OMRON ASTHMA DIARY PRIVACY STATEMENT

Version 0.2 – February 2021

Scope

This OMRON Asthma Diary Privacy Statement (“Policy”) together with the OMRON Asthma Diary End User License Agreement (“EULA”) applies to your use of:

  • Mobile application software ‘OMRON Asthma Diary and any updates or supplements to it (“App”), once you have downloaded a copy of OMRON Asthma Diary onto your smartphone or other handheld device (“Device”); and
  • Register/Sign-in to OMRON connect cloud service (“Service”).

This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable European data protection legislation, the data controller is Omron Healthcare Co., Ltd (“Omron”) based in Japan. Omron Healthcare Europe B.V. is Omron’s representative in the EU and shall serve as point of contact for EU data subjects and Data Protection Authorities.

Information we may collect from you

All personal data we collect from you will be encrypted with up-to-date encryption techniques to assure that your personal data cannot easily be accessed and/or read by unauthorized third parties. When you use the App and Service(s), we collect and process details of your use of the App through traffic data, application usage data, communication data (including, but not limited to traffic data, application usage data and other communication data (“Log Information”)) and information that you give us about yourself if you contact us for support.

This information may include:

  • name, e-mail address, username and encrypted password (“Contact Information”);
  • the Category, model and Serial Number of the connected Omron Health device, number of registered Omron Health devices, information regarding your mobile operating system, including Mobile Device Model storage capacity and available storage information of the Device, application error log and your region (“Technical Information”);
  • measurement information, entered manually or transferred from your Omron devices, stored and managed in the App, Wheeze Detection, Measurement date, rescue inhaler usage, Existence of Symptoms (Cough, Shortness of breath, Activity limitation, Night time waking), (“Measurement Information”);
  • Medication information, is entered manually and, stored and managed in the App, including, medication reminder time, medication name, type of medication, and medication amount (“Medication Information”);
  • country (“Location information”).

This app requests permission to access your phone’s Location to enable Bluetooth communication with OMRON devices. We don’t collect or use the Location data.

By selecting “Allow all the time” in the Location permission setting, OMRON Asthma Diary can transfer data from OMRON devices in your phone’s background even when the app is closed.

How we use your information

We use information held about you in the following ways:

For the performance of our agreement with you:

  • Contact Information: to handle your enquiries;
  • User Profile Information: to operate the Service;
  • Technical Information: to handle your enquiries;
  • Measurement Information: to operate the Service, to handle your enquiries;
  • Location Information: to operate the Service, to handle your enquiries;
  • General Trackers Information: to operate the Service, to handle your enquiries; and
  • Log Information: to handle your enquiries.

For our legitimate commercial interests

  • Contact Information: to ask you to fill in questionnaires, to develop or improve our products and services;
  • Log Information: to develop and improve our products and services; and

Following your explicit consent:

  • Measurement information: to operate the Service; to develop or improve our products and services and to analyse anonymized, aggregated data to understand usage trends and health data trends;
  • Marketing information: to inform you of products and/or services we offer.
  • Cookies and similar tracking technologies: to analyse user engagement to develop and improve our products and services. For more information, please read Omron Cookie Policy.

How to manage and cancel your account

You may request to cancel your account by using the ‘cancel account’ function within the App, by contacting the support service by using the ‘contact us’ function within the App or by sending an email with such request to technical.support@eu.omron.com.

Upon receipt of your cancellation request, we will process your request within 14 calendar days. We will confirm cancellation of your account within 31 calendar days of your request. When your account is cancelled, your User Profile Information and Contact Information is deleted. As a result, your Measurement Information and General Trackers Information is anonymized and cannot be linked back to you.

Disclosure of your information

We may disclose the data we collect from you to the following third parties:

Category of data Recipient Purpose

Log information

Cookies

Google Firebase

Google Cloud Platform

Google Data Studio

Application usage analytics

Contact Information

User Profile Information

Measurement Information

Patient Information

Technical Information

Medication Information

Location information

Amazon Web Services

Data storage

Technical Information

Contact Information

Patient Information

Measurement Information

Medication Information

Location information

Omron Healthcare Europe B.V.

Omron Software Co. Ltd.

Omron Healthcare Inc.

CTDI GmbH

Customer support

 

We may disclose your personal information to (other) third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the seller or buyer of such business or assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
    • enforce, apply or investigate potential breaches of the OMRON Asthma Diary Privacy Policy and/or EULA; or
    • protect the rights, property or safety of OMRON, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

Note: User Content, including any image, is stored locally on your mobile device and not accessible to Omron Cloud.

Transfer of your information outside the EEA

The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (“EEA”). Your personal data may also be transferred to, and used in countries outside the EEA for the purposes described in this Policy. Such countries may not have the same level of protection for your information as the country in which you reside. OMRON guarantees that all such data transfers are in accordance with applicable privacy legislation. OMRON will enter into ‘Model Clauses’ with entities in such countries. Model Clauses are standardized contractual clauses used in agreements between data controllers (such as OMRON) and their data processors to ensure that any personal data leaving the EEA will be transferred in compliance with EU data protection law and meet the mandatory requirements.

Security measures

We have implemented technical and organizational measures to protect your information against unauthorized access, use and disclosure. All information you provide to us is stored on secure servers. Any data transfer will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access the Service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone including support staff.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Service; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Retention of your information

We will retain your information unless you request us to cancel your account or until we cancelled your account due to inactivity. We will consider your account ‘inactive’ if you don’t use the Service during a one-year period. Before your account becomes inactive, we will notify you by email requesting you to use the Service to prevent your account becoming inactive. We will cancel your account within 31 calendar days of it becoming inactive at which time your User Profile Information will be deleted. As a result, your Measurement Information and General Trackers Information is anonymized and cannot be linked back to you.

Your rights

Based on European data protection legislation you have several rights with regards to our processing of your personal data, including:

  • Right of access. You may ask us for confirmation as to whether we process your personal data. If so, we will grant you access to that personal data and provide you with a copy of the data upon request.
  • Right of rectification. If you discover errors in the personal data that is being processed by us, you have the right of rectification. Likewise, you have the right to complete the data if incomplete.
  • Right to erasure. You may ask us for erasure of your personal data. Please refer to the process described in section ‘How to cancel your account’.
  • Right to restrict. If you want to restrict processing, you cannot continue to use the Service. Please refer to the process described in section ‘How to cancel your account’. You may decide to continue to use the App without using the Service.
  • Right to withdraw consent. If you want to withdraw your consent to our processing of your personal data, you cannot continue to use the Service. Please refer to the process described in section ‘How to cancel your account’. You may decide to continue to use the App without using the Service.
  • Right to data portability. You can export your personal data by using the ‘export’ function in the App to get a copy of your personal data in a structured, commonly used and machine-readable format.
  • Right to lodge a complaint. In case you may have a question or complaint about how we process your personal data, you may contact us as described in the ‘Contact’ section. Alternatively, you may consider lodging a complaint with a supervisory data protection authority.

Parental consent

Omron does not knowingly collect personal information from any person under the age of 13. A parent or guardian, however, may use the App to establish a personal health record for such purposes. If we learn we have collected or received personal information from a child under 13 without parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 without parental consent, please contact us at technical.support@eu.omron.com. The parent or guardian is solely responsible for providing necessary supervision of the use of Omron Asthma Diary. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through Omron Asthma App on behalf of the individuals they are responsible for.

Partners

The App may contain links to and from our partners and affiliates. If you follow any of these links, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected by them. Please check their policies before you submit any personal data to them.

Changes to privacy statement

Any changes we may make to our privacy statement in the future will be notified to you when you next start the App. We will ask you to read and accept any such changes to the privacy statement. If you choose to not accept these changes, you cannot continue to use the App.

Contact

If you have any concerns, questions, comments or requests about this document or the App, you can contact us through our representative in the EU via email to technical.support@eu.omron.com, the ‘contact us’ function within the App, or by regular mail to:

Omron Healthcare Europe B.V., Marketing and Communication Department
Scorpius 33
2132LR Hoofddorp
The Netherlands

Omron Healthcare Co., Ltd.
53 Kunotsubo, Terado-cho, Muko, Kyoto
Japan