Luscii Healthtech, B.V. (“LUSCII”, “Company”, “We”), a subsidiary of OMRON Healthcare, Co., Ltd., is committed to respecting your privacy. Our Consumer Privacy Policy describes how we handle your personal information generally. This supplemental Consumer Health Data Privacy Policy (“Consumer Health Privacy Policy”) explains our practices for “Consumer Health Data” as such term is defined by applicable laws including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, as each are amended and as and when they become effective including any regulations thereunder (“Health Privacy Laws”).

“Consumer Health Data” is broadly defined to mean personal information that is linked or can be reasonably linked to a consumer and that identifies past, present or future physical or mental health status. Consumer Health Data includes information about medical conditions as well as non-medical information, such as biometric data, information about use of non-prescription medication or use of health-related products. Consumer Health Data does not include information pertaining to individuals with whom we have an employment relationship and does not apply where an exception or exemption applies such as for Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). 

If we make any material updates to this Consumer Health Privacy Policy, we will notify you as required by Health Privacy Laws, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Consumer Health Privacy Policy earlier than required. We reserve the right to amend this Consumer Health Privacy Policy at our discretion and at any time.

Categories of Consumer Health Data that We Collect

LUSCII only collects, uses and discloses Consumer Health Data as needed to provide you with the products or services that you request or with your consent. 

LUSCII may collect Consumer Health Data related to the following categories of Consumer Health Data:

• Individual Health Conditions, Symptoms, Status, Diagnoses, Testing, Treatments and Diseases. Information about your health history, symptoms and/or treatment, such as your medical conditions and that of your family, medical diagnoses, test results and treatment results.
• Use or purchase of prescribed medication. Information about your past and current medications, images of your medication or medication bottles.
• Bodily Function, Vital Signs and Measurements. Information about the operations of the systems of your body, such as heart rate, pulse rate, irregular heartbeat, blood pressure readings, blood pressure cuff position, raw EKG measurement data and readings, movement error and location on the body where the electrocardiogram (“EKG” or “ECG”) recording was taken (e.g. finger tips, chest, limbs, etc), fitness and exercise activity, height and weight, body mass index, skeletal muscle percentage, resting metabolism, body fat percentage, visceral fat level, alcohol and caffeine consumption, whether you are a smoker or non-smoker, steps you have taken, distance walked, aerobic steps, calories burned, sleep duration, total awake time, low movement, high movement, auto sleep details, daily fitness goals (e.g. steps, sleep, weight, etc.), weight tracking, any notes, tags, dates, times and readings of the fitness and behavioral information and any other details relating to your bodily function, vital signs and measurements you choose to share.
• Precise location information that could reasonably indicate a resident’s attempt to acquire or receive health supplies. Information about your precise location to (i) provide you with the nearest location to purchase OMRON’s health supplies and (ii) locate and connect the connected health device.
• Internet or Network Activity Information essential to running our website such as Internet Protocol (IP) address, operating system and version, and Internet browser type and version which could identify your attempt to seek health supplies.
• Clinical Study and research program. Information you provide when participating in clinical trials and research studies. 
• Any Inferences of the above categories of health data derived or extrapolated from non-health information.

Purposes for Collecting Consumer Health Data and How We Use It

We may use your Consumer Health Data for the following processing purposes:

• Products/Services, including performing services for you and sending you certain products or samples you have requested.
• Consumer Management, such as:
  • Identifying and authenticating you to our different marketing programs, websites, and mobile apps.
  • Administering and maintaining accounts and preferences, as well as financial incentive, rewards, discounts (e.g., price or service coupons) and loyalty programs, if any.
  • Helping you manage your website or app preferences.
  • Allowing you to enter our contests or sweepstakes and leaving ratings and reviews for products.

• Consumer Service/Communications, such as:
  • Responding to your questions or requests for information
• Analytics, including monitoring and analyzing trends, usage, and activities in connection with our Services
• Quality and Safety, including:
  • Quality control, training, and analytics.
  • Safety maintenance and verification.
  • System administration and technology management, including optimizing our websites and applications.

• Security, including detecting threats and protecting against malicious or fraudulent activity.
• Recordkeeping and Auditing, including recordkeeping and auditing interactions with consumers, including logs and records maintained as part of transaction information.
• Legal/Compliance, including risk management, audit, investigations, reporting and other legal and compliance reasons.
• Research & Development (“R&D”), such as
  • Internal research
  • Designing and developing new products, services, and programs.

Sources of Consumer Health Data

We collect Consumer Health Data from the following sources:

• From you, such as when you request certain health-related products and services, join certain loyalty programs, or volunteer the information in connection with surveys or promotions.
• From your interactions with us, such as when you use our website, mobile application, products and services. 
• From third-party health application that you chose to connect to our mobile application, such as Apple Health, Samsung Health or Google Fit. 
• From our business and marketing partners, who provide us with information about consumers who are viewing our content across websites or apps, or purchasing our products.

We may also infer or derive Consumer Health Data by analyzing other non-health related data we have about you or other consumers.

Disclosures of Consumer Health Data

We do not sell your Consumer Health Data. We also do not share your Consumer Health Data with any Third Parties or Affiliates. We may disclose the categories of Consumer Health Data described above in the following circumstances:

• We may disclose Consumer Health Data with our data processors, service providers and contractors who assist us in providing goods and services to you. These processors may only use the data as permitted by our contracts with them. 
• We may also disclose Consumer Health Data as permitted by law, such as (i) with your consent, (ii) if needed to protect your vital interests, such as in the event of a medical emergency or natural disaster, (iii) to an acquiring organization if we are involved in a sale or a transfer of our business, (iv) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (v) as needed to preserve the integrity or security of our systems, or (iv) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.

Your Privacy Rights

You have specific rights with respect to your Consumer Health Data:

• You have the right to know if we are collecting, using or disclosing your Consumer Health Data, to access that consumer health data, including receiving a list of the entities and affiliates with whom we have shared or sold your information, though currently we do not sell or share your Consumer Health Data with Third Parties or Affiliates.
• You have the right to request that we delete your Consumer Health Data.
• If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent. For cookie-related Consumer Health Data, you can do this by visiting your “Cookie Preferences” in the bottom right corner of our health-related websites or in the Settings menu of our mobile applications. Withdrawing your consent for collection of non-cookie related Consumer Health Data will effectuate a deletion request.

We will not discriminate against you for exercising any of your rights. However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the services.

To exercise these rights, please submit your request through email: privacyrequests@luscii.com. We will authenticate your requests and process it as required by law. Please allow up to 45 days for a response. If we deny your request, you may appeal that denial by email. If your appeal is unsuccessful, you can file a complaint with the relevant government body in your state, including:

• Washington State Attorney General at www.atg.wa.gov/file-complaint.
• Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.
• Connecticut State Attorney General at https://portal.ct.gov/ag/common/complaint-form-landing-page

Contact Us

If you have any questions or concerns about your Consumer Health Data privacy or this Consumer Health Privacy Policy, please contact us at:

Email: privacyrequests@luscii.com

Address: Luscii healthtech B.V., Nicolaas Beetsstraat 216, 3511 HG Utrecht, The Netherlands