Hansel Medical Inc., Inc respects and actively protects your privacy. Hansel Medical Inc. (“Hansel”, “Hansel Medical”, or the “Company”) offers medical asset tracking, equipment management, and case scheduling to the users of app.completeor.com (the “Platform”) and/or users of Hansel’s mobile applications (the “Application” or “)(collectively referred to as the “Services)”). When you use our services, we know you are trusting us with your information. We understand that is an important responsibility and we work hard to ensure your information and data are protected.

This privacy policy is meant to help you understand what information we collect, why we collect it, and how we collect it. This Privacy Policy covers:

  • User Accounts & Accessing the Services
  • Information that is being collected
  • Why Hansel collects data
  • Visibility
  • Integrating with other third party services
  • How Hansel retains data we collect
  • How does Hansel use aggregated information
  • Cookies
  • Information security
  • Compliance & cooperation with regulators
  • Changes to this Privacy Policy

This Privacy Policy is incorporated as part of the Hansel Terms of Use and (the “Terms of Use” or the “Terms”). Your use of the Services is subject to the Terms of Use, Copyright Policy and this Privacy Policy and indicates your consent to them.

To use our Services you must be 16 years of age or older. If you are under 16, you may not download or use the Services.

In this Privacy Policy, the term “personal information” means information which you provide to us which personally identifies you, such as your name, email address or billing information, and, in certain circumstances, your location and or other data which can be reasonably linked to such information by Hansel.

Contact Hansel about privacy concerns

If you have any questions about this Privacy Policy, or if you believe that your privacy has been compromised in the course of using our Services, please contact us at [email protected].

User Accounts & Accessing the Services

In order to use and benefit from Hansel Services, you must register an account (the “Account” or “Hansel Account”) upon invite from Hansel by way of a Hansel team member or an administrative user (the “Administrator”, “Organizational Administrator”, “Facility Administrator”, “Org Admin”, or “Admin”) from your company organization (the “Organization”). Please note that after you install the Application on your mobile device and register for an account, Hansel will collect and use your information you provide, including meta-data (as described below), in accordance with this Privacy Policy. This may include linking your personal information provided with your Hansel account.

When you establish an Account in the Application:

Hansel will link all of your information with your Hansel Account. This includes information from all devices running the Application or Website which you have chosen to sign in using your account credentials.

With the exception described in the bullet below and as explained in the section “Visibility” below, your Account information associated with your Account will only be visible to Hansel and Administrators of your Organization; and

When using the Application, your approximate location and other information linked to your Account may be visible to other Service users associated with your Organization.

Your login details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your login details to someone else. You must maintain your login details in absolute confidentiality and avoid disclosing them to others. Make sure you change your password at least once every six months to avoid compromising your Account.

Information that is being collected

We want you to understand the types of information we collect as you use our services. We value your trust in Hansel and pride ourselves on our integrity.

Hansel collects information for the sole purpose to provide better services to all its users - from tracking your location when Equipment (the “Equipment”) is in your possession, to scanning for any nearby Equipment associated to the Platform for up-to-date Equipment location, to improve the Service’s reliability and performance, to notifying you when Equipment is idle or has arrived at the designated location on-time for an upcoming case. The information Hansel collects is vital to the betterment of the Service and for all of its users. How you choose to use the Service and manage your privacy will affect the benefits to your Organization, its users, and the all Hansel users of the Service.

Information you provide to us:

Account information: information required when setting up an account such as your user type, first and last name, email, mobile number, company role, and company. Keep in mind that any false, incorrect, or out-dated information may hinder Hansel’s ability to provide with Services and may contact you if necessary. Hansel will indicate the fields that are mandatory for completion. If you do not provide the required information, you may not be able to establish an active Hansel account on the Platform or be provided features of the Service.

Information that you choose to share with Hansel: information that you choose to share with Hansel, including your account information listed above, Equipment within your Organization, hospital accounts (the “Facility” or “Location”) associated to your Organization, addresses of your Organization warehouses (the “Warehouse” or “Location”), Equipment serial numbers, Equipment model numbers, Equipment images, Equipment checklists or inventory sheets, Equipment notes, calendar information, surgery case numbers, surgery case dates, assigned surgery case reps.

Information we collect as you use our services

We collect information about your activity in the Service, which we use to provide you with the Services of Hansel. This includes things like Equipment you are associated to, cases you may need to be notified or updated on, Equipment arrival to hospitals of cases you are assigned.

User location information. Location information is collected from GPS, WiFi, Bluetooth, and cellular network information that is sent by your mobile device on which the Application is installed and has an active user session. This location information is saved to the Platform solely for purposes of improving the Services for all Hansel users. Your user information will only be visible to your Org Admins and Hansel. This location information will never be shared with or distributed to any outside parties without written consent from the customer Organization.

Equipment location information. Hansel tracks Equipment that is created on the Platform and is transported with you or is in your proximity, at all times, while the Application is installed and active on your mobile device. Your mobile device scans for Bluetooth Low Energy (BLE) broadcasts from Equipment. The nearby Equipment broadcast data is collected and processed by your device, the location is correlated, and the information is sent to the Platform with the date and time for processing. This a fundamental need for the Service to operate. When there is no Equipment near (i.e. no BLE broadcasts from Equipment being detected by your phone) you and your Application session is active, Hansel will not make your location information available on the Platform but may use that data to improve the performance of the Services. In short, Hansel will not share your location data when there is no Equipment near your mobile device and will only share your location data to your Organization when Equipment is near you and owned by your Organization.

Visited location information. When you visit a Location that has Equipment inside its geofence. Your device will provide the Location information with the above Equipment and User location data and practices. This allows the Platform to provide the current Location for Equipment.

Platform search. Hansel may collect your history of terms, users, Equipment, or Locations you have searched, viewed, or edited to optimize the Service.

Third-party integration activity. Your activity or information on third-party services that you may be integrated with the Platform (e.g. your Organization’s existing inventory management system).

Meta-data (information about your device, browser and app use):

Once you install the Application or log into through the Platform, Hansel collects information about the use of Services and information from the device Hansel is accessed on. For example:

Hansel may collect and record how often you use the app and for how long, your device type, unique identifiers, operating system type & version, battery usage, third party web pages or applications you visit or use or interact with via the Application, information viewed on our Services, the Internet Protocol (IP) address and the name of the domain that serves you to access the Services, and the geographic location of the device that you are using to log in and use Hansel on.

Hansel may also collect information about apps installed on your device that Hansel can link with - such as third party navigation apps (e.g. Google Maps, Waze, Apple Maps).

We also collect information about the interaction of your devices with our Services, including, crash reports, system activity, and the date, time and referrer URL of your request.

Why Hansel collects data

Hansel may use information collected from or provided by you for the following purposes:

  • To provide our services
  • We use your information to deliver our services. For example: Use your location information to provide accurate Equipment location.
  • Use your search query information to provide suggested Equipment of importance to you.
  • To provide alerts and notifications based on Equipment states.

 

To maintain & improve our services

We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues you report to us. And we use your information to improve the service or to develop new features or services. For example, Hansel may use your location information to improve the accuracy and reliability of its tracking data.

To measure performance

We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your usage of the Services to do things like optimize product design.

To communicate with you

We also use your information to send you updates, notices, announcements, users’ requests and additional information related to the Services (including through push notifications, email address and SMS);

We may also use your information to conduct surveys and questionnaires; And if you contact Hansel we may keep a record of your request in order to help solve any issues you might be facing.

Subject to your prior indication of consent (to the extent required under applicable law), we may also use the email address that you provided to send you promotional and/or marketing materials. At any time you may choose not to receive such materials by clicking on the “Unsubscribe” link in the email messages that we may send to you. In any case, Hansel will not share your contact details with any advertiser, unless explicitly permitted or required by law.

To protect Hansel, our users, the public and for Legal reasons

We may also use and process your information and content, using different technologies to the following purposes:

To enforce the Terms of Use or Privacy Policy;

To contact you when Hansel believes it to be necessary;

To comply with any applicable law and assist law enforcement agencies under any applicable law, when Hansel has a good faith belief that Hansel’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;

To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;

To handle breakdowns and malfunctions;

To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services;

For purposes provided under this Privacy Policy and Terms of Use;

To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm Hansel, our users, or the public;

To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does Hansel use aggregated information”, below;

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

Visibility

Please note that your username (first and last name) will be visible to other Hansel users within your Organization. If you transport Equipment owned by your Organization, your username will be logged and visible to others on the landing page map, Equipment lists, Location inventory lists, and any other areas where that Equipment is currently located and all previous locations. Also - your colleagues on Hansel will see your name & profile photo of the Equipment you transport for the Organization.

Integration with other third party services

Hansel may integrate with a third party software service your Organization is using in other capacities such as help manage inventory, case scheduling, location or shipping status, billing or other similar activities. In the event of this occurring, your location information associated to Equipment you move may become accessible to those software packages. If your Organization chooses to connect the packages, Hansel will ask for your Organization’s permission to share the data with the third party service. These integrations are done at the Platform level but may communicate Equipment statuses based on Equipment movement you generate. Hansel is not responsible for the third party’s use of data. Your Organization can disconnect Hansel from a third party service at any time and Hansel will cease sharing data with that service from the point of disconnection onwards.

Controlling your personal information

You can always review and update certain information associated with your Account by editing your profile (such as your phone number, email, photo, and more). From the web Platform this can be done by clicking your username in the upper right corner, then clicking edit profile. On the mobile app, select the left menu button in the upper left corner, then click edit profile. Note, if you are a Rep or Courier user, you do not have access to the Hansel Platform. You will only have access to the Application.

If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up a username and impair the ability to provide you with Services.

Privacy controls

Your privacy is protected by the preceding information in the Privacy Policy. Hansel will not intentionally do anything to compromise your data and information.

There are other ways to control the information Hansel collects whether or not you’re signed in to a Hansel Account, including device-level settings: your device may have controls that determine what information we collect. For example, you can modify location settings on your device. We do not recommend changing these settings. In doing so, the Service provided will not function as intended.

Deleting your information

If you would like to delete your account you can do so by contacting your Org Admin or email Hansel at [email protected]

How Hansel retains the data we collect

The data you generate through the use of Hansel Services is owned by your Organization and the historical information is kept by Hansel for the Organization’s records. Some data may be deleted automatically and other data may be retained for longer periods of time when necessary.

Data that expires after a specific period of time - in some cases, your Organization will not actively need to request the deletion of data collected and retained by Hansel. Hansel has retention timeframes and may delete historical data for data storage purposes. If your Organization would like to retain that data before it is deleted please send us a request at [email protected].

Information retained until your Organization is deleted - we may keep some data for the life of your Hansel Account if it’s useful for helping us understand how users interact with our features and how we can improve our services. For example, we may keep information about where Equipment has traveled over a certain period of time previously to build reporting and analytics features for current and future users.

Information retained for extended time periods for limited purposes - sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when Hansel processes a payment for the Organization, we’ll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include:

  • Security, fraud & abuse prevention
  • Financial record-keeping
  • Complying with legal or regulatory requirements
  • Ensuring the continuity of our services
  • Direct communications with Hansel

 

How does Hansel use aggregated information?

Hansel may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).

Hansel may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/or anonymous form to help improve the map and solve map problems.

Cookies

Hansel may use cookies and similar technologies on the Services. Cookies are packets of information sent by the Website’s servers to your web browser and then sent back by the browser each time it accesses the Website’s servers.

Hansel may use cookies for various purposes, such as to save you the need to re-enter your username and password each time you log in, to facilitate the use of the Website, to collect statistical information, to verify information, and to customize the Website to your personal preferences and for information security purposes.

Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.

Information security

Hansel considers information security to be a top priority. Hansel services are built with strong security features that continuously protect your information. Hansel implements systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to Hansel employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.

However, these measures are unable to provide absolute assurance. Therefore, although Hansel takes great efforts to protect your personal information, Hansel cannot guarantee and you cannot reasonably expect that Hansel’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Compliance & cooperation with regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data Transfers

We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

Changes to this Privacy Policy

Hansel may from time to time change the terms of this Privacy Policy. Substantial changes will take effect 30 days after Hansel has posted a:

System message to users notifying them of changes to the Privacy Policy; and

Notification on the Website’s homepage or any other relevant web pages, explaining the changes to the Privacy Policy alongside a comparison of the “old” and “new” versions of the Privacy Policy.

Other changes will take effect 7 days after their initial posting on the Website. However, if Hansel amends this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the Services