LAST UPDATED: August 30, 2018
Collectively, we refer to the Websites, the Apps, our Social Media Pages, and the Emails as (the “Services”).
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual
If you are a patient using the Services at the direction of your healthcare provider, we also collect health-related information including medical condition and diagnosis, treatment, medications.
If you are an employee using the Services at the direction of your employer, we also collect employment-related information, including the name of your employer and your title.
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
We collect Personal Information through the Services, for example, when you register an account to access the Services and/or when you use the Services.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services.
Use and Disclosure of Personal Information Under HIPAA
If you are using the Services at the direction of a Mytonomy Customer that is subject to the Health Insurance Portability and Accountability Act (“HIPAA”), such as your healthcare provider, we will use and disclose your Protected Health Information (“PHI”) as permitted in our agreement with the Mytonomy Customer. This generally means that we will use and disclose your PHI to provide the Services, for our own internal management or as required to comply with applicable law.
Use of Personal Information
We and our service providers use Personal Information for business purposes including:
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
We will engage in this activity with your consent or where we have a legitimate interest.
We will provide personalized services either with your consent or because we have a legitimate interest.
We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our engagement campaigns, and compile statistics about usage of the Services and response rates.
Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to inform the Mytonomy Customer of where you consumed their patient/staff education (i.e. at home or in the hospital).
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Your choices regarding our use and disclosure of your Personal Information
If you no longer want to receive text messages from us, you can reply to the message with “STOP” or “UNSUBSCRIBE.”
We will try to comply with your request(s) as soon as reasonably practicable.
How you can access, change or delete your Personal Information
If you would like to request to review, correct, update, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by emailing us at email@example.com or mailing us at 7315 Wisconsin Ave #400 West, Bethesda, MD 20814. You may also updated or correct your Personal Information by visiting your Account profile page. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to fulfill our obligations to the Mytonomy Customer.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law
The criteria used to determine our retention periods include:
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
The Services are not directed to individuals under the age of thirteen (13), and, unless otherwise disclosed during collection and with parent or guardian consent, we do not knowingly collect Personal Information from individuals under 13. If you are under 13 years of age, do not provide Personal Information to us. If we discover that a child under the age of 13 has provided us with personally identifiable information and we do not have parental consent, we will promptly delete that child’s information from the Website and Service. If you believe that Mytonomy has been provided with Personal Information of a child under the age of 13 without parental consent, please notify us immediately at firstname.lastname@example.org.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
7315 Wisconsin Ave #400 West, Bethesda, MD 20814
Because email communications are not always secure, please do not include sensitive information in your emails to us.
You may also lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.