Movano Health Privacy Policy

• When you visit our websites, including Movanohealth.com and Eviering.com (together, “Sites”), for example, to purchase a product or learn more about us, the Site Privacy Information section below applies.
• If you use a wearable device we offer, like the Evie Ring, including its companion mobile app (together, “Devices”), the Device Privacy Information section below applies.
  

We may provide different or additional notices of our privacy practices for certain products or services. If there is a conflict between this Privacy Policy and the different or additional notices, the different or additional notices will control for that conflict. If you are a clinical trial participant and want to learn more about the information collected as part of those trials, please consult the documentation you received when you enrolled in the trial.

We may change our Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by emailing you, adding a statement to the Sites, or sending you a notification on your Device, as applicable). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Contact Us: If you have any questions about this policy, please contact us at support@movanohealth.com.

Sites and Devices Not Intended for Minors: You must be at least 18 years of age to use the Devices and the Sites, which are not intended for minors. If a minor under 18 submits personal information to Movano Health and we learn that the information is about or from a minor under 18, we will take steps to delete the information as soon as possible. If you are a parent or guardian of a child under 18 and believe that we have collected personal information from your child, please contact us at support@movanohealth.com.

Site Privacy Information – Contents

Collection of Information
Use of Information
Targeted Advertising and Analytics
Disclosures of Information
Your Choices – Site Information
Additional Information for Customers Residing in Certain U.S. States

Device Privacy Information – Contents

Collection of Information
Use of Information
Disclosures of Information
Your Choices – Device Information
Additional Information for Customers Residing in Certain U.S. States

Sites Privacy Information

This portion of our Privacy Policy describes the personal information Movano Health collects, uses, and discloses when you visit our Sites, including, for example, to make purchases from those Sites, sign up for our newsletters, and if you interact with us on social media or contact our customer service channels. We refer to this as “Site Information.”

Collection of Site Information

The Site Information we collect about you depends on how you interact with us and use our Sites. In this section, we describe the categories of Site Information we collect and the sources of it.

Site Information You Provide to Us

We collect Site Information you provide directly to us. For example, we collect Site Information directly from you when you make a purchase from our Sites, fill out a form on our Sites (such as to sign up for email newsletters from us), communicate with us via third-party platforms, including social media, or request customer support. The types of Site Information we collect may include your name, email address, postal address, phone number, and any other information you choose to provide. Additionally, if you make a purchase, we work with a third-party payment processor to collect and process your payment information.

Site Information We Collect Automatically

We automatically collect certain information about your interactions with us or our Sites, including:

• Site Activity Information: We collect Site Information about how you access our Sites, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We also collect data about your activity on our Sites, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Sites.
• Transactional Information: When you make a purchase or return, we collect Site Information about the transaction, such as product details, purchase price, and the date and location of the transaction.
• Site Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies and web beacons, to collect Site Information. Cookies are small data files stored on your hard drive or in device memory that help us improve our Sites and your experience, see which areas and features of our Sites are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Sites and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices – Site Information section below.

Site Information We Collect from Other Sources

We obtain certain Site Information from other sources. For example, we may collect information, such as your name or email address, from advertising networks, data analytics providers, and mailing list providers.

Site Information We Derive

We may draw inferences about you based on the other Site Information we collect. For example, we may infer that you would be interested in a certain type of product based on the information you provide, or we may use your IP address to infer the city where you live.

Use of Site Information

We use the categories of Site Information we collect to provide, maintain, and improve our Sites. We also use the Site Information we collect to:

• Personalize your experience with us;
• Send you technical notices, security alerts, support messages, and other transactional or relationship messages;
• Communicate with you about products, services, and events offered by Movano Health and others and provide news and information that we think will interest you (see the Your Choices – Site Information section below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our Sites;
• Target advertisements to you on third-party platforms and websites (for more information and to opt out, see the Your Choices – Site Information section below);
• Debug and repair errors;
• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Movano Health and others;
• Carry out internal operations that are reasonable in the context of your relationship with us;
• Comply with our legal and financial obligations;
• Create de-identified, anonymized, or aggregated information; and
• Carry out any other purpose described to you at the time the Site Information was collected.

Targeted Advertising and Analytics

We do not use information collected from our Devices to target you with online advertising.

On some of our Sites, we may use Site Information and engage others to deliver advertising targeted to your interests on other companies’ sites or mobile applications, analyze and track data, determine the popularity of certain content, and better understand your activity. To do so, these entities may use cookies, web beacons, and other technologies to collect information about your use of our Sites and other companies’ websites and mobile apps, including your IP address, web browser and mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. In addition, we may share other Site Information, including identifiers, such as email addresses, with some of our advertising partners. These advertising partners translate that information into a unique identifier that can then be used to show ads that are more relevant to you across the web and in mobile apps. For our Site(s) that use ad targeting cookies, you may opt out by following the prompts that emerge after clicking the “Your Privacy Choices ” footer link at the bottom of the Site you visit.

You can also learn more about interest-based ads or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance by visiting www.aboutads.info/choices.

Disclosures of Site Information

In certain circumstances, we disclose (or permit others to directly collect) Site Information about you. We disclose personal information as otherwise described in this Site Privacy Information section and in the following ways:

• Vendors and Service Providers. We make Site Information available to our vendors, service providers, contractors, and consultants who perform services on our behalf, such as companies that assist us with web hosting, financing, fraud prevention, data enrichment, analytics, marketing, and advertising.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose Site Information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• To Protect the Rights of Movano Health and Others. We disclose Site Information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Movano Health, our users, the public, or others.
• Professional Advisors. We disclose Site Information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We disclose Site Information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Corporate Affiliates. Site Information is disclosed between and among Movano Health and our parents, affiliates, subsidiaries, and other companies under common control and ownership.
• Consent. We make Site Information available to third parties when we have your consent or you intentionally direct us to do so.
• Aggregated Data. We may disclose aggregated or de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify such information, except as permitted by law.

Your Choices – Site Information

Opting Out of Marketing Communications

You may opt out of receiving promotional emails from Movano Health by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.

Cookies and Similar Tracking Technologies

Movano Health uses cookies and similar tracking technologies to analyze visits to and use of our Sites and how consumers are interacting with our marketing communications. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. On certain of our Sites, you may also adjust certain cookie settings by selecting the “Your Privacy Choices ” footer link at the bottom of the Site you visit.

Additional Information for Customers Residing in Certain U.S. States

California, Colorado, Connecticut, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”). To the extent these laws apply to Movano Health and you are a resident of one of these states, these additional disclosures apply to you.

In the preceding 12 months, we have collected Site Information that includes the following categories of personal information: identifiers, demographic information, commercial information, internet or other electronic network activity information, audio and visual data (such as if you contact customer service), and inferences. For details about the Site Information we collect and the sources of such collection, please see the “Collection of Site Information” section above.

In the preceding 12 months, we have collected the following categories of Site Information, disclosed them to the categories of recipients shown, and used the categories of information for the purposes shown:

Site Information that we “Share,” “Sell,” or Use for “Targeted Advertising”

Some of our advertising and analytics activities may be considered “sales” or “sharing” or use of personal information for “targeted advertising” under certain State Laws. In order to advertise our products to you and better understand, improve, and personalize our interactions with you, we share and sell the following categories of personal information to third parties:

Other Details About Our Site Information Practices

• We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
• The length of time we retain your Site Information depends on the status of our relationship with you and the requirements of applicable law. We will retain your personal information for as long as your relationship with us lasts and for a certain period thereafter, after which point it will be deleted or archived in accordance with applicable law. To determine that period, we take into account a number of factors, including our legal and regulatory obligations (such as financial reporting obligations) and whether we may need to retain personal information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.

Your Privacy Rights

Access, Deletion, Correction
Depending on your state of residence, you may have the right to request access to, or deletion or correction of, your personal information. To make such a request with respect to Site Information, please contact us at support@movanohealth.com.

Appeals
If we deny your request, you may have the right to appeal our decision by contacting us at support@movanohealth.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Authorized Agents
If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or signed permission from the individual who is the subject of the request.

Nondiscrimination
We will not discriminate against you for exercising your privacy rights.

Devices Privacy Information

This portion of our Privacy Policy describes the personal information Movano Health collects, uses and discloses, the choices available to you when you use our “Devices” – meaning, collectively, our wearable devices, including the Evie Ring, and companion mobile app, such as the Evie Ring App. We refer the information collected from both as “Device Information” in this section.

BY USING ANY OF OUR DEVICES, YOU EXPRESSLY CONSENT TO THE INFORMATION PRACTICES SET OUT IN THIS DEVICE PRIVACY INFORMATION SECTION.

Collection of Device Information

The Device Information we collect about you depends on how you use the Device. In this section, we describe the categories of Device Information we collect and the sources of it.

Device Information You Provide to Us

We collect Device Information you provide directly to us. For example, we collect information you provide to set up your account and profile on your Device or otherwise input into the Device, such as your weight, height, gender, age, and other information that you choose to input such as your sleep goals, step goals, menstrual cycle tracking, and information about how you’re feeling.

Device Information We Collect Automatically

We automatically collect certain information through the Device, including:

• The Device collects information about your body and activity, such as heart rate, heart rate variability, SpO2, respiration rate, skin temperature variation, sleep data, steps, activity intensity, calories burned, and distance travelled.
• We collect information about how you access and use the Device, such data about the network you use and mobile device you use to access the companion app, including your hardware model, operating system version, mobile network, IP address, unique device identifiers, and app version. We also collect information about actions you take, such as buttons tapped or pages viewed within a companion mobile app.

Device Information We Receive from Other Sources

If log into your Movano Health account through a third-party single-sign on partner (such as Apple or Google), we will have access to certain information from that platform, such as your name and email, and any other information the third-party platform discloses about you, in accordance with the authorization procedures determined by such platform.

Device Information We Derive

We may infer or derive certain Device Information, such as predicting that you may be interested in running based on other Device Information collected.

Use of Device Information

We use the Device Information to administer your account and deliver the services and functionality associated with the Device to you, including to track your activity and your body’s response to such activity while wearing your Device, in accordance with your Device settings. We also use the Device Information we collect to:

• Provide, maintain, and improve our Devices and the associated services and functionality, including by analyzing data to better understand how our Devices are used;
• Personalize and improve your experience with the Device (such as to send you push notifications celebrating your progress or deriving correlations between your sleep patterns and menstrual cycle);
• Send you technical notices, security alerts, support messages, and other relationship messages;
• Monitor and analyze trends, usage, and activities in connection with the Devices;
• Debug and repair errors in the Devices and the associated services and functionality;
• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Movano Health and others;
• Comply with our legal and financial obligations;
• Carry out internal operations that are reasonable in the context of your relationship with us;
• Create de-identified, anonymized, or aggregated information; and
• Carry out any other purpose described to you at the time the Device Information was collected.

Disclosure of Device Information

We disclose Device Information in the following circumstances:

• Vendors and Service Providers. We disclose Device Information to vendors, service providers, contractors, and consultants that need such information to provide services to us, such as companies that assist us with cloud storage, fraud prevention, customer service, cloud infrastructure providers, and marketing and advertising.
• Single Sign-On Partners. If you sign into your Movano Health account using a single-sign on partner, such as Apple or Google, we may disclose your email address to that partner.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We may disclose Device Information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• To Protect the Rights of Movano Health and Others. We may disclose Device Information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Movano Health, our users, the public, or others.
• Professional Advisors. We disclose Device Information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We may disclose Device Information in connection with or during negotiations concerning any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Corporate Affiliates. Device Information may be disclosed between and among Movano Health and our current and future parents, affiliates, and subsidiaries, and other companies under common control and ownership.
• Consent. We may disclose Device Information with your consent or at your direction.
• Aggregated Data. We may disclose aggregated or de-identified information that cannot reasonably be used to identify you. Movano Health processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

Except for the circumstances set out above, we will not share your Device Information with any other individual without your consent, and do not permit others, including your immediate family members, to create or access accounts for anyone else.

We do not disclose your Device Information for advertising purposes. 

Your Choices – Device Information

Your Account Settings

You can adjust a host of settings in your account, including changing your profile information or turning on or off menstrual tracking by visiting the Settings section of the companion mobile app.

Deleting Your Device Information or Menstrual Health Data

You can choose to stop using your Device at any time and elect to delete your Device Information by scrolling to the bottom of the Settings menu, tapping “Delete my account” and following the prompts. You can also delete only your Menstrual Health Data (tracked periods, Menstrual Flow, and Vaginal Discharge logged details) from within Settings by tapping “Menstrual cycle” > “Delete my menstrual data.”

Mobile Push Notifications

With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Additional Information for Customers Residing in Certain U.S. States

California, Colorado, Connecticut, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (together, “State Laws”). To the extent these laws apply to Movano Health and you are a resident of one of these states, these additional disclosures apply to you.

We collect the following categories of Device Information: identifiers, demographic information, internet or other electronic network activity information, fitness information, and inferences. For details about the Device Information data we collect and the sources of such collection, please see the “Collection of Device Information” section above.

We collect the following categories of Device Information, disclosed them to the categories of recipients shown, and used the categories of information for the purposes shown:

Other Details About Our Information Practices

• We do not “sell” or “share” Device Information or use it for “targeted advertising” as those terms are defined in State Laws.
• We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
• The length of time we retain your Device Information depends on the status of our relationship with you and the requirements of applicable law. We will retain your Device Information for as long as your relationship with us lasts and for a certain period thereafter, after which point it will be deleted or archived in accordance with applicable law. To determine that period, we take into account a number of factors, including our legal and regulatory obligations (such as financial reporting obligations) and whether we may need to retain Device Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.

Your Privacy Rights

Access, Deletion, Correction

Depending on your state of residence, you may have the right to request access to or deletion or correction of your Device Information. You may review, update, and correct certain account and other Device Information as set out above, or by contacting us at support@movanohealth.com. To make another request, please contact us at support@movanohealth.com, but note that we may retain certain information as required by law or for our legitimate business purposes.

Appeals

If we deny your request, you may have the right to appeal our decision by contacting us at support@movanohealth.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Authorized Agents

If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or signed permission from the individual who is the subject of the request.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.