Privacy Policy

We are Reemo Health, Inc. All references in this policy to “Reemo”, “us”, “we” and “our” refer to Reemo Health, Inc.

When you use our Services, you provide information to us. This Privacy Policy (“Privacy Policy”) explains how we collect, use, disclose, and protect information that constitutes personal data or personal information under applicable law (“personal information”) in any way, online or offline, including in relation to our Services. This Privacy Policy also explains your choices about the collection and use of your personal information. Nothing in this Privacy Policy should be construed as a concession or admission that any particular statute, law, regulation or other legal act applies to any particular data set or to your personal information.

Our “Services” include our personal wellness and monitoring software (“Software”), our website located at www.reemohealth.com and any online dashboard offered by Reemo (“Sites”), and Reemo mobile applications (the “Apps”). By using or accessing our Services, you are subject to the terms of this Privacy Policy and consent that to our processing or the data that we collect from you in accordance with this Privacy Policy.

1. Reemo’s Purpose

Through the use of wearables and smart home technology, Reemo offers wellness services, messaging capabilities, and gesture-controlled home automation. We use information we collect through your wearable devices to provide you services, identify healthy behaviors, predict your health risks, and improve our automation capabilities.

We also use this information for the public good. We use the information we collect about you and others to help improve our understanding of healthy and risky behaviors. From this information, we can build predictive models to help (i) prevent dangerous injuries, such as broken arms, legs, and hips sustained from unexpected falls, (ii) manage life threatening diseases, such as heart disease and diabetes, and (iii) improve quality of life through effective wellness activities, such as walking, household activities and socializing with friends. By using our services, not only do you work towards a healthier outcome for yourself, but you help us generate the knowledge to help reduce costly and tragic outcomes for seniors around the world.

2. What Information Do We Collect About You?

The categories of personal information we collect about you depends on how you interact with us. Depending on the Services you use, the following are the categories and specific types of personal information that we may collect, or have collected in the preceding 12 months:

  • Contact information—we will collect your name, email address, and mailing address.

  • Device information—we may collect information about devices you use to run our apps or that you use to visit the Site, such as your hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and settings of the device you use to access the Services.

  • Log information—we may track your use of the Services through activity logs that capture information such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your device.

  • Activity based information—if you use one of wearable devices, we may capture activity information such as steps, pace, heart rate, sleep patterns.

  • Protected health information—we may collect information related to your eligible health benefits and other health-related information such as diagnoses and medication use.

  • Location information—if you use one of our wearable devices, we may capture location information such as your device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.

  • Communications—if you use our Services to communicate with others or to allow others to communicate with you, those communications will be transferred through and stored on our systems.

  • Social Security Numbers—we do not collect social security numbers from our users and customers. If anyone asks you for your social security number and claims to be Reemo, please contact us using the contact information below.

  • Other information—we may collect other information about your use of the Services, such as the apps you use, the websites you visit, and how you interact with content offered through a Service.

3. How Do We Collect Information About You?

We collect your personal information in the following ways, pursuant to applicable law:

  • Directly from you—We collect information directly from you when you register to use our Services and when you use our Services.

  • Directly from your devices/computers—we collect some information directly from your devices and computers when you use our Services.

  • From health care providers, care coordinators, and insurance plans—we may receive data from our trusted business partners if you are treated by or insured by them. This information, and other information combined with it, will be designated as Protected Health Information and protected as required by HIPAA and subject to a business associate agreement between Reemo and the applicable business partner.

  • From third parties—we may acquire some of the information described above from publicly or commercially available sources.

  • We or our business partners might occasionally contact you via email or phone to request product feedback, request missing information for purposes of providing Services to you, or explain our services.

4. How Do We Use Your Information?

We may use information we collect for the following purposes:

  • To register you or your device for a Service;

  • To process or collect payment for our Services

  • Tο provide a Service or feature you request;

  • To evaluate your overall health and make healthy lifestyle recommendations;

  • For assessment and analysis of our market, customers, products, and Services (including asking you for your opinions on our products and Services and carrying out customer surveys);

  • To understand how you use our Services so that we can improve them.

We will use information classified as Protected Health Information in accordance with the use restrictions and protections required by the Health Insurance Portability and Accountability Act of 1996, as amended, and related regulations (“HIPAA”). We will not use your information in other ways without your express prior consent to do so.

5. What is the Legal Basis for Processing Your Information?

Reemo relies on the following legal grounds for the collection, processing, and use of your personal information:

  • As necessary to provide a service or perform a transaction (such as when we respond to your requests);

  • Consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies);

  • As necessary for legitimate interests (such as when we act to maintain our global business generally, including maintaining the safety and security of the Sites); and

  • Compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.

6. How Do We Share Your Information?

Except as noted below, we do not share your information with third parties without your consent. We may share your information with the following entities.

  • Business partners. We work with a limited number of trusted business partners. We may share your information, including Protected Health Information, with these trusted business partners, including healthcare providers, care coordinators and healthcare insurance companies. These business partners may use your information to provide you with services you request, make predictions about your interests and may provide you with promotional materials, and other materials.

  • Service providers. We may share your information with companies that provide services for or on behalf of us, such as companies that help us with product placement, product sales, product installation, call center and other customer support, and billing. These entities may only use your information to provide contracted services to Reemo. We do not share Protected Health Information with these service providers except in compliance with HIPAA.

  • Other parties when required by law or as necessary to protect our services. There may be instances when we share your information with other parties:

    - to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
    - to verify or enforce compliance with the policies governing our Services; and
    - to protect the rights, property, or safety of Reemo, or any of our respective affiliates, business partners, or customers.

  • Other parties in connection with corporate transactions. We may transfer your information to a third party who acquires all or part of our business as part of a merger, acquisition, or in the event of a bankruptcy.

  • Other parties with your consent or at your direction. We may also share information about you with third parties when you consent to or request such sharing.

We will share information classified as Protected Health Information in accordance with the use restrictions and protections required by HIPAA.

7. How Long Do We Keep Your Personal Information?

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

8. How Do We Use Tracking Technology?

We use Squarespace for our Site at https://reemohealth.com, which may collect information about you as part of its tracking functionality. This information is reported to us in the aggregate and your individual IP address and other identifying information is not reported. For example, we may learn what percentage of an aggregate number of users visited our Site by way of a search engine, referral link on a third-party URL, a social media link, or by directly typing in our address. We don’t use essential or non-essential cookies to track your individual use or behavior on our site or serve you ads or marketing. For further information about cookies, please see http://www.allaboutcookies.org.

9. What Privacy Choices Do You Have?

Depending on your location, you may have the following rights with regard to your personal information:

  • Access to Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you. Note that California and other state residents may be entitled to ask us for a notice describing what categories of personal information (if any) we disclose to third parties or affiliates for direct marketing. We will respond to such requests within the timeframe required by law.

  • Changes to Your Personal Information. We rely on you to update and correct your personal information. Our Services may allow you to modify or delete your account profile. If our Services do not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law, and you may not be able to change certain account information including your email address.

  • Portability. You may have the right to ask us to provide your personal information to a third party provider of services.

  • Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, have the right to request details about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. We will respond to such requests within the timeframe required by law.

  • Objection to Certain Processing. You may object to our use or disclosure of your Personal Information by contacting us at the address described below.

  • Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.

  • Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send reminders or notifications of upcoming events, free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.

  • Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us, you can remove yourself from our mailing lists by emailing us (our contact information is below) with "NO SNAIL MAIL" in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed or bulk mailings directed to ZIP codes or geographic areas.

  • Promotional Text Messages. If you receive a text message from us on your personal mobile device (whether on our own behalf or on behalf of a third party) that contains promotional information, you can opt-out of receiving future text messages by replying, “STOP.” Please note that by using a Reemo-provided wearable device, you consent to receive certain messages on such device as part of the Services and if you do not desire to receive such messages then you may stop using the device and opt out of the Services by either contacting us at the address below or your health care provider, care coordinator, your benefits provider or other applicable entity through which you have received our Services.

  • Opt Out of Sale or Sharing of Personal Information. We do not and have not in the preceding 12 months sold or shared (in this context, share means use of your personal information for cross-contextual behavioral advertising) your personal information.

  • Right of Non-Discrimination/Retaliation. We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.

  • Right to Opt Out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). We do not disclose sensitive personal information for purposes other than those which cannot be limited under applicable law.

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. Please also note that, to effectively deliver our Services to you, we require access to information about you and your physical activity. If you choose not to share this information with us, we cannot provide you the Services.

If you are located in the State of California in the United States, a person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To exercise your rights, please contact us as stated in the “How to Contact Us” section of this Privacy Policy.

10. What Do We Do to Keep Your Information Secure?

We use commercially reasonable safeguards to help keep the information collected through the Services secure from loss, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. Please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure.

11. Where Do We Store Your Data?

The Services are intended for a United States audience. If you access the Services from outside the U.S., your information will be transferred to and processed by a server located within the U.S., and subject to U.S. laws and regulations.

12. California and other State Disclosure Laws

California law indicates that organizations should disclose whether certain categories of information are collected, “sold,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). The categories of information that we collect and disclose are set out above and within this Privacy Policy.

13. Other Important Information

  • Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.

  • Changes to This Privacy Policy. We may change our Privacy Policy and practices from time to time. When we update our Privacy Policy, we will notify you by updating the “Last Updated” date at the bottom of this policy and posting the new Privacy Policy on our Site and providing any other notice required by applicable law. We recommend that you review our Privacy Policy each time you visit or use our Services to stay informed of our privacy practices. To the extent that our Privacy Policy changes in a material way, the version that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new Privacy Policy.

  • Children. Our Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We do not sell any information of children.

  • Third Party Applications/Websites. Our Services may include links to, or be accessible via, websites or applications that are owned or operated by third parties. Please note that any personal information that you provide to such third parties will be governed by their privacy policies, and we have no control over or responsibility for their privacy practices. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed prior to providing any personal information.

14. How To Contact Us

If you have any questions about this Privacy Policy or the Services, please contact us through email at privacy@reemohealth.com, by phone at 877-697-3366, or mail at the following address:

Attn: Privacy Officer
Reemo Health, Inc.
c/o Life Time Work
200 Southdale Center
Edina, MN 55435

Last Updated: October 31, 2023