Who We Are
Amara Therapeutics Limited t/a Amara Therapeutics is a digital therapeutics company determined to change the way pelvic healthcare is delivered globally. Our goal is to empower Patients to take control of their pelvic health using evidence-based medicine and behavioural interventions supported by our Digital Therapeutic Platform.
Our mission is to provide accessible, affordable effective care by connecting Healthcare Providers, payers, Patients and peers.
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your Personal Data when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the service we deliver through the RiSolve Platform. By using the RiSolve Platform, You agree to the collection and use of information in accordance with this Privacy Policy.
How to Contact Us
If you have any questions about this Privacy Policy, You can contact us:
- By email: dpo@risolvedtx.com
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. You will receive a notification within the RiSolve Platform regarding any changes.
We will let You know via email and/or a prominent notice on Our Service and update the "Revision" and “Revision Date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are published, which you will be notified of.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Anonymisation means rendering information to a point where it does not relate to an identified or identifiable natural person or to Personal Data rendered anonymous in such a manner that the data subject is not or no longer identifiable.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ Personal Data and determines the purposes and means of the processing of Consumers’ Personal Data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ Personal Data, that does business in the State of California.
CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Amara Therapeutics Ltd, Unit 109, University of Galway Business Innovation Centre, Upper Newcastle, Galway, H91AX62, Ireland.
For the purpose of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Country refers to: Ireland
Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a phone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
GDPR refers to EU General Data Protection Regulation.
Healthcare Provider (HCP) is a person or entity that provides medical care or treatment.
Patient is a person who is under medical care of treatment.
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Pseudonymisation (as defined in the GDPR) means the processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.
RiSolve Platform refers to RiSolve, the software program provided by the Company. The Platform has two main components, the RiSolve mobile app for Patients, and the RiSolve Portal for Healthcare Providers and Amara Therapeutics designated employees.
Service refers to the RiSolve Platform.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in
analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.
What is RiSolve and How does it Work
RiSolve is a treatment platform that has two main components, tailored to the three main parties that will interact with it:
- The RiSolve App (for Patient Users):
This is a mobile application that delivers an 8-week treatment program to the Patient via their Smart Phone. Throughout the RiSolve treatment program, the Patient user will be asked to log information and track their Health Data*. - The RiSolve Portal (for Healthcare Providers and Amara Therapeutics designated employees):
This is a web-based dashboard that generates and supplies reports and enables HCPs to view reports and view the progress of their Patients. The reports are generated by an algorithm, using patient Health Data* collected by the RiSolve App. Designated Amara Therapeutics employees can use the RiSolve Portal for administrative, regulatory and research purposes (e.g. post-market surveillance activities, scientific publications, conference presentations).
For Patients
Patients will be prescribed the RiSolve treatment by their HCP and it will be delivered via a mobile application. The Patient will receive an invitation code via email, which they enter during registration on the RiSolve App. The RiSolve App provides a variety of content (e.g. video, audio) throughout the program, to help treat OAB. At certain times during use of the RiSolve App, the Patient will be asked to provide Health Data* (e.g. data on bladder function, urinary events, general health and wellbeing). Personal Data and Health Data* provided by Patients will be viewable to the Patient’s HCP and designated Amara Therapeutics employees. Personal Data and Health Data* provided by Patients can also be downloaded in the form of a provider report PDF by their prescribing HCP via the RiSolve Portal. Pseudonymised Patient Personal Data* and Health Data* can be exported/downloaded by designated Amara Therapeutics employees for administrative, regulatory and research purposes (e.g. post-market surveillance activities, scientific publications, conference presentations).
For Healthcare Provider
HCPs prescribe RiSolve to their Patients by adding the Patient’s Personal Data to the RiSolve Portal via the web-based dashboard. The Patient will then receive an invitation code via email, which they enter during registration on the RiSolve App. As the Patient progresses through their treatment, reports are generated by an algorithm, using Patient Personal Data and Health Data* collected by the RiSolve App. This Patient Personal Data and Health Data* is viewable to the prescribing HCP via the RiSolve Portal and can also be to downloaded in the form of a provider report PDF. Patient Personal Data and Health Data* is only accessible to the prescribing HCP, via the HCP’s secure log-in to the RiSolve Portal.
For Research (Amara Therapeutics)
Designated Amara Therapeutics employees will have access to the RiSolve Portal for administrative, regulatory and research purposes (e.g. post-market surveillance activities, scientific publications, conference presentations). There are two Amara Therapeutics user roles: “Amara Admin” and “Amara Data Steward”. Amara Admin users can view HCP and Patient Personal Data and Patient Health Data*.
Amara Data Steward users have an additional access level, whereby they can export Pseudonymised Patient Personal Data for research purposes.
Amara Therapeutics Data Steward user will receive a monthly summary report via email, which will detail active HCP user names and the number of new Patients they have added to RiSolve within each reporting period.
Collecting and Using Your Personal Data
Types of Data Collected
For Patients
While using Our Service, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. Personal Data may include, but is not limited to:
Email address
Phone number
Address, city, state, country
Date of Birth
Age
Health Data*
Other Sensitive Information**
Usage Data*** *Health Data
We will ask you for data related to Your health, which you can provide on a case-by-case basis to us. This information will be captured via the RiSolve Platform and will only capture information provided by You, or provided via Your Healthcare Provider.
**Other Sensitive InformationThis may include, depending on the information you provide, information about your sex life, sexual orientation, or data that may reveal race or ethnic origin.
***Usage DataUsage Data is collected automatically when using RiSolve.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
For Healthcare Providers
While using Our Service, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. Personal Data may include, but is not limited to:
Email address
Phone number
Address; city, state, country
Professional ID Number
Organisation Name
Usage Data*
*Usage Data
Usage Data is collected automatically when using RiSolve.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Use of Your Personal Data
For Patients
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities or products including the security updates, when necessary or reasonable for their implementation.
To manage Your requests: To attend and manage Your requests to Us and the Healthcare Providers.
For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your Personal Data for other purposes, such as data analysis, identifying usage trends, and to evaluate and improve our Service, products, services, marketing and your experience. We may also use Your Personal Data for regulatory filings and scientific research and associated publications.
We may share Your Personal Data in the following situations:
- With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyse the use of our Service, to contact You.
- For business transfers: We may share or transfer Your Personal Data 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.
- With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. We may also share Your Personal Data with regulators and scientific research partners.
- With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
- With other users: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.
For Healthcare Providers
The Company may use Personal Data for the following purposes:
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
We may share Your Personal Data in the following situations:
For other purposes: We may use Your Personal Data for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.- With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyse the use of our Service, to contact You.
- For business transfers: We may share or transfer Your Personal Data 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.
- With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. We may also share Your Personal Data with regulators and scientific research partners.
- With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
- With other users: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Pseudonymised data, which may include Health Data, for the purpose of regulatory filings and scientific research. Such data will be processed in line with this privacy policy and in compliance with applicable regulations, particularly in line with Article 89 of the GDPR.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your Personal Data, including Health Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other Personal Data.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. We will at all times ensure we are meeting our regulatory obligations with regard to the security of Your Personal Data.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. You can do this by contacting us at dpo@risolvedtx.com.
You may update, amend, or delete Your Personal Data at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your Personal Data. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us. You can do this by contacting us at dpo@risolvedtx.com.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Usage, Performance and Miscellaneous
We may use third-party Service Providers to maintain and improve our Service, including:
Software Development Partners who support Service maintenance and improvement. Software Development Partners are bound by Data Processing Agreements and subject to Amara Therapeutics’ data processing instructions and information security requirements.
Microsoft Azure
Their Privacy Policy can be viewed at https://www.microsoft.com/en-us/trust-center/privacy
Mailjet (if You are in the EU)
Their Privacy Policy can be viewed at https://www.mailjet.com/legal/privacy-policy/
MessageBird (if You are in the EU)
Their Privacy Policy can be viewed at https://messagebird.com/legal/privacy
Twilio (if You are in the US or Canada)
Their Privacy Policy can be viewed at https://www.twilio.com/en-us/legal/privacy
SendGrid (if You are in the US or Canada)
Their Privacy Policy can be viewed at https://www.twilio.com/en-us/legal/privacy
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
Patients
We may use the following legal basis to process your data
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
Healthcare Providers
We may use the following legal basis to process your data
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
CCPA/CPRA Privacy Notice (California Privacy Rights)
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Data Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of Personal Data which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of Personal Data were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Data would only be collected if You provided such Personal Data directly to Us.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport
number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Data included in this category may overlap with other categories. Collected: Yes.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: No.
Category E: Biometric information.
Examples: Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
Category K: Inferences drawn from other Personal Data.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Category L: Sensitive Personal Data.
Examples: Account login and password information, geolocation data.
Collected: Yes.
Under CCPA/CPRA, Personal Data does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA/CPRA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Data
We obtain the categories of Personal Data listed above from the following categories of sources:
- Directly from You. For example, from the forms You complete on Our Service, preferences You express or provide through Our Service.
- Indirectly from You. For example, from observing Your activity on Our Service.
- Automatically from You. For example, through cookies We or Our Service Providers set on Your Device as You navigate through Our Service.
- From Service Providers. For example, other third-party vendors that We use to provide the Service to You.
Use of Personal Data
We may use or disclose Personal Data We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
- To operate Our Service and provide You with Our Service.
- To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our Service.
- To fulfil or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that Personal Data to respond to Your inquiry.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to You when collecting Your Personal Data or as otherwise set forth in the CCPA/CPRA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
- Other one-time uses.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of Personal Data or use the Personal Data We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.
Disclosure of Personal Data
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Data for business or commercial purposes:
Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of Personal Data were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose Personal Data for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.
Share of Personal Data
We may share, and have shared in the last twelve (12) months, Your Personal Data identified in the above categories with the following categories of third parties:
Our affiliates
Our business partners
Third party vendors to whom You or Your agents authorise Us to disclose Your Personal Data in connection with products or services We provide to You
Sale of Personal Data
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Data by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing Personal Data, but not necessarily a monetary benefit.
We do not sell Personal Data as the term sell is commonly understood. We do allow Service Providers to use Your Personal Data for the business purposes described in Our Privacy Policy, and these may be deemed a sale under CCPA/CPRA.
We may sell and may have sold in the last twelve (12) months the following categories of Personal Data:
Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of Personal Data were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
Sale of Personal Data of Minors Under 16 Years of Age
We do not knowingly collect Personal Data from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies. We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the Personal Data of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorisation (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of Personal Data may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorised representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with Personal Data, please contact Us with sufficient detail to enable Us to delete that information.
Your Rights under the CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their Personal Data. If You are a resident of California, You have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of Personal Data. Once We receive and confirm Your request, We will disclose to You:
- The categories of Personal Data We collected about You
- The categories of sources for the Personal Data We collected about You
- Our business or commercial purposes for collecting or selling that Personal Data
- The categories of third parties with whom We share that Personal Data
- The specific pieces of Personal Data We collected about You
- If we sold Your Personal Data or disclosed Your Personal Data for a business purpose, We will disclose to You:
- The categories of Personal Data categories sold
- The categories of Personal Data categories disclosed
- The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your Personal Data. To submit an opt-out request, please see the "Do Not Sell My Personal Data" section or contact Us.
- The right to correct Personal Data. You have the right to correct or rectify any inaccurate Personal Data about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your Personal Data, unless an exception applies.
- The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive Personal Data We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Data" section or contact Us.
- The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personal Data from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the Personal Data, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform Our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA/CPRA Data Protection Rights
Please see the "Do Not Sell My Personal Data" section and "Limit the Use or Disclosure of My Sensitive Personal Data" section for more information on how to opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:
- By email: dpo@risolvedtx.com
Only You, or a person registered with the California Secretary of State that You authorise to act on Your behalf, may make a verifiable request related to Your Personal Data.
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data or an authorised representative.
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We cannot respond to Your request or provide You with the required information if We cannot:
- Verify Your identity or authority to make the request
- And confirm that the Personal Data relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your Personal Data that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Data
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Data by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing Personal Data, but not necessarily a monetary benefit.
We do not sell Personal Data as the term sell is commonly understood. We do allow Service Providers to use Your Personal Data for the business purposes described in Our Privacy Policy, and these may be deemed a sale under CCPA/CPRA.
You have the right to opt-out of the sale of Your Personal Data. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your Personal Data. To exercise Your right to opt-out, please contact Us.
Limit the Use or Disclosure of My Sensitive Personal Data
If You are a California resident, You have the right to limit the use and disclosure of Your sensitive Personal Data to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.
We collect, use and disclose sensitive Personal Data in ways that are necessary to provide the Service. For more information on how We use Your Personal Data, please see the "Use of Your Personal Data" section or contact us.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
PIPEDA Addendum for Canadian Residents
This PIPEDA Addendum complements the RiSolve Privacy Policy and is specifically designed to meet the requirements of the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA). If You are a resident of Canada, the terms of this addendum apply to You in addition to the terms of the main Privacy Policy.
Meaningful Consent
By using the RiSolve platform, You explicitly consent to the collection, use, and disclosure of your Personal Data as described in this Privacy Policy. This consent is separate from any terms and conditions and ensures that You understand how your data will be processed.
Limited Collection and Use of Personal Data
The collection of Personal Data by Company through the RiSolve Platform is limited to what a reasonable person would consider appropriate under the circumstances. The purposes for which data is collected are specified in the main Privacy Policy and adhere to PIPEDA regulations.
Limiting Use, Disclosure, and Retention
Personal Data will not be used or disclosed for purposes other than those for which it was collected, except with Your explicit consent or as required by law. We will retain Your Personal Data only for as long as is necessary to fulfil the purposes explicitly laid out in this Privacy Policy.
Individual Access and Correction
If You are a resident of Canada, You have the right to access, update, or request deletion of your Personal Data as per PIPEDA regulations. Please refer to the main Privacy Policy for the mechanisms to exercise these rights.
Safeguards
We employ a variety of safeguards to protect Your Personal Data against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, in compliance with PIPEDA requirements.
Accountability and Openness
For the purposes of compliance with PIPEDA, the Data Protection Officer (or equivalent) within the Company is responsible for ensuring adherence to privacy regulations. For inquiries or complaints, You can contact Us at the details provided on page 1 of this policy.
Cross-Border Data Transfer
Please be informed that Your Personal Data may be processed in a jurisdiction other than Canada and may therefore be subject to the laws and lawful disclosure requirements of that jurisdiction, including access by regulatory and law enforcement authorities.
This PIPEDA Addendum, together with the main Privacy Policy, provides a comprehensive overview of how the RiSolve Platform collects, uses, and protects Your Personal Data in compliance with both EU GDPR and Canadian PIPEDA regulations.
By continuing to use the RiSolve Platform, you acknowledge and agree to the terms outlined in this PIPEDA Addendum and the main Privacy Policy.
Children's Privacy
Our Service does not address anyone under the age of 18. We do not knowingly collect Personal Data from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your Personal Data and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.