©2019 by Enabyl Inc

ENABYL BALANCE
PRIVACY POLICY

Effective: June 22, 2018

We build our products with patient privacy in mind. Please read our privacy policy for details on how we collect, store, and use information.

 

This privacy policy governs your use of the software application Enabyl Balance (“Application”) for mobile devices that was created by Enabyl Inc. The Application is a mobile application for prediction and tracking of freezing of gait (FoG) events in Parkinson’s disease patients. 


What information does the Application obtain and how is it used?


User-Provided Information


The Application obtains the information you provide when you download and create login credentials in the Application. Login credentials are required in order to use the basic features of the Application. 


When you create login credentials and use the Application, you generally provide (a) a user name and (b) a password; any other information that may be requested is optional and only intended for use in password recovery or multi-factor authentication (MFA) where appropriate. Login credentials are never transmitted with, stored with, or otherwise used to identify data collected by the device and are never accessed or shared by Enabyl Inc. for any purpose other than user authentication.


Real-Time Sensor Data


When you visit the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine where FoG events occur and display a location map displaying event locations when requested. We will not share your current or stored location data with other users or third-parties, nor is the data used by Enabyl Inc. for any purpose other than the reporting described. The Application also collects sensor data from the device’s accelerometer in order to detect FoG events. The data is processed in real-time on the device; metadata associated with each event is stored on a secure server (as described below) in order to improve application performance, but is not transmitted or otherwise accessed for any other purpose.


If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your mobile phone settings. Location data is not collected without consent of the user, obtained when first launching the application.


Where and how does the Application store information?


The Application stores metadata from the most recent detected FoG event on the device before it is transmitted to a remote server managed by Amazon Web Services (AWS) designed to protect personal health information (PHI) in accordance with Health Information Portability and Accountability Act (HIPAA) regulations. Data stored on the device and on the remote server is encrypted. Additionally, data in transit is de-identified and is not linked to the user’s login credentials or other device-identifiable information including but not limited to serial numbers or IP addresses.


Do third-parties see and/or have access to information obtained by the Application?


User-provided information and FoG event data may only be disclosed by Enabyl Inc. in the following circumstances:

  • as required by law, such as to comply with a subpoena, or similar legal process;

  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

  • if Enabyl Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.


What are my opt-out rights?


You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.


Data Retention Policy, Managing Your Information


We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain FoG event information for up to 24 months and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us at contact@enabyl.me and we will respond in a reasonable time. Furthermore, all FoG event data collected by the Application may be permanently deleted by the user by selecting the appropriate option within the Application itself.


Children


We do not use the Application to knowingly solicit data from or market to children 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 at contact@enabyl.me. We will delete such information from our files within a reasonable time.


Security


We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.


Changes


This Privacy Policy may be updated at any time and for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.


Your Consent


By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using or modifying information in any way, including, but not limited to, collecting, storing, deleting, using, and combining information, all of which activities will take place in the United States. If you reside outside the United States your information will be transferred, processed and stored there under United States privacy standards.


Contact Us


If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at contact@enabyl.me.