Effective Date of Current Policy: September 11, 2019
3. Transparency/Notice - Types of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with Company and the requirements of applicable law. Some of the ways that Company may collect Personal Information include:
- You may provide Personal Information directly to Company through interacting with the Services, participating in surveys, submitting a review of a doctor, and requesting Services, or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
When you use our Services or engage in certain activities, such as responding to surveys or contacting us directly, we may collect information about you.
- Account Information. If you create an Account, we may collect Personal Information such as your name, email address, year of birth, zip code, as well as your other interests that are pertinent to the Services such as, to the extent you elect to provide it to us: fertility-oriented conditions and fertility treatments.
- Communications with Us. We may collect additional Personal Information from you such as your name or email address when you choose to request information about our Services, register for Company’s newsletter, request to receive customer or technical support, or otherwise communicate with us.
- Reviews. If you are a patient and elect to take a survey on your doctor or clinic, all of the data provided (except your name, email address and employer) may be included in the review, and, as such, will be made publicly available on our Site.
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Site and/or services and in any manner consistent with the policies provided herein.
- Discover. Company may decide to offer publicly accessible blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Company’s blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
- Information from Other Sources. We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you.
3.2 How We Use Your Information
We acquire, hold, use, and Process Personal Information about individuals for a variety of business purposes, including:
1. To Provide Products, Services, or Information Requested. Company may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage your information and Accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of Company’s Services;
- Contact you to answer requests for customer support or technical support;
- Allow you to register for events.
- Facilitate the exchange of information regarding reviews, e.g., by sending questions to reviewers (if such reviewers have not opted-out), and then providing responses to the users that asked those questions.
2. Administrative Purposes. Company may use Personal Information about you for its administrative purposes, including to:
- Measure interest in Company’s Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify your identity;
- Communicate about your Account and activities on Company’s Services and systems, and, in Company’s discretion, changes to any Company policy;
- Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
- Process payment for products or services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms.
3. Marketing Company Products and Services. Company may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Company may provide you with these materials by email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- For other purposes disclosed at the time that you provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
4. Research and Development. Company may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Company may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve you by learning more about your needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, research, advertising campaigns, and/or promotional activities. If you participate in a survey, the information given will be used along with that of other study participants. We may share anonymous data about you and aggregate data for research and analysis purposes. We may work with academic or medical researchers to use anonymized data for publication in medical journals or other research.
5. Email Communications. Individuals who provide us with Personal Information may receive periodic emails, newsletters from us with information on Company’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to you by following the instructions in Section 5 below.
6. Anonymous and Aggregated Information Use. Company may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Company’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Company may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Company and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
7. Sharing Content. Company’s Services may allow you to share certain content with friends, or via third-party websites, applications or other services. To the extent you decide to invite your friends to use the Services, the e-mail addresses that provide may be used to send your friend the content or invitation you request, but will not be collected or otherwise used by Company or any other third parties for any other purpose.
8. Other Uses. Company may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use third-party analytics services, such as Segment and/or Google Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. While we do not currently do so, we may in the future use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third-party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites and Social Media Platforms
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Company does not endorse or make any representations about third-party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Company’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
3.5 Third-Party Payment Processing
When you make a purchase via our Services, we process your payments through a third-party application, including Stripe, Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and Social Networking Sites (“SNS”) such as Facebook. The third-party application may collect certain financial information from you to process a payment on behalf of Company, including your name, email address, address and other billing information.
4. Information We Share
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Company has executed appropriate contracts with our service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Reviews. To the extent you decide to post reviews on the Site, other users will be able to see your reviews, except for your name, email address, and employer.
- Marketing—Interest-Based Advertising and Third-Party Marketing. Through our Services, Company may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Company related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with third-party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Company policies or contracts; (v) to collect amounts owed to Company; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes—e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
5. Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Company’s Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting email@example.com, and asking that we delete your account.
5.2 Email Communications
5.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.5 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and http://www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
6. Rights of Access, Rectification, Erasure, and Restriction
Although Company makes good faith efforts to provide you with access to your Personal Information, there may be circumstances in which Company is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where it is commercially proprietary. If Company determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Company will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. International Users
All Personal Information collected via or by Company may be stored anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any storage, transfer and Processing in accordance with this Policy.
10. Children’s Privacy
The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Company does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. Company urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s Account.
11. Redress/Compliance and Accountability
12. EU Representative
VeraSafe has been appointed as the Company’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to email@example.com only on matters related to the processing of personal data. To make such an inquiry or file a complaint, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative or via telephone at: +420 228 881 031. Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd.
Unit 3D North Point House, North Point Business Park, New Mallow Road
Cork T23AT2P, Ireland.
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where your consent for the Processing of your Personal Information is otherwise required by law or contract, Company will endeavor to comply with the law or contract.
14. Revision history
|Third Party Analytics Update||November 24, 2019|
|Company Annual Review||April 27, 2020|