Tela Application Privacy Policy

Effective Date: July 17, 2018

THIS PRIVACY POLICY APPLIES TO PERSONAL INFORMATION COLLECTED BY TELA FROM USERS OF THE TELA APPLICATION (THE “APPLICATION”). “PERSONAL INFORMATION” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION TO IDENTIFY OR CONTACT A SINGLE PERSON OR TO IDENTIFY AN INDIVIDUAL IN CONTEXT. IF WE CAN LINK PARTICULAR INFORMATION (DIRECTLY OR INDIRECTLY) TO AN INDIVIDUAL, WE WILL CONSIDER THIS INFORMATION “PERSONAL INFORMATION,” AND WE WILL PROTECT IT.

WE AT TELA VALUE KEEPING YOUR PERSONAL INFORMATION CONFIDENTIAL AND USING IT SOLELY IN THE CONTEXT OF OUR MISSION TO EMPOWER INDIVIDUALS TO ACHIEVE THEIR HIGHEST POTENTIAL BY OFFERING YOU A CONVENIENT AND HIGH QUALITY APPLICATION THAT WILL ALLOW YOU AND YOUR PROVIDERS TO BETTER TRACK SYMPTOMS, MEDICATIONS, AND TREATMENT EXPERIENCE.

WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL INFORMATION IS IMPORTANT. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION.

Please read the following carefully to understand our views and practices regarding your Personal Information and how we treat it. For the purposes of Applicable Data Protection Laws, including the European Economic Area data protection law (the “Data Protection Law”) the data controller is Tela Inc., 1875 Connecticut Ave NW, 10th Floor, Washington, DC 20009.

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THIS APPLICATION, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT INSTALL THIS APPLICATION AND DO NOT SUBMIT ANY INFORMATION TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS IN THE APPLICATION. WE WILL ALSO CREATE AN UPDATE IN THE APP STORE. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY.

CAPITALIZED TERMS, IF NOT DEFINED IN THIS PRIVACY POLICY, ARE DEFINED IN THE END USER LICENSE AGREEMENT, WHICH IS ACCESSIBLE THROUGH THE APPLICATION AND IN THE APP STORE.

In case you have any questions or concerns after reading this privacy statement, please do not hesitate to contact us at privacy@tela.app. We appreciate your feedback.

WHAT INFORMATION DO WE COLLECT AND WHY?

Personal Information

When downloading and installing the Application, you may be asked to provide Personal Information about yourself. The Personal Information we collect from you includes demographic information, such as your name, birth year, gender, and e-mail address. You will also be asked to create a username and password and to provide a response to a security question for password reset. From within the Application, you will also be asked to provide information about your cancer diagnosis and stage, treatment, medications, and symptoms. Demographic, diagnosis, and treatment information is optional; however providing such information will allow Tela to better tailor the application experience to you.

Primarily, the collection of your Personal Information assists us in creating your User Account and providing a platform whereby you can track your treatments and symptoms in order to better enable you to communicate information with your healthcare providers and be an active participant with those providers in monitoring your care, tailoring interventions, and assessing treatment outcomes. The other primary purpose of collecting this information is to allow Tela to aggregate data that providers and research institutions can use to better understand the symptoms associated with certain treatments. We may also use your Personal Information to (1) communicate with you about and manage your User Account; (2) store data; (3) comply with the law; (4) respond to requests from public and government authorities; (5) to enforce our terms and conditions; (6) manage our operations and provide additional functionality; (7) protect our rights, privacy, safety or property, and/or that of you or others; and (8) allow us to pursue available remedies or limit the damages that we may sustain.

Failure to Provide Data

Providing your Personal Information is not statutorily or contractually mandated. If you choose not to provide this information, we cannot create a User Account, and you will be unable to use our Services.

Support Information

If you contact Tela for support or to lodge a complaint, Tela may collect technical or other information from you. Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Application and related services in accordance with this Privacy Policy. Calls with Tela may be recorded or monitored for training, quality assurance, customer service, and reference purposes.

Monitoring

Tela and its affiliates and agents are permitted, but not obligated, to review and/or retain information and/or communications stored and/or transmitted using the Application (“User Content”). Tela may monitor User Content for data collection purposes and/or to evaluate the quality of service you receive, your compliance with the Terms of Use, the security of the Application, or for other reasons.

You agree that such monitoring activities, if in compliance with applicable privacy laws, will not entitle you to any cause of action or other right with respect to the manner in which Tela or its affiliates or agents monitor your Communications and enforces or fails to enforce the Terms of this Agreement. In no event will Tela or any of its affiliates or agents be liable for any costs, damages, expenses, or any other liabilities incurred by you as a result of monitoring activities by Tela or its affiliates or agents.

Device and ISP Data

We use common information-gathering tools, such as log files, cookies and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our websites or interact with emails we have sent you. As is true of most websites, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Company’s security features.

WHERE IS MY PERSONAL INFORMATION STORED AND/OR PROCESSED?

Information Tela collects through our Application will be stored on secure U.S-based servers. The Application is “native” to your device, meaning information you enter into our Application is also stored directly on the device you use to access and enter information into the Application.

WILL YOU SHARE MY PERSONAL INFORMATION WITH ANYONE ELSE?

Yes, with third parties that help us power our Application

Tela has a limited number of service providers and other third parties (“Business Partners”) that help us run various aspects of our business. These Business Partners are contractually bound to protect your Personal Information and to use it only for the limited purpose(s) for which it is shared. Such third-party uses may include, but are not limited to, the provision of services such as data hosting and billing management.

Yes, with third parties and the government when legal or enforcement issues arise

We may share your Personal Information, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts in violation of this Agreement; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of Treatment Tracker or any third party, including other customers.

If we share your Personal Information with a third party other than as provided above, you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer.

Tela is provided to you free of charge; however, participating healthcare providers pay a fee for their use of Tela, including access to your Personal Information and other information entered and stored in the Application. Similarly, entities/institutions conducting research studies, as described above, may also pay a fee to use the Application, which may include access to your Personal Information and other information entered and stored in the Application.

In addition, we may, from time to time, rent or sell aggregated data and/or other information that does not contain any personal identifiers (i.e., if the information has been anonymized by stripping out identifiers such as name, address, phone number, etc.). The purpose of this type of disclosure is to provide healthcare professionals, research institutions, and other interested parties (e.g., pharmaceutical and/or device manufacturers) real-world information about the type, severity, and frequency of symptoms associated with specific treatments, beyond what is collected in pre-market clinical trials.

HOW LONG WILL YOU RETAIN THE INFORMATION?

Personal Information, Generally

We store your Personal Information for as long as you maintain a Tela User Account and up to five (5) years after the account is closed. At the end of this five-year retention period, we will remove your Personal Information from our databases and will request that our Business Partners remove your Personal Information from their databases. However, once we disclose your Personal Information to third parties, we may not be able to access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. Written requests for deletion of Personal Information other than as described should be directed to privacy@tela.app. We retain anonymized data indefinitely.

HOW DO YOU PROTECT MY PERSONAL INFORMATION?

Tela is committed to protecting the security and confidentiality of your Personal Information. Treatment Tracker uses a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Information, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot ensure the security of information you transmit to us. By using the Application, you are assuming this risk.

Safeguards

The information collected by Tela and stored on secure servers, is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, encryption, backups, and access controls. If Tela learns of a security concern, we may attempt to notify you and provide information on protective steps, if available, through the e-mail address that you have provided to us or by an in-app notification. Depending on where you live, you may have a legal right to receive such notices in writing.

You are solely responsible for protecting information entered or generated via the Application that is stored on your device and/or removable device storage. Tela has no access to or control over your device’s security settings, and it is up to you to implement any device-level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability, etc.). We recommend that you take any and all appropriate steps to secure any device that you use to access our Application.

NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR INFORMATION WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY INFORMATION YOU TRANSMIT TO US AND YOU TRANSMIT SUCH INFORMATION AT YOUR OWN RISK.

HOW DO I PROTECT MY PERSONAL INFORMATION?

In addition to securing your device, as discussed above, we will NEVER send you an e-mail requesting confidential information such as account numbers, usernames, passwords, or social security numbers, and you should NEVER respond to any e-mail requesting such information. If you receive such an e-mail purportedly from Treatment Tracker, DO NOT RESPOND to the e-mail and DO NOT click on any links and/or open any attachments in the e-mail, and notify Tela support at security@tela.app.

You are responsible for taking reasonable precautions to protect your user ID, password, and other User Account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You should immediately notify Tela at security@tela.app if you know of or suspect any unauthorized use or disclosure of your user ID, password, and/or other User Account information, or any other security concern.

EU DATA SUBJECT RIGHTS

If you are an EU data subject, you have the right under certain circumstances:

  1. to receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;
  2. to be provided with a copy of your personal data held by us;
  3. to request the rectification or erasure of your personal data held by us without undue delay;
  4. to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  5. to object to the further processing of your personal data, including the right to object to marketing;
  6. to request that your Personal Information be moved to a third party;
  7. to receive your Personal Information in a structured, commonly used and machine-readable format;
  8. to lodge a complaint with a supervisory authority.

Where processing of your Personal Information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at privacy@tela.app. You can also exercise the rights listed above at any time by contacting us at privacy@tela.app.

HOW CAN I UPDATE, CORRECT OR DELETE MY PERSONAL INFORMATION?

You can change your e-mail address and other contact information by editing your profile in the Application. If you need to make changes or corrections to other information, you may e-mail help@tela.app. If you remove data from your account, it will no longer appear to you in the Application. Backups of that data will remain associated with your account and in our archive servers. You can deactivate your account by writing to help@tela.app.

CAN I “OPT-OUT” OF RECEIVING COMMUNICATIONS FROM COMPANY?

We pledge not to market third party services to you. We only send e-mails to you regarding your Tela account and services. You can choose to filter these e-mails using your e-mail client settings, but we do not provide an option for you to opt out of these e-mails. We consider these e-mails very important to maintaining your account.

INFORMATION SUBMISSION BY MINORS

We do not knowingly collect personal information from individuals under the age of 18 and the Application is not directed to individuals under the age of 13. We request that these individuals not provide personal information through the Application. If you are aware of a user under the age of 13 using the Application, please contact us at help@tela.app.

CONTACT US

If you have any questions or comments about this Privacy Policy or the practices of our Application, please feel free to e-mail us at privacy@tela.app.

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