Effective date: 05.24.2022
Your Account Information:
When you use our Testing Platform, you may provide certain information directly to us. For example, when you register for an account to use our CLEO™ ONE services, we may collect the following information: an email address and password, first and last name, street address (including city, state, and zip code), and a phone number.
Your Communication with Us:
We collect information when you communicate with us. The specific types of information we collect will depend on the forum in which you communicate with us. For example, if you send us an email or fill out a contact form on our Website, we will collect your email address and the content of your email or form responses.
What Information Do We Collect and How Do We Use It?
The information we collect from you will depend on how you use our Testing Platform and our Website. Generally, we collect information directly from you when you voluntarily provide it to us.
Our Testing Platform:
1. Ask permission to access your mobile device camera
The Testing Platform will ask permission to access your mobile device camera to enable you to scan the QR code on your COVID-19 test cartridge or package. If you do not enable this permission, you will not be able to use the test platform. The Testing Platform only uses this permission while activating your test to obtain test cartridge information by reading the QR code if you choose to do so. The Testing Platform does not access any photos stored on your device and does not write to your device’s photo storage. Users who grant this permission can disable it at any time through their device’s app settings, but may not start the test if not enabled while performing a CLEO™ ONE test.
2. Ask permission to access GPS and to use location information
If required, we may collect information in connection with our governmental reporting obligations (which also includes deidentified demographic information) and zip code-level regions (or unidentified geographic units) of test results for public health reporting. We may also create de-identified information for internal, reporting and/or research purposes. The Test Platform may ask permission to use the location information or GPS information of the user's mobile device to get the user's consent.
3. Ask permission to use Bluetooth
The Testing Platform will ask permission to use the mobile device Bluetooth to operate the CLEO ONE device and perform the Test. While the test is being performed, the mobile device uses Bluetooth to connect with CLEO ONE device. The App may check the Test process steps of the CLEO ONE device and obtain the test results by Bluetooth pairing communication with the device.
4. Ask permission to access storage
The App may collect the test taker's name, date of birth, gender, and location information provided by the mobile device, the serial number of the test device, lot information and expiration date of the test cartridge, and the date and time when the test was performed.
In order to write, read, and store test results transmitted from the test device, the App may ask permission to access the storage of the mobile device. The App stores your test results (“positive,” “negative” or “invalid” results) and your test records in the App storage. If the user deletes the App, the user may permanently lose the previous test results stored in the app storage.
Information Received From Third Parties:
CLEO™ ONE receives information from third party providers as part of delivery and operational services necessary to provide customers with the expected functionality of the Testing Platform. These partners include, but are not limited to: physicians who provide lab testing requisitions and telehealth services.
Information from Cookies and Similar Technologies.
A cookie is a small piece of data that a website can send to your computer's internet browser, which is then stored on your computer's operating system. Cookies are how websites recognize users and keep track of their preferences. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Please review your web browser's "Help" file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Website, you may not be able to utilize the features of the Website to their fullest potential.
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we CLEO™ ONE such a signal from your browser. When our website cleo1.net a Do Not Track signal from your browser, it will still collect referring and exit page information and other information when you visit our website.
Information Automatically Collected
As with most apps and websites, when you use our Website or Testing Platform we automatically receive and collect information about you and your device. This information includes the following:
Information about your device, such as the operating system, hardware, system version, the Internet Protocol (IP) address, device ID, and device language.
The specific actions that you take when you use our Website or Testing Platform, including but not limited to: the pages and screens that you view or visit, search terms that you enter, and how you interact with our Website or Testing Platform.
The time, frequency, connection type, and duration of your use of our Website or Testing Platform.
Information about your wireless and mobile network connections, such as mobile phone number, service provider, and signal strength.
Location information, such as GPS information.
Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below); and
Pages you visited before or after navigating to our Website.
How We Use Your Information
In general, we collect personal information from you so that we can provide our Website and Testing Platform, operate our business, and provide information that you request from us. This includes the following uses and purposes:
Create and administer your account.
Provide testing services via our CLEO™ ONE services.
Provide, operate, improve, maintain, and protect our Website and Testing Platform.
Provide you with technical and other support.
Send you services and company updates, marketing communication, service information, and other information about our company and our services, and products and services of third parties that we think you may be interested in.
Conduct research and analysis, and monitor and analyze trends and usage.
Enhance or improve user experience, our business, and our services, including the safety and security thereof.
Send you push notifications through our mobile app.
Personalize our services to you.
Communicate with you and respond to inquiries.
Operate our business and perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Website and Testing Platform.
As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
CLEO™ ONE, prevent, or otherwise address fraud, security or technical issues.
Protect against harm to the rights, property or safety of CLEO™ ONE, our users, customers, or the public as required or permitted by law.
How Do We Share Information?
Third Party Vendors
We may have contractual agreements with affiliates, services providers, partners, and other third parties who may use the information described in this policy to operate our Website, and to develop, market, and provide our products. Any information collected or used by third party vendors is limited to the collection described in this policy, and may be used only for the purposes described. Additionally, if you use our CLEO™ ONE services, we may contract with third-party laboratories. Please note that laboratories may be subject to mandatory governmental reporting obligations, so information relating to those test results may be disclosed to governmental agencies where required.
Change in Control or Sale
Legal Process, Security, Defense, Protection
Occasionally, we may be required to share information with third parties for legitimate business purposes, or to comply with legal obligations. For example, we may share information when we believe in good faith that an applicable law requires it; at the request of law enforcement, judicial authorities (e.g. upon receipt of a court order or subpoena), or appropriate governmental authorities; to CLEO™ ONE and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety or security of third parties, visitors to our Website, our businesses, or the public. We may also disclose personal information when requested by state and federal governmental authorities or related entities to assist in efforts to track COVID-19 infections.
Retention of Personal Information
We generally retain your information as long as necessary to provide relevant services to you, comply with our legal and internal retention obligations and procedures, comply with governmental reporting obligations, and as permitted by law.
Security of Your Information
We use reasonable security measures, including measures designed to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage to your personal information. We also take certain measures to enhance the security of our services, however, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.
Your Privacy Choices
Individuals who create an account through our Website or Testing Platform can access and amend that information by logging into their account. Users who wish for CLEO™ ONE to delete all information about them should contact firstname.lastname@example.org or call +82 (70)7605 5066. Please note that in some cases we may not be able to delete some or all of your information.
Our Website and Testing Platform are not directed at children under 13, and we do not knowingly collect personal information from children under 13. If you are under 13, please do not attempt to use our Website or Testing Platform or send any information about yourself to us. If you are the parent of a child under the age of 13, and you believe he or she has shared personal information with us, please contact us at email@example.com so that we can remove such information from our systems.
If you have questions on the processing of your personal information, or have a complaint, please contact us here: firstname.lastname@example.org