TABLE OF CONTENTS
About our Platform
Collection and Use of Personal Information
Disclosure of Personal Information
Information Collected Automatically
Legal Basis for Processing
Third Party Sites
Security of Personal Information
Retention of Personal Information
Access to Personal Information
ABOUT OUR PLATFORM
Our Platform provides tools that allow physiotherapists and other practitioners (“Practitioners”) to create exercise, therapy and rehabilitation programs (“Programs”) for clients (“Clients”), to share Programs with Clients, to monitor Clients’ progress through and adherence to the Programs, to receive video assessments of Client’s movements, and to provide instructions, feedback, corrections and guidance to Clients.
Our Platform also allows Clients to view the Programs assigned to them by Practitioners, to generate videos and assessments of their exercises and to share the videos and assessments with Practitioners, and to ask questions or otherwise communicate with their Practitioner.
COLLECTION AND USE OF PERSONAL INFORMATION
Account creation: In order to access the Platform, you are required to create an account with us. You must be at least 13 years of age to create an account. We collect your email address, password, and full name. Additional information may be requested within your profile to allow us to better customize the experience for you, but this information will be optional. We may use this information to administer your account and personalize your experience on the Platform.
Video assessments and exercises: Our App allows Clients to log their exercises. It also allows Clients and Practitioners to use their mobile devices to take videos of exercises and movements to measure movement related to performance and technique. Our App will request permission to access the video and audio features on the mobile device for these purposes. Client’s logged exercises and video assessments will be shared with the Client’s Practitioners, unless the Client has revoked this access. A Practitioner may also generate video assessments of their Clients from the Practitioner’s device and can share the assessments with the Client. We use video content and assessment results only to provide Clients and Practitioners with the features of the Platform. However, we may generate aggregate and anonymous data from video assessments and other data we collect through the Platform and may use and share the aggregate and anonymous data for any lawful purpose.
Payment information: While certain features on the Platform are free, Clients are required to pay a monthly membership fee for access to certain features of the Platform. We collect your payment-card details (including payment card number, security code, expiration date, cardholder name and billing address) for the purposes of processing your membership payments.
Certifications: We may collect certifications from Practitioners who use our Platform for the purposes of verifying their credentials. This will include diplomas/degrees for physiotherapists or any other profession as we deem necessary.
Inquiries: If you contact us with an inquiry, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your inquiry. We may retain this information to assist you in the future and to improve our customer service and service offerings.
Feedback: We may collect and use feedback about our Platform to better understand users of the Platform and enhance our product and service offerings. With your consent, we may publish your feedback on our Website or other promotional materials.
Marketing Communications: We may use your personal information to send you newsletters and other promotional communications. You can opt-out of receiving promotional communications from us by following the opt-out or “unsubscribe” instructions provided in your email, or by contacting us as set out below. Please note that upon unsubscribing, you will continue to receive transactional and account-related electronic messages from us.
Push Notifications: If you provide your consent to receive push notifications, we may send push notifications to your mobile device to provide you with reminders, updates and information. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App in the settings of your mobile device.
DISCLOSURE OF PERSONAL INFORMATION
Service Providers: In connection with our Platform, we may transfer (or otherwise make available) personal information to third parties who provide services on our behalf. For example, we may use service providers to host our Platform, store data and provide back-up Platform (including cloud-based service providers), process payments, or provide data analytics. Personal information may be maintained and processed by us or our third party service providers in the US, Canada, United Kingdom or other jurisdictions. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. For more information about the way in which our service providers treat personal information, please contact us as set out in the “Contact Us” section below.
Practitioners: If you are a Client, we provide access to your personal information to your Practitioner. This information includes your logged exercises, messages, videos and assessment results.
Sale of Business: We may transfer personal information as an asset in connection with a prospective or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Cratos Inc. or as part of a corporate reorganization or other change in corporate control.
Legal: Cratos and our Canadian, US and other service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law.
INFORMATION COLLECTED AUTOMATICALLY
Visiting our Website: We collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to improve our Website.
Using our App: When you use our App, we collect information regarding your device type, operating system and version, carrier provider, unique device identifier, language setting, and the date and time that the App accesses our servers. With your consent, we may also collect your location data. We use this information to help us understand the activity on our App and to monitor and improve our App.
Analytics: We may use third party service providers like Google Analytics to collect information about your use of the Platform, such as the features used and time spent on the Platform, to help us better understand our users and improve our Platform. The information we gather is used in an aggregate, non-identifiable form. For information about information is processed in connection with Google Analytics please read the Google Analytics Policy here.
LEGAL BASIS FOR PROCESSING
We rely on one or more of the following legal grounds (as appropriate) to process personal information:
To enter and perform a contract with you or to perform any steps you require from us before entering into a contract.
To pursue our legitimate business interests in establishing, managing or concluding our relationship with you.
Where you have specifically consented to us processing your personal information.
To comply with our legal obligations and establish, exercise or defend our legal rights.
Where personal information is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as described below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain of our services.
THIRD PARTY SITES
Social Media: We may offer you the opportunity to engage with Cratos content on or through third-party social networking websites, plug-ins and applications. When you engage with us or our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender). We may use this information to personalize your experience on the Platform and on the third-party social networking websites, plug-ins and applications, and to provide you with other information you may request.
SECURITY OF PERSONAL INFORMATION
We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. However, please note that no security measures can offer absolute security and we cannot guarantee that your personal information will not be stolen or accessed without authorization.
RETENTION OF PERSONAL INFORMATION
ACCESS TO PERSONAL INFORMATION
You may request access, updating or correction of your personal information (subject to limited exceptions prescribed by law) by submitting a written request to our Privacy Officer (see “Contact Us” below). You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us to use for your own purposes, or to lodge a complaint with a supervisory authority. If you have any questions about these rights, or you would like to exercise any of them, please contact us as described below. We may request certain personal information for the purposes of verifying your identity.