Gecko Health Innovations, Inc. ® ("Gecko") offers CareTRx™, a connected device and a simple software that empower patients as well as their caregivers to better manage chronic conditions such as asthma. CareTRx allows patients and other stakeholders, such as a parent or other caregiver, to monitor usage online on their phones, tablets or computers (the "System"). We maintain and manage the patients’ and caregivers’ data on their behalf. For adults, our System liaises with caregivers and health care providers (i.e., your physician) only at your direction.
The Gecko Health Innovations, Inc. ("Gecko") CareTRx System consists of an inhaler sensor ("Sensor"), mobile and web applications ("Application"), and our associated website ("Site").
This notice describes the types of personal information we collect from or about you or your device (or in the case of a minor, your child or your child’s mobile device), how that information may be used and shared by Gecko, and the choices available to users of our Application and visitors to the Site regarding our use of the information.
Please review it carefully.
Through the CareTRx Sensor, the Site, and/or the Application, we may collect personal information including health information; passive information from your mobile device or computer, such as location data, may also be collected. Collectively, this information is referred to as Collected Information.
The Use of Collected Information. We may use Collected Information as follows:
In addition, we may create or share reports about our service for business or marketing purposes from aggregate, anonymous information (i.e., information that does not directly identify and cannot reasonably be used to identify an individual) collected from our registered users.
We may share, with your explicit consent, information relating to patients (as well as patients' caregivers) with the patients' medical professionals, whose use, handling, and disclosure of this personal information is subject to their privacy policies.
The Application offers you the option to invite others, such as a caregiver or medical professional, to view your Health Information.
In addition, we may use and disclose Collected Information as we believe to be necessary or appropriate:
We may also use and disclose Collected Information in other ways, with your explicit consent.
In addition, we may use or share Collected Information that is not personally identifiable (such as aggregated data) for any legitimate business purpose, including but not limited to sharing such information with our affiliates and third parties for analytics, research, or commercial purposes. However, any such personal information will be aggregated in such a way that you will not be personally identifiable.
If we combine information that is not personally identifiable with information that is (such as combining your name with your geographical location), we will treat the combined information as Personal Information as long as it is combined.
We may also use and disclose Passive Information for any other purpose, except where we are prohibited from doing otherwise under applicable law (for example, if we are required to treat such information as Personal Information).
We also reserve the right to transfer Collected Information in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that personal information.
As an aid to adherence to prescribed inhaler medication, the CareTRx is appropriate for use by minors, including potentially children under 18 years of age. However, for legal reasons, our corporate policy is to require that a parent or guardian register directly with Gecko, as well as create a profile on behalf of the minor child. For children under 14, parental identity will be verified consistent with the Children's Online Privacy Protection Act. Children under 18 should not register directly for our services, which requires entering into a legal agreement [see Terms and Conditions of Use available on our website or within the App].
If you would like to review, correct, update, suppress or delete Personal Information and/or Health Information that has been previously provided to us by you, you may contact us at firstname.lastname@example.org.
The System is controlled and operated by us from the United States, and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information and Health Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the System you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.
When you download the App to a mobile device, you will be responsible for protecting the privacy and security of the information that you enter (i.e., setting a passcode and maintaining security of the mobile device that is running the Application), and for deciding who to disclose, and give access to, the information. Gecko assumes no responsibility, and shall have no liability, for protecting the privacy or security of the information entered in the Application or Site or shared with others either intentionally or unintentionally.
While we cannot guarantee that such security measures will protect the confidentiality or integrity of the data in our custody from unauthorized access or acquisition, we have implemented strong technical, administrative and physical safeguards to protect the security of Collected Information, including:
Privacy Officer, Gecko Health Innovations, Inc.
101 Main Street, 15th Floor
Cambridge, MA, 02142