Privacy Policy

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.

This Privacy Policy (“Policy”) describes how NewTouch Digital (“Company” or the terms “we”, “our”, “us”) collects, gathers and uses information that we come to possess about you through your use of our technology and services. By visiting our website www.newtouchdigital.com or other websites we own or administer and any other linked pages, features, content, or related services offered by the Company in connection therewith (collectively, the “Site” as further defined in our Terms of Service (“Terms”)), using our mobile application (“App”) or using any of our services (“Services”), you consent to this Policy and to our use and processing of your personal information for the purposes set forth herein.

By accepting our Privacy Policy during registration, or by visiting and/or using the Site, our App or any of our Services, you expressly consent to our collection, use, disclosure and processing of your Personal Information (as defined below) in accordance with this Privacy Policy.

 

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.

1. WHAT DOES THE PRIVACY POLICY COVER?

 

Personal Information Overview

This Privacy Policy covers how our Company uses and discloses personally identifiable information that we gather from you when you access our Site, our App or use of our Services. Personally identifiable information is any information about you that can be used to identify you or contact you and information on your use or potential use of the Site, our App or our Services, including, but not limited to, your name (first and last name), your personal profile, your email address or other contact information (collectively referred to as your “Personal Information”). We are committed to securely and carefully managing your Personal Information related to the Services that we provide. However, it is important for you to understand that this policy does not apply to the practices of companies or websites or other third-party services that we do not own or control, or to individuals or groups that we do not employ or oversee.

 

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.

The Privacy Policy describes how we protect your privacy as a user of our Site, our Mobile Apps, our software and Services. Federal and state law provide you with additional rights related to the access to, use, and disclosure of Personal Information that constitutes PHI.

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

  • To prevent or take action regarding illegal activities, potential fraud, or situations involving threats or risks to the safety of any person or violations of our Terms of Service or this Privacy Policy.

4. HOW WE SHARE YOUR INFORMATION

We will not rent, sell or share your identifiable information with other people or non-affiliated companies except to provide the Site, App and/or Services, when we otherwise have your permission, as expressly permitted or when required under this Privacy Policy. We may share your information, including your Personal Information and/or Protected  Health Information only with your prior consent with outside parties and partners. Outside partner and parties you may potentially designate and consent to share your information with include healthcare providers and your family and caregivers. We may share data collected through the Site, App and/or Service with healthcare researchers and other research organizations, including de-identified profile information and aggregated data collected from you. We will not share any information that could specifically identify you such as your name. We 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. Sharing your information may be necessary to prevent or take action related to illegal activities, potential fraud, or situations involving threats or risks to the safety of any person or violations of our Terms of Service or this Privacy Policy.

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.

 

6. CHANGES TO THIS PRIVACY POLICY

By using the Site, App and Services, you agree to the current Privacy Policy and our Terms of Service, on which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to change, modify, discontinue, or terminate the Site, App, and/or Services or to modify this Privacy Policy at any time. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used or disclosed. If we change the way we use Personal Information, we will notify you by sending you an email and providing an announcement on our Site and/or App. By continuing to access or use the Site, App or Services after we have posted a change to our Privacy Policy or have provided you with notice of a change, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease accessing the Site or Mobile App and using the Services.

 

7. QUESTIONS

If you have any questions, suggestions, concerns or complaints regarding our Privacy Policy on our Site, App, or Services please contact NewTouch Digital’s Privacy Officer at:

By email: support@newtouchdigital.com

Address:

Privacy Officer
New Touch Digital Inc.
3124 Dumbarton Street NW
Washington, DC 20007

 

Updated July 2018

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