Privacy Policy



Sky Labs Inc. located in #703, 58, Pangyo-ro 255beon-gil, Bundang-gu, Seongnam-si, Gyeonggi-do, Republic of Korea (“we”, “our” or “us”) respect your concerns about privacy. This Privacy Policy applies to the personal information we collect through CART-I (Application) and website ( (collectively called the “Services”).


In this Privacy Policy, we describe the types of personal information we process through the Services, how we may use the information, how long we may keep the information, with whom we may share it and the choices available to you regarding use of the information and exercising your rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your Rights” section. We also tell you how to contact us about our privacy practices. Below you will find a summary of the key topics contained in our Privacy Policy. For more detailed information on how we process your information, please click on the headings or continue to read below.

1. Information We Collect

2. How We Use the Information We Collect

3. Information Sharing

4. Retention of Personal Information

5. Your Rights

6. How We Protect Personal Information

7. International Transfer of Information

8. Updates to Our Privacy Policy

9. Contact Us[BKL1] 

10. Children’s Personal Information








Effective Date: 01 July , 2020


1. Information We Collect


The following personal information is collected in connection with the Services:


■ Information You Provide Directly


Mobile Application Service for patients enables you to give us information directly. For example:

• When you create a account, we may ask for information such as your Email, password, location, name, sex, date of birth, height, weight.

• To provide responses when you contact Customer Services, we may need information to verify your identity and the product you’re inquiring about.


Web Service for physician enables you to give us information directly. For example:

• When you create a account, we may ask for information such as Email, password, name, hospital, medical license number, medical department, specialty, title, location and date of birth.


■ Information you provide additionally

• When you register your device, we collect additional information such as device number, QR number or serial number and the raw photoplethysmogram(“PPG”) measurement data of yours.

• When you login with your account, we collect additional information such as device number that you registered.


■ Information About Your Use of the Services

In addition to the information you provide, we will collect information about your use of our Services through the Services on your devices and by other means. We will collect:

• Your geographic location

• Your device information : Your hardware model, device hardware information, serial number, and current firmware version you use to access services.

• Log information : Operation information and usage information such as the time and duration of your use of services

•Your raw photoplethysmogram(“PPG”) measurement data

•Your raw electrocardiogram(“ECG”) measurement data

•Your raw accelerometer(“ACC”) measurement data

•The time the PPG, ECG and ACC signal collected, the time information includes your time zone and local time

•Your device information which the PPG, ECG and ACC signal is collected from

•The information of the physician who you connected to and share your data with, the physician you connected can view your data such as Email, location, name, sex, date of birth, height, weight, PPG and ECG signal


In addition to the information you provide, we will collect information about your use of our services through the services on your web:

• The information of the patient who tried to connect to you, bookmark of the patient list

•Your memo to your patient that you wrote the opinion about the patient

•Your memo to your patient that you wrote when you disconnect from the patient list

•Your question to the service


For more information about how we use cookies for our Services, please see our Cookie Policy



■ Other Information We Collect
We may also collect other information about you, your devices, or your use of the Service with your consent (where required by law).

■ Third-Party Analytics
Through certain Services, we may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. We may use third-party analytics services on the Services, such as those of Google Analytics. The service providers that administer these analytics services help us to analyse your use of the Services and improve the Services. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Services, help administer the Services, and diagnose technical issues. To learn more about Google Analytics, Please visit and


2. How We Use the Information We Collect

■ Provision of services based on your contractual relationship with us

  • Provide you with the Services, such as patient management service, measurement and analysis of physical activity data and response to questions and instructions made through the Services;

  • Identify and authenticate you so you may use certain Services;

  • Respond to your inquiries.

■ Use of information for further purpose based on our legitimate interests

  • Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;

  • Monitor use of services and use your information to help us monitor, improve and protect our products;

Where we rely on our legitimate interests, we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.


■ Use of information based on your consent:

  • Place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used.

  • Special categories of personal data

On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.


■ Change of purpose

We will use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


For purposes which are required by law:

  • Comply with and enforce applicable law requirements,

  • Respond to requests from government or law enforcement



3. Information Sharing

We disclose personal information about you through the Services as described in the following:

  • Users for the Services. In order to serve the Services, patient personal information is provided to the doctor, and doctor personal information is provided to the patient. However, this shall only be done within the required scope for service provision. For example, limited the physician's identity information will be disclosed for the purpose of verifying the patient's intention to provide information.

  • Business Partners. Partners who we work together with to provide you with the Services you’ve requested or bought. For example, we may work with a bank so that you can use one of our Services to make faster and more efficient payments. These business partners control and manage your personal information.

  • Service Providers. We may disclose your information to carefully selected companies that provide services on behalf of us, such as companies that help us develop and operate systems for the service with customer contact centers, customer care activities that send emails on our behalf. These entities are limited by contractual provisions in their ability to use your information for purposes other than providing services for us.

  • Other Parties When Required by Law or as Necessary to Protect Our Services. There may be instances when we disclose your information to other parties:

  • to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);

  • to verify or enforce compliance with the policies governing our Services; and

  • to protect the rights, property, or safety of us, or, in compliance with data protection laws, any of our respective affiliates, business partners, or customers.

  • Other Parties in Connection with Transactions. We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy.

  • Other Parties with Your Consent or on Your Request. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.


4. Retention of Personal Informaition

We take appropriate steps to ensure that we process and retain information about you based on the following logic:

  • at least the duration for which the information is used to provide you with a service; 

  • as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws); or

  • only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards.


5. Your Rights

Your personal information belongs to you. You can ask us to for a copy of the personal information we’ve collected, and you can ask us to delete it or correct any inaccuracies. You can also ask us to restrict or limit the processing of your personal information, as well as to provide to you with your personal information that you provided to us for a contract or with your consent in a structured, machine readable format, and to ask us to share this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in national laws. We will inform you of relevant exemptions we rely upon when responding to any request you make. To make a request concerning your rights or to make an inquiry, see the Contact Us( section below.


6. How We Protect Personal Information

We take protection of your information seriously and maintain safeguards designed to protect the information we collect in connection with the Service. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.


7. International Transfer of Information

Your use of our Service will involve the transfer, storage, and processing of your personal information within and outside of your country of residence, consistent with this policy. In particular, your personal information will be transferred to the Republic of Korea. Please note that the data protection and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country.

[For European Economic Area (EEA) Residents Only]

In addition, your use of the Service may also involve the transfer, storage, and processing of your personal information to other countries; such countries include, without limitation, countries in the European Economic Area, United States and South Korea. We will take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected. Such measures include for instance the use of the European Commission Standard Contractual Clauses to safeguard the transfer of information outside of the EEA and reliance on your explicit consent. To request more information or obtain a copy of the contractual agreements or other safeguards in place, please contact us. See the Contact Us( section below.


8. Updates to Our Privacy Policy
This Privacy Policy may be updated to reflect changes in our personal information practices with respect to the Services, or changes in the applicable law. We will post a notice on our Services to notify you in advance of material changes to our Privacy Policy and indicate at the top of the notice when it was most was most recently updated.


9. Contact Us

To exercise these rights, please contact us at

Data Protection Officer can be contacted same email address.

You can also contact the competent data protection authority as the responsible supervisory authority.

[For European Economic Area (EEA) Residents Only]
If you are residing in the European Union, you can also contact our representative:

E-mail :

Tel : +31 (0)85 007 3220

CE Medical


10. Children’s Personal Information

The Service is designed for adults who are over 19 years of age and is not directed to children.