This policy applies to all information collected through our websites (such as www.mirrorme3d.com) and/or any related sites, services, software, sales, marketing or events (which we refer to them collectively in this policy as the “Sites”).
PROTECTED HEALTH INFORMATION IS CONFIDENTIAL
We consider all Protected Health Information, as defined below (“Protected Health Information”), whether it was provided to MirrorMe by you or anyone else, to be Protected Health Information under the law. This information is your property, and you have the right to control who is authorized to access it.
We do not disclose or release any Protected Health Information to anyone, even members of your own family, without your Express Consent except as expressly set forth in this policy or as required by law.
Whenever we are compelled by law to release any of your Personal Information, we will only release the minimum necessary information required to accomplish the business use for which the permitted release is allowed.
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
Summary: We collect personal information that you provide to us such as name, address, contact information, passwords and security data used on our Sites, and payment information as applicable.
We collect personal data that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites (such as registering for an account, posting messages, completing marketing and sales forms) or otherwise contacting us.
The personal information that we collect depends on the context of your interaction with us and the Sites, the choices you make and the products and features that you use. The personal information we collect can include the following:
Personal Information: “Personal Information” is any information that uniquely identifies you as a patient, that your patient provides to you if you are a medical services provider, or that you might consider highly confidential or sensitive and includes your Personal Account Information and Protected Health Information. MirrorMe treats all Personal Information as private and confidential. We collect two types of Personal Information:
Personal Account Information: We use Personal Information, such as your name, address, telephone number, email address, organization affiliation, address, user name and password, to uniquely identify you and your use of the website. We then require you to create a password to control access to restricted portions of our Site and App.
Protected Health Information: Protected Health Information that we collect includes:
Medical Information: Medical Information includes any personal health information, including age, height, gender, ethnicity, medical history, family history, social history, medical images, scans and reports, and other personal health information
Payment Data: We collect necessary data to process your payment if you make purchases, such as your credit or debit card number and security code associated with the card. Some card issuers also require us to collect your billing address in order to verify authorized use of the card. All payment data is stored by our payment processor (Stripe, Inc) and you should review its privacy policies and contact the payment processor directly to respond to your questions regarding this matter.
All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
Summary: Some information, such as IP address and/or browser and device characteristics, is collected automatically when you visit our Sites.
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites as well as for internal analytics and reporting purposes.
Information collected from other sources
Summary: We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information, marketing leads and search results and links, including, at times, paid listings (such as sponsored links).
HOW DO WE USE YOUR INFORMATION?
Summary: We process your information and data for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use Personal Information collected via our Sites for a variety of business purposes described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicated the specific processing grounds we rely on next to each purpose listed below:
We use the Personal Information we collect or receive:
· To facilitate account creation and login processes: If you choose to link your account with us through a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and login processes.
· To send administrative information to you: We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
· To fulfill and manage your orders and services: We may use your information to fulfill and manage your orders, subscriptions, services, payments, and other business activity made through our Sites.
· To enforce our terms, conditions and policies.
· To respond to legal requests and prevent harm: If we receive a subpoena or other legal request compelling us to act, we may need to inspect the data we hold to determine how to respond.
· For other Business Purposes: We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
WILL YOUR PERSONAL INFORMATION BE SHARED WITH ANYONE?
Summary: We only share Personal Information with your consent, to comply with laws or legal requests compelling us to act, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
· Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
· Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
· Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
· Legal Obligations: We may disclose your information where we are legally compelled to act in order to comply with applicable law, government requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
· Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your Personal Information in the following situations:
· Vendors, Consultants, and Other Third-Party Services Providers: We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer services and marketing efforts. We may allow selected third parties, as necessary, to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
· 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 acquisitions of all or a portion of our business to another company.
· Business Partners: We may share your Personal Information with our business partners to offer you certain products, services or promotions.
Additionally, MirrorMe provides certain links to third-party websites operated by organizations not affiliated with our services. These links may be found within our content or placed beside the names and logos of these persons.
We do not release any of your Personal Information to organizations operating these third-party web sites. We do not review or endorse the privacy policies of these third-party sites and assume no responsibility for them. We encourage you to read the privacy policies and statements of each and every site before providing any Personal Information.
WHO WILL YOUR INFORMATION BE SHARED WITH?
Summary: We only share information with the following third parties.
We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. IF we have processed your data based on your consent, please contact us with further questions.
· Advertising, Direct Marketing, and Lead Generation
o Hubspot CRM and Drift
· Functionality and Infrastructure Optimizations
o Amazon Web Services, Hubspot CRM
· Invoice and Billing
o Stripe, Xero
· Web and Mobile Analytics
o Google Analytics, SEMRush
· Website Hosting
o Amazon Web Services, Squarespace
Log Files: When you access our site, our system automatically collects certain information about you for our logs. This data may include your browser type, your computer’s IP address, your Internet Service Provider, operating system, data and time you visited our site or App, and a list of the pages you visited. We use this information to analyze usage trends, administer the site, and gather demographic information about our community as a whole. It is not designed to identify you personally. However, under certain circumstances we may need to review this information in conjunction with specific Personal Account Information in order to identify and resolve certain issues for our community.
Cookies: MirrorMe uses a web technology, referred to as cookies, to make it easier for you to navigate our site and App, improve the security of your Personal Information, enhance the functionality of some features, and improve performance. These cookies are only applicable within the confines of our site and app. MirrorMe uses both session cookies, which expire when you close your browser, and persistent cookies, which remain on your computer. These cookies act as a user identification card for our servers. Cookies are only read by our computers and are unable to execute any code or virus. You can remove persistent cookies by following the directions provided in your Internet browser’s help file. However, if you set your browser security setting to reject all cookies, you may not be able to access certain portions of our web site. When accessing our site on a public computer, we recommend that you delete all persistent cookies according to the directions in your browser’s help file before you close the browser. For more detailed information on how to control cookies you may wish to visit www.allaboutcookies.org.
IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
Summary: We may transfer, store and process your information in countries other than your own.
Our servers are located in United States. If you are accessing our Sites from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above) in United States and other countries.
EU-U.S. Privacy Shield Framework:
In particular Company complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. As such, Company is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Company is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Company is subject to the regulatory enforcement powers of the U.S. FTC. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?
Summary: We aim to protect your Personal Information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
Summary: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using our Sites, you represent that you are at least 18 or that you are the parent or legal guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measure to promptly delete such data from our records. IF you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
WHAT ARE YOUR PRIVACY RIGHTS?
Summary: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal data, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html
You may access Personal Information in your account at any time through the website. You may update your Personal Account Information at any time by accessing your Personal Account and making necessary changes.
If you would at any time like to review or change the Personal Information in your account or terminate or your account, you can:
· Contact us using the contact information provided
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies or to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
· Contact us using the contact information provided.
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECFIIC PRIVACY RIGHTS?
Summary: Yes, if you are a resident of California, you are granted specific rights regarding access to your Personal Information.
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for directing marketing purposes and the names and address of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.
DO WE MAKE UPDATES TO THIS POLICY?
Summary: Yes, we will update this policy as necessary to stay compliant with relevant laws.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have any questions or comments about this policy, you may contact Legal Affairs by email at email@example.com, or by post to:
Attn: Legal Affairs
222 West 37th Street
New York, NY 10018