Numera believes in protecting your privacy. When we collect personally identifiable information from you, we comply with all applicable laws and regulations. We’ll regularly review how we’re meeting these privacy promises.
Tracking functionality notice and opt in:
The Libris device utilizes both Global Positioning System (GPS) and network Location Based Services in order to find the user’s current location. By activating the Libris product, the User agrees to allow Numera and its affiliates to use this information to provide the Libris emergency response services and related Numera Services.
1. Information Collected and How We Use It
We collect information from you, including PII and PHI (collectively, your information), for the purposes of providing our products and services, whether purchased by you or requested through the Website or Numera Services.
You are under no obligation to provide Numera with your information, but this may prevent you from using all or certain parts of the Website or Numera Services.
We do not sell or trade your information.
The following are the specific types of information we collect in connection with the Website or Numera Services:
(a) In order to use the Website or Numera Services, we have to create an account for you.
To make this account, we need your first and last name, and an email address. We’ll ask you to enter a User Name and Password that is unique to you, and may ask you to record your Date of Birth, Country, Culture (the language you are going to use for the application) and the Time Zone you are in.
In setting up this account we won’t ask you for health information – like what conditions you are managing, your health history or medications. If you purchase any products or services from us directly, where you may have to pay by credit card or PayPal, we will only ask you for information specific to that use. When we collect financial and address information for such purchases, we use that information to complete the transaction to ship you the devices or provide the services you have purchased.
In some cases, we may automatically create an account for you by receiving information from your response team or healthcare provider (HCP). We only ask for the data required to create the account.
(b) Some of our Numera Services are intended to receive, store and transmit your information to your authorized users including response teams and HCPs (collectively, Authorized Users). This information varies by product, but may include your: age, gender, height, smoker or nonsmoker, hours of exercise per week, pulse, blood pressure, (ir)regular heartbeat, the total number of aerobic steps and other steps taken, aerobic walking time, calories burned, fat burned, blood glucose levels, whether the blood glucose measurement was taken before or after a meal, body fat percentage, body weight, skeletal muscle percentage, visceral fat level, BMI, resting metabolism, the time and date of measurement and the targets you set related to this data.
(c) We may track details of your usage of the Website or Numera Services and the resources you access, including details about your browser language settings and IP address on your internet accessible devices such as computer(s) and/or smartphone(s) (Devices), if available. This information will not be stored in connection with the personal user data you provided.
(d) As stated above, the Libris device utilizes both GPS and network Location Based Services in order to find your current location and provide that data to your Authorized Users.
We may also use the information collected about you:
(a) To enable you and your Authorized Users to use the Website or Numera Services, including uploading, storing and tracking device data and manually entered data which may contain your information.
(b) To enable you and your Authorized Users to set targets related to the data above.
(c) To improve the content of the Website or Numera Services to provide and improve functionality in order to better meet your needs.
(d) To make sure that content and any services in the Website or Numera Services is presented in the most effective manner for you and for your Devices. Your browser language settings and IP address will only temporarily be stored for security and log in purposes and to present the Website or Numera Services in the language of your browser, if available.
(e) To carry out our obligations arising from related agreements that you or your Authorized Users have accepted.
(f) To notify you about changes to the Website or Numera Services.
(g) To construct de-identified (in accordance with applicable laws and regulations, such as HIPAA) data sets which we may use in whatever manner we see fit. Aggregated de-identified data may be exported to any country in or outside the European Union, USA or elsewhere.
(h) To provide you and your Authorized Users with support or troubleshooting assistance. If we have to provide support to answer a question or troubleshoot an issue, we’ll ask you or your Authorized Users permission to access your information.
2. Information Sharing
We share your information with certain third parties that help us provide Numera Services. These third parties are contractually prohibited from using the information for any other purposes or re-transferring it except as necessary to provide Numera Services and they are bound to strict obligations to protect the confidentiality of such information. We do not sell or trade your data. Your information may also be disclosed to your sponsoring organization, if you have one, and is generally viewable by only a small number of people at Numera who have a need to see the information to provide direct support to you.
We will allow you to opt out of any disclosures to a third party or use for any purpose other than for which it was originally collected. Numera may share non-personal, non-identifiable, summary, and/or aggregate data with its partners and other third parties.
Numera may also disclose your information when required to do so by law, or in response to a subpoena or court order, or when Numera believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of Numera, third parties or the public at large.
Notwithstanding the foregoing or anything else herein, in the event of a sale or other transfer of all or substantially all of Numera’s assets or capital stock, your data will be transferred and the acquirer will be bound by the promises we have made to you.
3. Our Commitments
We commit to:
(d) Ensure that any subcontractors that create, receive, maintain, or transmit your information on our behalf agree to the same restrictions, conditions, and requirements that apply to us with respect to such information; and
(e) Provide your available information, that we have access to, to you upon request; and
(f) Make our internal practices, books, and records available to regulatory bodies for purposes of determining compliance with applicable laws and regulations.
4. Contact Us
We’ll provide ways for you to access your information, as required by law, so you can correct inaccuracies.
To access your information, ask questions about our privacy practices, or issue a complaint:
You can reach us:
- by mail at 1201 3rd Avenue, Suite 700, Seattle, WA 98101, USA,
- by telephone at +011 888 253 5001,
- or by email at firstname.lastname@example.org
We’ll take appropriate physical, technical, and organizational measures to protect your information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
Many of our Numera Services are hosted applications. Numera hosts its software with nationally recognized leaders in cloud computing infrastructure, chosen because of their track record of offering trusted service. These vendors have obtained many certifications and third party attestations including SAS70 Type II, PCI DSS Level, ISO 27001, and ISO 27001, among others.
When we share information with you or a sponsoring organization, it is done via a highly secure connection. When we share data, we have specifically identified the requesting organization and verify that they received the data.
Our systems also include robust auditing, backup and data restoration capabilities.
6. Data Integrity
We’ll collect only as much of your information as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent. We’ll take reasonable steps to ensure that data is accurate, complete, current, and reliable for the intended use.
7. Safe Harbor
Numera complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Numera has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Numera’s certification, please visit http://www.export.gov/safeharbor/.
8. Resources and Links
The Website is not intended for children under 18 years of age. Numera does not knowingly collect PII or PHI from children under 18.
10. Business Transfers
11. Contacting the Webmaster
1201 3rd Avenue, Suite 700
Seattle, WA 98101
This Policy is effective as of and was last updated on February 5, 2015.