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Privacy Policy SIVA Smartphone Application

Our Company, SIVA Health AG, is the manufacturer of SIVA Smartphone Application. The security of your personal data with respect to the use of the SIVA Smartphone Application is very important to us. We take the protection of your data very seriously. Personal data is all information that can lead to your identification (hereinafter “Personal Data”).

This Privacy Policy explains what information we collect and how we use and protect the information we collect when you use SIVA Smartphone Application. This Privacy Policy applies to all Personal Data that we process.

1. Information about the SIVA Smartphone Application

SIVA Smartphone Application is a mobile application that manages the SIVA Wearable, which is a cough monitor worn by individuals to track their cough frequency. Both SIVA Smartphone Application and SIVA Wearable are part of SIVA System that enables to track the cough events and context information. SIVA Smartphone Application configures your SIVA Wearable to record audio and acceleration data to detect cough events, as well as the number of steps walked. This data is securely encrypted and can only be unlocked by a private key stored in your personal SIVA Smartphone Application. The recorded data will be transmitted by the SIVA Wearable for further processing to a cloud infrastructure.

Please note that neither the SIVA Smartphone Application nor the SIVA Wearable are medical devices, and do not provide medical advice, nor should they be considered a substitute for any form of professional health services.

2. Contact Details

Please contact SIVA Health if you have any questions about SIVA Smartphone Application privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights. You can reach SIVA Health’s Data Protection Officer at:

Alexander Duschau-Wicke
SIVA Health AG
Zurlindenstrasse 134
8003 Zurich
Switzerland

E-Mail:  privacy@siva-health.com

3. Collection of Data

We collect the following data:

  1. Audio data recorded by SIVA Wearable (uploaded as encrypted data, decrypted and automatically processed for cough detection, deleted after processing, not accessible to any human listener)

  2. Step counts acquired via accelerometer in SIVA Wearable

  3. Time-stamped cough event data obtained via processing encrypted audio data collected via SIVA Wearable

  4. Wearing compliance (worn hours, charging time) data collected via SIVA Wearable

  5. SIVA Smartphone Application and SIVA Wearable interaction information (number of times the SIVA Smartphone Application has been opened, number of times Bluetooth connection has been established between the application and the wearable)

  6. Responses to questions collected via SIVA Smartphone Application

  7. IP address of the smartphone with the SIVA Smartphone Application

  8. Email address used when registering you to use SIVA System by a health care provider

  9. Approximate geolocation (with reduced accuracy of 11.1 km / 6.9 miles) collected when opening via SIVA Smartphone Application

4. Storage and Processing of Personal Data / Transfer of Personal Data

SIVA Health’s use of Service Providers

SIVA Health requires all service providers to safeguard your data. We carefully select these providers and mandate them to adhere strictly to data protection standards. The updated list of these parties can be requested from SIVA Health at any time.

Transfer, Storage and Processing

SIVA Health uses an authentication service provider in the United States of America that processes the following data:

  • Your email address, the smartphone’s IP address and the SIVA Wearable’s IP address

SIVA Health uses a system monitoring service provider in the European Union that processes the following data:

  • Logging and system interaction data

SIVA Health is based in Switzerland; thus, your data is transferred to Switzerland for SIVA Health to access the data to undertake system administration.

All remaining data processing and storage is carried out in secure data processing centers in the European Union by cloud-service providers.

Retention and Deletion

We will only retain Personal Data for as long as is necessary for us to render the service you have requested or to which you have given your consent, or to fulfill the purposes as set out in this document except where otherwise provided by law (e.g. in connection with a pending litigation).

Any decrypted original audio data recorded by the SIVA Wearable will be immediately deleted after processing to guarantee that neither SIVA Health nor third parties are able to access the original data.

All other data is deleted once the contract between your health care provider and SIVA Health has expired. Consult your health care provider for details.

Anonymized data

Short segments of maximally 1 second duration around the identified cough events will be additionally stored in a separate secure storage for the purpose of quality control. In the quality control process, these anonymous data segments may be reviewed by human listeners to check the correct performance of the cough detection algorithm.

5. Purpose of Use

We collect your data so that we can:

  • Provide insights into when and how much you cough.

  • Provide associated metadata to monitor the use of SIVA Wearable

6. Security

SIVA Health uses technical and organizational security measures to protect data against manipulation, loss, destruction or access by unauthorized persons (use of a certified infrastructure). These security procedures are continuously adapted to new technological developments.

7. Right of Access to, Rectification, Erasure or Restriction of Processing, Right to Object to Processing, Right to Data Portability

SIVA Health would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

  • The right to access – You have the right to request copies of your personal data.

  • The right to rectification – You have the right to request correction of any information you believe is inaccurate. You also have the right to request completion of information you believe is incomplete.

  • The right to erasure – You have the right to request for erasure of your personal data, under certain conditions.

  • The right to object to processing – You have the right to object to processing your personal data, under certain conditions.

  • The right to data portability – You have the right to request transfer of your collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@siva-health.com or at the address specified in section 2.

8. Right to Withdraw Consent at Any Time

You have the right at any time to withdraw your consent to the processing of your Personal Data for the future. For clarifications sake such withdrawal will, however, not affect the lawfulness of processing based on consent before its withdrawal. If you would like to exercise this right, please contact us at our email: privacy@siva-health.com or at the address specified in Section 2.

9. Right to Lodge a Complaint with a Supervisory Authority

Contact your national data protection authority, to lodge a complaint if you do not agree with the processing of your Personal Data.

In Switzerland, you can lodge a complaint with the competent data protection authority (https://www.edoeb.admin.ch) if you do not agree with the processing of your Personal Data.

 

If you are resident in the EU, you also have the right to lodge a complaint with your national data protection authority or with the European Data Protection Supervisor (https://edps.europa.eu/) if you do not agree with the processing of your Personal Data.

10. Change to this Privacy Policy

SIVA Health reserves the right to make changes to this Privacy Policy at any time. It is strongly recommended to check this page often and consider the date of the last modification listed at the bottom of this document.

Last update: 2023-11-29

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