KEEP Labs Inc. is firmly committed to respecting your privacy and recognizing your need for appropriate protection and management of your personally identifiable information.
Collection of Information
In order to create and operate your account, communicate and respond to you (including, without limitation, to communicate with respect to the Services or respond to your inquiries), or communicate with other stakeholders involved in your care, such as, but not limited to providers of patient support programs and HUB services, pharmacies, distributors, caregivers and other healthcare providers (each, a “Provider” and collectively, “Providers”) (where permitted), we need to collect your information, including personal information.
In addition to the above, in order to provide certain Services, we will collect your health information and you may need to transfer certain health information to us. We will also receive and transmit information provided by KEEP Devices that connect with our Services. Your Provider may give us information about you, including, without limitation, the following:
Use of Personal Information
Personal Information Needed to Properly Provide Services
In order for us to be able to perform or for you to operate the applicable Service as intended, we will need to use or process your personal information to:
Marketing and Promotions
If you choose to receive marketing or promotional communications from us or any third parties, based on your preferences and behaviour, we may provide you with marketing or promotional materials or communications via email, phone or any of the Services (including, without limitation, a KEEP Site or mobile application). We will need to process, use and analyze your personal information in order to send you such communications or materials that are specific to your preferences and behaviour.
Use of Anonymized Information and Aggregated Information
In accordance with applicable laws, we may de-identify and aggregate your personal information. Any such de-identified, aggregated or combined information will not contain any information that could be used to contact or identify you. We may analyze and/or combine all information we receive related to your health and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our partners and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Services.
What are cookies?
What information is obtained through cookies?
We obtain information through cookies and other similar technologies, such information includes, without limitation, the IP address of your device, identifying information associated with your device, type of device connected to the Services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to the Services.
What cookies are used?
Below is a description of the cookies that we use in our Services.
What are your choices?
You can disable cookies from your web browser by selecting the appropriate settings. Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, how to disable or remove existing cookies and when cookies will expire. You can find out how to do this for your particular browser by clicking “help”, “tools” or “edit” in your browser’s menu or by visiting www.allaboutcookies.org. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
Please note, however, that without certain cookies, you may not be able to take full advantage of our Services. For example, if you disable all essential cookies in your browser, you may not be able to use any of our Services that require you to login and you may also need to manually adjust some of your preferences every time you visit one of our Services.
Some consumers may not know that cookies are being placed on their computers when they use our KEEP Site. If you want to know when this happens or to prevent it from happening, you can set your browser to advise you when our KEEP Site attempts to place a cookie on your computer.
Providing Personal Information to Third Parties
In order to provide certain Services and receive the benefit thereof, you may elect to share your personal information or other information with your Provider. Such sharing may be enabled by sending a Provider an invitation through the Service or by accepting an invitation from a Provider to download and use a Service, or otherwise using the Service settings to share your information to such Provider. In these cases your consent to our sending personal information and the Provider monitoring your personal information, including, without limitation, information relate to your use of the Services, the KEEP Sites and KEEP devices, your medications and your compliance with your medication regime with your Providers and the Provider monitoring . Such sharing of your information is at your discretion and is solely your responsibility.
You may also allow a Provider that is a caregiver, family member or other close relationship to make changes to the Services including to your personal information on your behalf (if applicable).
If you use the Services on behalf of your child or an incapacitated person, you shall be considered such person’s authorized Provider. In such event, you represent and warrant that you have the legal authority to act on behalf of that person, that you will keep confidential and only use the person’s personal information made available to you through the Services for the purpose for which it was made available to you, that any permission and personal information provided to you through the Services will be used with due care and only for that person’s own good and best interests.
You may opt out or otherwise restrict the disclosure of your personal information, including your health information to any Provider at any time by providing written notice as provided herein.
Partners and Third Parties
We may also share your personal information with our partners and with third-party independent contractors, including, without limitation, our providers that deliver (a) necessary hardware, software, networking, storage, transactional services and/or related technology required to run the Services provided and (b) data storage services.
We contract with a third party to maintain and host the KEEP Sites and our mobile applications. Therefore, any information you submit, including personal information, will be placed and stored on a computer server maintained by this third-party host.
The third parties that we partner with have agreed to implement technology and security features and strict policy guidelines to safeguard the privacy of your personal information from unauthorized access or improper use.
We require these service providers to provide a comparable level of protection of your personal information as we provide, to only process your personal information for the specific purposes mentioned above, and to have access to the minimum amount of data they need to deliver a specific service.
If we allow a third party to transfer your personal information outside of your geographic region, we will take steps to protect your privacy rights through the use of contractual arrangements or other means, which will provide a comparable level of protection while the information is being processed by our third parties.
Disclosure Required by Law or to Enforce Terms
We may also disclose your personal information to third parties in the following situations:
Transfer in an Merger, Acquisition or Sale
We reserve the right to transfer your personal information to a third party in the event of a merger, amalgamation, change of control, acquisition or other similar transaction related to KEEP or a sale or other transfer of all or a portion of our assets.
Interactions and Links To Third-Party Sites
Our KEEP Sites and Services may allow you to link to the web sites, software applications and other services of third parties in order to provide certain features or experiences. For example, you may be able to connect your KEEP device or account to a non-KEEP service. In addition, a KEEP Site may provide links to other online services for your convenience and information, and may include third-party features such as apps, tools, payment services, widgets and plug-ins.
These third-party services and features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy policies of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, we are not responsible for these third parties’ information practices. By using or engaging with such services and features, you are requesting and authorizing us to transfer or provide access to information on your behalf, for example, your account ID, email address, data about your KEEP device usage or collected by your KEEP device.
International Users and Visitors
Personal information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside of Canada, please note that data we collect about you may be transferred to, processed and stored in the United States, unless otherwise noted. Further, if you are located outside of the United States, please note that data we collect about you may be transferred to, processed and stored in the United States, unless otherwise noted.
If you reside in the UK or the European Union, please note that some of our service providers may be located outside the European Economic Area. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection in accordance with the instructions of the European Union commission as updated from time to time.
Data protection laws in certain jurisdictions provide individuals with certain statutory rights with respect to their personal information. For example, if you reside in the UK or the European Union, you may have the right to request to: (a) receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information; (b) receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format; (c) request rectification of your personal information that is in our control; (d) request erasure of your personal information; (e) object to the processing of personal information by us; (f) request to restrict processing of your personal information by us; and (g) lodge a complaint with a supervisory authority if you believe your privacy rights have been prejudiced by us.
If you reside in another jurisdiction, you may also be afforded with certain rights with respect to your personal information, as determined by such jurisdictions’ applicable laws. Such rights may be similar or may differ from those set out above with respect to residents of the UK or the European Union.
We comply with applicable laws and respect the privacy rights of our users. If you wish to exercise any of your rights, or ask us a question, please contact us by using the contact details provided below. However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
You also may opt out of receiving promotional communications from us (by, for example, using the “unsubscribe” button below each email we send you or by contacting us at firstname.lastname@example.org). For the avoidance of doubt, there are certain communications about our Services that we need to send you and you will not be able to opt out of those communications.
We will retain your information for as long as we are required in order to provide the Services to you, as required to fulfill our legal obligations (e.g. under applicable law), commitments we made to and on behalf of you or any of our customers in order to provide the Service to you, and as required to defend legal claims. After you have terminated your use of our Service, we may store your information in an anonymized format.
We, and our third-party providers, employ organizational, technical and physical safeguards designed to protect against the loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
California Privacy Rights – California Residents Only
Under the California Consumer Privacy Act, California residents are entitled to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.
If you are a California resident and would like to make such a request, please contact us at email@example.com with “California Privacy Rights” as the subject line or write to us at the address set forth in the “How to Contact Us” section below. You must include your full name, email address and postal address in your request. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Your Nevada Privacy Rights – Nevada Residents Only
“Do Not Sell My Personal Information” – We may elect to share information about you with third parties for those third parties direct marketing purposes. Nevada Revised Statutes §§ 603A.300-.360 permits Nevada residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and opt-out of the sale of your personal information to third-parties for their direct marketing purposes.
If you are a Nevada resident and would like to make such a request, please contact us at firstname.lastname@example.org with “Nevada Privacy Rights” as the subject line or write to us at the address set forth in the “How to Contact Us” section below. Please provide sufficient information for us to determine if this applies to you and attest to the fact that you are a Nevada resident. You must include your full name, email address, and postal address in Nevada in your request. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
If you discover that your child has been using a Service, KEEP Site or KEEP device without your consent, or that someone has been using a Service, KEEP Site or KEEP device for or on behalf of your child without your consent, please contact us using the information below under “How to Contact Us” and we will take reasonable steps to delete the child’s information from our active databases.
We reserve the right to check our user base from time to time and remove users whom we have grounds to believe they are in fact minors, including without limitation, restricting those user accounts, or deleting them, as we may deem appropriate.
How to Contact Us
KEEP Labs Inc.
1108 - 250 Consumers Road #750 North York, ON M2J 4V6
You may also contact our Data Protection Officer: DPO@keeplabs.com
We will endeavor to deal with your request as soon as possible.
The foregoing is without prejudice to your right to raise a complaint with a relevant supervisory authority.
If you do not agree to the revised policy, you should alter your preferences, or consider stop using our Services, KEEP Sites, or any KEEP device.