Last updated 02/25/19
WHO WE ARE
Revelar (“Pulse Health, LLC”) is a limited liability corporation, with its principal place of business in Lake Oswego, Oregon U.S.A. Revelar is committed to respecting your privacy and the security of your personal information. We are committed to transparency relating to your personal data, how it is collected, and with whom it is shared. Please email questions to Hello@Revelar.com.
"Controller" means the organization(s) that determines the purposes for which, and the manner in which, any Personal Data is Processed and used in its business.
"Processor" means any Person Processing Personal Data.
"Data Subject" means all living individuals about whom the Company holds Personal Data.
"Electronic" means relating to technology having electrical, digital, magnetic, wireless, optical, electromagnetic, or similar capabilities.
"Person" means a natural person, corporation, association, organization, partnership, or other legal entity.
"Personal Data" means information (whether stored Electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal Data can be:
- factual - such as a name, address, email, phone, or date of birth
- sensitive - such as financial account information, information about your racial or ethnic origin, political opinions, religious or similar beliefs, physical or mental health or condition or sexual life; or
- opinion - such as the results of a performance appraisal or physical assessment.
"Processing" is any activity that involves use of the Personal Data. It includes, without limitation, obtaining, recording or holding the Personal Data, or carrying out any operation or set of operations on the Personal Data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Data to third parties.
"Sensitive Personal Data" is Personal Data that reveals a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; biometric or genetic information; or information about a person’s health, sex life or sexual orientation; criminal records or suspected criminal activity. This Sensitive Personal Data will be handled with extra care as further described in this Policy.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
The information we receive, and how we use it, depends on what you do when visiting our website or being tested with our equipment. We collect and use non-Personal Data (information that does not identify you personally) differently from your Personal Data.
YOUR PERSONAL DATA
When using our website, visiting our social media sites or testing equipment we may request, and you may submit Personal Data or Sensitive Personal Data, which may include:
- First and last name
- address, telephone number, e-mail address or other contact information
- date of birth or age
- social media username or profile
- interests and qualifications
- IP (Internet Protocol) address when such address is associated with a specific user
We may collect Personal Data about our users these ways:
- When you enter Personal Data on certain pages of our website, such as a Contact form, and/or
- social media sites
THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
In order to comply with the General Data Protection Regulation (“GDPR”) and other applicable data privacy laws, we are required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data, as set forth below, the legal basis for processing your Personal Data will typically be one of the following:
- your explicit consent where appropriate; or
- the performance of a contract that we have in place with you; or
- our own legitimate business interests, or the legitimate business interests of our third party partners and vendors, such as, for example: communicating with you to offer marketing materials; maintaining and promoting our business by providing customers with feedback opportunities; handling inquiries from our third party distributors, vendors, or operators; or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest; or
- compliance with our legal obligations.
HOW DOES REVELAR USE PERSONAL DATA?
Revelar does not use your Personal Data in any way that is incompatible with the purposes for which it was collected or for which you have consented.
We may use the information that you have shared with us through this website for the following purposes:
- to respond to your requests
- to allow you to subscribe to email updates, announcements and offers
- to provide the services or information you request,
- to manage our relationship with you and facilitate any necessary follow up (e.g., by storing relevant information and preferences for a reasonable amount of time)
- to enter into, or perform a contract with you
- to enable you to participate in our online communities, including social media and blogs
- to contact you with information that might be of interest to you – as set forth in the Marketing and Education section below
Revelar may also use your Personal Data to the extent necessary to achieve the following legitimate interests, so long as it is compatible with your rights and expectations of privacy:
- to enforce this Privacy Statement and other rules about your use of this website
- to protect our rights or property
Revelar may also legally use your Personal Data in order to comply with a law or regulation, court order or other legal process.
Where required by law, we will ask you to "opt-in" or affirmatively consent to the processing of your personal data for a particular purpose. For example, where the law so requires, we will only send you newsletters if you have subscribed to them.
Non-Personal Data is information that cannot identify you or be tied to you in any way. Therefore, the non-Personal Data that we collect through this website does not identify you as an individual person and will not be linked to you. It may include information such as the following:
- the type of web browser software you use (for example, Internet Explorer)
- the name of the domain from which you access the Internet
- the Internet address of the website from which you linked directly to our website
- the date and time you access our website
- which pages you have visited on our website
- the search terms you use
- the links on which you click
- automated means, specifically through cookies. For more information about cookies, please click https://www.revelar.com/cookies.
WHAT DOES REVELAR DO WITH NON-PERSONAL DATA?
We are always looking for ways to better serve you and improve our products, services and website experience. We will use non-Personal Data from you to make this website more useful to visitors. We may also use non-Personal Data for other business purposes. For example, we may use non-Personal Data or aggregate non-Personal Data to:
- create reports for internal use to develop programs, products, services or content
- adapt or improve the information or services provided
- provide information on how our site is used, such as "traffic statistics" and "response rates" to third parties
DIRECT MARKETING AND EDUCATIONAL MATERIALS
Revelar may wish to provide you with educational materials or other information about our products and
services, as well as information about services customized for you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of Revelar
We will ask you to "opt-in" or affirmatively consent to the use of your Personal Data for the purposes of such communications, in accordance with applicable laws.
If at any time you decide not to receive any educational, commercial or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at Hello@Revelar.com and mention “OPT-OUT” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any relevant message you receive from us.
Please note that if you opt out of receiving promotional messages from us, we may still continue to send you relevant information that is required for business purposes, such as administer an account.
DOES REVELAR EVER SHARE PERSONAL DATA WITH THIRD PARTIES?
Revelar will not share your Personal Data with a third-party except as described in this Privacy Statement.
In the ordinary course of business, we may share your Personal Data with Revelar affiliates or third-party companies that we hire to perform services or functions on our behalf.
For example, we may:
- use a service provider to administer certain newsletter or informational mailings that you have signed up for and provide access to your email address for this purpose.
- use a third-party application or platform to allow us to manage and keep track of our communications with you.
- use our company affiliates to provide services relating to your Personal Data (e.g., we may store your information on a secure server based at our affiliate’s site in Europe or the United States.). For more information on the circumstances in which we may transfer your information to other countries, please see the relevant section below.
In all cases we will not share more information than is necessary, and we will not authorize any third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above.
Please note that subject to applicable laws, we may disclose your Personal Data if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that all or part of our business is acquired by a third party, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.
In addition, we may use and disclose your Personal Data to third parties if necessary, to:
- enforce this Privacy Statement and the other rules about your use of this website
- protect our rights or property
- protect someone's health, safety or welfare
- comply with a law or regulation, court order or other legal process
- investigate or take action in cases of suspected fraud or illegal activities
DO WE TRANSFER PERSONAL DATA TO OTHER COUNTRIES?
The data that we collect from you is stored on our servers and may be transferred within or outside the European Economic Area (“EEA”) to areas where privacy laws may be less strict than in the EEA. In certain cases, Revelar may transmit your Personal Data to our affiliates or third-party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Statement.
In cases where Personal Data is transmitted from Europe to other countries we will ensure that safeguards equivalent to those provided by European data protection laws are in place. For more information on the safeguards implemented by Revelar, please contact us at Hello@Revelar.com.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We will only keep your Personal Data for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Statement.
WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?
The effective date of this Privacy Statement is listed at the top of the document. We may change this Privacy Statement at any time and for any reason. If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this Privacy Statement each time you visit the website.
WHAT ABOUT PRIVACY ON OTHER WEBSITES?
This website may contain links to other websites. Some of those websites may be operated by Revelar affiliates, and some may be operated by third parties. This Privacy Statement does not apply to other websites, even other Revelar websites. Therefore, whenever you leave this website we recommend that you review the privacy practices that apply to information you provide on other websites. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others.
ARE THERE SPECIAL RULES ABOUT CHILDREN'S PRIVACY?
We care about protecting the online privacy of children. We will not intentionally collect any Personal Data (such as a child's name or e-mail address) from children under the age of 18 without the consent of someone holding parental responsibility. If you think that we have otherwise collected Personal Data from someone under the age of 18, please contact us Hello@Revelar.com.
We use technology and security precautions, rules and other procedures to protect your Personal Data from unauthorized access, improper use, disclosure, loss or destruction. To ensure the confidentiality of your information, Revelar also uses industry standard firewalls and password protection. It is, however, your personal responsibility to ensure that the computer you are using is adequately secured and protected against malicious software, such as “Trojans”, computer viruses and worm programs. Please be aware of the fact that without adequate security measures (e.g. secure web browser configuration, up-to-date antivirus software, personal firewall software, no usage of software from untrusted sources) there is a risk that the information and passwords you use to protect access to your data could be disclosed to unauthorized third parties.
Subject to certain exceptions, you have the following rights with respect to your Personal Data:
- To receive or access a copy of the Personal Data that we hold about you;
- To request that any inaccurate or incomplete Personal Data be corrected or supplemented;
- To have your Personal Data erased, unless we have a legitimate reason to retain the Personal Data (such as if we are required to do so for legal reasons);
- To object to our processing your Personal Data for a particular purpose, including for marketing.
- To restrict our processing of your Personal Data in any of these scenarios: (a) the data accuracy is contested; (b) the processing is unlawful and erasure is not requested; (c) the data must be preserved due to legal claims; (d) pending verification whether the controller has legitimate grounds to continue processing when the data subject has objected.
- Not to be subject to a decision based solely on automated processing including profiling;
- If your Personal Data is processed on the basis of consent, then you have the right to withdraw your consent at any time.
- In case we are processing your Personal Data in an automated manner as part of a service to you or based on your consent then you also have the right to request a copy of your information in a structured, commonly used and machine-readable format (known as the right to “data portability”), and the right to request that we transmit that data directly to another controller.
All of these rights are subject to certain conditions and exemptions. For example, Revelar will not be obligated to erase your Personal Data if we need to retain it to protect ourselves in the event of a legal claim.
HOW TO CONTACT US
If you have any questions about anything in this document or if you believe your personal data has been misused or mishandled, you can contact us at Hello@Revelar.com.
Or by post at:
Director of QA & RA
Two Centerpointe Dr. Suite 500
Lake Oswego, OR 97035