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Privacy Policy

Last updated: November 12, 2025

Table of Contents

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to My Movement RX, the software program provided by the Company.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Remote Monitoring LLC, 3865 West Front St, Traverse City, MI 49684.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: Michigan, United States
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Application or the Website or both.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to My Movement RX, accessible from https://mymovementrx.com/
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

GDPR/UK-GDPR Applicability

Our services are intended only for users in the United States. We do not offer our services to individuals in the European Economic Area (EEA) or the United Kingdom, and we do not monitor their behavior. Accordingly, based on Article 3 of the EU GDPR and UK GDPR, those laws do not apply to our processing at this time.

If we expand to serve users in the EEA or UK, we will update this Privacy Policy and implement all required GDPR/UK-GDPR measures (e.g., appropriate notices, rights handling, data protection impact assessments where needed, and—if applicable—appointment of an EU/UK representative and appropriate transfer safeguards).

Collecting and Using Your Personal Data

Data Minimisation

We collect and process only the minimum personal information necessary to provide our services. For each purpose described in this Policy, we identify the specific data elements required and do not collect more than is needed. We do not collect sensitive categories unless strictly necessary and lawful. We limit access to personal information to those who need it, and we retain it only for as long as required for the stated purpose (see Retention). If we change our purposes, we will update this Policy before collecting any additional data.

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

In addition to the above, we collect the following categories of information to provide the Service:

  • Identifiers: Email address or phone number (used for authentication), and a unique internal account ID.
  • Device and Application Data: Device model, operating system, application version, and push notification token (required to deliver chat notifications).
  • Usage and Diagnostics Data: Service event logs, crash reports, and performance metrics used to maintain service reliability and troubleshoot issues.
  • User-Provided Content: Chat messages and any attachments you send, as well as responses to programmed alerts (e.g., “How are you feeling today”).
  • Support Information: Any information and attachments you voluntarily provide when you contact our support team.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

If you choose to upload a photo or file to the Service, we will request your prior permission to access your device’s camera and/or photo library for that specific action only. You can enable or disable access to this information at any time through your device’s settings.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Free Privacy Policy website article.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: by email, SMS, or in-app push for service/transactional purposes (e.g., sign-in/verification codes, security or service alerts) and to deliver push notifications for chat messages.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers (acting on our behalf): We may share your information with trusted service providers that process it under our instructions to (i) monitor and analyze use of our Service, (ii) provide advertising and remarketing across Google and Meta advertising networks (e.g., Google, YouTube, Facebook, Instagram) and their partner sites and apps, based solely on visits to our public website (never on in-app, patient, or health information), (iii) process payments, and (iv) contact you for service and support purposes where permitted by law. We require these providers to keep your information confidential, use it only to provide their services to us, and to implement appropriate security measures.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Changes of Purpose

If we intend to collect, use, or disclose personal information for a new purpose that is materially different from, unrelated to, or incompatible with the purposes described in this Policy, we will update this Policy to describe the new purpose before we begin that processing and will notify you via in-app notice and/or email. Where required by law, we will also request your consent before using your information for the new purpose.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

  • Chat history: retained for 6 months, then deleted, subject to lawful holds.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

Where and How We Store Data

We store personal information on your device (e.g., session tokens in Android Keystore / iOS Keychain) and on secure cloud servers, including Amazon Web Services—Amazon S3 for media and Amazon Pinpoint for service analytics—and PubNub for chat history. Our application data is held in MySQL 8.0 on secured servers.

All data is protected in transit (TLS/HTTPS) and at rest (e.g., S3 server-side encryption with AES-256 by default; PubNub TLS 1.2+ and encryption at rest; MySQL InnoDB data-at-rest encryption via keyring). Chat messages are retained for 6 months before deletion.

 

Health App Declaration

Activity and Fitness:

  • Users can track their physical activity, exercise routines, and fitness progress.
  • Features may include step counting, workout logging, and goal setting.

Healthcare Services and Management:

  • Users can access healthcare-related information, such as medical articles, symptom checkers, or appointment scheduling.
  • Features may include telehealth services, health records, or medication reminders.

Physical Therapy and Rehabilitation:

  • Users can receive guidance on exercises, rehabilitation routines, and recovery plans.
  • Features may include personalized PT exercises, progress tracking, and injury-specific content.

Data Breach Response & Notification

What we mean by a breach. A “personal data breach” is any security incident that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

Our response process. If we become aware of a potential breach, we will: (1) start our incident response; (2) contain and investigate; (3) assess risks to individuals; (4) document the incident and our actions; and (5) notify as required by law. We keep a breach log for all incidents, whether notifiable or not.

Who we notify and when (jurisdiction-specific):

– UK/EEA users (GDPR): If a breach is likely to risk people’s rights and freedoms, we’ll notify the relevant supervisory authority within 72 hours of awareness and inform affected individuals without undue delay where the risk is high. [ICO/GDPR guidance]  

– United States — HIPAA-covered data: If unsecured PHI is involved, we’ll notify affected individuals and HHS (and, when applicable, the media) without unreasonable delay and no later than 60 days after discovery. Business associates must notify us so we can meet these deadlines.  

– United States — health apps/PHR data not covered by HIPAA: We comply with the FTC Health Breach Notification Rule, including timely notice to users without unreasonable delay and in no case later than 60 days after discovery, and required notice to the FTC (aggregated annual filing for breaches affecting <500 people; faster for ≥500).  

– Michigan residents: We provide consumer notice without unreasonable delay and no later than 45 days after discovery (subject to lawful delays), and include the content elements Michigan law specifies. Where required, we also notify consumer reporting agencies if >1,000 residents are notified.

What our notices include. We explain what happened, what data is involved, steps we’ve taken, guidance for protecting yourself, and how to contact us.

Contact point. For breach-related questions, contact us at support@mymovementrx.com.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We use third-party Service Providers to monitor and analyze the use of our Service. We use Amazon Web Services (AWS) Amplify Pinpoint for analytics within our mobile application and Google Analytics on our public-facing website. This data helps us understand feature usage, improve service reliability, and troubleshoot technical issues. We do not use analytics data for targeted advertising or share it for marketing purposes.

Marketing and Promotional Communications


We do not use your personal information to send marketing or promotional communications. We only send service and transactional messages that are required for the operation of the Service, such as account verification codes, security alerts, and push notifications to deliver chat messages you request. If we ever decide to introduce marketing communications for registered users in the future, we will first request your separate, explicit, opt-in consent for each communication channel (e.g., email, push notification) before sending any such messages. You will have the right to withdraw that consent at any time.

Payments

We use third-party services (e.g., payment processors) to bill our Business Customers for the Service..

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Information from Prospective Business Customers and Website Visitors.

When you visit our public-facing website, request a demo, or otherwise interact with our sales and business development teams, we may collect professional contact information, such as your name, company, job title, and business email address. We process this information based on our legitimate business interests to respond to your inquiries, provide you with information about our services, and manage our business-to-business outreach in compliance with applicable laws, such as the U.S. CAN-SPAM Act. This processing is distinct from the data processing activities conducted to provide our services to registered users and their patients.

Advertising and Remarketing on Our Public Website

We use third-party advertising services, including Google Ads and Meta (Facebook) Ads, to market our services to other businesses. These services are used only on our public-facing website (mymovementrx.com) and do not apply to registered users of our Application.

These services may use cookies, pixels, and/or web beacons to:

  • Serve ads to you on other websites or social media platforms based on your past visits to our website (Remarketing).
  • Measure the effectiveness of our advertising campaigns by tracking actions you take on our website, such as submitting a ‘request a demo’ form (Conversion Tracking).

Third-party vendors, including Google and Meta, use this information to show our ads on sites and platforms across the Internet. You can manage your ad preferences for these services at the following links:

  • Google: You can opt out of Google’s use of cookies or device identifiers by visiting Google’s Ad Settings.
  • Facebook: You can manage your ad preferences and opt-out options in your Facebook Ad Settings.

Alternatively, you can opt out of many third-party vendors’ use of cookies by visiting the Network Advertising Initiative opt-out page.

 

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

Your Privacy Rights (United States)

Limit Processing (where applicable)

You may request that we limit certain processing of your personal information where applicable law provides that right (for example, while we verify accuracy, where processing is unlawful and you prefer limitation to deletion, or where we no longer need the data but you need it for legal claims). During a limitation we will store your data but will not otherwise use it except with your consent, for legal claims, to protect others’ rights, or as required by law.

How to exercise your rights: Email support@mymovementrx.com (subject: “Privacy Rights Request”). Please include the email/phone associated with your account and the right you wish to exercise.

We respond without undue delay and within one (1) month of receiving your request. This period may be extended by two (2) further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Contact Us

For further information about our Privacy Policy or practices please contact us using the details set out below:

Andrew C. Gorecki
Clinical Safety Officer (CSO) and Data Protection Officer (DPO) 
Email: support@mymovementrx.com
Phone: (231) 944-6541