Effective Date: April 20, 2019


Gram Health, Inc. (“Gram Health,” “us” or “we”) recognizes the importance of protecting your privacy and we are committed to respecting our customers’ right to privacy. This Privacy Policy addresses how information we receive through the Gram App (“The App”) is collected, utilized and stored. In continuing to use The App, you consent to the collection, transfer, storage,disclosure and other uses of your information as described in this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use The App.

Gram Health does not receive through your download or usage of The App any personally identifiable information. As explained more fully below, when you download The App, Gram Health will collect, on an anonymous basis, certain general information about your usage of The App itself. The App has the ability to collect certain information regarding usage of the Gram Health device linked to The App, but such information is collected on an anonymous basis and is only collected if you “opt-in” to The App’s usage recording feature (the “Usage Recording Feature”). If you do not opt-in to the Usage Recording Feature, The App will not collect any device usage information.

Gram Health reserves the right to change this Privacy Policy. Seethe section captioned “Modifications to this Privacy Policy” below for an explanation of our modification policy.

Applicability Of This Privacy Policy

This Privacy Policy applies only to information received by Gram Health through The App. It does not apply to information collected by:
• Gram Health through its website ( (the “GRAM Website”), including any information provided by you or otherwise collected when you link to the GRAM Website through The App;
• Gram Health offline or in any non-electronic fashion; or
• Any third party, including our affiliates, including through any application or content (including advertising) that may link to or be accessible from The App or the website.

How Do We Collect Information From You?

In connection with your use of The App, we collect information from you in several ways. We automatically collect certain anonymous information when you download The App. If you opt-in to The App’s Usage Recording Feature, we also collect anonymous information regarding the compatible Gram Health device you linked to The App and usage of that device when The App is running. Finally, we collect information when you elect to contact us through The App.

What Information Do We Collect From You?

Personally Identifiable Information. 

When you download or use The App, regardless of whether you opt-in to The App’s Usage Recording Feature, we do not receive personally identifiable information such as your name, address, email or other contact information. The App will have a link to our customer service website which will open inside The App. This will permit you to contact us via email. Whenever you send an email in this manner you will be providing us with your name, email address and any information you choose to include in the text of your message. For example, you may choose to provide your mailing address, phone or mobile number or other information necessary or helpful for us to address your query or other concern.

Diagnostic and Usage Information Regarding The App. 

When you download and use The App, Gram Health will automatically receive certain anonymous information about your mobile device and your usage of The App (as distinct from information regarding usage of the Gram Health device linked to The App). We will receive certain general information regarding your mobile device, such as the operating system and version, but no information which could identify you, including any mobile device identifier. In addition, we will receive information regarding your use of The App, such as the time spent using The App and in using in different portions of The App, as well as error messages, However, we do not use common automated information gathering tools,commonly referred to as “cookies,” in connection with The App. GRAM Device Usage and Diagnostic Information. When you connect your GRAM device to the Internet through The App, and opt-in to The App’s Usage Recording Feature, we will automatically receive certain information about your GRAM device and your use of the GRAM device, including log files, modes, settings, durations and error rates. We receive this information solely in anonymous form and in an encrypted manner.


We do not engage in the collection of personally identifiable information about your online activities over time and across third party websites or online services. Accordingly, we do not currently process or comply with any web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third party websites. Without limiting the provisions under the Caption“Used of Information Collected – Our Sharing of Information” below, we also do not allow third party companies to collect information when you visit our Site.

Our Use of Information Collected

We use the information we collect via The App only for legitimate business purposes as follows:

• To improve your experience with and the overall quality of your GRAM Device and The App;
• For internal business purposes, including to develop new technologies and services;
• For external research purposes, including collaborations with public and private Universities and research laboratories;
• For inclusion in our data analytics;
• To troubleshoot technical problems or other difficulties and analyze GRAM device errors;
• To communicate with you – either through email, telephone or otherwise; and
• To comply with applicable laws.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Our Sharing of Information

Your trust is important to us, which is why we don't share information we receive about you with others unless we have:• received your permission; or• given you notice, such as by telling you about it in this Privacy Policy. In any event, as noted above, Gram Health does not receive any personally identifiable information in which to share. To the extent that we have anonymous information, Gram Health will not share, distribute or reference any such anonymous information with third parties except as follows:

• With our affiliates and third parties providing services on our behalf. We require our affiliates and third parties providing services on our behalf to limit their use and disclosure of your information to uses and disclosures that are consistent with this Privacy Policy, however, we cannot guarantee their compliance.

• If necessary to comply with laws, a judicial proceeding, court order, or other legal requests, in circumstances involving potential threats to the safety of any person, or as evidence in litigation in which Gram Health is involved.

Business Transfer

If Gram Health is acquired by or merged with another company, all of our assets, including information that has been collected pursuant to The APP, will be transferred to the new entity. In that event, you would be notified and will have the opportunity to have your data removed.

Age Verification

Full use of The App is only enabled by linking a Bluetooth-enabled GRAM device, the purchase of which is age restricted. While state and countries differ, no one under the age of 18 should be able to purchase a GRAM device. Accordingly, use of The APP is not directed to persons under 18, and we do not knowingly collect personal information from persons under 18. If you under age 18 do not use The App. If we become aware that a person under 18 has provided us with personal information, we take steps to remove such information.

Rights with Respect to Your Data

Because we do not collect any personally identifiable data, we are unable to provide you with any data and there is no personally identifiable data to correct.

Third Party Websites

The App may contain links establishing a connection between The App, the GRAM Website and/or websites operated by third parties. This Privacy Policy does not apply to information collected through the GRAM Website and you should review the GRAM Website Privacy Policy before electing to link theretofrom The APP. Gram Health does not control nor does this Privacy Policy apply to any third party (non-GRAM) websites. Links to such third party websites should be clicked at your own risk and it is your sole responsibility to review the privacy policy and applicable terms and conditions of any third-party website accessed.

Modifications to this Privacy Policy

Gram Health reserves the right to change this Privacy Policy at any time for any reason and all such revisions shall be effective upon posting. Please revisit this page often to remain fully informed of our policies. Continuing to use The App after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.


We are dedicated to using rigorous efforts to ensure that the information we collect or you share with us is secure. The App supports the industry standard Secure Socket Layer (SSL) encryption which is applied to all data transmitted so it cannot be read by others. Unfortunately, the transmission of information via mobile platforms is not completely secure. Although we do our best to protect all information collected through The App, especially any which may be deemed by applicable jurisdictions to be personally identifiable information, we cannot guarantee the security of your information collected and/or transmitted through The App. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Users Outside the United States

When a user of The App who is located in the European Union or elsewhere outside of the United States chooses to download and use The App or elects to make certain information available to us, that user is responsible for ensuring that the sharing of information with us conforms to the user’s local data protection laws. Gram Health is not responsible under such local data protection laws for information obtained through The App. Irrespective of which country you reside in or supply information from, you authorize Gram Health to use your information in the United States and any other country where Gram Health operates. We may process your information on a server located outside the country where you live.

Notice To California Residents - California Shine The Light Law

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes