Privacy Policy
Autonomous Healthcare Inc. (“AHI”, or “we,” “us,” or “our”) provides the website located at www.countra.ai and mobile application available to download from the Google Play store and Apple App Store (the “Site”). We respect the importance of your privacy, and we have created this Privacy Policy to set forth our privacy practices and policies.
As used in this Privacy Policy, your “information,” “personal information” or “personal data” as used in this Privacy Policy means any information relating to an identified or identifiable individual. If you are located in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”), we are the data controller of your information, personal information and personal data.
This policy applies to information we collect on this Site and in email, text and other electronic messages between you and AHI through or regarding this Site. It does not apply to information collected by AHI offline or through any other means, including on any other website operated by AHI or any third party.
BY USING OR ACCESSING IN ANY WAY THE SITE, YOU ASSENT TO THIS PRIVACY POLICY. If you do not agree with the terms of this Privacy Policy, you are not permitted to use the Site.
DISCLOSURES SPECIFIC TO AUTONOMOUS HEALTHCARE CUSTOMERS
In the course of providing our products and services (collectively, “Services”) to our customers (“Customers”) pursuant to our Terms of Service, AHI acknowledges that it may have access to Protected Health Information (“PHI”) and that it is a Business Associate to the extent required under the Health Insurance Portability and Accountability Act, Public Law No. 104-191 (“HIPAA”). AHI and Customer agree to comply with the terms of the then-current AHI Business Associate Addendum (“BAA”). The BAA is deemed incorporated into, and a part of, the Agreement (as defined in the Terms of Service) by this reference and supersedes controls over any contrary term of this Privacy Policy or other document comprising the Agreement.
In addition, AHI may collect other personal information (besides PHI) under the direction of its Customers and has no direct relationship with those individuals whose personal data it processes in such circumstances. We will use and disclose your personal information as provided in the Agreement regarding such Services with the Customer, which may differ from the terms of this Privacy Policy. If you are an employee, contractor, agent, and/or user of one of our Customers and would like more information about our use and disclosure of your information, or if you wish to correct, amend or delete inaccurate data, please contact that Customer.
INFORMATION COLLECTION AND USE
When you use the Site, or when you correspond with AHI regarding the Site, we will collect or obtain certain personal information from you:
● Personal Contact Information. We collect basic information about you (including your name, telephone number, time zone, type of computer or mobile device you use and e-mail address) in order to be able to process and notify you about your request, to provide service and support, to operate and improve our business and services, and to communicate with you, including for marketing purposes. For information about updating your communication preferences, please see “Promotional Communications” below. We will disclose this information to third parties who provide services to us (“Service Providers”) who need it for these purposes. We will not sell or provide this information to a third party for their own marketing purposes unless we obtain your consent.
● Device and Usage Data. We use common information-gathering tools which may contain details of your visits to our Site, including traffic data, location data, logs and other communication data and the resources that you access and use on the Site (behavioral tracking). We also collect information about your computer or mobile device and Internet connection, including your IP address, operating system and browser type. In addition, when we send you emails, we may use embedded pixels or similar technology to track information about your receipt of the emails and your interaction with them (such as whether, when and for how long you opened the emails, or clicked on any links in them, or forwarded them to someone else, your general location and information about your device), so that we can learn from and improve our communications with customers and users, and to improve our products and services. For more detailed information, please see “Cookies and Other Information Gathering Tools” below.
● Feedback. From time to time, we may ask you to provide, or you may otherwise provide to us, evaluations, submissions, suggestions, ideas, recommendation and other feedback regarding the Site or AHI products or services (“Feedback”). Your provision to us of Feedback is at your discretion; if you choose to provide any Feedback to us, you agree that it may be used internally by AHI without restriction for any of its business purposes, including enhancement and modification of products and services, without any obligation to compensate or reimburse you. AHI may also disclose Feedback to our Service Provider(s), and we also may use your comments in our marketing and promotional materials (including on this Site) but will not disclose any personal information in the Feedback to any other third party (including publicly giving attribution to you) unless otherwise provided in this Privacy Policy or you have given us permission to do so.
LEGAL BASIS FOR PROCESSING IN EUROPE
If you are located in Europe, we process your personal data only when we have a legal basis to do so. The legal bases we rely on may include one or more of the following:
1) the provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;
2) where it is necessary for compliance with our legal obligations as set forth in applicable law;
3) for our legitimate interests (this includes our own legitimate interests and those of other entities and branches in our group of companies) such as the following (provided these are not overridden by your interests and fundamental rights and freedoms):
a) to contact you and respond to your requests and inquiries;
b) for business administration, including statistical analysis;
c) to provide the Site and any products and services to you; and
d) for fraud prevention and detection purposes; and
e) to comply with applicable laws, regulations or codes of practice.
We may also process your personal data on the basis of your consent. You are entitled under Data Protection Law to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may adversely affect your ability to access and use the Site.
COOKIES AND OTHER INFORMATION GATHERING TOOLS
AHI and our Service Providers may collect personal information using cookies (small text files that we store on your browser or computer or mobile device), pixel tags and web beacons (graphic images), or other information-gathering technologies (collectively, “Cookies”) on the Site and in our emails for various purposes. Cookies help us to determine whether you have performed a specific action. We also use Cookies to distinguish you from other users of the Site and to collect information about your browsing activities which can help enhance your experience in using the Site and help us to improve the Site’s functionality (for example, by remembering preferences and log-in details) and to analyze how our Site is being used in order to improve its performance information.
Below is an overview of the types of Cookies we and third parties may use on our Site and in our emails to collect personal information:
Strictly Necessary Cookies: These Cookies are essential to use the Site; you cannot use the Site without these Cookies. We use the following Strictly Necessary Cookies:
Authentication Cookies (AWS Cognito/Amplify)
idToken
• Name: idToken
• Purpose: Contains user identity information and claims for authenticated sessions
• Provider: AWS Cognito (via AWS Amplify framework)
• Lifespan: Session-based (typically 1 hour, cleared on logout)
• Data Type: JWT token containing user identity claims and authentication status
accessToken
• Name: accessToken
• Purpose: Authorizes API requests and resource access for authenticated users
• Provider: AWS Cognito (via AWS Amplify framework)
• Lifespan: Session-based (typically 1 hour, cleared on logout)
• Data Type: JWT token for API authorization
clockDrift
• Name: clockDrift
• Purpose: Compensates for time differences between client and server for token validation
• Provider: AWS Cognito (via AWS Amplify framework)
• Lifespan: Session-based (cleared on logout)
• Data Type: Time offset value for clock synchronization
LastAuthUser
• Name: LastAuthUser
• Purpose: Remembers the last authenticated user for improved user experience
• Provider: AWS Cognito (via AWS Amplify framework)
• Lifespan: Persistent until logout or manual clearing
• Data Type: User identifier for login convenience
signInDetails
• Name: signInDetails
• Purpose: Stores authentication method and sign-in related information
• Provider: AWS Cognito (via AWS Amplify framework)
• Lifespan: Session-based (cleared on logout)
• Data Type: Authentication method and sign-in metadata
Functional Cookies: Also known as “preference” cookies, these Cookies allows us to remember choices you have made on the Site in the past so that we can adapt our content for you and remember your preferences. We use the following functional Cookies:
Authentication Cookies (AWS Cognito/Amplify)
refreshToken
• Name: refreshToken
• Purpose: Used to obtain new access tokens without requiring user re-authentication
• Provider: AWS Cognito (via AWS Amplify framework)
• Lifespan: 30 days (cleared on logout)
• Data Type: Refresh token for maintaining authenticated sessions
You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block Cookies (including Strictly Necessary Cookies), you may not be able to access all or parts of our Site or be able to use the Site in the manner intended. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Site using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.
PROMOTIONAL COMMUNICATIONS
We may contact you with special offers, promotional deals, newsletters, other marketing announcements regarding AHI and our service offerings. If you wish to opt-out of any such promotional communications, simply contact support@countra.ai or select the “unsubscribe from email” located at the bottom of the email you received from AHI.
INFORMATION DISCLOSURE
● Service Providers. AHI uses Service Providers to perform certain of the technical processing, administration and support of the Site and services. Such Service Providers generally are permitted to use and disclose your personally identifiable information only as provided in this Privacy Policy. However, with respect to certain services, some Service Providers may have their own privacy policies that will apply to their use or disclosure of your information obtained through those services. You will be notified of any other privacy policies or terms when you sign up for or access or use these services.
● Others. AHI and its Service Providers reserve the right to disclose information about you, including the content of your communications through the Site, in order to: (a) comply with the law or respond to lawful requests or legal process; (b) protect the rights or property of AHI, its providers, suppliers and licensors or other clients or third parties; or (c) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of AHI, its providers, suppliers and licensors or other clients or third parties.
INFORMATION RETENTION
AHI will retain your personal information as needed to (a) fulfill the purposes for which it was collected or obtained, (b) comply with our business requirements or legal obligations, (c) resolve disputes, (d) protect our assets and interests, and (e) enforce our rights and agreements.
For individuals based in Europe, we store personal data (unless otherwise required by law) for as long as necessary to fulfill the purposes for which we collect the data which we determine based on various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.
LINKS TO OTHER SITES
The Site contains links to third party sites that are not owned or controlled by us. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies only to information collected, retained and accessed by the Site, including services available through the Site. In addition, certain Service Providers may have their own privacy policies that will apply to certain services, as described above.
SECURITY
We take precautions including organizational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal information we process or use. While we follow generally accepted standards to protect personal information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of the Site and any applications and services after your sessions. If you have any questions about the security of our websites, please email us at support@countra.ai.
BUSINESS TRANSITION
We may transfer your information to service providers, advisors, potential transaction partners and other third parties in connection with the discussion, negotiation, execution and/or performance of a transaction in which we are acquired by or merged with another company, or we sell, liquidate or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.
INTERNATIONAL DATA TRANSFERS
Personal information collected through the Site and/or the Services may be stored and processed in the United States or in any other country in which AHI or its providers (or its or their affiliates or providers) maintain facilities. By using the Site and/or the Services, you consent to any such transfer and processing of information outside of your country. If you are located in Europe or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy, including by transferring personal information to countries which have been found to provide adequate protection by the competent authorities as appropriate, use contractual protections for the transfer of personal information based on European Commission-approved or UK Government-approved Standard Contractual Clauses, transfer to recipients who have adopted Binding Corporate Rules, or rely on an appropriate legal derogation. If you wish to inquire further about these transfers, or to obtain a copy of the contractual safeguards we use for such transfers (if applicable), please contact us at support@countra.ai.
CONSENT TO ELECTRONIC COMMUNICATIONS
By using the Site or otherwise providing personal information to us, you agree that we may communicate with you electronically (including by posting a notice on the Site or by sending you an email) regarding security, privacy and administrative issues relating to such use, including but not limited to notifying you of a security breach.
YOUR PRIVACY RIGHTS AND CHOICES
Subject to applicable law, you may have certain rights regarding your personal information.
Data Deletion Requests
You have the right to request that we delete personal information we have collected from you. However, this right is not absolute. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
a) Comply with a legal or regulatory obligation, such as retaining records for healthcare or DEA compliance audits.
b) Complete the transaction for which we collected the personal information.
c) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
d) Debug products to identify and repair errors that impair existing intended functionality.
e) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
To submit a data deletion request, please email us at support@countra.ai. We will review your request and will notify you if your request is denied and the basis for our denial.
For individuals in Europe, please see the section below for rights that may apply to you.
FOR RESIDENTS IN EUROPE
If you are located in Europe, you have the following rights in respect of your personal data that we hold:
a) Right to object. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON WHATSOEVER.
b) Right of access. The right to obtain access to your personal data.
c) Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
d) Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
e) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
f) Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
g) Withdraw consent. You may withdraw any consent you previously provided to us regarding the processing of your personal data at any time and without charge, and we will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.
If you wish to exercise one of these rights, please contact us at support@countra.ai. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that if you do exercise one of these rights, your ability to access or use the Site may be impaired.
You also have the right to make a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at National Data Protection Authorities.
CHILDREN’S PRIVACY
We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of our Site or Services is directed to children. If you learn that a child has provided us with personal information, then you may let us know at support@countra.ai.
TERMS OF USE
Your use of the Site is governed by our then-current Terms of Use.
CHANGES TO THIS POLICY
AHI may update this Privacy Policy from time to time, and when we do, we will also revise the “last updated” date at the top of this Privacy Policy. If we consider any change to this Privacy Policy to be material, we will place a prominent notice on the Site or we may notify you directly by e-mail, at our discretion. Changes are effective upon posting to the Site, unless we say otherwise in our notice, so please check this site often for changes.
HOW TO CONTACT US
Please feel free to contact us at support@countra.ai to assist in updating your personal information or if you have any questions regarding this Privacy Policy.
