E – Policies

Effective Date: September 1, 2018

General Introduction

Amiko Digital Health Limited and its affiliates (collectively “Amiko,“ “we”, “us”, or “our”) are committed to protecting your privacy acting in compliance with the EU Regulation no. 2016/679 (the “GDPR”). We have prepared these E – Policies to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at www.amiko.io (the “Site”), our software applications (“Software”), the services provided through the Site or Software (“Services”). The term “you” refers to the person visiting the Site

The following paragraph from A to D shall apply to the Website Policy, Service Policy, the relevant Cookie Policies and to our Terms of Use.

  • E – Policies. Mean Website Policy, Service Policy, the relevant Cookie Policies and to our Terms of Use.
  • User Consent. By using or visiting our Site or by submitting Personal Data through our Site, you agree to the terms of this Website Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Website Policy.
  • Children. Our Site, Software, and Services are not geared towards children under 14. Our Services may be used by children under the age of 16 only with the consent of a parent or guardian.
  • Processing Outside of the European Union. Personal Data may be processed in the country in which it was collected and in other third countries. By using the Site, Software or Services, a transfer of Personal Data to a third country or an international organisation shall take place where the Commission has decided that the third country ensures an adequate level of protection for the Users, as set forth in Article no. 45 of the GDPR. In this case such a transfer shall not require any specific authorisation from you. In the absence of a decision pursuant to Article 45 of GDPR, we shall transfer Personal Data to a third country only if one or more safeguards set forth in Article 46 to 48 of GDPR or one or more conditions set forth in Article 49 are met.

Website Policy

  • Data Controller identity. Amiko Digital Health Limited, with registered office at Salisbury House, 31 Finsbury Circus, London, EC2M 5QQ, UK is the Data Controller of your Personal Data.

    Types of Data We Collect. “Personal Data” means data that allow someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

    • Information you Provide to us.
      • If you contact us via email, we will collect your name and e-mail address. Please, do not include in your e-mail any other Personal Data that you do not want us to know.
    • Information Collected via technology.
      • To make our Site more useful to you, our servers (which may be hosted by a third party Cloud service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and a date/time stamp for your visit. We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions.
      • At this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions. However, you can change some of your privacy preferences through your browser.
      • We currently use Google Analytics. Google Analytics collects information anonymously and reports website trends without identifying individual visitors. Google Analytics uses its own cookie to track visitor interactions. Website owners can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. Please see the following links for more information about Google Analytics:
        http://www.google.com/privacy.html and http://www.google.com/analytics/tos.html
      • We do not currently share any personal information of our Users with third parties for their direct marketing purposes. If our practices change, we will notify you as required by applicable law.
        If you want to know more about Cookies please see our Cookie Policy for further details.
  • Use of Your Personal Data

    • General Use. We use your Personal Data to identify you as a user in our system, conduct research, improve our Site; provide the Services you request; send you administrative e-mail or other notifications; reply to your inquiries. We can process Personal Data without your prior consent because the processing is necessary to perform Site services and functionality or to comply with your requests as set out in Article no. 6 paragraph b) of the GDPR. Otherwise, you will not be able to surf the Site or receive the information required.

    • Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyse request and usage patterns so that we may enhance the content of our Services and improve the performance of the Software and the Site.

    • Marketing Purpose. Subject to your prior explicit and specific consent, we shall use your Personal Data to send you newsletters, surveys, offers, and other promotional materials related to Amiko products and services, including, but not limited to, the Site, Software and Services (“Promotional Communications”). You will always have an easy way to withdraw your consent in receiving our promotional communications for Marketing Purpose at any time.

    • Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in these E – Policies.

      • Third Party Cloud Service Providers. We may share your Personal Data with third party service providers: to provide you with the Site to conduct quality assurance testing; to provide technical support; and/or to provide other services to Amiko. These third-party service providers are required not to use your Personal Data other than to provide the services requested by Amiko.

        Third Party Reason for sharing
        Amazon Hosts our cloud storage system.
        Mailchimp.com The service provider allows us to send you email communications and alerts us if you request to be removed from our mailing list.
      • Affiliates and Acquisitions. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honour these E – Policies. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in these E – Policies.

      • Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Amiko may disclose Personal Data if it believes in good faith that such disclosure is necessary

        • in connection with any legal investigation;
        • to comply with relevant laws or to respond to subpoenas, court orders, warrants, or similar documents issued by a court having jurisdiction and served on Amiko;
        • to protect or defend the rights or property of Amiko or users of the Services; and/or
        • to investigate or assist in preventing any violation or potential violation of the law, these E – Policies, Terms of Use for the Site, or the Software License Agreement for the Software.

        Amiko shall appoint the above-mentioned recipients as Data Processors as required under Article 28 of the GDPR. We will send you a list of all these Data Processors upon your request in writing.

  • Way of processing of Personal Data. We shall process Personal Data both with analogical or technological means according to the requirements set out in Article 5 of the GDPR and in compliance with any other national or European laws or regulations.

  • Storage of Personal Data. Your Personal Data shall be stored as following:

    • Just for the time needed to you to surf our Site for the General Use;
    • Until you object to receive our Marketing Communication for Marketing Purpose,

    Without prejudice to the above, we may be obliged to keep Personal Data for a longer period to comply with any law or regulations requirements.
    We store Personal Data on secure cloud storage system provided by Amazon in some data center based in the EU area. Amazon Web Services are fully compliant with the GDPR.

  • Third Party Websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Website Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites. If you engage with our Site content through third-party social networking sites, we may have access to certain information associated with your social media account such as your name, email address, photograph, birthday, location, and people you follow or like. For information on controlling access to your personal information through social networking sites, you should review their privacy policies and terms of use. You may choose to import information from other applications.

    Third Party Websites Privacy Policy
    Facebook https://www.facebook.com/policy.php
    Twitter https://twitter.com/en/privacy
    Linkedin https://www.linkedin.com/legal/privacy-policy
  • Your Rights Regarding Your Personal Data.

    • We may periodically send you Promotional Emails (as described above). When you receive Promotional Emails from us, you may indicate a preference to stop receiving further Promotional Emails from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to our Terms of Use for the Site, Website Policy or Software License Agreement for the Software.
    • If at any time Amiko wishes to use or disclose your Personal Data in a way or for a purpose other than described in this Website Policy, Amiko will give you the opportunity to choose (opt-in) whether your personal data may be used for a purpose other than the purposes that are set forth in this Website Policy.
    • Access to Personal Data. If you wish to have access to the Personal Data that we have concerning you, or to have incorrect information updated please email us at privacy@Amiko.io We will respond to your request within 30 days.
    • Deletion of Personal Data. You may request that we delete your Personal Data, but please note that we may be required to keep this information and not delete it under applicable law (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information as necessary to comply with our legal obligations, resolve disputes, enforce our rights, or similar purposes.
  • Security of Your Personal Data. Amiko is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Amiko uses reasonable efforts to protect your Personal Data, Amiko cannot guarantee its absolute security.

  • Contact Information. Amiko welcomes your comments or questions regarding these E – Policies and any request you may have to access, correct or delete your Personal Data. Please contact us at the following email address: privacy@Amiko.io If you wish to contact us by postal mail, please use the following mailing addresses, as appropriate:

    Amiko Digital Health Limited
    Attention: Privacy Department
    Salisbury House, 31 Finsbury Circus, London, EC2M 5QQ, UK

    Amiko also appointed a Data Protection Officer. Amiko’s Data Protection Officer is Mr Massimo Donna, attorney at law with the Milan Bar, owner of Paradigma – Law & Strategy, with head office at Piazza L. V. Bertarelli n. 1, 20122, Milan.

    If you wish to contact him, please use the following addresses, as appropriate: dpo@paradigma-law.com

  • Disputes. Amiko is committed to resolving complaints about your privacy and our collection or use of your personal data. If you have any inquiries or complaints regarding these E – Policies you should first contact Amiko at: privacy@Amiko.io.

    User rights. You shall have the right to obtain from us the confirmation as to whether or not your Personal Data concerning are being processed, and, where that is the case, access to the personal data and the following information:

    • the purposes of the processing
    • the categories of personal data concerned;
    • the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organisations;
    • where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
    • the rectification or erasure of your Personal Data or restriction of processing of such data or to object to such processing;
    • the right to lodge a complaint with a supervisory authority;
    • where the Personal Data are not collected from the data subject, any available information as to their source;
    • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
    • the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer of your Personal Data to a third country or to an international organisation
    • the right to ask for a copy of the Personal Data undergoing processing (for any further copies requested we may charge you with a reasonable fee based on administrative costs).
  • Changes to These E – Policies. These E – Policies are subjects to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us, if any, and/or by prominently posting notice of the changes on our Site. Any changes to These E – Policies will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Site, Software or Service, as applicable. Changes to These E – Policies may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes. Continued use of our Software, Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Cookie Policy

  • As you interact with our Site, we may automatically collect Personal Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Cookies are small text files that are placed on your machine to help the Site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this Site and on others. The most effective way to do this is to disable cookies in your browser. Please see our cookie policy here for further details.
  • Cookies in use. Generally, our cookies perform up to three different functions:

    Essential cookies: Some cookies are essential for the operation of the Website. If you opt to disable these cookies, you will not be able to access or use all of the features that the Website incorporates.

    Performance Cookies (Google Analytics): We utilise other cookies to analyse how our visitors use the Website and to monitor performance. This allows us to provide a high-quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, identify unique users, store information about users’ sessions, determine which method of linking between pages is most effective, and why some pages are receiving error messages.

    Functionality Cookies. We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you use the Website, and recall your customisation preferences.

  • How to Disable Cookies. Please follow the instructions below to manage the disablement of our cookies on the most popular browsers:

    IE: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies

    Safari: https://support.apple.com/kb/PH19214?viewlocale=it_IT&locale=en_US

    Chrome: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies

    Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie

    To disable Google Analytics you may download the following tool: https://tools.google.com/dlpage/gaoptout

    We want to remind you that the disablement of some of our Cookies, like the technical cookies, could cause Site malfunctioning.

  • Further Informations. For more details about cookies please see the following pages:

    or contact us at privacy@Amiko.io

Amiko Service Policy

*PLEASE NOTE: Because of the distinct features of our specific products, we have prepared a Service Policy which describes our practices specifically in regards to the use of Amiko Software.

Effective Date: September 1, 2018

Amiko Digital Health,® Limited (“Amiko”) provides a digital medicine service to individual consumers (“Consumer”) through the combined use of inhaler sensors, and possibly other devices such as a spirometers, peak flow meters or activity trackers (availability subject to change), with information accessible via a mobile app or a browser-based dashboard (the mobile app and browser access constituting the “Patient Interface”). The inhaler sensors, the other devices and the Patient Interface are collectively referred to as the Service. Consumer may invite one or more people (such as medical professional, spouse, parent, etc.) who are considered “Caregivers,” each of whom will have some level of access to Consumer’s personal information. Depending on the Consumer’s needs and the version of the Patient Interface used, one of these Caregivers might be granted access to the Patient Interface. The Service Policy applies to personal information collected through Consumer’s use of the Service and use of the Patient Interface by Consumer or Caregivers.

Amiko is committed to protecting the privacy of personal information collected from Consumer and Caregivers (collectively “Users” or individually “You”), in accordance with GDPR and other applicable national laws. This Service Policy provides details of Amiko’ privacy practices. Please read this Service Policy carefully.

We may only provide the Service (which implies also processing data included in special categories of Personal Data) if the Users grant us their consent before they begin using the Service.

Users under the age of 16 may only use the Service with consent from their parents, which must be provided to us before the User begins using the Service. Parents of Users under the age of 16 will be required to provide consent as described in the section titled “What Data will Amiko collect and how will that Data be used?” and will be permitted to revoke their consent to further use and maintenance of information about their child as described in the section titled “Choices Regarding your Data.”

Your use of the Patient Interface or the Service, and any dispute over privacy, is subject to this Service Policy and the Terms of Use.

  • What Data will Amiko collect and how will that Data be used?

    Data We Collect Directly From You. Your use of the Patient Interface requires registration. The initial registration data is limited to basic identifiers such as your name, last name, email address or similar. We can process such Personal Data without your prior consent because the processing is necessary to the initial registration in compliance with Article no. 6 paragraph b) of the GDPR. Otherwise, you will not be able to log in and use the Service.

    We collect data from you that you have voluntarily submitted. For Users under the age of 16, their parents will be asked to provide consent permitting us to collect registration information, analytical data and any of the other data we collect from Users. A parent may revoke his or her authorization at any time and may request that we discontinue our use of any data collected from that parent’s child under the age of 16. Please see the section titled “Choices Regarding Your Data” below for more information. Please note that revoking your authorization to collect data may result in the User no longer being able to use the Services.

    We collect analytical data generated by the Service. Data required for use of the Service will be identified as such. The following are other examples of personal data that Amiko might collect about you:

    • Registration data (e.g., name, email address, and password and from the Consumer and other optional information provided such as – phone number, gender, height, weight, and date of birth).
    • Data generated by the Service during use (e.g., information about inhaler use, other physiologic metrics, medication sensor battery status, etc.);
    • Data relating to your use of the Service (e.g., smart feedback, alerts, and permission settings, depending on the functionality of your version of the Patient Interface), your receipt of smart feedback and alerts, and your access to the Patient Interface;
    • Data that you provide when responding to questionnaires and surveys; and Data about you when you contact Amiko (for example with a question about the Service or Patient Interface) or if we contact you in connection with the Service or Patient Interface.

      The above mentioned categories of Personal Data can include some data from special categories of Personal Data. We will process these data only with your prior and specific consent. Anyway, without Users consent we will not be able to provide the Service.

      Data We Collect Automatically. We automatically collect “Log Data” about your use of the Patient Interface through cookies, web beacons, and other technologies, including: your domain name; your operating system; your browser type and operating system; web pages you view; links you click; your IP address; internal service provider (ISP); referring/exit pages; date/time stamp; and the length of time you use any portion of the Patient Interface and different actions you perform when using the Patient Interface. We also collect “Log Data” about your use of the mobile app, including: mobile device ID; location and language data; device name and model; operating system type, name, and version; your activities within the mobile app; and the length of time that you are logged into the Patient Interface through the mobile app. We may combine this data with other data that we collect about you, please see the following paragraph 3 about profiling activity. Please note that disabling cookies may affect the functionality of the Patient Interface, and may prevent us from being able to provide you the Service.

      Data We Receive From Others. Depending on the type of Service being provided to you and the authorization that you provide, we may receive additional data about you from your healthcare team, including: basic data such as age, gender, and height; and medication use data. In order for your healthcare team to share such information with us, you must authorize such sharing. You may revoke that authorization at any time. At the time of your registration for the Service, you will receive a form of authorization. You are not required to sign or accept the authorization in order to receive the Services.

      We may process some special categories of Personal Data about you via third parties (for example, where a Caregiver gathers details about health and Biometric Data in order to comply with medicolegal documentation obligations) where the third parties act as Data Controllers. Where this happens it is the duty of the Data Controller to inform you and a higher standard of protective measures will apply.

      Combined Data. Data generated by the Service will be combined with other data to improve the Service. Data profiling is a crucial part of the Service. It means that we can use automated processing of Personal Data to evaluate and optimise respiratory therapies, allow medical professional to provide Consumers with bespoke medical advise etc. In this case, without Consumers consent we will not be able to provide the Service. Please see the following paragraph 3 about profiling activity.

      • 1.1 Use of Combined Anonymised Data. Combined data with no personal identifying information will be used to:
        • conduct research and product development;
        • carry out market research;
        • to improve clinical care and contribute to medical science and literature;
        • analyse use of the Service and Patient Interface;
        • analyse the performance of the Service and Patient Interface;
        • enhance the Service and Patient Interface and to develop new products and services; and/or
        • support Amiko’s commercial product offering.
      • 1.2 Use of Personal Data. Personal data will be used to:
        • provide you with the Service;
        • enable the Service to send smart feedback and alerts in accordance with Patient Interface functionality and User settings;
        • contact you with administrative/service related notices;
        • investigate, and assist you with, any questions or complaints that you may have about the Service or Patient Interface; and/or
        • contact you for feedback, opinions and suggestions related to the Service and Patient Interface via email, Patient Interface surveys, telephone calls and other similar means. Your participation in such feedback activities is voluntary.
      • 1.3 Use of Log Data. We use Log Data for:
        • analysis
        • optimizing the Patient Interface; and
        • resolving technical issues.
      • 1.4 Push Notifications. Subject to your prior explicit and specific consent, we will send push notifications to notify you of product related data. If you no longer wish to receive these types of communications, you may turn them off at the device level. However, by doing so, you may alter the way the Service operates. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification data. We will send application updates to your device, which you can decide whether or not to install depending on your device’s setting. If you have an Amiko provisioned device, updates will usually install automatically if the Service is active.
  • How we protect the information

    We take commercially reasonable steps to protect your Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction according to paragraph no. 32 of the GDPR. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

  • Disclosing Your Data

    Amiko will not share data about you with third parties except as described in this Service Policy. Subject to the laws of applicable states and jurisdictions, Amiko may disclose your data:

    • to our service providers who are involved in providing the Service or Patient Interface; these third parties will not use personal data other than to provide the services requested by Amiko;
    • where there is a change in the ownership of Amiko or Amiko assets (e.g., another company acquires Amiko’s business or assets, whether by merger, sale of assets, sale of stock, through bankruptcy, or otherwise), to the new owners; the new owners will assume the rights and obligations regarding your data as described in this Service Policy;

    • in aggregate or de-identified format for research, analytical, or similar purposes;

    • to researchers by your participation in surveys, but we will not share personal data for research purposes without your prior consent;

    • in connection with any legal investigation or where Amiko (or our service providers) are required to do so by law, regulation or legal proceedings or to respond to subpoenas, court orders, warrants or other similar documents issued by a court having jurisdiction; and/or

    • to protect or defend the rights or property of Amiko, our service providers, or other users.

      Amiko may appoint the above-mentioned recipients as Data Processors as required under Article 28 of the GDPR. We will send you a list of all these Data Processors upon your request in writing.

      Third party Reason for sharing
      Amazon Hosts our cloud storage system.
      Mailchimp.com The service provider allows us to send you email communications and alerts us if you request to be removed from our mailing list.
    • 3. Way of processing of Personal Data. We shall process Personal Data both with analogical or technological means according to the requirements set out in Article 5 of the GDPR and in compliance with any other national or European laws or regulations.

    • 3.1 Automated processing, including profiling. We shall process Consumer Personal Data (e.i. to optimise respiratory therapies, allow medical professional to provide Consumers with bespoke medical advise), included personal data referred to in Article 9(1) of the GDPR, with automated processing, including profiling only relying on your prior specific consent. Please note that, if you shall not give your consent to us we will not be able to provide the Service.

    • 3.2. Marketing Purpose. With reference to the Marketing Purpose, we may contact you by marketing texts, emails, faxes, make calls or make any automated marketing calls. You will always have an easy way to withdraw your consent in receiving our promotional communications for Marketing Purpose at any time.

      With your prior specific consent, we may periodically send Users free newsletters and promotional messages. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the message you receive or by contacting us directly (please see contact information below). Despite your indicated preferences, we may send you Service related communication, including notices of any updates to our Terms of Use or E – Policies. Please note that it may take up to 10 business days for us to process opt-out requests.

      We do not currently share any personal information of our Users with third parties for their direct marketing purposes. If our practices change we will notify you as required by applicable law seeking for your possible consent.

  • Storage of Personal Data.

    We store Personal Data on secure cloud storage system provided by Amazon in some data center based in the EU area. Amazon Web Services are fully compliant with the GDPR. We may transfer your Personal Data to a third country outside di EU area, in this case, we will transfer them only if one or more requirements set out in the paragraph D of the General Introduction are met.

  • Enabling Caregivers to see Consumer Data

    If you are a Consumer, you can allow people you trust, such as your designated healthcare professionals or family members, to become Caregivers. You can allow access to your data via the Patient Interface. You may choose Caregivers to receive smart feedback and alerts regarding data that is collected or generated by use of the Service. The extent to which a Consumer can manage each Caregiver’s access rights will vary based on Patient Interface version and features. Consumer may also terminate or change a Caregiver’s access at any time, subject to Consumer’s Internet connectivity at that moment. Each Caregiver’s access will automatically terminate upon termination of Consumer’s access to the Service.

    Note that if the Caregiver is a Consumer’s family member the following paragraph 6 shall not apply.

    Details of how Consumer can manage each Caregiver’s access can be found in the Help section of the Patient Interface.

  • Where the Caregiver acts as the Data Controller and Amiko as the Data Processor

    In circumstances where a Caregiver (who is an healthcare professional) supplies Personal Data to us which relates to a Consumer and which may be collected, stored and processed as a result of your use of Patient Interface, the Caregiver will be the Data Controller and Amiko will be a Data Processor only.

    In cases where the Caregiver is collecting, storing and processing Consumer Data, the Caregiver will determine the purposes for which and the manner in which that Personal Data is, or is to be processed.

    The Caregiver will also be responsible for:

    • informing its staff and Consumers of its privacy policy and practices, including, the lawful grounds upon which the Caregiver is processing any Personal Data;
    • compliance with data protection laws;
    • drawing the Consumer’s attention to this Service Policy; and
    • informing us if any Consumer objects to either the Caregiver’s or our processing.

    As a Data Controller, the Caregiver will ensure that it has all necessary appropriate consents and notices in place to enable lawful transfer of the Consumer to us for the duration and purposes of the use of the Service.

    As a Data Processor, we will:

    • Process that Consumer Data only on the written instructions of the Caregiver unless we are required by the laws of any member of the European Union or by the laws of the European Union applicable to us to process Personal Data;
    • Ensure that we have in place appropriate technical and organisational measures, to protect against unauthorised or unlawful processing of Consumer Data and against accidental loss or destruction of, or damage to, Consumer Data, as are appropriate;
    • Ensure that our staff who have access to and/or process Consumer Data are obliged to keep the Consumer Data confidential;
    • Not transfer any Patient Data outside of the European Economic Area unless one of the safeguards described in the paragraph D of the General Introduction is in place;
    • Assist the Caregiver, in responding to any request from a Consumer and in ensuring compliance with its obligations under the data protection laws with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;
    • Notify the Caregiver without undue delay on becoming aware of a Personal Data breach;
    • Within 45 days of the date of termination or cancellation of your contract delete Consumer Data and copies thereof unless required by applicable laws to store the Consumer Data; and
    • Maintain complete and accurate records and information to demonstrate our compliance with these obligations.

    We are not liable in respect of any Consumer Data which is controlled by the Caregiver in breach of data protection laws or outside the scope of the permissions granted to the Caregiver by the Consumer.

  • Cookies and Other Tracking Mechanisms

    We and our third-party service providers use cookies and other tracking mechanisms to track data about your use of the Patient Interface or Services. We may combine this data with other data we collect from you (and our third-party service providers may do so on our behalf).

    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).

    Cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Patient Interface, while others are used to enable a faster log-in process or to allow us to track your activities on the Patient Interface. There are two types of cookies: session and persistent cookies.

    • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Patient Interface. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through the Patient Interface.

    • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about User activity and to retain login information.

      Disabling Cookies. If you access the Patient Interface from the Internet instead of our mobile app, your web browser may be set to automatically accept cookies, but if you prefer, you may edit your browser options to block them in the future. 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 the Patient Interface who disable cookies will be able to browse certain areas of the Patient Interface, but some features may not function.

  • Third Parties

    Google Analytics

    We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help analyse how Users use the Patient Interface. Please see the following link for more information on Google’s web analytics services http://www.google.com/analytics.

    If you want to know more about Cookies please see our Cookie Policy for further details.

  • Third Party Websites and Applications

    When you click on a link to any other website or location, you will leave the Patient Interface and go to another site and another entity may collect data from you. We have no control over, do not review, and are not responsible for, these outside websites or their content. Please be aware that the terms of Amiko’ E – Policies do not apply to these outside websites or content. You may choose to import information from other applications and in doing so, please consult their privacy policies or terms of use.

  • Choices Regarding Your Data

    You have the right to request a copy of personal data we have about you. If you would like a copy of some or all of that information, please contact Amiko at the address below. Each Consumer should be able to access most of the data via the mobile app (patients) or the Patient Interface (health care providers).

    You may ask Amiko to correct or remove data that is inaccurate by contacting us at the address below. When you login to the mobile application or Patient Interface, you can change certain details directly.

    Parents of Users under the age of 14 have the right to refuse to permit further collection of their child’s information, and the use and maintenance of such information, even if the parent had previously consented to our collection and use of the data. A parent can revoke his or her consent to further collection, use and maintenance by us of information about his or her children by contacting us through the methods described in the section titled, “Contacting Us About Your Data.” Please note that revoking consent to collect and use data may result in a User no longer being able to use the Services.

    Subject to applicable law, parents of Users under the age of 18 may have the right to access certain or all of the User’s information. Please contact us for more information.

    We will send you smart feedback and alerts via email, push notification, and/or SMS in accordance with Consumer’s settings and the Patient Interface version. If you are the Consumer, you may change your smart feedback and alerts settings to stop these smart feedback and alerts. If you are a Caregiver, when you receive these smart feedback and alerts, you may indicate a preference to stop receiving them and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the message you receive or by contacting us directly (please see contact information below). By accepting an invitation from the User to be a Caregiver, you consent to receiving SMS messages as described above. You understand that your wireless carrier’s standard rates apply to these messages.

    In order to provide certain features and functionality of the Service, we may, with your prior consent, automatically collect geolocational information from your mobile device, your wireless carrier, or certain third-party service providers (“Geolocational Information”). Collection of such Geolocational Information occurs only when the Patient Interface is running on your mobile device. We need your prior consent to geolocalise you but you may decline to allow us to collect such Geolocational Information just note that in which case Amiko will not be able to provide certain features of the App to you (such as personalised respiratory forecast for given areas).

    Please check paragraph 18 of our Website Policy to have more details about your rights.

  • Retention of Your Data

    Amiko shall retain your Personal Data for the purposes detailed in the above paragraph 1.2 as long as the Service is provided to you.

    Amiko shall retain your Personal Data for the purposes detailed in the above paragraph 1.3 as long as the Service is provided to you.

    Amiko shall retain your Personal Data for the purposes detailed in the above paragraph 1.4 until you withdraw your consent.

    Amiko shall retain your Personal Data for the purpose detailed in the above paragraph 3.1 as long as the Service is provided to you or you have objected to this processing and unless Amiko demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject.

    Amiko shall retain your Personal Data for the purpose detailed in the above paragraph 3.2 until you withdraw your consent.

    Amiko shall retain your Personal Data for the purpose of Geolocational Information until you withdraw your consent.

    Without prejudice to the storage periods set out above, we may be obliged to keep Personal Data for a longer period to comply with any law or regulations requirements.

  • Security

    Amiko uses a variety of security technologies and procedures designed to help protect data from unauthorized access, use, or disclosure. Any sensitive data transmitted through Amiko applications will be encrypted during transmission. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, Amiko cannot guarantee its absolute security.

    Each user is responsible for keeping their individual password secure and confidential. You should take all necessary steps to ensure the confidentiality of your passwords to avoid third parties gaining unauthorized access to Consumer’s data. Amiko accepts no responsibility for any loss, damage or harm arising as a result of Consumer or Caregivers sharing or disclosing passwords to others. Please contact us immediately via email or the postal address listed below if you suspect that there has been any unauthorized access to your account.

  • Changes to This Service Policy

    This Service Policy is subject to occasional revision, and if we make any material changes in the way we use personal data, we will notify you as required by applicable law. Any changes to this Service Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of the communication (email or push notification) or thirty (30) calendar days following our posting of notice of the changes on the web access to the Patient Interface. These changes may be effective immediately for new users. In any event, changes to this Service Policy may affect our use of personal data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of this data, you must notify us prior to the effective date of the changes that you wish to cease using the Service and/or Patient Interface. Continued use of the Service and/or Patient Interface, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

  • Disputes

    Amiko is committed to resolving complaints about your privacy and our collection or use of your personal data. Users with inquiries or complaints regarding this Service Policy should first contact Amiko at: privacy@amiko.io.

  • Contacting us about Your Data

    Please contact Amiko Customer Support if you have any questions about the data that Amiko holds about you and for any request you may have to access, correct or delete your personal data. Please contact us at the following email address: privacy@amiko.io.

    We appointed as Data Protection Officer, Mr. Amiko’s Data Protection Officer is Mr Massimo Donna, attorney at law with the Milan Bar, owner of Paradigma – Law & Strategy, with head office at Piazza L. V. Bertarelli n. 1, 20122, Milan – dpo@paradigma-law.com

  • If you wish to contact us via postal mail, our address is provided below.

    Amiko Digital Health Limited
    Salisbury House, 31 Finsbury Circus, London, EC2M 5QQ, UK

    All geographies, Helpdesk Email: support@respiro.io

Corporate Headquarters

Salisbury House, 31 Finsbury Circus, London, UK

Amiko Italy

Via Washington, 105,
20144, Milan

Amiko Germany

Schillerstraße 80
D-64625 Bensheim

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