Privacy Policy

This Privacy Policy explains how Luscii Healthtech B.V. (“LUSCII” “we,” or “us”), a subsidiary of OMRON Healthcare, Co., Ltd. (“OMRON”), collects, uses, and discloses information about you. This Privacy Policy applies when you use our website located at https://luscii.com/en-us/home (the “Site”), as well as our other websites and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

What is Not Covered in the Privacy Policy?

Unless otherwise stated herein, this Privacy Policy does not apply to information collected by or through (i) any third party (including our affiliates and subsidiaries); and (ii) our product Omron Connect Pro and its mobile application. The Omron Connect Pro Privacy Notice specifically addresses the use and treatment of protected health information associated with VitalSight, which we offer as a business associate through our partnered covered entities. Some LUSCII affiliates’ sites and services (e.g. luscii.com, omron.com, automation.omron.com, components.omron.com, and omronhealthcare.com) are governed by that OMRON affiliate’s own separate privacy policies and practices.

Changes to the Privacy Policy

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you regarding your personal information. Please also review the Terms of Use or End User License Agreement linked to the Services that apply to your use of the specific OMRON Service.

By using our Services, you consent to our Privacy Policy and agree to our Terms of Use. If you do not consent to this Privacy Policy, your choice is to not use our Site or Services.

Collection of information

Information You Provide to Us

We collect information you provide directly to us. The types of personal information we may collect include your name, email address, postal address, phone number, and any other information you choose to provide. For example, you share information directly with us when you have an account, sign up to receive our newsletter or other email communications from us, fill out a form, submit or post content through our Services, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us.

Information We Collect Automatically When You Interact with Us

We collect information automatically through your use of our Services , from your devices . When you access or use our Services, we automatically collect certain information, including:

Device and Usage Information: During the course of the Services we provide to you, we collect information about how you access our Site and Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, application version, and device language. We also collect information about your activity on our Services using analytics tools (see the Analytics section below), such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
Location Information: In accordance with your device permissions, we may collect information about the location of your device. You may stop the collection of location information at any time (see the Your Choices and Updating Your Information section below for details).
Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies, and web beacons to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about tracking technologies and how to disable them, see our Cookie Policy and the Your Choices and Updating Your Information section below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from internet service providers, data analytics providers, operating systems and platforms) directly.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior.

Use of Information

We use the information we collect directly, automatically and through other sources to deliver the Services you request and customize your experience with us. We also use the information we collect to:

Provide our Services to you, communicate with you about your use of our Site and Services, respond to your inquiries, fulfil your orders, set up your account profile, and for other customer service purposes;
Tailor the content and information that we may send or display to you, offer location customization, offer personalized help and instructions, and otherwise personalize and improve your experiences while using the Site or Services;
Send marketing and promotional information, including news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third-party products and services, to the extent permitted by law and, where required, with your consent;
Authenticate your identity;
Provide, maintain, and improve our products, our Site and Services;
Better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes;
Send you customer experience surveys, questionnaires, and recall notices;
Personalize and improve your experience on our Site and Services;
Send you technical notices, security alerts, and support and administrative messages;
Respond to your comments and questions and provide customer service;
Communicate with you about products, services, and events offered by LUSCII and others and provide news and information that we think will interest you (see the Your Choices and Updating Your Information section below for information about how to opt out of these communications at any time);
Monitor and analyze trends, usage, and activities in connection with our Site and Services;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of LUSCII and others;
Debug to identify and repair errors in our Site and Services;
Monitor your compliance with any of your agreements with us;
Comply with our legal and financial obligations;
Manage or transfer our assets or liabilities, for example in the case of an actual or potential acquisition, disposition or merger; and
Carry out any other purpose described to you at the time the information was collected.

Cross-Device Tracking Use

We and our third-party service providers may use the Device and Usage Information and Location Information (see the section in this Privacy Policy titled Information We Collect Automatically When You Interact with Us) that we collect about you, or from a third-party) to identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). See the section in this Privacy Policy titled Analytics below for more information

Sharing of Information

We do not sell or share your personal information for money but we engage third parties to provide marketing and analytics services to us. We do not sell or share your sensitive personal information to any third parties for any other purpose except to provide services to you. We share personal information in the following circumstances or as otherwise described in this Privacy Policy:

We share personal information with affiliates and subsidiaries of OMRON.
We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, web security, fraud prevention, customer service, and marketing and analytics.
If you submit a product review or post content in another public area of our Services, we share this information publicly on our Services, including third party retailers’ sites.
We share personal information with third-parties for analytics purposes, unless you opt out of this type of sharing. For analytics sharing, you may opt out by clicking the Cookie Settings link that is displayed in our Site’s footer or contact us to receive detailed instruction to opt out of this type of sharing. For California residents, you may opt out of any tracking technologies by clicking the “Do Not Sell or Share My Personal Information” link that is prominently displayed in our Site’s footer. To learn more about tracking technologies, analytics and cookies, please refer to Analytics below and our Cookie Policy.

We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of OMRON, our users, the public, or others.
We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

Links to other websites and applications

The Site or our other Services may contain various links to, as well as plug-ins or widgets from, social media and other third-party websites or applications, which may provide additional information, goods, services, and/or promotions. These third-party websites or applications are owned and operated independently of LUSCII and have their own separate privacy and data collection practices. We are not responsible for the privacy practices of any third party; therefore, you should review their privacy policies and practices prior to interacting with their websites or applications, using any of their tools, or sharing any of your personal information with them.

Analytics

We allow third parties or service providers to provide analytics services. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Site, Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by LUSCII and third parties or service providers to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.

The device you use to access and use our Services may allow you to opt out of having certain information collected, and used for behavioral advertising purposes (e.g., “Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android).

Online Tracking

For more information about interest-based ads and how to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

Visitors to the site from outside the United States

LUSCII is headquartered in the Netherlands, and we have operations and service providers in the United States and other countries. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in Germany. Therefore, your information may be transferred to, or maintained on computers, databases or servers located outside your home jurisdiction, such jurisdiction may not provide levels of data protection that are equivalent to those of your home jurisdiction. If the personal information that we collect is processed outside the United States, we will take reasonably necessary steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing, transfer and storage of your information in the Netherlands, the United States and in other countries.

Your choice and updating information

Account Information

We will make a reasonable effort to ensure that your personal information used or disclosed by us is accurate and complete. In most cases, however, we rely on you to ensure that your information is current, complete, and accurate. Some of our Services may allow you to update your account information. If so, you may do so at any time by logging into your account or by contacting us . If you wish to delete your account, please contact us, but note that we may retain certain information as required by law or for our legitimate business purposes.

If you demonstrate the inaccuracy or incompleteness of the information we maintain about you, we will assist you in updating the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Site and Services. For more information about cookies and how to disable them, see our Cookie Policy.

Communications Preferences

You may opt out of receiving text messages or promotional emails from LUSCII by following the unsubscribe or opt out instructions in those communications, such as email or text messages that you received from us.

If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

State privacy rights

Many states have enacted comprehensive data privacy legislation. Depending on the state in which you reside, you may exercise certain privacy rights by contacting us. Based on your state, you may be able to request to:

Access your personal information. You have the right to request access to your personal information that we hold. This means you can ask us to provide a copy of your personal data, along with details about how we process it. We will provide this information in a readable format, allowing you to understand how we use your data. If your state provides specific rights regarding disclosures to third parties, we will include these details in our response to your access request.
Data Portability. You may also have the right to obtain your personal data in a portable format that enables you to transfer it to another entity of your choice. We will provide your data in a structured, commonly used, and machine-readable format to make this transfer as simple as possible.
Correct your personal information. If any of the personal information we hold about you is incorrect or outdated, you have the right to request that we correct or update it. We will make the necessary changes to ensure that your data is accurate and reflects your current circumstances. In addition, if we have shared incorrect data with third parties, we will inform them of the correction if required by law.
Delete your personal information. A request to delete personal information is subject to certain exceptions, defined by law.
Review Automated Decision-Making. We do not use any automated processes to make any decision about you. If we do, you may have the right to request a review of these decisions by a human. We will provide transparency regarding any automated decision-making processes and explain how they impact you.
Withdraw Consent. Where you have previously provided consent for us to process your personal data, you have the right to withdraw that consent at any time. This withdrawal will not affect the legality of processing based on your consent prior to its withdrawal.

Residents of applicable states may opt out of certain treatment of their personal information by going to the footer of our website or the settings section of our app and selecting the “Do not sell or share my personal information” or “Cookie Setting” button to:

Opt Out of the Processing of Your Personal Information for Purposes of Targeted Advertising.
Opt Out of the Sale or Sharing of Your Personal Information.

You may also use the Global Privacy Control (GPC) to opt out of the processing of personal information for purposes of Targeted Advertising or the sale of your personal information through the use of the GPC. If you notify us of your opt-out preferences through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal, and when you log in to your account from that device, the opt-out will extend to your account, as well. Our Sites will not respond to other types of “do not track” signals.

Additional state privacy notices and disclosures:

California Privacy Notice

If we decline to take action on one of your rights, you can submit an appeal by going to our privacy request page.

We will not discriminate against you for exercising your rights. We will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Some programs or membership services require usage of personal information to function, so compliance with your request may impact those experiences.

We may disclose personal information to third parties or process your personal information for various purposes, including targeted advertising. These kinds of disclosures may be deemed selling under certain state privacy laws. You have the right to opt-out of the sale or processing of your Personal Information for targeted advertising as described in the State Privacy Rights section.

Security and Retention

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security completely. Although we do our best to protect your information, we cannot guarantee the security of your personal information transmitted through our Site and Services, including our mobile applications. Further, we are not responsible for circumvention of any privacy settings or security measure we provide. Please take steps to protect against unauthorized access to your password, phone, mobile device, or computer by, among other things, signing off after using a shared computer or device, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Data Retention

We keep your personal information and communication records for as long as your account is in existence and for so long as necessary to fulfill the purposes for which it was collected and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Children's Privacy

We do not knowingly or intentionally gather personal information about consumers under the age of 16. If you become aware that a child has provided us with personal information, a parent or guardian of that child may contact us at privacyrequests@luscii.com to have the information deleted from our records. If we learn that we have inadvertently collect personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law.

California Privacy Rights

The California Consumer Privacy Act or “CCPA”, the California Privacy Rights Act of 2020 or “CPRA" (Cal. Civ. Code § 1798.100 et seq.), and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. This section of the Privacy Statement applies to information collected online and offline through or in connection with our Site, mobile applications, or other Services.

California Consumer Privacy Act

We collect the categories of personal information set forth in the table below. For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. We disclose the following categories of personal information for business purposes to the following categories of recipients:

Category of Sensitive Personal Information	Examples	Collected	Disclosed for a business purpose within the past 12 months?	Sold or Shared with Third Parties within the past 12 months?	Categories of Recipients
Identifiers	Name, alias, address, email address, IP address, account name, unique device ID, etc	Yes	No	No	Affiliates. Vendors and service providers such as web hosting, information technology cloud service. Third parties, such as analytics providers.
Personal Information listed in California Customer Records Statute (Cal. Civ. Code §1798.80(e)) Note: Some personal information included in this category may overlap with other categories	Name, signature, physical characteristics or description, address, telephone number, state ID number, financial information, medical information, and health insurance information. etc.	Yes	Yes	No	Affiliates. Vendors and service providers such as web hosting, information technology cloud service. Third parties, such as analytics providers.
Protected classifications characteristics	Gender, age, marital status, etc.	No	No	No	N/A
Commercial information	Information about Services purchased, obtained, or considered	No	No	No	N/A
Biometric information	Medication, Blood pressure, electrocardiogram information, and weight from our mobile application	No	No	No	N/A
Internet or other similar network, browsing, or search activity	Domain information, browsing activity, session information, cookie information	Yes	No	No	Affiliates. Vendors and service providers such as web hosting, information technology cloud service. Third parties, such as analytics providers.
Geolocation information	Physical location or movements	No	No	No	N/A
Sensory information	Audio, electronic, visual, thermal, olfactory, photo or images of an individual, or similar information	No	No	No	N/A
Professional or employment-related information	Current or past job history or performance evaluations	No	No	No	N/A
Non-publicly available educational information under the Family Educational Rights and Privacy act (FERPA) and related regulations	Education records directly related to a student maintained by an educational intuition or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	No	No	No	N/A
Inferences drawn from other personal information to create consumer profiles.	Characteristics, interests, and trends	Yes	No	No	Affiliates. Vendors and service providers such as web hosting, information technology, customer service, cloud service.Third parties, such as analytics providers.

Category of Sensitive Personal Information	Examples	Collected	Disclosed for a business purpose within the past 12 months?	Sold or Shared with Third Parties within the past 12 months?	Categories of Recipients
Government Identifiers	Social security, driver's license, state identification card, or passport number	No	No	No	N/A
Complete account access credentials	User names, account numbers, or card numbers combined with required access/security code or password	Yes*	No	No	Vendors and service providers such as web hosting, information technology, and cloud service.
Precise geolocation	Physical location or movements	No	No	No	N/A
Racial or ethnic origin	-	No	No	No	N/A
Religious or philosophical beliefs	-	No	No	No	N/A
Union membership	-	No	No	No	N/A
Genetic data	-	No	No	No	N/A
Mail, email, or text message contents		Yes*	No	No	N/A
Unique identifying biometric informatio	-	No	No	No	N/A
Medical information	Health information (such as EKG readings, medication data, sleep data, health related information, sex lift, or sexual orientation information)	No	No	No	N/A

*only clinical dashboard website: https://vitals.luscii.com/nl/login

Under CCPA and CPRA, personal information does not include:

Publicly available information from government records
De-identified or aggregated consumer information
Information excluded from the CCPA’s scope, such as:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
Personal information covered by certain sector-specific privacy law, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Do Not Sell or Share My Personal Information.

For analytics, we and our business partners use tracking technologies to help us to understand our customers and visitors to the Site and Services, to enhance your online experience, and to customize our offerings in ways that may be deemed a “sale” or “sharing” of personal information under the CCPA and CPRA. This includes working with third parties such as ad networks that collect personal information via tracking technologies to personalize advertisements on and off our Site and Services and to provide us with data collection, reporting, and ad response measurement. To the extent we or our partners use such technologies on the Services, we offer a “Do Not Sell or Share My Personal Information” button (“Cookie Settings”), as discussed in the Sharing of Information and Analytics section above. If you elect to opt out of the sale and sharing of your personal information, then we will notify third parties of your request.

We do not knowingly sell personal information about consumers under the age of 16.

Data Retention

Your Rights under the CCPA and CPRA.

Subject to certain limitations, you have the right to:

request to know more about the categories and specific pieces of personal information we collect, use, disclose, and sell,
request deletion of your personal information,
request to correct inaccuracies of your personal information
opt out of any “sales” or “sharing” of your personal information that may be occurring,
limit the use and sharing of sensitive personal information
opt out of automated decision-making
request to have your personal information transmitted to another entities (“Data portability”), and
not be discriminated against for exercising these rights.

The privacy rights request is subject to our being able to reasonably verify your identity and authority to make these requests. In order to verify your identity when you submit a request, we will ask you to provide two (2) or three (3) pieces of personal information to confirm in our records. For example, if you purchased an OMRON product or Service through our Site, you will be asked to provide at least your name and details of your recent interactions with us.

How to Submit a Request Under the CCPA or CPRA. If your Personal Information is subject to the CCPA or CPRA, you may make these requests by email: privacyrequests@luscii.com or completing this Form. You may also authorize someone to exercise these rights on your behalf. In order to do so, we require signed permission. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or equivalent document that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA or CPRA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. Once we have a copy of the valid signed authorization, your designated representative/authorized agent will be able to exercise these rights with respect to the account(s) listed on such authorization for the life of the account, unless there is a specified term or expiration date on the authorization form. Any information gathered as part of the verification process will be used for verification purposes only. Responses to verifiable consumer requests will be delivered through secure email or postal mail, depending on your election when you submit such requests.

Authorized Agents. You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation reflecting that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 413. If you are an authorized agent seeking to make a request, please contact us by email: privacyrequests@luscii.com or online by completing this Form.

California Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacyrequests@luscii.com.