New Touch Digital Inc. (the “Company”) is dedicated to protecting your personal information and understands your need to know how your personal information is gathered, used and shared. We take your privacy seriously.
As set forth under this Policy, the terms “using” and “processing” information include, among other things, using embedded scripts or cookies on a computer device including, browser, laptop, tablet, mobile phone or other device (a “Device”), subjecting the information to statistical or computational analysis, and using or handling information as needed, including without limitation collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within the Company, as well as using personal information to respond to you, the user, or your sponsor (i.e., the entity paying for your use of our Services) requests and to provide the requested products and services.
Personal Information Overview
Protected Health Information (“PHI”)
We understand that it is imperative that we maintain the privacy and integrity of protected health information (“PHI”) that we receive as you use our Site, App or Services. PHI is personal information that we receive as part of your use of our Site, App or Services that relates to (a) your past, present, or future health or physical, medical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care, which is created, received, transmitted, or maintained by the Company.
2. PERSONAL INFORMATION WE COLLECT
We collect information directly from you, from devices and third-party services you connect, as well as automatically through your use of our Site, our App, and/or our Service. The information you provide us and that we gather from you enables us to administer and manage your account, administer our App, and provide you with our Services. Additionally we use your information to respond to your questions and inquiries along with sending you communications regarding the Services and your access to and use of the same, obtain your feedback on our Site, our App and our Services, analyze your user activity, personalize and improve our Services, conduct research activities and contact you about our Company. We may use, enhance or augment the Personal Information we have about you with information obtained from a third-party.
We receive and store any information you enter on our Site, our App or provide to us through the Services, including any third-party services that you connect with our Services (e.g., Apple, Google). Personal Information that we collect may include things like your full name, your gender, mobile phone number, credit card or payment information, your email address, the email addresses of your contacts, home and business addresses, IP address, browser information, username, password, health information such as weight, height, pre-existing medical conditions, medications, tracking of movement activity and insurance information, and any other information or data that you provide when using our Site, our App and/or our Services. You may choose not to provide us with certain information but doing so may result in our us being unable to provide you with the full functionality of our Site, App or Services. Our goal is to use the Personal Information directly for your benefit.
When you use our App (on phone, tablet or wearable device): We collect your raw movement and motion data (i.e. accelerometer data, gyroscope data) along with other health and wellness information which may include heart rate, sleep, physical activity (e.g. steps, flights walked) and your location and time when data is being collected. In addition, we collect device model and operating system, the device ID, the device language, activities performed within the App and how long the App is open.
When you use third-party services: If you choose to connect your App to a compatible third-party service, such as those administered by Apple or Google, we will collect with your permission additional information such as: username and email address, step count, heart rate, distance and floors traveled, active and resting energy levels, sleep analysis, blood pressure readings, glucose and oxygen saturation levels, and workout history.
When You Contact Us. When you reach out and contact the New Touch Digital team directly (e.g. NewTouch Customer Support), we receive the information you send us in your message and any additional information you choose to provide.
3. HOW WE USE YOUR INFORMATION
We collect, process, and analyze your information, including your Personal Information and/or Protected Health Information for the following purposes:
To provide our Site, App and/or Service to you in a personalized manner
To communicate with you about your use of our Site, App, and/or Service
To answer questions you may have about our Site, App, and/or Service
To research and develop new features and future products
To understand how you and other users utilize our Site, App, and/or Service, both on an individualized and aggregated basis, in order to improve our Site, App, and/or Service by enhancing and adding features and capabilities
To understand if collected information is your personal information
To offer location customization
To gather feedback through surveys and questionnaires
To comply with any and all legal obligations
4. HOW WE SHARE YOUR INFORMATION
We make great effort to protect your privacy. However, we do and cannot control, and expressly disclaim any responsibility for, whether or how users will subsequently use or disclose previously disclosed information. If you do not consent to the disclosure of this information, do not access or use the Site, our Apps or our Services.
5. HOW WE SECURE YOUR PERSONAL INFORMATION
We utilize industry standard measures to safeguard and protect your information under our control from unauthorized access, use, and disclosure. When we collect, maintain, access, use, or disclose your information we will do so using systems, procedures and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
Your user account is protected by a password for your safety, privacy and security. To ensure that there is no unauthorized access to your account, we have incorporated safeguards in assigning and maintaining your password. We strongly suggest you diligently protect your account password and limit access to your account by signing off after you have finished accessing your account.
New Touch Digital Inc.
3124 Dumbarton Street NW
Washington, DC 20007
Updated July 2018