Respiri US Inc. (“Respiri,” “we,” “us,” or “our”) is committed to privacy and data protection. The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this policy, “parents” or “you”) about our practices if we are collecting, using, and disclosing personal information directly from children under the age of 13 (“children” or “child”). This notice (“COPPA Notice”) provides additional details regarding the practices described in the our Privacy Policy as it relates to children.
This COPPA Notice only applies to the data collection practices of Respiri with respect to use of the wheezo® respiriTM mobile application and device (collectively, the “Services”) where a child has registered directly to use such Services. Please note that our usual practice is not to collect personal information directly from children. We only collect personal information from children if they have been signed up for the Services by their health care provider with the consent of their parent or legal guardian.
How Do We Protect Children’s Privacy?
We take special precautions to protect the privacy of children using our Services. If you have a question about whether a particular Service is directed to children, please contact us by sending an email to [email protected].
What Data Do We Collect from Children?
Respiri only collects the minimum amount of personal information necessary for children to use our Services, including:
- name, date of birth and gender;
- physical traits, such as height and weight;
- contact details such as telephone number, email address or delivery address;
- if applicable, payment (such as credit card) or banking information (including related payment verification information);
- information about your interest in or use of our products or Services;
- health (sensitive) information, for example your wheeze rate;
- geographic location when a child uses the respiriTM app; and
- information about the child’s treating medical practitioners;
We store a child’s user name and password on our system if the child separately registers for the Services. We may also store the IP address from which the child access the Services in connection with the child’s use of the Services.
We use cookies, and other similar technology, to collect information when children use our Service such as the amount of time children spend on the Services, the actions performed by children such as logging in and out, and the pages children visit. This information may also be used for analytical and security purposes by Respiri.
How Do We Use Children’s Personal Data?
We use children’s personal information to provide the Services as described in our Privacy Policy and our Terms of Use.
We may use the non-personally identifiable data we collect to improve the Services and to deliver a better and more personalized experience.
Respiri retains personal information in a form which permits identification of a child for as long as necessary to provide the Services in which the child is participating, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g., under our agreement with health care providers or statute of limitations).
When Do We Disclose Children’s Personal Data?
We do not sell or rent children’s personal information or market directly to children.
We may disclose use and aggregated data about our users and data that does not identify any individual or device, including de-identified health data.
In addition, we may disclose children’s personal information: (i) to the child’s health care provider if the Services are provided under the direction of such health care provider; (ii) to third parties we use to provide or support our Services (who are obligated to maintain the confidentiality of such information); (iii) if we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request; (iv) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety our company, our customers or others, including to protect the safety of a child, protect the safety and security of the Services; or enable us to take precautions against liability; (v) to law enforcement agencies or for an investigation related to public safety; and (vi) to others with the consent of the parent or legal guardian of the child.
In addition, if Respiri is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Respiri’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.
How Can You Access, Review, and Update Your Child’s Personal Data?
At any time and upon providing proper verification of your identity and relationship to the child, you may access and review your child’s personal information maintained by us, request that we update or delete such personal information, and/or refuse to allow us from further collecting or using your child’s personal information. Please note that requiring deletion of such personal information may impact our ability to provide the Services to your child.
You can review, change, or delete your child’s personal information by sending us an email to [email protected]. To protect your and your child’s privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any personal information or make corrections.
We understand that you may have questions or concerns about this COPPA Notice or our privacy practices or may wish to file a complaint. In such case, please contact us in one of the following ways:
by email to [email protected]
by mail to: Suite 1, Level 9 432 St Kilda Road Melbourne Victoria Australia, 3004.