SmartDrive MX2+ and PushTracker (collectively PushTracker System) Privacy Policy

When you register to use the PushTracker and SmartDrive MX2+ System, Permobil collects and processes Personal Information, including name, email address, age, username, and password. In addition, Permobil collects the information you provide through your use of the system, including contact information and personal characteristics. The PushTracker System requires access to Bluetooth to connect with your SmartDrive device in order to properly work as intended.

PushTracker (Android): https://play.google.com/store/apps/details?id=com.permobil.pushtracker
PushTracker (iOS): https://apps.apple.com/us/app/pushtracker/id1121427802
SmartDrive MX2+ (WearOS): https://play.google.com/store/apps/details?id=com.permobil.smartdrive.wearos
SmartDrive MX2+ (WatchOS): https://apps.apple.com/us/app/smartdrive-mx2/id1575416237

To connect with, configure, and control your SmartDrive using Bluetooth the PushTracker app requires access to the Coarse Location permission. From this permission Permobil will not be accessing any location data.

• To provide you with the PushTracker System and to manage our relationship with you regarding the product

Identity Information
Identity information includes your first name, last name, username or similar identifier, date of birth, and gender. We collect identity information when you, your dealer, or your clinician reaches out to us for services, when you make a request, or when you lodge a complaint. In some cases, we receive your identity information from your dealer or clinician when your product order is placed. For the PushTracker and SmartDrive MX2+ System, this information may be optionally provided by you within the PushTracker app. Permobil does not use this information without your consent.

Contact Information
Contact information includes your email address. We collect your contact information when you reach out to us for services, to make a request, or to lodge a complaint. In some cases, we receive your contact information from your dealer or clinician when your wheelchair order is placed.

In most cases, we collect this Personal Information as a processor or business associate of your dealer or clinician; however, there are instances where we act as a controller or non-covered entity health care provider when processing this information, such as with complaint handling, product maintenance, and accounting processes.

Usage Information
Usage information includes details about how you use your SmartDrive MX2+. This includes your SmartDrive MX2+ battery level, drive distance, and configuration data. If you use the SmartDrive MX2+ and have provided your consent, we collect your usage information from your SmartDrive MX2+.

Sign-in Information
Before you may enroll to access our software and apps, you or your clinician will need to register for an account with the PushTracker app. Personal Information collected in the registration process includes your name and email address.

Limited Health Information
If you have registered for any of our online services, we collect information on behalf of the clinic or health services provider that you have chosen to deliver and maintain our Products, including information about your use of our Products, please see the Our Products section for further information about what type of information related to Our Products that we collect.

In conducting business, we will receive and create records containing limited health information. Any health information collected is not combined with data from other Products or used for other purposes without your explicit consent. For example, we will not use your health information to market or advertise our Products to you without your explicit consent.

Information from Device Sensors
Permobil offers SmartDrive MX2+ devices with sensors that will collect data about your mileage, battery status, configuration information, and diagnostic data. These data are not collected or used without your consent, which you can provide or deny at any time within the PushTracker app.

Location Information
The PushTracker and SmartDrive MX2+ system do not collect location information about you or your device. The PushTracker and SmartDrive MX2+ apps access Bluetooth to communicate with your SmartDrive MX2+ and PushTracker devices - for which they need access to the location permission.

• Directly from you or from your dealer or clinician.
• Collected from device sensors.

Consent

We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your Personal Information. If you have any questions about your right to erasure, please contact us. We may not be able to erase Personal Information from backups.



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