Privacy Policy

Introduction

BoundaryCare LLC (“BoundaryCare”, “we”, “us” or “our) conducts business in the United States and is headquartered in Saint Paul, MN. We understand the importance of privacy to our customers, visitors, suppliers, business partners, employees, end users, and other individuals (“you”, the “user”, or “data subject”). We are committed to protecting and respecting your privacy.

This BoundaryCare privacy policy (“Policy”) applies only to information collected through the website on which it is posted (“Site”) as well as any other applications (apps), events, newsletters, communications, or services provided by or on behalf of BoundaryCare that link or reference this Policy (“Services”). It does not apply to third-party platforms or to other BoundaryCare-operated websites or other BoundaryCare-operated platforms where it is not linked or referenced. This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business.

Some of the information we collect through the Site or using our Services may be “Personal Information” as defined below.

Among other things, this Policy describes:

What information we collect about you
How and on what basis we use the information we collect
How we collect your Personal Information
How long we keep your Personal Information
How we share the information we collect
How we protect your information
How you can exercise rights regarding your information
How you can contact us

If you have a disability, you may request access to this Policy in an alternative format by contacting us at info@boundarycare.com.

Your acknowledgment of this Policy

By using the Site, including your choices regarding cookie settings, or using the Services, you are acknowledging and agreeing to the collection, use, disclosure, and transfer of your information as described in this Policy (and any additional Privacy Notices that apply to you). If you do not consent to the collection, use, disclosure and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), you should not use this Site or the Services. If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below.

Where we rely on your consent for the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), you may revoke your consent by contacting us directly.

Complete agreement for use of the Site

This Policy is part of the End User License Agreement that governs your use of this Site and the Services, where applicable. A link to our End User License Agreement is provided at the bottom of each page of the Site and within the applications used for accessing the Services.

Except as written in any other disclaimers, policies, or other notices on this Site, this Policy and the End User License Agreement are the complete agreement between you and BoundaryCare with respect to your use of this Site and the Services. Any terms we use in this Policy without defining them have the definitions given to them in the End User License Agreement. There may be additional terms that apply to particular materials or sections of this Site.

Changes to this Policy

BoundaryCare reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information we collect after we have posted the revised Policy or Privacy Notice on this Site.

Your use of this Site or the Services following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy” at the bottom of each page of the public areas of this Site.

What is Personal Information?

Personal Information means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

How do we collect your Personal Information?

How we collect Personal Information will depend upon the nature of your relationship to BoundaryCare. We may collect Personal Information directly from you and may also collect Personal Information from third parties, including in the course of providing products to you through your health care provider, your caregiver or guardian, as well as publicly available information and databases supplied by third parties.

If you elect not to provide Personal Information to us, this may affect our ability to provide products and services to you.

Information We Collect

General

Generally, Personal Information we collect may include but is not limited to:

Name and contact details
Details of your company, industry, role and qualifications
Information from your visits to our websites, including the IP address, type of browser, device (including unique device identifiers) and operating system you use, network information, access times, pages viewed, links clicked on, cookie information
Details of products and services you have inquired about or that we have supplied to you, including any additional information necessary to deliver those products and/or services and to respond to your inquiries
Credit information, payment, credit card and debit card or bank account information for product deposits, purchases, or refunds
Information that you provide to us directly through one of our websites, apps or that you email to us
Information you provide in customer surveys, interviews, or case studies.

End Users

If you are an end user of our services, including a caregiver (“Caregiver”) or an individual monitored by our services (“Patient”), we will collect information provided when you are making an account as well as information generated during your use of the Services. In some cases, we may receive this or other information from third parties, such as your health care provider. It is important that the Personal Information we hold about you is accurate and current. Please let us know if your Personal Information changes.

If you are a Caregiver, we may collect:

first and last name,
email address,
phone number,
mailing addressIf you are a Patient, we may also collect (depending on your situation and the features enabled by you or on your behalf):

Patient id number
your gender,
date of birth,
weight,
your medical history and conditions,
treatment information,
your geographic location,
safe zone exit and entry information,
Device information (battery status, connection status),
heart rate,
falls and gait,
oxygen saturation,
sleep analysis,
physical activity metrics,
VO2 max,
Responses to reminders,
Responses to micro-surveys,
other services which may be added or modified over time

Please note: Some of the information we collect regarding end users will be Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act (or “HIPAA”) handled by BoundaryCare as a business associate on behalf of your health care provider. In this case, the handling of PHI is also subject to your health care provider’s Notice of Privacy Practices. For more information about your health care provider’s privacy practices, consult your provider.

Suppliers, Customers or Other External Stakeholders

If you are a supplier, customer, distributor, or a health care professional that supplies our products to end users: we may collect additional specific information including information about your professional details, practice specialty and areas of interest, membership of professional associations, product usage and your dealings with us. If you create an account with us to use our Services, we may also collect information such as contact details, username and password, and details about the use of our Services tied to your account.

Employees, Contractors and Applicants

If you are an employee, contractor or applicant: we may collect additional specific information including your gender, date of birth, contact details, information collected in our employment records, including tax file number, job application, reference checks, curriculum vitae/resume, records of training, immigration status, documentation of performance appraisals and disciplinary matters, employment terms, and medical condition or history. We may receive some of this information from third parties such as recruiters or from reference checks.

Personal Information You Manually Provide through this Site

BoundaryCare collects the information you manually provide (using your keyboard, mouse, or touchpad) when you use this Site. For example, we collect the information you provide if you choose to complete a questionnaire, contact us with questions, or otherwise interact with this Site. Some of the information you may choose to manually provide will be Personal Information including but not limited to:

• Contact data: such as name, title, address, phone number, mailing address, and email.

• Other identifiers: such as device ID or serial number, various types of personal health information (e.g., health insurance information, medical information, and similar), online identifiers, and other similar identifiers.

• Information submitted by you through forms (such as “contact us” forms).

• Demographic data: such as language, age, and gender.

• Marketing preferences: such as e-mail subscription and frequency preferences.

Information Automatically Collected through this Site

BoundaryCare collects information through the Site that is sent to us automatically by your web browser or mobile device. This information may include but is not limited to:

• Product use and application data (including date and time of your visit)

• IP address

• The browser you are using (including name and version)

• Your location and other geographic data

• The website you came from and the website you visit after leaving

• Pages viewed on the Site

• Links clicked on the Site

• Time spent on a particular page of the Site or the Site as a whole

• Site data used to facilitate the use of the Site such as login and technical data

The information we receive may depend on your browser or device settings as well as your cookie settings. The information we receive from your web browser and device typically is not, in and of itself, personally identifiable. However, we may combine it with other information that either does, or may, identify you.

Information Collected by Cookies and Other Technologies through this Site

We use “cookies” and other technologies to collect information and support certain features of this Site. For example, we may use these technologies to:

• Collect information about the ways visitors use the Site—which pages they visit, which links they use, and how long they stay on each page

• Support the features and functionality of the Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits

• Personalize your experience when you use the Site; and

• Improve our marketing efforts, including through use of targeted advertising.

The information we collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to Personal Information that you provide. If you do not wish to receive cookies, you may choose to reject cookies in your cookie settings when you visit our Site. You may also set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if you or your browser rejects cookies.

Information Collected by Third-Party Cookies through this Site

In addition to the cookies BoundaryCare delivers to your computer or mobile device through this Site, certain third parties (Tracking and Performance Cookies) may deliver cookies to you for a variety of reasons. For example, we may use a web analytics tool that helps us understand how visitors engage with our Sites.

Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.

You have choices about the collection of information by third parties on our Sites. You may download an Opt-out Browser Add-on to opt-out of Google Analytics by clicking here. Similarly, to opt-out of cookies used for interest-based advertising by similar services globally, click here or here.

You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that the industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.

How We Use Your Information

Collected through this Site

We may use the information we collect through the Site for various purposes, including but not limited to:

• To provide you with access to the Site.

• To respond to your requests.

• To personalize your access to the Site.

• To develop records (including records of your Personal Information).

• To contact you with pertinent information about products, clinical trials, or important safety information, and about products and services of ours and of others.

• For analytical purposes and to research, develop, and improve programs, products, services, and content.

• To remove your personal identifiers. Once we have de-identified information, it is considered non-Personal Information and we may treat it like other non-Personal Information.

• To enforce this Policy and other rules about your use of this Site.

• To protect someone’s health, safety, or welfare.

• To protect our rights or property.

• To comply with a law or regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

Collected through our Services

Generally, the purpose for which we collect Personal Information will be apparent from the context in which we collect it or will be disclosed before or at the time of collection. Where permitted by law and our contractual obligations, we may use your Personal Information for various purposes including but not limited to:

Provide you and your healthcare professionals with product support.
Respond to and fulfill requests from you, your healthcare professional, or suppliers.
Administer, improve and promote our products.
Analyze the performance of our products.
Improve our services and services of our third-party suppliers and distributors.
Monitor the safety of our products and record, analyze and respond to and act on medical queries, complaints and safety reports and to report as required to regulatory bodies and other relevant companies which market and sell our products.
Notify you of matters concerning the safety of our products which we consider you should be notified of or to notify you as may be required by law or regulation.
Generate and maintain customer lists for the purposes of our own market research and to enable us or our distributors to undertake marketing to you and others.
Administer patient support, health awareness/management programs or other similar programs organized by us.
Organize and administer conferences, symposia, seminars or other events and meetings.
Generate and maintain our investor information to comply with legal requirements and to enable reporting to investors.
Provide you with information such as our press releases.
Comply with applicable laws, regulations, guidance, codes of conduct, product approvals, license requirements and ethical requirements including to comply with demands or requests made by regulators, governments, courts and law enforcement authorities.

How We Share Your Information

Generally, we may share your Personal Information with:

companies within our group;
third parties with whom we have a business relationship, including distributors, agents, suppliers, healthcare professionals, and advisors. This would also include companies that provide technology services to us, our professional advisors, and auditors;
governments, regulators, courts and law enforcement authorities;
third parties or individuals (such as a caregiver or health care provider) at your request; and
other third parties in connection with any reorganization or sale of all or any part of our business.

We will not sell, share or otherwise distribute Personal Information about you to any person, except as provided in this policy and in accordance with applicable law and regulation. The circumstances in which we may disclose that information include where:

we may share your information with selected third party service providers in connection with our business operations; for example, email or cloud service providers;
we expressly tell you at the time you supply the information or it is expressly permitted under any agreement with you;
the information is aggregated and/or no longer personally identifiable;
it is necessary to provide you with the products which you have requested;
it is requested by third parties for use in the ordinary operation of our business. We will only disclose your Personal Information to reputable third parties and only on a confidential basis;
disclosure is in response to demands or requests made by regulators, governments, courts and law enforcement authorities;
permitted or required by law, regulation or applicable guidance.

How We Protect your Information

BoundaryCare takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and we encourage you to take appropriate precautions such as special care when submitting information by email and taking appropriate precautions to keep your usernames and passwords confidential.

Transfer and Storage of your Personal Information

This Site and our Services are intended for residents of the United States. If you are not based in the United States, we may store, collect, transfer, and process your Personal Information in a country other than your country of residence. The laws of countries to which your information may be transferred may be different than in your country.

Retention of Your Information

We make reasonable efforts to keep Personal Information for the period required to comply with applicable laws, regulations, guidance, codes of conduct, product approvals, license requirements, ethical and safety requirements. We may also maintain your information as required to comply with contractual requirements.

Children’s Privacy

This Site is not targeted to children under the age of 13 and we do not knowingly collect or solicit Personal Information about such children. If we discover that a child has provided us with Personal Information online through this Site, we will take delete this information as quickly as possible. If you believe we may have received Personal Information from a child under the age of 13, please contact us immediately.

Your Rights

To stop us contacting you by email, you may use the “unsubscribe” functionality included in emails we send you or contact us directly. You should note that this will not affect all communications from us, for example, we are legally required to provide notices such as notification of a data breach in which case you should expect to receive a notification via email.

You may make a request to access, correct, or delete your Personal Information or otherwise object to our processing of such Personal Information by contacting us directly. We will respond to reasonable requests in accordance with applicable law and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights.

There may be times where we cannot grant you access to the Personal Information we hold. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. We will provide written explanation for our refusal to grant access.

California residents, please see the respective Privacy Addendum to understand your rights.

Links to Other Websites

This Policy applies only to the BoundaryCare-operated websites on which it is posted. BoundaryCare and its affiliates may operate different websites for different purposes and in different countries, where different laws may apply. If you visit another BoundaryCare website, please take a moment to review the privacy policy posted on that site to learn what information may be collected through that site and how it is processed. This Site may also contain links to websites that are not operated by or on behalf of BoundaryCare or its affiliates. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. BoundaryCare does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any Personal Information.

Contact Us

If you have any questions regarding this policy or about our privacy practices, or need to contact us for purposes related to this Privacy Policy, please contact us:

Email: info@boundarycare.com
Mail: 438 Portland Avenue #6
Saint Paul, MN 55102

Addendum: California Residents Privacy Notice

“Do Not Track” Policy California Online Privacy Protection Act (CalOPPA)

Our Site does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

California’s Shine the Light law

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided in this Policy.

California Privacy Rights for Minor Users (California Business & Professions Code § 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided in this Policy and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Last updated: February 9, 2023