Connecting care through patient engagement

Introduction

ASD.ai LLC (“ASD.ai,” “we,” “us,” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website www.ASD.ai (the “Site”), users of our mobile Application Rootines(the “App”) and the services available through our Site and App (collectively, the “Services”), and how we use and disclose that information. We do not sell, trade or rent your personal information. We use your data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions. By visiting the Site, using or downloading the App, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site, App or Services, and any dispute over privacy, is subject to this Policy and our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“Agreement”).


Definitions

‍SERVICES refer to our website (http://www.ASD.ai), mobile applications (Rootines), and other products and services offered by ASD.AI, LLC.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data. THE USER is the individual using our Service.



The Information We Collect About You

Personal Data

We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services. We collect your name and email address when you register to use our Services. When you create your profile, and one for the end user, you may also submit information including your phone number, zip code, the end user's height, weight and age, and daily updates. Daily updates could include, but are not limited to mood, sleep quality, hunger level, food intake, or outbursts. In addition, if you make a purchase, we will also request that you provide your credit or debit card information and your billing address.
If you are a care giver, we will collect your name, email address, phone number. When you create your profile you may also submit information including a profile picture. We may use your Personal Data to contact you with notifications, newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Wearable Devices and Biometric Information

You may link your wearable device account information to your ASD.ai profile and/or you may use the facial health metrics feature embedded in our app. If you link your wearable device profile and/or use the facial health metrics feature, these services may include collection of certain information such as your exercise, activity, sleep, or health data, including respiration, blood pressure, oxygen saturation, the number of steps you take, distance traveled, calories burned, weight, heart rate, sleep stages, active minutes, female health data, and any similar information to which you grant us access.

Social Networking Data

You also may log into our Services through your social networking accounts, including Facebook, and Google. If you do this, we obtain information from these sites as follows:
Facebook. If you log into our Services using Facebook, you must enter your Facebook email address and password. We will ask that you grant us permission to: (i) access and collect your Facebook basic information (this includes your name, profile picture, user IDs, age range, email address, link, location, time zone and any other profile information you have set to public). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public.
Google. If you log into our Services using Google, you must enter your Google account email address and password. By logging in through your Google account, you are granting us access to your profile information, which includes your name, profile picture, gender, user IDs, date of birth, email address, location, and any other information you have set to public.
We store the information that we receive from Facebook, and Google with other information that we collect from you or receive about you.
Any third-party social networking site controls the information it collects from you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies. We have no control over how any third party site uses or discloses the personal information it collects about you.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:
• Session Cookies: We use Session Cookies to operate our Service.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.

Use of Data

ASD.AI, LLC uses the collected data for various purposes:

• To provide and maintain our Service;
• To notify you about changes to our Service;
• To allow you to participate in interactive features of our Service when you choose to do so;
• 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 Site, App or our Services.
• To better understand how users access and use our Site, App and Services, both on an aggregated and individualized basis, in order to improve our Site, App and Services and respond to user desires and preferences, and for other research and analytical purposes.
• To provide customer support;
• To gather analysis or valuable information so that we can improve our Service;
• To monitor the usage of our Service;
• To detect, prevent and address technical issues;
• To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection;
• To provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
• To provide you with news, special offers, general information, and services unless you have opted not to receive such information;
• For any other purpose with your consent.

How We Share Your Information

We may share your information, including personal information, as follows:
Caregiver. If you log in through one of your social media accounts, your username and profile picture will be visible to other caregivers who you have granted access to on an ASD.ai family plan.
ASD.ai End User. End user information will be displayed to approved caregivers under an ASD.ai family plan. This includes profile image, name, and Information We Collect About You.
Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ASD.AI, LLC  will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.


Disclosure of Data

We may disclose personal information that we collect, or you provide:

Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

Business Transaction

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Security of Data

We have implemented commercially 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 100% security. 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 are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at Support@ASD.ai.

In certain circumstances, you have the following data protection rights:
• The right to access, update or to delete the information we have on you;
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
• The right to object. You have the right to object to our processing of your Personal Data;
• The right of restriction. You have the right to request that we restrict the processing of your personal information;
• The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/

According to CalOPPA we agree to the following:
• Users can visit our site anonymously;
• Our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
• Users will be notified of any privacy policy changes on our Privacy Policy Page;
• Users are able to change their personal information by emailing us at Support@ASD.ai.

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/

Firebase

Firebase is analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en For more information on what type of information Firebase collects, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

‍CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

GitHub

GitHub is provided by GitHub, Inc. GitHub is a development platform to host and review code, manage projects, and build software. For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

Behavioral Remarketing

ASD.AI, LLC uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/..

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page:
‍https://www.facebook.com/help/
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook:
‍https://www.facebook.com/help/
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/ , the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/

Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors) including the Apple AppStore and Google Play App Store.

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Services are not intended to be used by children under the age of 18 (“Children”). Parents, guardians, or care givers would be considered the User of the system.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: Support@ASD.ai