Hancock Medical, Inc (DBA Beddr) Privacy Policy

This Privacy Policy describes the personal and non-personal information collected by Hancock Medical, Inc. (“HM,” “we,” “us” or “our”) when you visit our website (the “Site”) or use our mobile application (“App”) for our Beddr SleepTunerTM Product(the “Product”), and how we use that information.

About HM
HM is the manufacturer of the Product and the App. We are not a HIPAA Covered Entity or medical services provider.  The Product is a wellness oximeter, a non-invasive device that measures functional oxygen saturation of arterial hemoglobin (SpO2), Pulse Rate (PR), sleep position, and movement with a number of sensors. It is a continuous monitoring device designed for use while at rest while sleeping at home or in a clinic. The App gathers information from the Product and displays that information in a useful, clear format to provide you with personalized insights into your sleep quality and actionable recommendations on how to improve it.

Information Collection and Use
Personal Information
In order to use the App with the Product, you must provide your name, email address and password to register an account through the App (“Registration Information”). Registration Information is not used for any purpose other than to contact you about your account, the App and the BeddrSleepTuner and to enable you to access your account.  W use the information you share during registration to provide a customized scoring and analysis of your data. When you order Products directly from us, send us customer support requests, or otherwise request information from us, we collect the information you provide for those purposes – and only for those purposes.

Sleep Data, Phone Data and Background Data
The Product collects information about your pulse, movement and position (“Sleep Data”), and information about the device itself, such as battery level, settings, user-defined device name and firmware version. That Sleep Data is then collected by the App and transferred to our servers and associated with your account.  The App also collects your phone model number and OS version (“Phone Data”), but does not collect any IP addresses, device identifiers, or location data. If you elect to provide information through the App, which can include your age, gender, weight, height, body mass index, and survey feedback (collectively, “Background Data”), it is also transferred to our servers and associated with your account, and all of that information is transferred to our servers as well. We use the information you share during registration to provide a customized scoring and analysis of your data. We use Sleep Data, Phone Data and Background Data in order to make the Product and App features available to you, and we may de-identify and anonymize all of that data so that it cannot be identified to you in any way (“Anonymous Data”). We may use and share with third parties the Anonymous Data and Phone Data (neither of which identifies you personally) for any purpose. We may also send you alerts and notifications via the App.

We may provide links and/or connections to third-party web sites or services from the Site. We are not responsible for the privacy practices or content of these third-party sites.

Cookies, Tags & Analytics
Like many technology companies, we may use cookies and similar technologies, such as tracking pixels on the Site, in email correspondence and analytics tools on the Site and the App, (collectively, “Tags”) to collect additional usage information. We and our service providers use Tags to collect and analyze Anonymous Data about your use of our Site and/or App. We use that Anonymous Data to monitor and improve our services and as provided above.  You hereby expressly consent that we are entitled to place Tags for the above-mentioned uses on your computer or device and to use the information gathered from Tags as provided in this Privacy Policy. Most browsers allow you to disable cookies or set your browser to alert you when cookies are being sent to your computer.

Information Sharing

As noted above, (i) we may share Anonymous Data and Phone Data for any purpose; (ii) we host our servers with hosting providers, so Registration Information, Sleep Data, Phone Data and Background Data is stored on servers hosted by third parties, but the data itself is not made accessible to them; and (iii) we may share your name and email address for the purpose of providing customer support, responding to your requests, for sending our newsletter (if and when we make them available), for contacting you about our products and services, or for fulfilling your orders. We do not rent, sell or share any of your personal information for any other purpose except as expressly agreed upon by you and in for the following circumstances:

* As necessary, if we believe that there has been a violation of our terms for use of the App and related service or of our rights or the rights of any third party;
* As necessary, to identify, investigate, prevent or take action regarding illegal activities or suspected fraud or other abuse of the App and related service;
* To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation, as permitted by law, or otherwise as required by law; and
* In the event that we go through a business transaction, such as a merger, an acquisition by another company, or a sale of all or a portion of its assets, your information may be one of the transferred assets.

HM takes appropriate steps to ensure data privacy and security through various hardware and software methodologies. However, we cannot ensure or warrant against all risks with regards to the security of that information, so information you choose to transmit to HM and which we store is provided to us at your own risk and HM does not guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our safeguards.

We do not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Site or Service is directed to persons under 13. If we learn that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then we will take the appropriate steps to delete such information.

Do Not Track
Currently, we do not respond to “Do Not Track” browser features, but we may do so in the future as industry standards evolve.

Changes to this Privacy Policy
We may change this Privacy Policy from time to time. If we do, we will post the changes on the Site and update the last updated date of this Privacy Policy.

Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at: privacy@beddrsleep.com.

LB 01275 Rev A
Revision Date: March 18, 2019