Privacy Policy

What does this policy cover

Our Privacy Policy explains how CarePredict, Inc. (“CarePredict” or “we” or “us”) collects, uses, discloses, and protects information that applies to our elder care platform, comprising of wearable devices, mobile applications and web applications (collectively the "Service"), and your choices about the collection and use of your information.  In addition, this policy also covers any information collected when our company’s public web site at www.carepredict.com is accessed (“Website”).

The Service is provided through a care home operator or owner (these congregate living buildings are sometimes also referred to as Independent Living, Assisted Living or Memory Care Centers; a home care agency; direct purchase through an ecommerce web site by an elderly person or a family member or other guardian; a distributor or a reseller, all hereinafter referred to as a “Customer” individually or “Customers” collectively.  

The Service is used by Customer and their customers which may include care home operators or owners; care home staff members; care home residents; Family members or others authorized by a care home resident; a home care agency operator or owner; home care agency staff; an elderly person; Family members or others authorized by an elderly person; or a visitor to our Website; all hereinafter referred to as “User” or collectively “Users”.

The Website is accessible by any person (hereinafter “Visitor”) in any country through a web browser and contains general information about our company, our products and the markets we address, any job openings and an inquiry form to seek additional information about the company or a job opening.

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Use and any particular commercial agreement signed between a Customer and CarePredict.  If you do not want your information processed in accordance with this Privacy Policy in general or any part of it, you should not use our Service or Website.

This policy applies to all Users of the Service and Visitors to the Website.  

Summary: This policy sets out how we collect and use the information that we collect when you use the Service or Website. This policy also explains the choices that you can make about the way that we use your information.

1. Information we collect

We collect the following types of information about you:

(a) Information you provide us

If you are a care home resident or elderly person: We may ask for certain information when you or a Customer registers you with the Service (such as a username, password, first and last names, email address, physical address, phone number and optionally birthdate, gender, any assistive devices you use and any existing health conditions you choose to disclose). We collect content you generate on the Service such as your motion state, steps, location and physiological data such as heart rate, ambient data such as humidity, pressure, temperature and light levels.

If you are a care home staff or home care agency staff: We may ask for certain information when you or a Customer registers you with the Service (such as a username, password, first and last names, email address, phone number).  We collect content you generate on the Service such as messages between you and care staff, resident or family member;  number and duration of audio calls between care staff or care staff and residents; your motion state, steps and location.

If you are a care home operator or owner: We may ask for certain information when you or a Customer registers you with the Service (such as a corporate name, corporate address, physical location address, title, username, first and last names, email address, phone number, floor plan of a care home).

If you are a family member of a care home resident or an elderly person: We may ask for certain information when you or a Customer registers you with the Service (such as a username, first and last names, email address, phone number) in order for you to access the information on the resident or elderly person.

We use this information to operate, maintain, improve and provide the features and functionality of the Service to you, to correspond with you, and to address any issues you raise about the Service.

If you or a Customer does not provide your personal information to us, you may not be able to access or use our Service.

If you are a Visitor to our Website and use the inquiry form, we may collect any information you provide to us in the inquiry form such as name, email address, phone number, area of inquiry, reason for inquiry.

Summary: We collect info about you that you or Customer choose to give us, for example when an account is registered, the Website or Service is used or otherwise you interact with us.

(b) Information we receive from third-party applications

We may receive information about you from third parties if you communicate with us via social media, including Instagram, LinkedIn, Facebook, X or TikTok and choose to share your account name and your comments about us.

Summary: We collect information you communicate to us on third party applications outside of our Service. For example, if you post a comment about us on LinkedIn and tag us with it or you send a direct message on a social media application to our social media account.

(c) Information we receive from other third parties

If you are a Customer: we may receive data from other third parties about you such as credit worthiness, business reputation, business established date, business compliance metrics with regulations and laws. We do this to better understand your business and to decide on whether to conduct business with you.

If you are not a current Customer or User, we may obtain your contact details from a social media platform, such as LinkedIn, or a third-party data provider, so that we can promote our product offerings and subscriptions to you if we think they would be helpful in your role.

We also may have obtained your details from another CarePredict Customer or User, for example if they refer you to us as a potential Customer or User.

We may also receive information about you and your engagement with our advertisements on web sites, ad networks, search engines and social media platforms. This may include the websites you visited before coming to CarePredict so that we can determine advertising effectiveness.

Summary: We may obtain information about you from third-party sources so that we can understand your interests, suitability to enter into business with you and personalize our communications and promotions to you.

(d) Information we collect from you automatically

We will directly collect or generate certain information about your use of the Service or Website (such as user activity data, data generated by the CarePredict wearable you wear, analytics event data, and clickstream data) for data analytics and machine learning, and to help us provide the Service and Website. We may also use third party analytics tools that automatically collect information sent by your browser or mobile device, including the pages you visit and other information, that assists us in improving the Service or Website. For more information, please see the paragraphs below on cookies information, log file information, wearable data, device identifiers, and location data.

Summary: We collect and generate certain info about how you use our Service or Website automatically. This helps us to provide and improve the Service and Website for you.

(e) Cookies information and information taken from similar technologies

When you visit the Website or use the Service, we will send cookies (a small text file containing a string of characters) to your computer that uniquely identifies your browser and lets us do things like help you log in faster, enhance your navigation through the site, remember your preferences and generally improve the User experience.

You can control or reset your cookies and similar technologies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service or Website may not function properly if the ability to accept cookies is disabled.

Summary: We use cookies to help you use the Service and Website.

(f) Log file information

Log file information is automatically reported by your browser or mobile device each time you access the Service or Website. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service or Website, domain names, landing pages, pages viewed, and other such information.

Summary: Whenever you load a page from the Website or the Service, your browser sends us information about itself and your interactions with our Website or Service. That information gets stored on our servers.

(g) Clear gifs/web beacons information

When you use the Website or Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our Visitors or Users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Service.

Summary: We might use small images in order to check how many people open our emails and visit our Website or use our Service.

(h) Device identifiers

When you access the Website or Service on a device (including smart-phones or tablets), we may access, collect and/or monitor one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers uniquely identify your mobile device. A device identifier may convey information to us about how you use the Website or Service. A device identifier may remain persistently on your device, to help you log in and navigate the Service better. Some features of the Service may not function properly if use of device identifiers is impaired.

Summary: Your phone or device sends us information about your usage of the Website or Service.

(i) Location data

We collect information in order to understand where its Users are located. Geographical information helps us to localize content, comply with local laws and undertake aggregated analytics.  We use location data to analyze behavior patterns, provide location to care staff when assistance is needed to help reach you quicker; determine proximity of care staff to a resident; determine proximity of residents to one another.  Location data is obtained:

- from you, if you wear the CarePredict Wearable which tracks your indoor location within a care home or a home;

- from you, if you use the Service from a device (including smart-phones or tablets) which tracks your geographical location if you provided it permission to do so;

- from you, when you provide, correct or confirm your address;

- by inferring your location from your IP address; and

- from Customer when they register accounts for Users.

Summary: We may collect and use your location data for providing the Website or Service.

(j) Content within your account

If you wear a CarePredict Wearable device on your wrist, we receive data it generates that includes your motion state, steps, location and physiological data such as heart rate, ambient data such as humidity, pressure, temperature and light levels.  We can use this data to derive your activity and behavior such as eating, bathing, cooking or presence and duration in a particular location and rate of movement, your proximity to other residents or to care staff, and time spent with either.

If you carry a CarePredict Wearable on your body such as on your lapel or around your neck, we receive data it generates that includes your motion state, location and ambient data such as humidity, pressure, temperature and light levels.  We can use this data to derive your level of activity, rate of movement and location within a building, your proximity to other residents or to other care staff, and time spent with either and amount of time spent in a particular location.

Any content such as messages between other Users and you that you create or receive.

Summary: We collect the data your wearable device generates and content you create or receive on the Service.

2. How we use your information

We use the information we collect about you for the purposes set out below:

• Providing you with the Service: We use the information that you directly give us to provide the Service to you. This includes allowing you to log in to the Service, operating and maintaining the Service, giving you access to content created by you or others via the Service. We also use data we collect about you automatically to remember information about you so that you will not have to re-enter it during your visit or the next time you visit the site.
• For data analytics: We use information about you to help us improve the Website and Service and our Users experience, including by monitoring aggregate metrics such as total number of Visitors, Users, traffic, and demographic patterns.
• For Service improvement (including analytics and machine learning): We may analyze your activity, content, and related data in your account to provide and customize the Service, and to train our algorithms, models and AI products and services using machine learning to develop, improve and provide our Service. The data for training of AI models will not include any identifying information about you. These activities include, but are not limited to:
   
  • labeling and detecting activity and behavior patterns, locations and duration in order to provide predictive analytics on declines in wellbeing.;
   
  • labeling individual data such as fall detected, sitting, standing, eating, bathing, cooking, sleeping etc.
   
  • Measuring the frailty levels in aggregate of a care home to inform predictive staffing; and
 
• Customizing the Service for you: We use and combine the information you provide us and information about you that we collect automatically and receive from other sources (including information we receive on and off our Service) and combine it with information about the behavior of other users to make sure that your use of the Service is customized to your needs. For example, to predict a particular decline in wellbeing, we may use information derived from your prior behavior on our Service, the use of training models on behaviors by anonymized others with similar behaviors on our Service and other inferred information.
• To communicate with you about the Service: We use your contact information to get in touch with you and to send communications about critical elements of the Service. For example, we may send you emails about wellbeing alerts, fall detection, predictive analytics-based alerts, technical issues, security alerts or administrative matters.
• To promote and drive engagement with our Service: We use your contact information to get in touch with you about features relating to the Service that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant information based on your use of the Service.
• For advertising purposes on our Website: We use information about you, including cookies and other information we (and our third-party partners) collect from you automatically about your use of the Website, to serve, personalize and measure the effectiveness of advertising on the Website and third-party sites and platforms. This includes showing you advertising we think you might find interesting as well as displaying advertising to new Visitors that have similar interests.
• Customer Support: We use information about you, information that we collect, information from within your account, information that you provide to our customer support team, and information about your interactions with the Service or Website to resolve technical issues you experience with the Service or Website, and to ensure that we can repair and improve the Service or Website for all Users and Visitors to improve customer satisfaction.
• For safety, security, fraud and abuse measures: We may use information about you, your activity, content, media uploads and related data to prevent, detect, investigate and address safety, security, fraud and abuse risks, to develop our algorithms and models, and to identify violations of this Privacy Policy or our Terms of Use.
• For matters that you have specifically consented to: From time-to-time we may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.
• For troubleshooting, error resolution and service improvement: We may need to review your data to support your request for help, correct errors with the Website or Service or improve our Website or Service.
• For matters that we are required to use your information by law: We will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Website or Service; and/or (c) to exercise or protect the rights, property, or personal safety of us, our Users, Visitors or others.

Summary: We use information about you for different reasons, including to provide, customize and improve the Website or Service.

3. Sharing your information

(a) How we share your information

We share your information with third-party service providers for the purpose of providing the Website or Service to you, to facilitate our legitimate interests or if you consent. These service providers are vetted by us, and will only be provided with access to your information as is reasonably necessary for the purpose that we have engaged the service provider. We require that such third parties comply with applicable laws, and have security, privacy and data retention policies consistent with our policies to the extent necessary for them to perform a business or technology support function for us.

Some of the third parties with whom we may share your personal information are service providers who assist us with functions such as:

• Billing;
• Customer support and customer management;
• Email services;    
• Hosting and storage;
• Data analytics and predictive analytics;
• Data labelling and machine learning;
• Security;
• Advertising and marketing services;
• Domain name registration;
• Delivery of physical products; and
• Other service providers.

Provider (Purpose)

• Amazon Web Services (data storage, service emails)
• Atlassian (user support)
• QuickBooks (billing)
• Jira (user support)
• Monday.com (shipping)
• FedEx (shipping)
• DHL (shipping)
• UPS (shipping)
• USPS (shipping)
• Confluence (user support)
• ClickHouse (data storage)
• Pingdom (error monitoring)
• AlertOps (error monitoring)
• Firebase (user analytics)
• Slack (platform support)
• Zoho (CRM)
• HubSpot (CRM)
• WebFlow (Web site hosting)
• Zendesk (user support)

Summary: We might share some information about you with third-party service providers in order to provide the Website or Service to you or to fulfill our legitimate business interests.

(b) How you can share your Content

(i) As a Visitor to the Website

You can use the inquiry form to contact us and provide any content you wish to communicate to us.  There is no facility however to share your content publicly on the Website.

(ii) As a User of the Service

You can create direct or group messages on the Service that are then shared with other users such as care home staff, family members or Users authorized by the Customer or you.

If you accept an invitation to view a User’s data

• your name will be visible to any other person authorized to see that same User’s data;

Summary: Our data in the Service are private by default to the Customer, unless shared explicitly by you or an authorized User

(c) Sharing in connection with a merger, acquisition or reorganization

We may also share, sell or transfer your information to third parties in connection with or contemplation of (including as part of the due diligence process) any merger, acquisition, reorganization, financing, sale of assets, bankruptcy or insolvency event involving us or any portion of our assets, services or businesses. Information such as customer names and email addresses, User Content and other user information related to the Service may be among the items shared, sold or otherwise transferred in these types of transactions. You will be notified via a notice on the Website or Service if such a transaction takes place and be given notice of any material changes to the way we handle your data under this policy.

Summary: If we sell our business, any of the info which we’ve acquired about you may be part of the sale.

(d) Your employer or other organization associated with your email address

If you sign up for the Service using an email address associated with Customer, we may:

• share your name, email address, and basic account activity information with the Customer; and
• transfer control of the account to the Customer upon request.

Summary: Where you use a work email to set up an account, we might share information about the account with your employer or organization associated with the email address they manage and we might transfer control of the account to them.

(e) Sharing with other third parties

We will also share your information with third parties in certain circumstances, such as where you request us to share it with a third party for a particular purpose.

These third-party products and apps are not controlled by us, and this privacy policy does not cover how third-party apps use your information. You should review the terms and conditions of any third-party apps before requesting sharing them with the Service. If you object to information about you being shared with these third parties, do not request to share the data with that app.

Summary: We may share your data where you use third-party products or have integrated your use of CarePredict with third-party applications that are not controlled by us.

(f) Sharing aggregate data

We may also aggregate data stripped of all personally identifying characteristics and may share that aggregated anonymized data with third parties

Summary: We may share anonymized data with third parties.

(g) Sharing with authorities

We access, preserve and share your information with regulators, law enforcement, police, intelligence sharing and others in accordance with applicable laws and regulations where we have a good-faith belief that it is necessary to detect, prevent or address fraud, breaches of our Terms of Use, harmful or illegal activity, to protect our rights, property or intellectual property, you or others, including as part of investigations or regulatory enquiries or to prevent death or imminent bodily harm.

Summary: We may share data with authorities in accordance with applicable laws and regulations or where we feel it is necessary.

4. Advertising

We partner with third party ad servers, ad networks and social media platforms (like Facebook, LinkedIn, Google) to deliver personalized advertisements (“ads”) about our Products or Service that may be of interest to you and/or to measure their effectiveness, and/or to identify potential new users of our Service.

We may share certain information with our third-party advertising partners, such as your email address, location, cookie information and information relating to your use of our Website, and allow partners to perform a match of your information against information from other third party networks or sites to serve ads either on Website or on third party sites and to measure the effectiveness of these ads. We also share certain information with social media platforms, to display advertising to potential new Users or Visitors whose demographics and behavior look like those of our existing Users or Visitors.

In addition, these third-party ad servers or ad networks may use technology to send, directly to your browser or mobile device, these personalized ads and ad links directly to your browser or mobile device, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs) to compile information about your browser’s or device’s visits and usage patterns on the Website, and to measure the effectiveness of their ads and to personalize the advertising content. Please see Section 1 on our use of Cookies.

We do not sell or rent the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

The CarePredict Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

Summary: If we have ads on our Website we might use some of your info to show you appropriate ads. We may also use some of that info to send you relevant ads on other sites, like Facebook or Google.

5. How we transfer, store and protect your data

Your information collected through the Service will be stored and processed in the United States and any other country in which we or our service providers maintain facilities or employ staff or contractors. We transfer information that we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. As a result, we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. However, we always take steps to ensure that your information remains protected wherever it is stored and processed in accordance with applicable laws. Where required under applicable laws, you consent to the transfer of information to the U.S. or any other country in which we or our service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Summary: To run our Service, we’ll have to use vendors around the world. This means your information might be transferred to the U.S., Europe and anywhere else the Service is operated.

6. Keeping your information safe

We care about the security of your information, and use appropriate safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from us, at all times. However, we cannot ensure or warrant the security of any information you transmit to CarePredict or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third-party sites and services that you use along with the CarePredict Service, such as password managers, browsers and mobile devices. CarePredict is not responsible for the functionality or security measures of any third party.

Summary: We care about the safety of your data and have implemented industry recognized measures to protect it, but we can’t guarantee that nothing bad will ever happen to it.

7. Your choices about your information

(a) You control your account information and setting

We provide choices about how we process your account information:

• You can request access, correction or deletion of the data we hold on you by contacting privacy@carepredict.com; and

• You can opt out of receiving marketing messages by clicking on the “unsubscribe link” provided in such communications. However, you may not opt out of Service-related communications (e.g., account verification, wellbeing alerts, task alerts, changes/updates to features of the Service, technical and security notices).

Summary: You have control over marketing email notifications, but there’s some important stuff we’ll always send you. If you have any questions about reviewing or modifying your account information, you can contact us directly at privacy@carepredict.com.

(b) Opting out of collection of your information through tracking technologies

Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents CarePredict or its business partners from tracking your browser’s activities in relation to the Website and Service, and for use in targeted advertising activities by CarePredict, including via third-party websites. However, doing so may disable many of the features available through the Website and Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, please read Section 1 on use of Cookies.

Summary: If you want us to stop collecting information about you, there may be some settings you can adjust in your browser or device, but the Service or Website may no longer work.

(c) Rights in respect of your Information

The laws of some countries grant particular rights in respect of personal information. Individuals in certain countries, including the European Union, United Kingdom, and Brazil have the right to:

• Request access to their information;
• Request that we correct inaccuracies in their information;
• Request that their information be deleted or that we restrict access to it;
• Request a structured electronic version of their information; and
• Object to our use of their information.

Should you wish to make a request in respect of your personal information please contact us at privacy@carepredict.com.

In some circumstances CarePredict will not be able to comply with your request regarding your personal data. If we are unable to remove any of your information, we will explain why. For example, we may not be able to provide a copy of your information where it infringes on the rights of another user. In some cases, you may have shared your information with third parties, such as by publishing content on a third party’s website. In that case CarePredict will not be able to delete the information, and you will need to contact that third party directly.

If we are unable to resolve your request, or if you are concerned about a potential violation, you also have the option to report the issue or make a complaint to the data protection authority in your jurisdiction. Where you have provided your consent to certain processing and no longer want us to use your information for that purpose, you may withdraw your consent to this use, although this will not affect the lawfulness of processing based on consent before its withdrawal.

Summary: You may have specific rights in relation to your information depending on where you live.

8. How long we keep your information

Following termination or deactivation of your User account, we will retain your information and Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, CarePredict will retain your information for the purpose of complying with its legal and audit obligations, anonymized for training data, and for backup and archival purposes.

Summary: We retain your information and content for the purpose of providing our Service to you and to comply with our legal and regulatory obligations.

9. CarePredict for Minors

In this policy, a minor is considered a person under the age of 18 years old (or the minimum legal age in the child’s country to be able to provide lawful consent to the processing of their personal data).

The Service and our content are not directed at minors. Minors are not permitted to sign up by themselves for the Service.

We do not knowingly collect or solicit personal information from minors. If we learn that we have collected personal information from a minor without verification of parental consent where this is required, we will delete that information as quickly as possible. If you believe that we might have any information from or about a minor, please contact us at privacy@carepredict.com

Summary: Our Service is not intended for minors.

10. Links to other websites and services

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our Website, are subject to that third party’s own rules and policies. In addition, you acknowledge that we are not responsible for and we do not exercise control over any third parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

Summary: If we post a link to a third-party website on our Service or Website, we can’t control what happens on the other end when you follow the link. The same applies if you let another site use your data on CarePredict; the use of your information will be governed by the Privacy Policy of the third party.

11. Additional information for users in Europe

This section of the policy applies to our users that are located in the European Economic Area (EEA), Switzerland or United Kingdom (UK). CarePredict processes your personal data in accordance with European laws and regulations, such as the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR).

(a) Processor’s details

For the purposes of the GDPR and UK GDPR, CarePredict, Inc. is the processor of your personal data on behalf of the Customer (Controller). CarePredict Inc.’s registered address is at 600 N. Pine Island Rd, Ste 370, Plantation, Florida USA 33324, and we can be contacted using the details provided in the section below with heading “How to contact us”.

We process personal data as a processor on behalf of our Customer. Our Terms of Use set out the circumstances where we process personal data as a processor. In these cases, it is the CarePredict Customer that is responsible for the controlling of your personal data and our processing will be governed by the terms of the Data Processing Addendum we have entered into with the Customer. If you have questions or concerns about how your personal data is handled by one of our Customers, you should contact the relevant Customer that is using our Service and refer to their separate privacy policies.

(b) Legal basis for processing

If you are located in the EEA, Switzerland or UK, we need a lawful basis to collect, use and disclose your personal data as a processor. Our lawful basis will depend on the information concerned and the context in which it is processed.

Generally, we will collect and use your information as follows:

• Contractual necessity: We need it to provide the Service to Customer and fulfill our obligations to Customer under our Terms of Use. For example, this includes creating and maintaining your account, resolving issues you may experience with the Service, obtaining payment for our Services and providing you with access to your data.
• Legitimate interests: It is necessary for our legitimate interests, for example, providing a useful and customized Service, using information we collect about you so that we can make more informed predictions for our Users, helping Users connect with other Users and enhancing our Service via research and development, data analytics, data labelling, machine learning and predictive analytics relating to your collected data. We do not rely on this lawful basis where our legitimate interests are overridden by your rights and interests.
• Consent: You consent to us, and our third-party partners, using your information in a certain way – for example, for machine learning and predictive analysis relating to your generated data.
• Legal obligations: It is necessary for compliance with our legal obligations –  for example, to disclose your information in response to law enforcement requests and to retain your information for our record keeping purposes.

If you consented to our use of your information, you can withdraw that consent at any time. You can withdraw your consent by contacting the respective Customer.

Where we use your information for our legitimate interest, you have the right to object to that use by contacting privacy@carepredict.com. However, if you do, it may diminish the quality of the Service you receive or prevent you from using the Service.

(c) Cross-border transfers of information

By signing up, you understand and agree that CarePredict, Inc. (an entity in the United States of America) will receive and process your personal data. We may transfer your personal data to other countries where our service providers are located. Please note that some of these countries may have data protection laws that are different from your country (and, in some cases, may not be as protective). For Users in the EEA, Switzerland or UK, where we transfer your information to a third-party service provider that is not located in Europe, and is not in a country that benefits from an adequacy decision by the European Commission, UK or Swiss authorities, we will require those third-party providers to enter into an agreement that provides appropriate safeguards for your information, including by using the EU Model Clauses and the UK International Data Transfer Addendum.

Summary: If you are accessing our Service from Europe, CarePredict, Inc. is the processor of your personal data processing your information on behalf of Customer as a Controller. We only process your data if we have a lawful basis. We may transfer your information outside of Europe subject to appropriate safeguards.

12. Additional information for users in the United States

This section of the policy applies to Users that are located in the United States. In certain U.S. states, Users have additional rights afforded to them under applicable state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act and the Virginia Consumer Data Protection Act.

(a) Categories of personal information collected by CarePredict

For more details about the personal information we have collected in the past year, please see Section 1 “Information we collect”. For details on how we use that information, who we share it with, and how long we keep it, please see Section 2 “How we use your information”, Section 3 “Sharing your information”, and Section 8 “How long we keep your information.”

(b) Rights in respect of your personal information

These state privacy laws give resident Users various rights with respect to the personal information we collect, including the right to (subject to applicable law and certain limitations):

• Request access to the personal information CarePredict has collected about you;
• Request that CarePredict delete your personal information;
• Request that CarePredict correct inaccurate personal information;
• Opt-out from the "sale" of your personal information;
• Opt-out of the "sharing" of your personal information for advertising;

Appeal decisions where we deny your rights request.

(c) Exercising your rights

You may make a request by contacting us at privacy@carepredict.com. We will authenticate your request using the email address associated with your Service account and if necessary, proof of residency. Depending on applicable state law, you may also appeal a refusal to take action on a request by contacting us at privacy@carepredict.com.

You may opt out of the “selling or sharing” of your personal information, which may include us sharing your information with third party advertising partners as described in section 4 "Advertising".  You can opt out by emailing privacy@carepredict.com.

Summary: Certain U.S. state laws give Users resident in those states’ certain rights with respect to their personal information

13. Changes to this Policy

We may update this policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this policy, we will revise the “Last Updated” date at the top of this policy. If we make any material changes to the way we collect, use, store and/or share your personal information, we will notify you on our Website or within the Service. We recommend that you check this page from time to time to inform yourself of any changes.

Summary: We won’t make any major changes to our Privacy Policy without giving notice – but it’s a good idea to check this page occasionally.

13. Data Privacy Framework (DPF), Onward Transfer, Dispute Resolution

The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Should we need to Onward Transfer your personal data for purposes other than for providing the Service and in accordance with DPF Principles, we will, to the extent permitted by law, obtain assurances from the recipients that they will safeguard your personal data in a manner that is consistent with this policy. In addition, if we learn that a recipient is using or disclosing your personal data in a manner that is contrary to this policy, we will take reasonable steps to prevent or stop such use or disclosure. We may be liable for onward transfers of personal data to third parties in violation of DPF Principles and the DPF.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact us at: privacy@carepredict.com

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States, the European Union, the United Kingdom, and/or Switzerland (as applicable).  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or visit https://www.jamsadr.com/file-a-dpf-claim to file a complaint.  The services of JAMS ADR are provided at no cost to you.

Under certain conditions of the EU-U.S. DPF (https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction) you may invoke binding arbitration for certain residual claims.

Summary: Our compliance with the DPF is governed by the US FTC. If we have to transfer your personal data onward to others, we will require they adhere to this policy, and if they don’t, we may be liable to you.  We will work with you to resolve your complaint. If we are not able to, you can contact the named independent dispute resolution provider to file your complaint, at no cost to you.

14. How to contact us

If you have any questions about this Privacy Policy or the Service or Website, or wish to make a complaint please contact us at:

Email: privacy@carepredict.com

Write To:

Privacy Officer,

CarePredict, Inc.

600 N. Pine Island Rd, Ste 370

Plantation, Florida 33324, USA

Summary: Your privacy is important to us and we are happy to answer any questions you may have.

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