Welcome to Compliance Meds Technologies, LLC.

Privacy Policy

Last updated: Feb. 2020

Compliance Meds Technologies, LLC (“CMT”) designs products and tools that track medication adherence habits to empower better health outcomes. This Privacy Policy applies to our adherence tracking and monitoring services and our electronic medication adherence products (“Devices”), our websites located at www.cmtCares.com and www.clevercap.org (individually a “Site” and collectively “Sites”), the CMT Medication Management Platform (“Software”), and the CleverCap Mobile Apps (the “Apps”). The Devices, Sites, Software and Apps are collectively referred to in this Policy as the “CMT Service.” By proceeding to use the CMT Service you consent that we may process the data that we collect from you in accordance with this Privacy Policy.

This policy may change over time, but any future changes will not affect data that was collected under a previous version of this policy. If any modifications substantially change your rights, we will send an email summarizing the changes to the address associated with your CMT account and provide notice on the Site.

When We Collect Data

When activating a CMT Device, you may be asked to download the CMT App or install Software and enter information about yourself.

If you want to access data collected by your Device, you must create a CMT account. When you create a CMT account, we ask for some personal information, including your email address and date of birth. Your email address will be your CMT account user name, which you will use to log-into your account. We do not display your email address to other users.

CMT collects industry standard data from everyone who visits our Sites—even if you don’t have a CMT account. This includes log data that automatically records information about your visit, such as your browser type, operating system, the URL of the page that referred you, the different actions you performed, and the IP address you used to access pages on the Site. We use this type of information to provide you with an experience that’s relevant to your location based on the IP address, to prevent Site misuse, and to ensure the Site is working properly. We also collect data from cookies. To see the full list cookies, we use and how we use them, please see Cookie Policy below.

When you sync your Device through an App or the Software, data recorded on your Device about your medication adherence habits is transferred from your Device to our servers. This data is stored and used to provide the CMT Service and is associated with your account. Each time a sync occurs, we log data about the transmission. Some examples of the log data are the sync time and date, device battery level, and the IP address used when syncing.

Whenever you contact CMT for help, we collect your name and email address along with additional information you provide in your request so that we can provide you with assistance and improve the CMT Service. If you contact us when you are already logged in to your account, the web form automatically pre-fills this information, so you don’t have to type it manually. You can also contact CMT on public forums such as Twitter or Facebook; however, we cannot maintain the privacy of your communication to us if you contact us through these channels.

To help you stay motivated on your adherence habits, CMT lets you add friends or caregivers to receive alerts. When you share your friends or caregiver’s contact information with us we will only use it for this purpose.

The CMT Service includes features that collect of location information including: GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We store this information in your CMT account.

Why We Collect Data

CMT uses your data to provide you with the best experience possible, to help you make the most of your service and improve adherence habits, and to improve and protect the CMT Service. Here are some examples:

• Contact information is used to send you alerts and to inform you about new features or products we think you would be interested in.

• Data and logs are used in research to understand and improve the CMT Device and CMT Service; to troubleshoot the CMT Service; to detect and protect against error, fraud or other criminal activity; and to enforce the CMT Terms of Service.

• De-identified data that does not identify you may be used to inform the health community about trends; for marketing and promotional use; or for sale to interested audiences. See “Sharing of De-identified Data That Does Not Identify You” to learn more.

Personal Identifiable Information (PII) is data that includes a personal identifier like your name, email or address, or data that could reasonably be linked back to you. We will only share this data under the following circumstances:

• If we believe that disclosure is reasonably necessary to comply with a law, regulation, valid legal process (e.g., subpoenas or warrants served on us), or governmental or regulatory request, to enforce or apply the Terms of Service or Terms of Sale, to protect the security or integrity of the CMT Service, and/or to protect the rights, property, or safety of CMT, its employees, users, or others. If we are going to release your data, we will do our best to provide you with notice in advance by email, unless we are prohibited by law from doing so.

• We may disclose or transfer your PII in connection with the sale, merger, bankruptcy, sale of assets or reorganization of our company. We will notify you if a different company will receive your PII and the promises in this Privacy Policy will apply to your data as transferred to the new entity.

• Some of your PII will include, without limitation, your individually identifiable device readings.

CMT may share or sell aggregated, de-identified data that does not identify you, with partners and the public in a variety of ways, such as by providing research or reports about adherence trends. When provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from re-identifying it back to you.

You can direct us to share data with other parties. For example, you might authorize us to link your CMT account with a third-party app; or direct us to share data with a health care provider with which CMT has an active Master Services Agreement as part of a medication adherence and monitoring program.

CMT may also ask you to participate in surveys (processed by CMT or third parties) that help us understand your use of the CMT Service. Any PII you provide to CMT (or supplied by you or CMT to such third-party survey providers) will only be used in relation to that survey and as stated in this policy.

How Long We Save Your Data

We store your PII for as long as you maintain a CMT account.

How to Deactivate Your CMT Account

You can deactivate your CMT account by contacting Customer Support. When you do, data that can identify you will be removed from the CMT Service, including but not limited to your email and name. CMT may continue to use your de-identified data after you deactivate your account.

CMT’s Policies for Children

CMT is not directed at persons under the age of 13. We do not knowingly collect any PII from children under 13. If you are aware of a user under the age of 13 using CMT, please contact us at support@cmtcares.com.

How Does CMT Keep My Data Safe?

CMT uses a combination of technical and administrative security controls to maintain the security of your data. If you have a security-related concern, please contact Customer Support at support@cmtcares.com

Cookie Policy

We use cookies and other technologies like pixel tags and web beacons to improve the functionality of the CMT Service.

Cookies are text files that are sent by servers to web browsers and stored on your computer. They tell us which parts of the CMT
Service you’ve visited so we can figure out which promotions you may like to see or to alert you to software compatibility issues.

Web beacons and pixel tags are images embedded in a webpage or email for the purpose of measuring and analyzing usage and activity. CMT, or third party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality.

We use the following third-party advertising cookies to present you with opportunities to purchase CMT products on our Site; and retargeting cookies, to present you with CMT advertising on other websites based on your interaction on our Sites and other websites:

• DoubleClick and DoubleClick Floodlight: This cookie and web beacon is owned by Google. You can adjust Google’s use of cookies with Google’s Ads Settings. You may permanently opt-out of the Google DoubleClick cookie.

• Google AdWords Conversion: You can adjust the Google Ads Settings and opt-out of this program.

• Twitter Advertising: This cookie allows us to present you with retargeting advertising for CMT products on Twitter. This Twitter FAQ explains how their advertising program works and gives you the option to adjust your Twitter settings.

• Facebook Custom Audiences: You can adjust your Facebook advertising settings from within your Facebook account and opt-out of advertisements from within the Facebook application.

For Data Subjects in the EU (GDPR):

We appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to
make use of your GDPR data privacy rights, please visit:

Contact GDPR-Rep.eu
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Compliance Meds Technologies, LLC
Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence:
GDPR-REP ID: 11901473

Information according to Art 27 EU GDPR
Compliance Meds Technologies, LLC is a company located outside of the European Union. In order to comply with Art 27 EU GDPR, GDPR-Rep.eu has been nominated as
our representative in the European Union.

If you want to make use of your data privacy rights, please visit:

GDPR-Rep.eu certificate of Art 27 representation

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