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Privacy Policy

Thank you for choosing to be part of our community at AR Medical Technologies Inc., doing business as AR Medical (“AR Medical”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at info@ar-medical.com.

When you access or use our website(s) (the “Sites”), web and mobile application(s) (the “Apps”), or use our online services (“Cloud Services”), you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites or Apps and our services.

This privacy policy applies to all information collected through our website(s) (such as maskfitar.com), mobile application(s) (such as MaskFit AR), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services").

We collect different types of information from or through the Services. The legal bases for our processing of Personal Information are primarily that the processing is necessary for providing the services to you and that the processing is carried out in our legitimate interests, which are further explained in this policy. We may also process Personal Information upon your consent, asking for it as appropriate.

This Policy applies indistinctly and generally to any Patient and Medical Professional using the Services (particularly MaskFit AR) (collectively “Users”).

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  4. HOW LONG DO WE KEEP YOUR INFORMATION?
  5. HOW DO WE PROTECT YOUR PERSONAL INFORMATION AND DATA SUBJECT RIGHTS?
  6. WHAT ARE YOUR PRIVACY RIGHTS?
  7. HOW TO GIVE, DENY OR WITHDRAW CONSENT TO COLLECT AND USE YOUR PERSONAL INFORMATION OR MAKE COMPLAINTS?
  8. HOW TO REQUEST TO MAKE CHANGES, MODIFY, DELETE, OR CORRECT INACCURACIES TO YOUR PERSONAL INFORMATION?
  9. HOW YOU ARE NOTIFIED IN THE EVENT YOUR PERSONAL INFORMATION LEAKS TO AN UNAUTHORIZED THIRD PARTY?
  10. CHILDREN
  11. SURVEYS
  12. DO WE MAKE UPDATES TO THIS POLICY?
  13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

  1. WHAT INFORMATION DO WE COLLECT?

    1. Personal Information You Disclose to Us

      We collect personal information that you voluntarily provide to us when signing up to use our Services, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services, or otherwise contacting us.

      The personal information that we collect depends on the context of your interactions with us and the services or apps, the choices you make, and the products and features you use. We may collect information including your name, organization, username, password, email address, phone number, mobile phone number, device model and serial number, date of birth, gender, region, and other information you enter, provide us, post on our services or allow us to access when you do certain things (collectively, “Personal Information”), such as:

      • Use one of our Services;
      • Provide registration information and/or create an Account;
      • Provide us with feedback or reviews;
      • Request certain features or information from us (e.g., newsletters, updates, and other services);
      • Download or use the Apps;
      • Contact customer support;
      • Apply for a job posting;
      • Connect with the Services or otherwise allow us to access certain information about you via a social networking service; or
      • Post user-generated content.

    2. Health Information Provided by You or Your Care Provider

      We collect health data you provide to us or the data collected by your care provider through one of our Services. When you use our Services, you can enter your own health information or the health information of patients you are examining (“Patient Information”). Patients Information collected through our Services may include height, weight, facial measurements, diagnosis, medical notes, and other related health information.

      Securing and preserving the confidentiality of Patient Information you entrust to us is a top priority for AR Medical. Patient Information is stored securely when uploaded to our Cloud Services. We will not collect, use or disclose any Patient Information other than as permitted by you or your care providers, this Privacy Policy, as required by law, or in accordance with additional applicable written agreements (e.g., for U.S. users, a Business Associate Agreement (BAA) as specified in the Health Insurance Portability and Accountability Act (HIPAA) or for E.U. users, a similar agreement constituting a Data Protection Addendum) that govern our use and disclosure of Patient Information. In the event of any inconsistency between the terms of any applicable written agreement such as the BAA and those in this Privacy Policy, the terms of the written agreement will prevail.

    3. Information from Other Sources

      We may obtain information, including Personal Information, from third parties and sources other than the Services, such as our partners or advertisers. If we combine or associate information from other sources with Personal Information that we collect through the Services, we will treat the combined information as Personal Information in accordance with this Policy.

    4. Information Automatically Collected

      Some information, such as IP address and/or browser and device characteristics, is collected automatically when you visit our services or apps. We automatically collect certain information when you visit, use or navigate the services or apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services or apps and other technical information. This information is primarily needed to maintain the security and operation of our services or apps, and for our internal analytics and reporting purposes.

      Like many businesses, we also collect information through cookies and similar technologies.

      Online Identifiers. We collect devices; tools and protocols, such as IP (Internet Protocol) addresses; applications; cookie identifiers, or others such as the ones used for analytics and marketing; device's geolocation; and other similar data.

    5. Information collected through our Apps

      We may collect information regarding your geo-location, mobile device, push notifications when you use our apps. If you use our Apps, we may also collect the following information:

      Geo-Location Information: We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device's settings.

      Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's camera, SMS messages, storage, reminders, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

      Mobile Device Data: We may automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP address.

      Push Notifications: We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

    6. Information Collected Through TrueDepth API

      We may use TrueDepth API provided by Apple and device camera to automatically measure facial feature dimensions such as nose length, nose width, eye distance, etc. We do not transmit or collect user photos and only measurement data is collected through the app.

  2. HOW DO WE USE YOUR INFORMATION?

    We process your information for purposes based on legitimate business interests and in compliance with our legal obligations, and/or your consent. We use the information we collect or receive:

    • To facilitate account creation and logon process. you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see Section 9 below).
    • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
    • Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
    • Request Feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.
    • To protect our Services. We may use your information as part of our efforts to keep our Services or Apps safe and secure (for example, for fraud monitoring and prevention).
    • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
    • To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
    • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
    • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
    • To deliver services to the user. We may use your information to provide you with the requested service.
    • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
    • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

    In certain circumstances, we may share the information we collect in order to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

    We may process or share data based on the following legal basis:

    • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
    • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
    • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
    • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
    • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

    More specifically, we may need to process your data or share your personal information in the following situations:

    • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
    • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
    • Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services or Apps) or otherwise interact with public areas of the Services or Apps, such personal information may be viewed by all users and may be publicly distributed outside the Services or Apps in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services or Apps, and view your profile.

  4. HOW LONG DO WE KEEP YOUR INFORMATION?

    We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than the period of time in which users have an account with us.

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  5. How do we protect your personal information and data subject rights?

    We aim to protect your personal information through a system of organizational and technical security measures. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate physical, technical, and administrative safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our services or apps is at your own risk. You should only access the services within a secure environment.

  6. WHAT ARE YOUR PRIVACY RIGHTS?

    In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

    In some regions, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please send a message to info@ar-medical.com. We will consider and act upon any request in accordance with applicable data protection laws.

    If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

    If you have questions or comments about your privacy rights, you may email us at info@ar-medical.com.

  7. HOW TO GIVE, DENY OR WITHDRAW CONSENT TO COLLECT AND USE YOUR PERSONAL INFORMATION OR MAKE COMPLAINTS?

    If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact information provided.

  8. How to request to make changes, modify, delete, or correct inaccuracies to your personal information?

    If you would at any time like to review or change the information in your account or terminate your account, you can:

    • Log into your account settings and update your user account.
    • Contact us using the contact information provided.

    Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

    Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services or apps.

    Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

    • Access your account settings and update preferences.
    • Contact us using the contact information provided.

  9. HOW YOUR ARE NOTIFIED IN THE EVENT YOUR PERSONAL INFORMATION LEAKS TO AN UNAUTHORIZED THIRD PARTY?

    A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when AR Medical Technologies Inc. believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that AR Medical Technologies Inc. becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information AR Medical Technologies Inc. will promptly investigate the matter and notify the applicable Supervisory Authority.

  10. CHILDREN

    We are committed to protecting the online privacy of children. Our Products and Services are intended for individuals who are trained and certified to use the Product and not geared towards children. In order to protect the privacy of children, children under 16 years of age are not permitted to provide any personal information to us and any users of our Product and Services are to ensure that any information of a minor (including any Patient Information and/or Examination Information) is only be provided to us with parental consent. Please email us at the contact information noted below if you believe we may have collected information from your child without proper consent and we will work to delete it.

  11. SURVEYS

    You may be asked to complete surveys when you visit the Site. We use information from surveys to better understand the needs of our users and to gather information about health care trends and issues. We may share anonymized information from surveys with third parties who perform data management services for our site. Those third parties have agreed to keep all data from surveys confidential. Also, we may share information from surveys in an aggregated, anonymized form with third parties with whom we have a business relationship.

  12. DO WE MAKE UPDATES TO THIS POLICY?

    Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

  13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

    If you have questions or comments about this policy, you may email us at info@ar-medical.com or by post to:

    Attention: Data Protection Officer

    AR Medical Technologies Inc.

    Vancouver, British Columbia Canada

    Email: info@ar-medical.com

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