Privacy

IKONA Inc. Privacy Policy

This IKONA Privacy Policy (“Privacy Policy”) describes IKONA Inc.'s, its affiliates', and subsidiaries' (collectively “IKONA,” “we,” “us,” or “our”) practices regarding the collection, use, storage, sharing, and safeguarding of your information collected from any IKONA-operated website or application, including the IKONA VR app, which comes pre-loaded onto the IKONA-provided Oculus Go VR Headset that comes with a subscription.

Changes to this Privacy Policy

IKONA may make changes to this Privacy Policy. The most current version of the Privacy Policy will govern IKONA's use of information about you and will be located here. If IKONA makes material changes to this Privacy Policy, and IKONA has your email address on file, IKONA will notify you by sending an email to that address. Please ensure that your address remains current so you will receive updates.

Types of Information that IKONA Collects

IKONA collects data in two ways: 1) through its website and 2) through the IKONA VR application. The nature of the data collected differs between these two mediums.

Data collected through the website

IKONA may collect information that you provide to IKONA when you send email messages, forms, or other information to IKONA using the website. This information may include your first and last name, address, email address, telephone number, and any additional information you provide to IKONA during your use of the Service.

IKONA may also collect certain technical information about your use of the website. This technical information may include information about your device(s), browser type and version, geo-location, computer, computer connection, statistics on page views, traffic to and from the Service, Wi-Fi connection, internet protocol (“IP”) address and standard web log information.

Data collected through the IKONA VR application

When you use the VR application IKONA collects usage data. This usage data includes what content is being used, how much it is being used, and a device-ID corresponding to the device being used. Knowledge of the device-ID associated with usage enables IKONA to tie data to the institution or organization to which the headset is registered. IKONA does not, however, collect any personally identifiable information about patients or caregivers that are using the headset and does not tie any data collected to specific patients or caregivers.

How IKONA Collects Your Information; Tracking and Cookies

IKONA, and third parties we interact with, including our third-party service providers, may use cookies, web beacons, locally shared objects (sometimes called "flash cookies"), and similar technologies in connection with your use of the Service to provide and support the Service (collectively referred to in this policy as "Cookies"). Cookies may be used to collect personally identifiable information about your online activities over time and across different websites. Cookies are small data files that may have unique identifiers, and reside, among other places, on your mobile device, in emails we send to you, and on our applications. Locally shared objects, or “flash cookies,” are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Locally stored objects are different than cookies because they are stored in different parts of your computer than cookies. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. While the VR Kit may use cookies, these cookies cannot be used to identify patients that are using the kit.

If Cookies are used, they may be used to collect information about you and your use of the Service, such as your browser type, preferences, data relating to content that has been displayed to you or that you have clicked on, and the date and time of your use. Cookies may also be used in order to further features and processes on the Service, provide authentication and security for your transactions using the Service, store your preferences, facilitate relevant advertising, and help us learn more about how users engage with the Service.

We sometimes use service providers to help us provide certain products and services or to integrate other features. These third-party service providers may collect information when you view or use them, including information about you and your device or browser. They may do this using Cookies or similar technologies. These third-party service providers also may use Cookies or similar technologies to help share information with us, like how you use their website or application. To learn more about the information they collect or receive, review their privacy policies.

For example, we work with a service called Google Analytics provided by Google, Inc. (“Google”). Google Analytics uses Cookies to help us analyze how users use our website. The information generated by these Cookies (including your truncated IP address) is transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your, and other users', use of our products and services, compiling reports for us about how you and others use our products and services and providing other services relating to activity on our products and services and Internet usage. Please note that Google only receives your truncated IP address. This is sufficient for Google to identify (approximately) the country from which you are using our products and services, but is not sufficient to identify you, or your computer or mobile device, individually. Google's privacy policy is found here: https://support.google.com/analytics/answer/6004245.


You can use the settings within your browser to control the cookies that are set on your computer or mobile device. To find out how to see what cookies have been set and how to reject and delete cookies, please visit http://www.aboutcookies.org.

How IKONA Uses Collected Information

IKONA may collect personally identifiable information through our website, such as any information you submit to IKONA via contact forms or in-browser messaging. IKONA does not collect any personally identifiable information through the IKONA VR application or headset. IKONA does, however, collect IKONA VR application device-IDs, which enables IKONA to know what content a particular headset is viewing. This enables IKONA to tie headset usage data to the specific organization or individual to which the headsets are registered. While IKONA can identify the organizations or individuals to which the headsets are registered, and the specific usage patterns of their headsets, IKONA will not know the identity of patients that are using the headset.

IKONA may use information that IKONA collects about IKONA VR application usage to: A) measure, and improve IKONA's services and content; (B) prevent, detect, and investigate potentially prohibited or illegal activities or a breach of the applicable agreement(s) between you and IKONA; (C) analyze the accuracy, effectiveness, usability, or popularity of the Service; (D) generate and review reports and data about service usage patterns; (E) compile aggregate data for internal and external business purposes; (F) resolve disputes and troubleshoot problems; and (G) contact you with information, including promotional, marketing, and advertising information and recommendations that IKONA believes may be of interest to you. Consistent with applicable laws, including United States CAN-SPAM laws, if you do not wish to receive commercial emails, you may unsubscribe following the instructions on any email. We may still send you administrative notices, however.

Categories of Third-Party Persons or Entities With Whom IKONA May Share Your Personally Identifiable Information

Companies that Acquire IKONA's Business or Assets. If IKONA becomes involved in a merger, acquisition, sale of assets, securities offering, bankruptcy, reorganization, or dissolution or if the ownership of all or substantially all of IKONA's business relating to the Service otherwise changes, IKONA may provide your information to a third party or parties in connection with the applicable transaction.

IKONA's Affiliates. IKONA may share some or all of your information with IKONA's parent company, subsidiaries and corporate affiliates, joint venturers or other companies under common control with IKONA.

Aggregate Information. IKONA may share information relating to visitors and users of the Service with affiliated or unaffiliated third parties on an aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this information with other data they have about you, or that they receive from third parties, in a manner that allows them to associate this aggregated data with your personal data.

Legal Requirements. IKONA may share your information with law enforcement, governmental agencies, or authorized third parties, in response to a request relating to a criminal investigation or alleged illegal activity or any other activity that may expose IKONA, you, or any other IKONA user to legal liability, or to protect IKONA's rights or property, or during emergencies when public safety is at risk. IKONA may also share your information in response to court orders, subpoenas, or other legal or regulatory requests, and may provide IKONA's legal counsel and other consultants access to your information in connection with actual or potential litigation.

DMCA Notices. IKONA may share your information with third parties when we forward Digital Millennium Copyright Act (DCMA) notifications, which will be forwarded as submitted to us without any deletions.

Unforseen Disclosures. Your information may also be disclosed to third parties in unforeseeable situations or situations that are not preventable even when commercially reasonably protections are employed, such as in the case that IKONA or the Service is subject to a hacking or other attack.

Do Not Track

You may be able to adjust your browser settings or other settings so that “do not track” requests are sent to the Service's websites and mobile applications. IKONA will not disable tracking technology that may be active on the Service in response to any “do not track” requests that are sent to the Service.

Links

IKONA's website or applications may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Security

IKONA takes reasonable measures to protect the information you provide to IKONA or submit through the Service against misuse, loss, theft, unauthorized use, disclosure, or modification. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Protected Health Information

While the IKONA VR application may be used with patients and caregivers, IKONA only collects non-identifiable usage data, and does not collect any Protected Health Information (PHI). Any PHI collected by health care providers relating to patients’ use of the headset is the responsibility of the health care provider and subject to the health care providers’ obligations of confidentiality and privacy. Your health care provider should provide you with a notice of privacy practices that will detail how your health care provider maintains your PHI and under what circumstances it may be disclosed.

Accessing, Changing and Managing Your Information.

The only personally identifiable information IKONA collects is information submitted through our website, such as through contact forms and other customer service platforms. If you wish to remove yourself from our databases, you may request this by contacting us at solutions@ikona.health. Because IKONA cannot identify individual IKONA VR application users from the usage data IKONA collects, IKONA is unable to fulfill any requests to retrieve, modify, or delete a particular user's IKONA VR application usage data.

Retention of Your Information. We retain information as long as it is necessary and relevant for our operations. Information about you that is no longer necessary and relevant for our operations will be disposed of securely. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, and enforce the Service's terms and conditions and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Notice of Privacy Rights to California Residents. Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, information related to the personal information disclosed by IKONA to third parties for direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing IKONA at solutions@ikona.health or sending a letter to: IKONA 1 Penn Plaza Suite #6243 New York, NY 10119.

Contact

If you have questions or complaints regarding IKONA's Privacy Policy or practices, please contact IKONA at solutions@ikona.health.