Privacy Notice for Teton services
We, at Teton.ai ApS, Teton.ai Ltd, Teton.ai Inc., and Teton.ai GmbH (“Teton,” “we,” “us,” or “our”) have created this privacy notice (this “Privacy Notice”) because we know that you care about how information collected through our solution is used and shared.
This Privacy Notice applies solely to the Teton One care-monitoring platform, together with the cameras and edge devices installed in care environments (the “Platform”). It does not cover our publicly available website. For information about how we process personal data in connection with our website, please refer to the separate Teton Website Privacy Notice, available at www.teton.ai.
This Privacy Notice applies to the care providers, hospitals and nursing homes that have signed up to access and use the Platform (the “Customers”), the Customer’s staff authorized to access and use the Platform (“Authorized Users”), and the senior citizens, residents, patients and their relatives who are monitored by the Platform (together, the “Data Subjects”).
Description of Users and Acceptance of Terms
By accessing and/or using the Platform, each Customer and Authorized User agrees to the terms of this Privacy Notice and the accompanying Platform terms. Where required, senior citizens, residents or their legal representatives provide separate affirmative consent before any images are collected for the training and optimization of the Platform.
Capitalized terms not defined in this Privacy Notice shall have the meaning set forth in the agreement between Teton and the relevant Customer.
Definitions
Platform (Teton One) is a proprietary computer-vision and artificial-intelligence solution that, through the collection of video data of senior citizens, helps care staff deliver safer and more efficient care. It comprises the cameras and edge devices installed in care environments and the associated software and mobile application.
Personal Data refers to data about a living individual who can be identified, directly or indirectly, from those data.
Data Controller is the natural or legal person who determines the purposes and means of processing Personal Data. Teton is the Data Controller of Personal Data processed for the training and optimization of the Platform; the Customer care facility is the controller of data processed for the delivery of care.
Data Processor (or Service Provider) is any natural or legal person who processes data on behalf of the Data Controller. Teton may use the services of various suppliers and partners to process data on its behalf and following its written instructions.
Data Subject (or User) is any living individual whose Personal Data is processed by Teton through the Platform, including senior citizens, residents, patients, their relatives and care staff.
Information collection and use
In the course of operating the Platform and/or interacting with you, we will collect (and/or receive) the types of information described below. You authorize us to collect and/or receive such information.
Types of data collected
Personal data
Teton collects images via the cameras installed in the senior citizen’s or patient’s room. We review these images to identify data points such as whether a person is present, the person’s figure and movement patterns, estimates of health markers (for example rest, sleep and respiration), and the context of the room, including the presence of staff and other objects relevant to care. These data points are crucial for training our algorithm so that Teton constantly improves for the benefit and safety of the senior citizen or patient.
We process images of senior citizens, relatives or staff when they are present in the citizen’s or patient’s room. The clips do not contain any name, social security number or other information that can be directly linked to a senior citizen, member of staff or relative, other than the image itself. The clips contain only the following metadata: an acronym for where the clip was recorded (site ID); the date of the recording; and the ID number of the installed camera.
Teton does not process data with the purpose of identifying specific senior citizens (no profiling).
Use of data
Teton uses the collected data for the following purposes:
- To provide, operate and maintain the Platform, including detecting falls and other situations that need attention and alerting care staff.
- To continuously train and optimize our computer-vision algorithms so that Teton constantly improves.
- To generate health and care-quality insights, such as sleep, activity and respiration trends, to support care planning.
- To provide customer support to Customers and Authorized Users.
- To monitor the usage, performance and reliability of the Platform.
- To detect, prevent and address technical and security issues.
- To notify you about changes to the Platform.
- To comply with our legal and regulatory obligations.
We may process your Personal Data because: you (or your legal representative) have given us affirmative consent; the processing is necessary to perform a contract with our Customer; the processing is in our legitimate interests in training and improving safe care technology and is not overridden by your rights; or we need to comply with applicable law.
Retention of data
Teton 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.
Transfer of data
Teton is headquartered in Denmark, and your information, including Personal Data, may be processed in Denmark and in other countries where Teton or its Service Providers operate. Teton may use suppliers and partners in connection with the operation, further development and optimization of the Platform; these Service Providers only process personal data on behalf of Teton and following our written instructions.
Where personal data is transferred to third countries (countries outside the EU/EEA), the transfer is based on an adequacy decision of the European Commission or on the European Commission’s Standard Contractual Clauses (SCCs), and you have the right to request access to the relevant safeguards.
Teton will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice, including data minimization and appropriate technical and organizational measures.
Important Notices to U.S. Residents
Notice to California Residents
Residents of certain U.S. states, including California, have the right to request information about the categories of personal information we collect and how it is used and shared. Teton does not sell personal information. Where we process sensitive personal data, including images and health-related data, we do so only on the basis of your affirmative consent. To submit a request, please contact us at Privacy@teton.ai.
Where Teton processes sensitive personal data in Texas, it does so based on your affirmative consent in accordance with the Texas Data Privacy and Security Act (TDPSA), as required under Section 541.107.
If you are a resident of a facility that is a HIPAA-covered entity, this Privacy Notice and your consent also serve as your authorization under 45 CFR §164.508 for Teton and its authorized agents to collect and process health-related data for the purpose of training and improving the Platform. Data will not be further disclosed without your consent unless required by law.
Disclosure of data
Teton will only disclose personal data to third parties performing tasks on our behalf and under our instructions. These Service Providers may include IT support, cloud hosting and data-analytics providers, and the electronic health record (EHR) systems that our Customers use with which the Platform integrates so that care records stay in sync. Data is shared strictly for purposes such as delivering and improving our services and ensuring compliance and security, and we require these third parties by contract to protect personal data.
Disclosure for law enforcement
Under certain circumstances, Teton may be required to disclose your Personal Data if required to do so by law, rule or regulation, or to comply with law enforcement or valid requests by public authorities (for example a court or a government agency).
Investigation and Enforcement Powers
As a data controller established in Denmark, Teton is subject to the supervision and enforcement powers of the Danish Data Protection Authority (Datatilsynet) and, where applicable, other competent supervisory authorities responsible for overseeing compliance with applicable data protection law.
Legal requirements
Teton 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 Teton; prevent or investigate possible wrongdoing in connection with the Platform; protect the personal safety of users of the Platform or the public; and protect against legal liability.
Security of data
We take security seriously and have implemented appropriate technical and organizational measures to ensure that your information is treated securely and is protected from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations.
Your data protection rights
You may exercise certain rights regarding the personal data we process about you. In particular, subject to the exceptions laid down in applicable law, you have the right to access the personal data we hold about you; to object to the collection and processing of your personal data, and to have it corrected or the processing restricted; to have your personal data deleted, unless the processing is necessary to establish a legal claim, to respond to your request, or where we are required by law to store the information; and to receive a copy of your personal data in a structured, commonly used and machine-readable format.
As our processing is based on your consent, you have the right to withdraw your consent at any time. If you withdraw your consent, we will cease processing your personal data unless we are entitled or obliged to continue on another legal basis. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
Any request to exercise your rights can be directed to us using the contact details in this Privacy Notice, at any time and free of charge. We will address all requests as early as possible and always within 30 days, and we may ask you to verify your identity before responding.
Data Protection Complaints
You have the right to raise a complaint with Teton if you are concerned about how we collect, use, store, disclose, protect or otherwise process your Personal Data. You can submit a complaint by contacting us at Privacy@teton.ai.
We will acknowledge receipt of your complaint and take appropriate steps to review and respond to it without undue delay, keeping you informed of progress where possible and informing you of the outcome.
You also have the right to lodge a complaint with your local data protection authority.
Notification of Data Protection Authority Cooperation for Data Complaints
You have the right to complain to a data protection authority about our collection and use of your Personal Data. In Denmark, the competent authority is the Danish Data Protection Authority (Datatilsynet)
Carl Jacobsens Vej 35
2500 Valby
Tel. +45 3319 3200
Email dt@datatilsynet.dk.
If you are located elsewhere in the EEA, you may contact your local supervisory authority.
Opt-Out Rights
Because our processing of images and other sensitive data relies on your affirmative consent, you may decline to provide consent, or withdraw it at any time, without affecting the care you receive. Where we rely on consent to send you communications, you may opt out at any time by contacting us at Privacy@teton.ai.
Binding Arbitration
Where required by applicable law, disputes regarding our processing of your personal data may be subject to the dispute-resolution mechanisms available to you under that law. This does not limit your right to lodge a complaint with a supervisory authority or to seek a judicial remedy.
Right to Lodge Complaints
Teton is committed to resolving complaints about our collection and use of your personal data. Individuals with inquiries or complaints regarding our handling of personal data should first contact us at Privacy@teton.ai.
Children’s privacy
The Platform is designed for use in adult care settings and is not directed to children. We do not knowingly collect personal information from children under the age of 18 through the Platform. If you believe that a child under 18 has provided, or had collected, personal information through the Platform without appropriate authorization, please contact us and we will take appropriate steps to address it.
Changes to this Privacy Policy
We reserve the right to change this Privacy Notice if there are significant changes in relevant legislation or to ensure that we provide you with correct information. This Privacy Notice is effective as of the date stated at the top. We will make any changes available to Customers and Authorized Users, and continued use of the Platform after changes are made constitutes acceptance of them.
Please refer back to this Privacy Notice on a regular basis.
Contact us
If you have any questions about Teton’s processing of personal data through the Platform, wish to exercise your rights, or wish to report a privacy issue, please contact us at Privacy@teton.ai.