MediSens Wireless Inc. Privacy Policy (DRAFT)

Effective Date: 05 March 2025

1. Introduction

MediSens Wireless Inc. ("MediSens," "we," "us," or "our") is committed to protecting the privacy of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our websites, mobile applications, products, and services (collectively, the "Services"). We adhere to the principles of the EU-U.S. Data Privacy Framework (DPF) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.

2. Scope

This Privacy Policy applies to all users of our Services who are located in the European Union, including visitors to our websites, customers, and individuals who interact with us through other means.

3. Information We Collect

We collect various types of information, including:

  • Personal Information: This includes information that can be used to identify you, such as your name, email address, postal address, phone number, and other contact details.

  • Device Information: We collect information about the devices you use to access our Services, such as IP address, browser type, operating system, and device identifiers.

  • Usage Information: We collect information about how you use our Services, such as the pages you visit, the features you use, and the time and duration of your activities.

  • Health-Related Information: If you use our health-related Services, we may collect health information, such as vital signs, medical history, and other health data. We will only collect and process this information with your explicit consent.

  • Cookies and Tracking Technologies: We use cookies and similar technologies to collect information about your browsing activity and preferences.

4. How We Use Your Information

We use your information for various purposes, including:

  • Providing and improving our Services.

  • Communicating with you, including responding to your inquiries and providing customer support.

  • Personalizing your experience.

  • Analyzing and understanding how our Services are used.

  • Detecting and preventing fraud and abuse.

  • Complying with legal obligations.

  • For health related data, to provide the service requested by the user, and only with the explicit consent of the user.

5. Disclosure of Your Information

We may disclose your information to:

  • Service Providers: We may share your information with third-party service providers who assist us with various aspects of our business, such as hosting, data analysis, and customer support.

  • Business Partners: We will only share data with business partners with your consent, and only when necessary to provide the services you have requested.

  • Legal Compliance: We may disclose your information if required by law or to comply with a legal process.

  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.

  • ABENA A/S: As our representative in Europe, ABENA A/S may have access to data of EU residents for the purpose of fulfilling legal obligations.

6. Data Privacy Framework (DPF) Compliance

MediSens complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. MediSens is waiting for approval from the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. If there is a conflict between the terms in this privacy policy and the DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit: https://www.dataprivacyframework.gov/

7. Choice

In compliance with the DPF Principles, MediSens commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our DPF policy should first contact MediSens at: compliance@medisens.com.

MediSens has further committed to refer unresolved DPF Principles complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information and to file a complaint. The services of JAMS are provided at no cost to you.

8. Accountability for Onward Transfer

MediSens is responsible for the processing of personal data it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. MediSens remains liable under the DPF Principles if its agent processes such personal data in a manner inconsistent with the DPF Principles, unless MediSens proves that it is not responsible for the event giving rise to the damage.

9. Data Security

We implement reasonable security measures to protect your information from unauthorized access, use, or disclosure. However, no method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee absolute security.

10. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by law.

11. Your Rights

You have the right to:

  • Access your personal information.

  • Correct inaccuracies in your personal information.

  • Request the deletion of your personal information.

  • Object to the processing of your personal information.

  • Restrict the processing of your personal information.

  • Data portability.

  • Withdraw consent at any time, when processing is based on consent.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on our website.

13. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

MediSens Wireless Inc.

2855 Kifer Rd, Suite 210

Santa Clara, CA 95051

Email: compliance@medisens.com

Phone: +1 408 748 1446

European Representative:

ABENA A/S

Egelund 35

6200 Aabenraa

Denmark

CVR no. 25682742

14. FTC Enforcement

MediSens is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

15. Arbitration

Under certain conditions, more fully described on the Data Privacy Framework website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.