Effective on December 2, 2019
"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 Provide
We 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:
You can find more information about the individual cookies we use and the purposes for which we use them here:
Third Party Cookies & Purpose
"Google Analytics" (Google, Inc.)
For more information on Google Analytics cookies, visit: www.google.com/policies.
"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/.
"Engagio" (Engagio, Inc.)
For more information about Engagio cookies, please visit:
"ion" (i-on interactive, Inc.)
For more information about ion cookies, please visit: https://www2.ioninteractive.com/privacy-policy/.
How Do We Use the Information Collected?
Operation of the Website
We 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:
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). 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 do 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 EC standard contractual clauses for transfers of personal data, (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm) or certifying under the EU-US privacy shield framework (see below).
Our Participation to the EU-US Privacy Shield Framework
iRhythm Technologies, Inc. ("iRhythm US") participates in and complies with the EU-US Privacy Shield, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States.
How to make a complaint?
In compliance with the Privacy Shield Principles, iRhythm US commits to resolve complaints about our collection or use of your personal data. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at email@example.com.
iRhythm US has further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If your complaint is not satisfactorily resolved by either iRhythm US or the third-party resolution service, you may, under certain conditions, pursue binding arbitration through the Privacy Shield Panel here.
Data sharing to third parties
iRhythm US may provide personal data to third parties who perform services on our behalf. Third parties who receive such information must maintain compliance with our Privacy Shield obligations.
We are responsible and remain liable for the processing of personal data we receive, under the Privacy Shield Framework, including if we subsequently transfer to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Federal Trade Commission enforcement
iRhythm US is subject to the investigation and enforcement actions of the Federal Trade Commission. iRhythm US may be required to share your personal data, including the disclosure of EU personal data, to public authorities and law enforcement agencies in response to lawful requests, including requests to meet national security and law enforcement requirements.
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.
You have the right under certain circumstances:
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.
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.
iRhythm Technologies Ltd. and iRhythm Technologies, Inc. ("iRhythm™"), care about your confidentiality and privacy rights and comply with data protection laws to keep your information safe. Please read this patient notice carefully.
Your doctor has prescribed the Zio service for you. iRhythm provides the Zio service, which includes long-term heart monitoring and evaluation. Your doctor will, with your consent, start the Zio service by attaching an adhesive monitoring device to your chest. This device will collect your heart rhythm data. Your doctor will collect identification information such as your name, address and date of birth, and send it to iRhythm. Your heart rhythm data will be sent to iRhythm when you return the Zio patch by post.
iRhythm receives and processes your personal data in confidence to help create a report of the findings. Only iRhythm, your doctor and hospital will have access to this report for the purpose of supporting your direct care. iRhythm may also replace your direct identifying information with a reference number and study your heart rhythm data for two reasons: (i) reporting to your doctor and (ii) improvement of iRhythm services.
You have the right to object to the disclosure of your personal data. If you wish to do so, please contact the iRhythm Privacy Official through our UK office at 0-808-189-3411 or via email at firstname.lastname@example.org. Please also consult your doctor regarding his or her privacy practices.
Here we explain how iRhythm collects and uses your personal data and heart rhythm data during and after your use of the Zio service.
How will iRhythm use information it receives about you?
iRhythm will use your personal data for the purpose of providing preventive medicine services, supporting medical diagnosis and the provision of direct health care or treatment by your doctor and/or hospital.
iRhythm may also use your personal data in the following situations:
Your personal data will be used only for the purposes set out in this patient notice. If iRhythm needs to use your personal data for an unrelated purpose, we will notify you and where relevant obtain your consent.
We may share your information in the following circumstances:
We are responsible and remain liable for the processing of personal data we receive, under the Privacy Shield Framework, including if we subsequently transfer to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. By returning the Zio patch to us, you acknowledge that you have read and understood this patient notice (as contained in the Zio booklet). It is important to note that the Zio booklet contains a similar separate notice which is provided physically to you. It includes an invitation for you to sign a declaration confirming your agreement to use the Zio patch and that is then sent back by you to iRhythm for the purposes set out in this patient notice.
International Data Transfers
In accordance with European Union data protection law, iRhythm will transfer your personal data to its clinical center(s) and systems in the United States. iRhythm participates in and complies with the EU-US Privacy Shield, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States.
How long will your information be used for?
We retain personal data for the length of your use of the Zio service and as necessary to meet our contractual obligations, to identify issues or to resolve 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 rights in connection with personal data
You have the right under certain circumstances:
Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent by contacting us, your doctor or hospital. The possible consequences of this will be explained to you and could include delays in diagnosis, care or treatment that the Zio service supports.
Contacting iRhythm and resolving disputes about your information
Additionally, any inquiries or complaints regarding how we handle your personal data under Privacy Shield should be addressed to email@example.com. If we are unable to resolve your complaint, you may submit it free of charge to an independent third-party dispute resolution service based in the U.S at https://feedback-form.truste.com/watchdog/request.
If your complaint is not satisfactorily resolved by either iRhythm or the third-party resolution service, you may, under certain conditions, pursue binding arbitration through the Privacy Shield Panel at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
If your request or enquiry relates to a UK related data protection query and is not satisfactorily resolved by us, you may approach the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
iRhythm is subject to the investigation and enforcement actions of the Federal Trade Commission (FTC). iRhythm may be required to share your personal data, including the disclosure of EU personal data, to public authorities and law enforcement agencies in response to lawful requests, including requests to meet national security and law enforcement requirements.