fat level, alcohol and caffeine consumption, whether you are a smoker or non-smoker, steps, calories burned, distance walked, aerobic steps, sleep duration, total awake time, low movement, high movement, auto sleep details, daily steps goal, daily sleep goals, daily weight goals, weight tracking, any notes, tags, dates, times and readings of the fitness and behavioral information and any details relating to your fitness and behavioral information where you choose to share.
  • Contact Information. When you contact OMRON directly, such as when you contact our Customer Support team, we will collect your name, email address, physical address, phone number, or other contact information and we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.
  • Third Party Health Services You Connect. If you have connected your mobile device to a compatible third-party service, such as Apple Health, Samsung Health, Google Fit or any other application(s) that may contain your information, you may choose to connect or link our mobile application with any of the aforementioned compatible third-party service. If you choose to do so, with your permission, we may collect information from your user profile.  However, we do not share with anyone nor do we use information collected from Apple Health, Samsung Health, Google Fit or any other application(s) that may contain your information for marketing, advertising or user-based data mining purposes.
  • Information collected by Cookies and Similar Tracking Technologies.

We (and our service providers) use tracking technologies, such as cookies, web beacons and SDKs, to collect information about you.

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits.

Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.

SDKs (also known as “software development kit” is a set of software-building tools that we use on our mobile application to help us improve our Services and your experience.

For more information about cookies and how to disable them, see our Cookie Policy.

  • Information We Derive. When you use our Service, we may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

How We Use Your Information

As permitted by applicable law, we use your information, including your personal information, for the following purposes (or otherwise with your consent):

  • To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to set up your account profile, to remind you to take medication or blood pressure readings, and for other customer service purposes. For example, we need to use your personal information to provide you with the dashboard tracking your exercise, activity, and other trends; to enable features of the Services; and to give you customer support.
  • To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services. For example, we use your personal information to make inferences and show you content that is more relevant.
  • To personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Third-Party Analytics section below.
  • For marketing and promotional purposes in accordance with applicable law. For example, we may use your email address to send you news and newsletters, special offers and promotions, or to otherwise contact you about products, services, or other information we think may be of interest to you. You can control and set any marketing communications and notifications within the Services or via the “unsubscribe” link in an email.
  • To send you technical notes, security alerts, and support and administrative messages.
  • To improve, research and develop new products and features. For example, we use your personal information to improve the Services, troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services. When required by law, we will use de-identified or anonymized information for these purposes.
  • To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services and respond to user desires and preferences, and for other analytical purposes.
  • To administer surveys and questionnaires.
  • To detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of OMRON and others.
  • To identify, debug and repair errors in our Services.
  • To comply with legal obligations, enforce our legal rights, including regarding terms and policies, billing and collection, as part of our general business operations, and for other business administration purposes.
  • To protect against fraud and abuse; and conduct audits.
  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Policy.
  • To authenticate your identity.
  • To monitor your compliance with any of your agreements with us.
  • To manage or transfer our assets or liabilities, for example, in the case of an actual or potential acquisition, disposition, or merger.
  • To carry out any other purpose described to you at the time the information was collected.

Cross-Device Tracking Use

We and our third-party service providers may use the information that we collect about you (whether directly from our mobile applications, through your device(s), or from a third-party) to identify other devices that you use (e.g. a mobile phone, tablet, other computer, etc.). This information helps us and our service providers serve targeting advertising on your devices and to send you emails. See the section in this Policy titled Advertising and Third-Party Analytics below for more information.

How We Share Your Information

We do not sell your information for money. We only share your information, including personal information in the limited circumstances described as follows:

  • With Your Consent. With your prior consent and authorization, we may share or disclose your information from the mobile application with third party applications, including your personal information and data collected from your connected devices. If you want to remove any third party applications’ access to your information within the mobile application, you will need to withdraw such access from the third party application or you may revoke your consent and authorization by submitting a request through the Form.
  • Your Healthcare Providers. With your consent and direction, we may share or disclose your information, including information collected from your connected devices, with your health care providers that you designate to receive your information.
  • Third-party. You have the option to share your reports or information within the mobile application with your friends, family or any third party by inputting the third-party email address(es) in the mobile application. You can remove any third-party email address(es) that you previously added to your account at any time.
  • Other Health-focused Mobile Apps. With your consent, we may share your profile information and data collected from your connected devices with other health-focused mobile applications installed on your mobile device to help you track your health and wellness information. If you share your information with these apps, your personal information, including your health information, will be used in accordance with those apps own privacy policies and terms, not this one. You can revoke any consent using the account settings within the App.
  • Health Researchers. We may share de-identified and/or anonymized data collected through our Services (including our mobile application) with healthcare researchers and other research organizations, including de-identified and/or anonymized profile information and data collected from your connected devices. For example, we may share information such as your gender, height, weight, information about medications you have provided, and data from your connected devices, but we will not share your name or other information that could identify you.
  • Affiliates and Subsidiaries. We may disclose the information we collect from you to our affiliates or subsidiaries. This allows each entity to comply with applicable laws, regulations and requirements, and ensures that your information is consistent, accurate and up to date. In addition, it increases the quality and relevance of the services you receive and improves your interactions with OMRON through easier access to your information within the group. If we do share your information with our affiliates and subsidiaries, their use and disclosure of your personal information will be subject to this Policy.
  • Advertising and Third Party Analytics. With your consent, we share the information with third-party to provide analytics and serve advertisements on our behalf across the web and in the mobile applications, see Advertising and Third Party Analytics section below. You may change your Cookies settings displayed in our Site’s footer anytime if you want to withdraw this type of sharing. You may also withdraw any third party analytics sharing by tapping the “opt out” button within the mobile application.
  • Service Providers. We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures and only use the information for the purposes for which we disclose it to them.
  • Business Transfers. If we are, or may be, acquired by or merged with another company, if substantially all of our assets are or may be transferred to another company, or as part of a bankruptcy proceeding or reorganization, we will give affected users notice before transferring any personal information to a new entity.
  • In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our End User License Agreement or this Policy, or as evidence in litigation in which OMRON is involved.

Advertising and Third Party Analytics.

We allow others to provide analytics services and serve advertisement on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and application, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile applications, links clicked, and conversion information. This information may be used by OMRON and others to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other website, and better understand your online activity.

Additionally, when you use the Site and our Services or its content, certain third parties may collect information about you or your device. These third parties may include analytics companies, your mobile device manufacture and/or your mobile service provider. We use automated application, such as Google Analytics, Adobe Analytics, OneSignal, and Mixpanel, to evaluate usage of our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance, and user experiences. These third parties may use the tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information and online activities over time and across different Services and other online services.

These third parties may use this information to provide you with behavioral advertising or other targeted content. You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or Network Advertising Initiative.  You can also access these two websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device.

You can learn more about internet-based advertising in mobile apps and to opt out of this type of behavioral advertising or other targeted content by using the AppChoices tool, you can download the AppChoices for your device at https://youradchoices.ca/appchoices/.

Opting out does not mean you will no longer receive online advertising. It means that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.  We do not control these third parties’ tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Links To Other Websites and Applications

Our Site or our other Services, including our mobile applications, may contain links to third-party websites or applications. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites or applications. We are not responsible for the privacy practices of such third-party websites. You are encouraged to review their privacy policies and practices prior to interacting with their websites or applications.

Transferring Your Personal Information

We will transfer and store your personal information that we collect or you provide to us in a third-party server, outside of Canada or Quebec, which is managed by OMRON in the United States. We may also transfer your personal information to contractors, service providers, and other third parties we use to support the Services who may be located outside of Canada or Quebec, and who are contractually obligated to keep personal information confidential, to use it only for the purpose for which we disclose it to them, to communicate with any third parties with your consent only, and to process the personal information with the same standards set out in this Policy. We may process, store, and transfer your personal information in and to other countries with different privacy laws. Whenever we engage a service provider or vendor that may process, store, handle or otherwise have access to your personal information, we require that its privacy and security standards comply with this Policy and applicable Canadian laws. However, your personal information may be subject to the laws of other countries.

Residents of Quebec

In accordance with Quebec private sector privacy legislation, Omron assesses personal information that is being transferred outside of Quebec to ensure that the information received adequate protection. We will also notify you if your personal information may be transferred outside of Quebec to the extent possible, except as otherwise required or permitted by applicable law.

You are welcome to contact us to obtain further information about other OMRON privacy policies for the information stored in the United States.

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security completely. Although we do our best to protect your information, we cannot guarantee the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk.

You should take steps to protect against unauthorized access to your password, phone, mobile device, and computer by, among other things, signing off after using a shared computer or device, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. If you have a security-related concern, please contact us at [email protected].

Data Retention

We keep your personal information only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Policy or as required by law. We may keep certain personal information for an extended period of time even when you are no longer our customer (such as, for required tax and financial record keeping, security, regulatory, fraud prevention, and to manage business operations). Under some circumstances, we may anonymize or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Your Rights

Subject to certain limitations, you have the right to:

  • request to know and access to the information we retain about you
  • request to erase or delete of your personal information
  • request to rectify and correct inaccuracies of your personal information
  • request to withdraw consent

Residents of Quebec may have additional privacy rights, you may

  • request to restrict processing (if any)
  • request to have your personal information transmitted to another entities (“Data portability”)
  • request a review of certain automated decisions
  • file a complaint with Office of the Privacy Commissioner of Canada

For mobile application, you may modify or correct personal information that you have submitted by logging into your account and updating your personal information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the application for a period of time.

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. In some situations, we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information. When an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

We store information associated with your account until your account is deleted. You can delete your account at any time. Please note that it may take a bit of time to delete your account information, and we may preserve it for legal reasons or to prevent harm, including as described in the How We Share Your Information section.

Accuracy

We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete. In most cases, we rely on you to ensure that your information is current, complete and accurate.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.

Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, submit your request through this Form.  Please note that if you withdraw your consent we may not be able to provide you with a particular service. We will explain the impact to you at the time to help you make your decision.

What Choices Do I Have Regarding Promotional text messages or emails or other Uses of My Personal Information?

As permitted by law and where required, with your consent, we may send periodic text messages or promotional emails to you. You may opt-out or unsubscribe of such communications by following the opt-out or unsubscribe instructions or link contained in the text message or email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt-out of receiving text messages or promotional emails about recommendations or other information we think may interest you, please understand that we may still send you non promotional emails, such as those about your account or our ongoing business relations.

You may also withdraw your consent to our collections, uses and disclosures of your information at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of your withdrawal of consent. When we receive notice of withdrawal of consent, we will inform you of the likely consequences of that withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.

Users Under 18

Our services are not designed for users under 18. If we discover that a user under 18 has provided us with personal information, we will delete such information from our systems.  If you believe we might have personal information from or about a user under 18, please contact us at [email protected]

Contact Us

If you have questions, complaints or concerns about the privacy aspects of our Services, please contact us our Privacy Officer at [email protected].

You may also contact us at:

OMRON Healthcare, Inc.

Attn: Privacy Officer

2895 Greenspoint Parkway, Suite 200, Hoffman Estates, IL 60196 USA

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site or any other Services that we provide to you. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice and give you an opportunity to review in advance of such change by highlighting the change.