Privacy Policy.
We at Pery Digital Health Ltd. (“Pery”) value your privacy and believe that transparency about the use of your personal data is of utmost importance In this Privacy Policy (“Policy”), we describe how Pery and its subsidiaries and affiliates (collectively, “Pery”, “Company”, “we”, “our”, “us”) collects, uses, and discloses information that we obtain about visitors to our website URL (the “Site”) and the services available through our Mobile Application, as described by the Terms and Conditions of Use (collectively, the “Services”).
The Policy describes how we collect and process information provided or collected through the Services. Pery is a “business associate” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Accordingly, this Policy is to be read in conjunction with any Notice of Privacy Practices (“NPP”) provided to you by your healthcare provider, and in the event of a conflict between the Policy and the NPP relating to the use of your protected health information under HIPAA, the language of the NPP shall take precedence. We follow this privacy policy in accordance with applicable law in the places where we operate.
When we say “personal data” or “personal information” we mean any information that can be used on its own or combined with other information to identify or contact you.
In this Policy, the terms “you” and “your” means you, as the user of the Services, your dependents if any, any other person accessing your User Account (as defined in the Terms and Conditions of Use), and each of your heirs, assigns, and successors.
Please read the following carefully to understand our views and practices regarding your Personal Data.
We collect different types of information about you or other members of your family, including your child (all information, including about other family members or your child, is included under the definition of “your information” or “information about you”), including information that may identify you, information that does not individually identify you, and information that we combine with information from our other users (aggregate data). We collect information about you directly from you and may collect information from third parties, and automatically through your use of our Site or Services.
Information We Collect Directly From You. The information we collect from you depends on how you use our Services and you decide to share with us. We may collect your email, contact information, name, home address, billing address, shipping address, telephone number, date of birth, credit or debit card number (for payment purposes), ethnicity, family demographics, medical history, other health information, behavioral/mental health information and associated diagnoses and medications, audio records, video records (when you connect with us via video, which we may record for quality assurance purposes), documents, images and photographs you share with us, and any other information you volunteer when contacting us through the Site or mobile app. We collect demographics, diagnosis, medication and goals via the clinic’s EHR integration. In addition, we collect assessment responses, questionnaires, and session scheduling information (excluding credit card information, etc.) directly from the patient. We may also ask you for information when you report a problem with our Services. We may collect certain basic information about your medical history before you create an account to become a customer. You are responsible for the accuracy of any information you provide to us. You may be required to provide financial information before using or placing an order through our Services.
Information We Collect Automatically. We automatically collect information about your use of our Site through cookies, web beacons, geolocation, and other technologies. When you use our Services, we may collect and store information about your general location by converting your IP address into a rough geo-location. We may also access your mobile device’s GPS coordinates or location, but only if you have previously agreed that we can collect this information by allowing the sharing of your location information. If you do not want us to have your location information, you need to disable the location sharing feature on your device or browser.
To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
The Site may collect the following:
- Your browser type, IP address and operating system;
- Web pages you view on the Site; links you click on the Site;
- The length of time you visit our Site and/or use our Services;
- The referring URL, or the webpage that led you to our Site.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- Provide the Services. To provide our Services to you; to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes; to provide our Site and its functionality and content to you; to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services; to process, fulfill, support and administer transactions and orders for products and services through the Services.
- Improve the Services. We may use your personal information to facilitate and improve the operation of the Services, perform market research and analysis, analyze how the Services are being used and accessed, improve the functionality of the Services, the Site, and your user experience, conduct quality assurance activities, perform internal business reviews, and develop new Services or functionality. We may also de-identify and aggregate your personal information by removing certain identifiable data components in order to conduct research and further develop our products and Services.
- Improve AI Tools and Machine-Learning: We may use your persona information to improve our AI based services, and our AI responses and machine learning.
- Communications. To communicate with you about your user account, in response to a request from you, to administer surveys, promotions or other online offerings; to carry out our obligations and enforce our rights arising from any contracts between you and us including for billing and collection; to send you news, updates and information about our Services, including changes to our Services and any new services we may offer or other information about goods or services that may be of interest to you.
- Learning and Research: we may use your information for learning and research to better provide our Services and for clinical proof of the necessity and effectiveness of our Services, and we may publish our research and study deanonymized information only. When we intend to perform a specific analysis and study we will request your consent and may request further information not provided by all users in the ordinary course of using the services.
- Marketing. We may use information collected about your use of our Services to arrange for advertisements about our Services or new services to be offered. We may, or one of our vendors may, place or recognize a unique cookie on your browser and use other techniques, such as pixel tags to track your usage and direct marketing about our Services and related services that may be of interest to you.
- Legal Obligations. To comply with legal obligations, as part of our general business operations, and for other business administration purposes. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms and Conditions of Use or this Privacy Policy.
- Other. We may use your personal information in any other way that we describe when you provide the information or for any other purpose not mentioned in this privacy policy, in which case you will receive prior notice.
How We Share Your Information
We may share your information, including personal information, as follows:
- Business Partners: We may disclose your personal data with our business partners, who help us provide our services. These business partners are contractually bound to protect your personal data and to use it only for the limited purpose(s) for which it is shared with us. Business Partners’ use of personal data may include, but is not limited to, the provision of services such as data hosting, IT services, customer service, payment processing, session recording and remote access services, performance measurement services, data optimization and marketing services, content providers, and our legal and financial advisors. Such service providers may have access to personal data according to their roles and purposes and may only use the information for such purposes.
- Company Users. Information you post to our Site, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Site and Services.
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
- In Response to Legal Process. We may disclose your information 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.
- To Protect Us and Others. We may disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions of Use or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, our business purposes, research or similar purposes.
- Other Third Parties: If we share your personal data with a third party other than as provided above, you will be notified at the time of data collection or transfer.
Our Use of Cookies and Other Tracking Mechanisms
We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can change your browser options to block them in the future on each device and each browser. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Third Party Analytics. We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site’s performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Third-Party Links. Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security of your data. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or in your operating system.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your user account via unauthorized password activity. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
Retention of Information
We will retain personal information about you for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic informational emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
As further set forth in the Terms and Conditions of Use, by providing your mobile phone number, you are agreeing to be contacted by or on behalf of Pery at the mobile number you have provided, including through telephone calls and text messages, to receive information, product or service related messages and communications. Message and data rates may apply. To stop receiving text messages with promotional content, reply to us with the word “STOP”.
Accessing and Correcting Your Information
You may contact us to access or change your personal information that we have about you. You can contact us to access or find out what information we have about you and to ensure that the information we have about you is correct, complete and current. We may not be able to accommodate your request if we believe that it would violate any law or legal requirement or cause the information to be incorrect.
How to Request Data Deletion
You may ask us to delete your personal information. If required by law, we will grant such a request, but note that in many cases, we must keep your personal data to comply with legal obligations, resolve disputes, enforce agreements, or for other business purposes.
If you would like to request the deletion of your personal information in our systems, please follow these steps:
- Email us at [email protected] with the subject line “Data Deletion Request.”
- Include your full name, the email address associated with your account, and a brief description of the data you’d like removed.
The rights of access, correction and deletion are not absolute, and they do not apply in all circumstances. We may limit or deny some requests because the law permits or requires us to.
Retention of Personal Information. We retain your personal information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information).
International Residents
Our Services are not available to individuals located outside of the United States. If you are located outside of the United States, or if you are a resident of another country, do not access or use our Services.
Changes to this Policy
We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
Contact Us
For more information about our privacy practices, or if you would like to make a complaint, please contact us via email at [email protected].
You may also contact us at the following address:
Pery Digital Health Ltd.
3245 MAIN ST
STE 235 #423
Frisco, TX 75034