AdhereTech Privacy Policy

Information You Provide to Us

Your Interaction with Us:

We collect personal information when you interact with us. The specific types of information we collect will depend on the forum in which you interact with us. For example, if you send us an email, we will collect your email address and the content of your email.

If you inquire about our Services through our Site, we may collect your contact information and information about your organization.

Aidia System and Related Services.

We collect personal information through our Aidia Smart BottleSystem and related services (collectively, the “Aidia System”). This information includes:

• Your contact details such as your name, address, email address, and phone number
• Date of birth
• Information about your guardian or caregiver, including your guardian’s or caregiver’s phone number (to receive dose reminders)
• Medical condition(s) you are being treated for
• Your medication and medication dosing regimen
• Other prescription information
• Your preferences related to the Aidia System

We collect this information from you directly, through your pharmacy, or from your caretaker/guardian. Please only provide information to us that you have permission to give. For example, if you provide personal information about another person to us, you must have that person’s consent to provide it to us.

Information We Automatically Collect

General.

We may use a variety of technologies that automatically (or passively) collect certain non-personally identifiable information whenever you visit the Site or use certain parts of our Services (“Non-Personally Identifiable Information”). Non-Personally Identifiable Information may include the browser that you are using, the URL that referred you to our Site, and how and when you use the Services. We may use Non-Personally Identifiable Information for various reasons, such as providing and enhancing the Services for you and other users. In addition, we may collect your IP (internet protocol) address or other unique identifiers that identify the device from which you access the Site or Services. Your IP address is a number that is automatically assigned to your device and which our computers use to identify your device. This information does not identify you, but if we were to associate any Non-Personally Identifiable Information or information that identifies your device with your personal information, we will treat it as personal information.

Cookies.

A cookie is a data file placed on a computer or other device when it is used to access our Site or Services. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. Cookies can be disabled or controlled by setting a preference within your web browser or on your device. If you choose to disable cookies on your device, some features of our Services may not function properly or may not be able to customize the delivery of information to you. You should be aware that we cannot control the use of cookies (or the resulting information) by third-parties, and use of third party cookies is not covered by our Policy.

At the present time our Services do not respond to “Do Not Track” signals or similar mechanisms.

Analytics.

We use third party analytics partners to collect certain Non-Personally Identifiable Information about how our Services are used. We and our analytics providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Services through your computer or mobile device. By using the Services, you consent to the processing of data about you by our analytics partners in the manner and for the purposes set out this Policy. Currently, our analytics partners include, without limitation, Google Analytics. In order to make sure you understand how our analytics partners handle your non-personally identifiable information and how they interact with our Services, you should visit the pages linked below for more information, as AdhereTech has no ability to control or monitor our analytics partners’ data collection or data use practices with respect to such information. Google Analytics uses cookies to help us understand how visitors use our Service and to compile reports on website activity. For more information regarding Google Analytics please visit https://www.google.com/analytics/terms/us.html. For information on how to opt-out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/.

Location Information.

We may collect approximate (but not specific) location information through your use of the Aidia System. We do not use this information for commercial purposes in any way.

Web Beacons.

Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Services. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence. Web beacons or similar technologies help us better manage content on our Services by informing us what content is effective, count users of the Services, monitor how users navigate the Services, count how many e-mails we sent that were actually opened or to count how many particular articles or links were actually viewed. We do not tie the information gathered by web beacons to our customers’ personal information.

Embedded Scripts.

An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. We may use embedded scripts in providing the Services. If we do, the code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

Aidia System

We automatically collect information about your usage of the Aidia Smart Bottle System, such as your activity (for example, when the Aidia Smart Bottle was opened), information about your dose adherence (for example, when you forget a dose or take it late), and reminder preferences.

In general, we collect personal information so that we can provide our Services, operate our business, and provide information that you request from us. Specifically we collect and use personal information for the following purposes:

• Create and administer your account.
• Provide, operate, improve, maintain, and protect our Services.
• Provide you with technical and other support.
• Send you services and company updates, marketing communication, and other information about AdhereTech and our Services, and products and services of third parties that we think you may be interested in.
• Conduct research and analysis, and monitor and analyze trends and usage.
• Enhance or improve user experience, our business, and our services, including the safety and security thereof.
• Personalize our Services to you.
• Communicate with you and respond to inquiries.
• Operate our business and perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our services.
• As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
• Enforce contracts and applicable Terms of Service, including investigation of potential violations thereof.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of AdhereTech, our Services users, or the public as required or permitted by law.

The Aidia System.

If you use our Aidia System, in addition to the uses described above, we may use your personal information, to provide individualized or specialized Services to you (for example, we may alert a care partner if you have a streak of missed doses captured by the Aidia System), communicate with your pharmacy, and manage your account.

General.

We do not sell, share, rent or trade the information we have collected about you, including Personally Identifiable Information, other than as disclosed within this Privacy Policy. We do not use your Personally Identifiable Information for direct marketing purposes or share your Personally Identifiable Information with third parties for those third parties’ direct marketing purposes. We may share Non-Personally Identifiable Information, such as aggregated user statistics and log data, with third parties for industry analysis or for other business purposes.

The Aidia System

In addition to the other applicable sharing identified in this section, if you use the Aidia System, we share personal information with your pharmacy and/or healthcare service organization about your use of the Aidia Smart Bottle such as, for example, if you have a streak of missed doses captures by the Aidia System, or if you pause or discontinue taking a certain medication. We may also share such information with your designated health care provider, as well as for clinical and academic research purposes.

Service Providers

We use third parties to assist us with operating our business and providing our Services, such as our technology vendors that help us maintain our services and partners that assist us with our marketing and communication. In some cases, these service providers will have access to your personal information in order to provide services to us. We will enter into special contracts with such vendors strictly limiting the service providers’ ability to use and disclose personal information and requiring the use of certain security measures by the service providers.

Administrative and Legal Reasons.

We may share personal information with third party companies, organizations, governmental authorities, or individuals outside of AdhereTech if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or governmental request;
• Enforce a contract, including but not limited to any applicable Terms of Service, including investigation of potential violations thereof;
• Detect, prevent, or otherwise address fraud, security or technical issues; or
• Protect against harm to the rights, property or safety of AdhereTech, our Services users, or the public as required or permitted by law.

Business Transfer.

We may, to the extent permitted by law, share personal information with our parent, subsidiaries and affiliates for internal, business related, marketing, and other lawful purposes. We also reserve the right to disclose and transfer personal information: (i) to a subsequent owner, co-owner or operator of the Services or our business; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process, all to the extent permitted by law. In such a case, unless otherwise directed by applicable law, your information would remain subject to the terms of the applicable Policy in effect at the time of such transfer.

As Directed By You and With Your Consent.

Except as otherwise provided in this Policy, we share personal information with companies, organizations or individuals outside of AdhereTech only at your direction or when we have your consent to do so.

Aggregate Information.

We may de-identify or aggregate personal information so that you are not identified as an individual, and use and provide that information to third parties without restriction. We may also provide aggregate usage information to third parties (or allow third parties to collect that information from you), who may use such information to understand how often and in what ways people use our Services. However, we never disclose aggregate usage or de-identified information to a third party (or allow a third party to collect such information) in a manner that would identify you as an individual person.

The Aidia System.

If you use our Aidia System, you may contact us at support@adheretech.com to request that we correct, delete, or rectify your personal information that is stored on our systems. Changes will be made as soon as practicable. You may also contact your pharmacy or health care provider to request changes to your personal information. We will make changes to such information on our systems if notified by pharmacy or health care provider to do so.

Retention of Information.

We retain personal information in accordance with applicable laws. The length of time we keep personal information depends on the type of information and whether we have an on-going business or legal need to retain it (for example, if you have an account with us, or to comply with applicable legal, tax or accounting requirements).

Choices.

You may contact us at support@adheretech.com to request that we correct, delete, or rectify your personal information that is stored on our systems. Changes will be made as soon as practicable. Please note that in some cases, we may not be able to fulfill your request, or may be prohibited from correcting, deleting, or rectifying some or all of your personal information. We will let you know in such instances.

If you opt-in, we may send you promotional and other SMS text messages or pre-recorded voice messages. You have the right to opt out of these messages at any time by texting STOP or a similar message in response to a message from AdhereTech or the Aidia System. You may also otherwise contact us to opt out of these messages. No further texts will be sent unless and until you re-enroll. Text HELP for help.

Additionally, you can always choose to stop receiving newsletters or other communications from us by clicking the “unsubscribe” link at the bottom of any AdhereTech marketing message.