PRIVACY POLICY
Effective Date: 29 December, 2017

This Privacy Policy (“Policy”) applies to your use of the Kairy mobile device application (the “App”) owned by Kairy Limited (“Kairy”, “we” or “us”). This Policy sets out the information and data that we collect from you and/or your children (“Users”/ “you”), how such information may be used, with whom the information may be shared, and your options in respect of such uses and disclosures. Users are encouraged to read this Policy carefully prior to installing and using our App and services (“Service”). Upon registering for our Services, Users are deemed as accepting the terms and conditions of this Policy.

We have the highest regard for your privacy and personal information and realize that the success of our Service depends on the trust Users have in the way we handle their personal information. Any and all collection of information by Kairy under this Policy is strictly in compliance with the Hong Kong Personal Data (Privacy) Ordinance (Cap 486). If you do not agree to the terms of this Privacy Policy, you are herein required to immediately cease using the App.

Information Collection and Use

Kairy respects your right to privacy. If you choose to register with us, you will be asked to provide certain personal information to us as set out in this Policy. It is your voluntary decision whether or not to provide us with any such information, but if you refuse to provide such information, we may not be able to register you with the App or your use of the App may be limited.

By using our Service, we will collect information including any medical information that you wish to provide directly to us and/or that may be obtained through your use of the App or Wristband (as hereinafter defined), together with any information obtained upon registration, your submission of information via our App, contacting our customer support, and/or otherwise communicating with us. This information may include: name, email, phone number, location, age, general personal medical/ health information, postal address, profile information, payment information and any other information you choose to provide (“Personal Information”). Personal Information shall also include as follows:-

Device
We will also collect and store the information of the device our Service is run on. This may include basic analytics of the device, i.e. hardware model, operating system and version, software, preferred language, unique device identifier, serial number, advertising identifiers, and information in respect of device motion and mobile network.

Email
You will be asked to provide to us your email address in order to register an account with us. We may send you services and administrative emails, or contact you to inform you about changes in our services. We may also from time to time send to our Users newsletters, medical information, marketing and promotional materials and information regarding Kairy or its third-party advertiser’s products and services.
Location Information
In order for our Service to properly run on your device, you will be asked to permit our App to access the location services used by your mobile operating system, we may then collect the precise location of your device when the app is running in the foreground or background. We may also derive your approximate location from your IP address.

Log Information
We collect server logs from your interaction with our Service, including information such as device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser.

Transaction Information
Transaction details in relation to your use of our Service, including the date and time the Service was provided, amount charged, and other relevant transaction details.

Information related to Health of Users

During or subsequent to registration, Users will have the option to use certain features of the App that will require the input of information with respect to the Users’ health, including but not limited to medications, dosage, date of prescription, number of refills made, required reminder to take medications, doctor’s name and the name of the pharmacy, diet, patient symptoms, allergies, seizure occurrences, among numerous other medically sensitive information (collectively the “Health Information”). Health Information shall also include the Users’ bodily data collected from any wristband device use by the Users in association with the App (“Wristband”), such data shall include but are not limited to heart rates, body temperatures, the time and frequency that seizures occur, the severity of the same, and any and all other bodily states or information of Users that can be detected and recorded by the Wristband. Health Information shall also include as follows:-

  • data that is clearly or inherently medical data of Users;
  • raw data that the Wristband has obtained from sensors, which is processed by the App and/or can independently or when combined with other data lead to a conclusion in relation to the User’s health status or potential health risks; and
  • information gathered by the App, of which conclusions in relation to the User’s health status or health risks can be drawn from.

Use of Information

The Personal Information and Health Information we collected shall be utilized in the following manner:-

Improve the Lives of People with Epilepsy
To provide help to Users in managing various health conditions, including but not limited to seizure disorders and epilepsy more easily, to effectively handle the way epilepsy affects Users in respect of their daily lives including their social, emotional and physical well-being, and to ultimately improve the lives of people with epilepsy.

Improve and Deliver of Service
To provide, maintain, and improve the Service by adjusting the Services in accordance with the Personal Information and Health Information collected, to facilitate payments, send receipts, develop new features, and send Service updates and administrative messages.

Customer Support
To provide customer support to Users and to personalize and improve our Service by providing and recommending features, content, and referrals.

Internal operations
To prevent fraud and abuse of our Service and to troubleshoot software and operational malfunctions of our Service; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.

Research Purposes
To be sent to various research facilities in any university of Kairy’s choosing from time to time in an anonymous manner in order to facilitate and advance the medical research on epilepsy and other diseases, disorders and/or syndromes. Kairy seeks to utilise the information collected from Users to advance the current understanding of the causes and consequences of epilepsy, the diagnosing and treatment for epilepsy patients, and various measures of controlling and easing the epileptic seizures.

Transfer of Information

We will not share any of your information except as described below:-

Information Shared for Research Purposes
As abovementioned, Personal Information and Health Information collected from Users may be sent to epilepsy research facilities in any university of Kairy’s choosing from time to time. Users may opt out of having their Personal Information and Health Information being provided to such research facilities by contacting us at info@kairy.io.

Information Shared with Our Services Providers
We may engage third party service providers to work with us in order to administer and provide our Service. These third party service providers will have access to your information only for the purpose of performing services on our behalf and are expressly obligated to secure and not to disclose or use your information for any other purpose.

Information Disclosed in relation Business Transactions
Information that we collect from our users is considered to be a business asset. In the event we are acquired by a third party as a result of a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, your information may be disclosed or transferred to a third party acquirer in connection with the transaction. In the event of such a transaction, we will give you notice of the transaction and the opportunity of a period of 30 days to refuse disclosure or transfer of your information to the third party acquirer in connection with the transaction.

Information Disclosed for Our Protection and the Protection of Others

Information Required to be Disclosed by Law
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. In the event that we, in our sole discretion, believe that it is necessary or appropriate to respond to claims, legal process and/or to protect the property, rights, and safety of Kairy, a third party, or the public in general, we may disclose your information to government or law enforcement officials or private parties. We may also disclose your information in order to identify and stop any activity that we consider illegal, unethical, or legally actionable activity.

Third-Party Caregivers

Users are also entitled to invite third-party caregivers to access the User’s information, of which by accepting such invitation and using the App, the third-party caregiver shall register with the App and become a User. By sending such invitation, you agree and undertake to be solely responsible for your Personal Information and Health Information being exposed to such third-party caregiver.

Information Users Share

While we take great care to keep your Personal Information confidential and secure, when you share your health or medication information with others or provide feedback regarding health matters, medications and otherwise, on our App or by means of social media sites, any information disclosed may automatically be made public and will not be considered Personal Information by us. You should exercise caution when disclosing any information (including Personal Information) in such ways. The User’s Personal Information will not be combined with other information and will not be used for other purposes, except as explained in this Policy. Please note that we are not subject to medical secrecy obligations.

Accuracy of Information

Ensuring the accuracy and completeness of the Personal Information and Health Information that you provide in connection with your use of the App is important. Inaccurate or incomplete information will affect the functioning of the App, as well as the information you receive from us and our ability to contact you.

Use of Aggregated Data

We may analyse all information we receive and/or combine your Personal Information, including Health Information and information regarding your use of the Application, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion for purposes of content marketing, for research purposes, in order to understand behavior patterns and in order to increase adherence to medication regimens. Such aggregated data will not contain any information that could be used to contact or identify you.

Disabling the Service, Access, Corrections and Deletion

At any time, you can stop the collection of your information by uninstalling the App. You may also request that your Personal Information and/or Health Information be deleted from our active databases by contacting us at info@kairy.io. We cannot restore information that we have deleted. You are responsible for backing up the data that you store on the Application. We may retain any data in non-identified form, subject to applicable law.

Links to Other Websites or Apps

Our Application may link to or refer to websites or mobile device applications that we do not control. Any Personal Information you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or applications, and we are not responsible for the privacy practices or content of any website or application not controlled by us. If you have any concerns, we urge you to review the terms of those other websites or applications for more information about their applicable policies.

Security

We take reasonable steps to protect your information as you transmit it to us and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, you should keep in mind that no Internet transmission is ever completely secure or error-free.

If you use and/or access the Application on or from a rooted Android device, or a jail broken iOS device, Kairy shall not be responsible for the security of your data, including your Personal Information and Health Information, and you shall solely bear all responsibility for any breach, illegal access, loss and/or corruption of such information.

Children

If you are using the Application for the benefit of a child, please do not provide information relating to such child unless you have obtained the child’s parents’ or guardians’ consent, including their consent to this Privacy Policy. If you discover that your child has been using the Application without your consent, or that someone has been using the Application for or on behalf of your child without your consent, please contact us at info@kairy.io and we will take reasonable steps to delete the child’s information from our active databases.

International Transfers

Kairy shall store your Personal information and Health Information on servers of Kairy. In addition, we may use subcontractors to process information we receive. All our subcontractors will be subject to non-disclosure and non-use obligations.

Changes to Privacy Policy

This Policy may be amended or revised from time to time. If significant changes are made to the way we treat your information, or to the Policy, we will provide you notice through our Service or by some other means, such as notification through email or standard mailing. Your continued use of the Service after such notice represents your consent to the changes. Users are encouraged to periodically review the Policy in order to obtain the latest information on our privacy practices.

Contact Us
Please contact us at info@kairy.io if you have any questions about our Policy, or if you wish to make a complaint about our collection, use, or disclosure of your information under this Policy. We will use our reasonable endeavours to address any complaint you may have as soon as possible.