Thank you for using the proprietary Propeller System, including the Propeller inhaler sensor (the “Sensor”), our mobile application
(the “App”) and the my.propellerhealth.com website (the “Site”), made available by Reciprocal Labs, Inc. d/b/a Propeller
Health (“Propeller”). For purposes of clarity, the Propeller System, including the Sensor, App and Site are collectively
referred to as the “Services.”
In accordance with the Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA"), this Privacy
Policy for Children Under the Age of 13 (the “Policy”) is intended to inform parents and legal guardians ("Parents")
about our practices for collecting, using, and disclosing personal information from children under the age of 13
(each, a “Child” or "Children") who use the Services and our practices for notifying and obtaining Parents’ consent,
including how a Parent may revoke consent. This Policy only applies users of the Services who are under the age of
13 and supplements the provisions of the Propeller User Agreement (the “User Agreement”), provided with the Services.
Collection of Information
Account Registration. Parents will not be able to register their Children for the Services until we obtain verified consent
from a Parent. To perform such verification we use a third party service offered by Veratad Technologies, LLC (“Veratad”).
Parents will submit information to Veratad for the purposes of verifying their identity, including, without limitation,
name, postal address, and date of birth. The information submitted to Veratad will only be used for identity verification
purposes and will not be shared with any third party.
When a Parent registers his or her Child for the Services, the Parent will create a password, which will allow the Child
to use the Services. At the time of registration, we may collect the following information about the Parent: name,
email address, postal address and date of birth (collectively, “Parent Information”). We may use the Parent’s email
address to notify the Parent about our privacy practices, to send the Parent communication about the Child’s account
on the Services or about features of the Services, and for the other purposes described in this Policy or the User
At the time of registration, we will also collect the following information about the applicable Child or Children: name,
email address, race, gender, postal address and date of birth (collectively, “Child Information”).
Information We Collect Regarding Use of the Services. When a Child uses the Services we collect the following information:
- The Sensor collects data regarding usage of the inhaler, including, without limitation, the date, time, and location
- If a Child uses the App, additional optional information such as symptoms, triggers, lifestyle factors and notes
may be added to the details of the usage.
Automatic Information Collection.
When a Parent registers for the Services, and each time a Parent or Child (each, a “User”) signs in to App or Site, we automatically
collect the Internet Protocol (“IP”) address of the computer or mobile device being used to access the Services as
well as information about the User’s web browser or app. This information is used to provide an enhanced on-line
experience for our visitors by optimizing our web pages for your computer or device (e.g.: the identity of your Internet
browser (e.g., Safari, Google Chrome, Internet Explorer), the type of operating system you use (Mac or Windows),
and the domain name of your Internet service provider). We may also use this non-personal information to develop
utilization data on our Site.
for internal purposes. Cookies do not contain any personally identifiable information. With most Internet browsers,
you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored.
Please refer to your browser instructions or help screen to learn more about these functions. If you turn off cookies,
you will not have access to some of the features that make your experience on our Site smoother, and some of our
services may not function properly.
How We Use Your Child's Information
We use the Child Information we collect from a Parent or Child to:
- register the Child with the Service;
- administer the Services;
- track his or her use of the Services; and
- communicate with him or her about the Services.
We use the information we collect automatically through technology (see Automatic Information Collection) and other non-personal
information we collect to improve our Services and to deliver a better and more personalized experience by enabling
- store information about the Child's preferences, allowing us to customize the content according to individual interests;
- estimate our audience size and usage patterns; and
- improve and deliver our Services.
Our Practices for Disclosing Children's Information
We do not share, sell, rent, or transfer Children's personal information other than as described in this section.
Information Shared with the Program Sponsor.
In certain situations, we may share information with a program sponsor that makes the Services available to the Child.
In such situations, we may disclose Child Information to the Program Sponsor as permitted by the HIPAA-compliant
Business Associate agreement in place between us and the applicable Sponsor for their internal business purposes,
including, without limitation, in connection with their healthcare operations or for treatment purposes.
Information Shared with Our Service Providers.
We engage other companies to provide services to us to enable us to operate the Services, such as hosting the Site and
App or sending communications on our behalf. These third-party services providers have access to personal information
only for the purpose of performing services on our behalf.
Information Shared with Third Parties.
We may share anonymized or aggregated data we collect from the use of the Services, such as de-identified demographic
information, de-identified location information, information about the computer or device from which you access the
Services, market trends and other analysis that we create based on the information we receive from you and other
Users, with third parties.
We utilize Google Analytics, a service provided by Google, Inc., to gather information about how Users and visitors engage
with our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.
You can prevent the storage of Google Analytics cookies through your browser, as described above. You can also opt
out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Propeller is interested in better understanding the management and impact of respiratory disease and in identifying and
supporting better way to address it at the public health level. In connection with these efforts, we may use the
Child Information to create aggregated health information and de-identified data (“De-Identified Data”) and share
such De-Identified Data with third parties for research and analysis purposes, to improve the Services or to promote
the Services. De-Identified Data will not include personally identifiable information that can reasonably be used
to identify a Child.
Information Disclosed in Connection with Business Transactions.
Information that we collect from our Users, including Child Information, is considered to be a business asset. Thus,
if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if
our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our
assets, including information collected from Users, may be disclosed or transferred to a third party acquirer in
connection with the transaction.
Disclosed for Our Protection and the Protection of Others.
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We
may disclose any information about you to government or law enforcement officials or private parties as we, in our
sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas);
(ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public
in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity. We
will comply with any additional HIPAA (Health Information Portability and Accountability Act) limitations on the
information that is shared for these purposes.
Accessing and Correcting Your Child's Personal
At any time, a Parent may review his or her Child's personal information maintained by us, require us to correct or delete
the personal information, and/or refuse to permit us from further collecting or using the Child's information.
You can review, change, or delete your Child's personal information by:
- Signing in to your Child's account and adjusting account settings
- Sending us an email at firstname.lastname@example.org. To protect your privacy and security, we may require you to take
certain steps or provide additional information to verify your identity before we provide any information or
Responding to Do Not Track Signals
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect
from or about Users from unauthorized access, use or disclosure and to comply with all applicable laws. Please be
aware, however, that no method of transmitting information over the Internet or storing information is completely
secure. Accordingly, we cannot guarantee the absolute security of any information.
Please note that a User’s personal information may be transferred to, and maintained on, computers located outside of
your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective
as those in your jurisdiction.
Links to Other Sites
Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-Party
Service”). Any information that you provide on or to a Third-Party Service or that is collected by a Third-Party
Service is provided directly to the owner or operator of the Third-Party Service and is subject to the owner’s or
any Third-Party Service. To protect your information we recommend that you carefully review the privacy policies
of all Third-party Services that you access.
Please contact us at email@example.com if you have any questions about our Policy.