Effective Date: August 1, 2023
ZEPHYRx LLC ("ZEPHYRx", “we”, “our”, “us”) is committed to protecting the privacy and security of your personal information. This Policy provides details regarding how we treat personal information that we receive when you visit our website, www.zephyrx.com, and when you use our Breathe Easy mobile App or any other ZEPHYRx products and services (collectively the “ZEPHYRx Platform”).
1. What Personal Information We Collect About You
Information You Provide
We obtain information that you provide directly to us when you use the ZEPHYRx Platform, for example, when you fill out a form to contact us or register for our support forum, or perform spirometry tests.
The ZEPHYRx Platform provides you the opportunity to authorize ZEPHYRx to share your personal health information with us and your healthcare provider, physician, hospital, or other third-party.
Information you may choose to submit to us may include:
• Identity data, such as full name and date of birth
• Contact information, such as phone number(s), email address, home address
• Personal Health Information, such as results of spirometry tests, medical history, medications, and questionnaire responses
• Body data, such as weight and height
• Special categories of personal data such as ethnicity
• Serial number of a medical device you use
• Company name
• Information about your interests in and use of various products, programs, and services
• Any other information that you decide to provide us with
Personal Information Collected Automatically
The types of information we collect automatically when you visit our website or use the ZEPHYRx Platform may include IP addresses, device identifiers, browser characteristics, operating system details, language preferences, referring URLs, length of visits, anonymous traffic data, and pages viewed.
2. How We May Use Your Personal Information
This is how we may use personal information collected through our website or your use of the ZEPHYRx Platform:
• To perform the services requested of ZEPHYRx, such as displaying your data to you through the use of the ZEPHYRx Platform and sharing with your healthcare provider (with your authorization), or other authorized third-parties (i.e. in the case of research studies, authorized third-parties may include study doctors, study sponsors, and study staff).
• To communicate with you:
• responding to your inquiries and fulfilling you requests for information regarding our products or services
• sending administrative information to you, for example, any updates or changes to the ZEPHYRx Platform, our Terms & Conditions, or our policies.
• To send you marketing communications on products or services that we believe may be of interest to you, including via email and SMS in compliance with applicable laws and in accordance with your preferences.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Websites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• To improve the functionality of ZEPHYRx product and service offerings.
• To de-identify or anonymize personal information. ZEPHYRx uses non-personal information:
• to produce statistics and/or aggregated data analysis,
• to publish research or white papers, and
• for other legally permissible purposes.
3. How We May Share Your Personal Information
ZEPHYRx may share your personal information as follows:
• With authorized service providers assisting us in carrying out the transactions or services offered by ZEPHYRx. These service providers are under obligations of confidentiality, and their use of personal information is limited to the purpose(s) defined within our contracts.
• In the case of research studies or clinical trials, personal information / data may be transferred to authorized third-parties, such as the applicable sponsor, site investigator, or site.
• With our affiliates, subsidiaries, and any company owned or controlled by ZEPHYRx.
• When required by subpoena, search warrant, or other legal processes, or in response to activities that are unlawful or a violation of ZEPHYRx’s rules for use of the Service, or to protect and defend our rights or property.
• With others only with your consent or authorization.
We take industry-standard measures to protect your personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. All data is encrypted at rest and in transit using industry-standard technologies such as TLS and AES encryption.
Collection and processing of location data, cookies, special categories of personal data and any sharing/transfers of personal health data to third-parties will be based on consent or authorization that we will ask you to provide through the website and/or through your use of the ZEPHYRx Platform.
• You may consent or withdraw your consent to our use of your personal information for marketing at any time by following the instructions to unsubscribe included in each marketing- related email sent to you or by sending an unsubscribe request to email@example.com.
• Please note that if you opt-out of receiving marketing-related emails from us, we may still send you administrative messages relevant to any specific services you may have signed up for.
• You may withdraw or revoke your authorization to share your personal health information at any time and can do so by submitting a request in writing to: ZEPHYRx, 2 Third Street, Suite 201, Troy, New York 12180 USA
We will retain your personal information for no longer than is necessary for the performance of our services, to achieve the purposes for which the information was collected, or as may be permitted under applicable law.
4. Click Here for Data Protection for European Union Residents
5. Click Here for California Privacy Rights under the CCPA
Attn: Privacy Office
2 Third Street, Suite 201
Troy, New York 12180