Effective on December 1, 2020
"Personal data" means any information relating to an identified or identifiable individual as defined in the Data Protection Law.
This WPP applies to all users of the Website. This WPP does not address our data protection practices related to use of patient personal data. If you are a patient please read our Patient Notice which explains how iRhythm collects and uses your personal data and heart rhythm data during and after your use of the Zio Service. Also, please contact your health care provider for information regarding their privacy practices.
A Word About External Websites
External websites that may be referenced within this Website are not covered by this WPP; they have their own policies, and we encourage you to review those policies prior to using such external sites.
For the purposes of European Economic Area data protection law, the General Data Protection Regulation and the UK Data Protection Act 2018, (the "Data Protection Law"), the data controller for those accessing this Website from Europe is iRhythm Technologies Limited.
What Information Do We Gather About You?iRhythm collects various types of personal data that you provide us as well as information collected from automatic means when you use the Website. What we gather and how we use it is explained below.
Information You ProvideWe collect any information that you provide when you use the Website. For example, the Website may include web pages that give you the opportunity to provide us with personal data about yourself, such as your name, email address, job function, etc. You do not have to provide us with this information if you do not want to; however, that may limit your ability to use certain functions or to request certain services or information.
Information Automatically Collected From You
We may automatically collect certain technical information from your computer or mobile device when you visit the Website, such as your Internet Protocol address, your browser type, your operating system, the pages you view, and the search terms you enter.
We and our service providers may collect information using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies may enable us to personalize your experience on the Website, maintain a persistent session, and carry out marketing and other activities. The Website may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).
Most web browsers automatically accept cookies and similar technologies. If you prefer, you can disable this functionality. Please refer to your browser’s help section for further information. If you block all cookies this may limit your ability to take advantage of all the features of the Website.
We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Website and under our terms with you. They include, for example, cookies that enable you to move from one page to another within a session or to log into secure areas of the Website.
- Functionality cookies. These are used to preserve your preferences when you return to the Website. This enables us, subject to your choices and preferences, to personalise our content on the Website.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors navigate the Website. We also use analytical/performance cookies to operate, maintain and improve our services, and for advertising purposes. This helps us for our legitimate interests of improving the way the Website works.
You can find more information about the individual cookies we use and the purposes for which we use them here:
Cookies & Purpose
We use a cookie from CloudFlare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information. This cookie expires 1 month after your site visit.
For more information on the CloudFlare cookie, please visit: https://support.cloudflare.com/hc/en-us/articles/200170156-Understanding-the-Cloudflare-Cookies#12345679
For more information on Google Analytics cookies, visit: www.google.com/policies.
"FreshMarketer" (Freshworks Inc. and its affiliates)
For more information about FreshMarketer cookies, please visit: https://support.freshmarketer.com/support/solutions/articles/50000001615-freshmarketer-cookies To opt out, please visit: https://www.freshmarketer.com/optout/index.html
"Hubspot" (Hubspot, Inc.)
For more information about Hubspot cookies, please visit: https://legal.hubspot.com/privacy-policy.
"Triblio" (Triblio, Inc.)
For more information about Triblio cookies, please visit: https://triblio.com/privacy-policy/.
"Twitter" (Twitter, Inc.)
For more information about Twitter cookies, please visit:
"LinkedIn" (LinkedIn, Inc.)
For more information about LinkedIn cookies, please visit:
For more information about Facebook cookies, please visit: https://www.facebook.com/policy/cookies/
In addition, for callers, we or our service provider(s) automatically collect the caller’s phone number; the name displayed on Caller ID (if available); call recordings and transcripts of calls you place to this number; and other data that may be combined with data sources of ours, our service providers, other third parties, or publicly available information such as from government records.
How Do We Use the Information Collected?
Operation of the WebsiteWe may use and store personal data we collect about and from you in our legitimate interests, where we have considered these are not overridden by your rights:
- Administer the Website and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes
- Keep the Website safe and secure
- Respond to requests that you make
- Improve and manage the Website
- Better tailor content, offers and features
- For purposes disclosed at the time you provide your information
Marketing and Communications
Where permitted in our legitimate interest or with your prior consent where required by law, we may collect certain personal data about you to send you electronic newsletters or promotional emails that we believe may be of interest to you, consistent with your choices.
In particular, if you fill out a form on the Website to receive a piece of content, we may collect information regarding your interactions with that content (e.g., clicking on content). We may also collect personal data about you that is publicly available on the Web and that is tied to the information you provided in the form (e.g., email address, name). Further, we may use personal data (e.g. phone number) to understand how you interact with our services and the effectiveness of our marketing campaigns. In addition, we may collect statistical information regarding website visitors’ navigation on the Website at an aggregated level (e.g., IP address, location, browser type, referral source, length of visit and pages viewed).
The information gathered will be used solely for marketing in connection with iRhythm’s business and will not be shared with any other third parties. You may opt out of receiving marketing communications from us by following the unsubscribe instructions in each such message, or by contacting us as indicated below.
Patients and physicians who provided testimonials for use by iRhythm sign release forms.
Can Third Parties View Your Information?
No personal data will be divulged to third parties outside the iRhythm Group (iRhythm Technologies, Inc. and iRhythm Technologies Ltd.), except as described below.
Merger Or Sale
In the event that iRhythm is acquired by or merged with a third-party entity, we may transfer or assign the personal data that we have collected as part of such a merger, acquisition, sale, or other change of control.
Other Disclosures Required Or Authorized By Law
We may disclose personal data about you: (i) if we are required to do so by law, regulation, or legal process, such as a court order or subpoena; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to protect against or respond to physical, financial or other harm, injury, or loss to property; or (iv) in connection with an investigation of suspected or actual unlawful activity.
Service Providers And Other Third Parties
We also may share personal data with our vendors, partners, agents, and service providers who perform certain services, such as website hosting, data hosting or marketing automation, on our behalf in accordance with our instructions and the Data Protection Law ("Third Parties"). We authorize Third Parties to access, use or disclose the information only as necessary to perform their services or comply with legal requirements. iRhythm requires all Third Parties with access to personal data to agree to safeguard the privacy and security of personal data they process on our behalf.
What Measures Are Taken To Protect Your Personal Data?
iRhythm maintains appropriate administrative, technical and physical safeguards to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Data transmitted to or from the Website is secured under industry encryption standards such as SSL.
International Data Transfers
We may transfer your personal data to recipients in countries other than the country in which the personal data was originally collected. In particular we transfer personal data to the United Sates, where we are headquartered and where some of our service providers process and host your personal data. The laws in the United States may not offer the same level of data protection as the country in which the information was initially provided. When we transfer your personal data we will protect the information as described in this policy. We have also implemented specific safeguards to ensure your personal data is protected when transferred, in accordance with data transfer restrictions that apply in the European Economic Area ("EEA") including implementing the standard contractual clauses (“SCCs”) for transfers of personal data, (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
How Long We Keep Your Personal Data
We retain your personal data for the term of our contractual obligations to you or your employer, and to identify or anticipate any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Your RightsYou have the right under certain circumstances:
- To request to be provided with a copy of your personal data held by us;
- To request the rectification or erasure of your personal data held by us;
- To request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- To object to the further processing of your personal data, including the right to object to marketing (as mentioned in our 'Marketing and Communications' section; and
- To request that your provided personal data be moved to a third party.
Your right to withdraw consent
Where the processing of your personal data by us, is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at firstname.lastname@example.org. You can also change your marketing preferences at any time as described in our 'Marketing and Communications' section.
These rights may be limited in some circumstances by local law requirements.
You can also exercise the rights listed above at any time by contacting the iRhythm Privacy Officer at email@example.com.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, see: https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en. The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
iRhythm Technologies Ltd.
56 London Road
Surrey, GU19 5HL
Phone: 0808 189 3411
Fax: 0808 189 3303
iRhythm Technologies Ltd.
699 8th Street
San Francisco, CA 94103
Attn: Privacy Official
Any changes to the WPP will be posted on this Website promptly. Your continued use of the Website constitutes your agreement to this WPP.