Last Revised
September 2023
[Insert company name] and its affiliates (collectively, “MediBoard”, “Company”, “we”, “our” or “us”) respect the privacy of the users of its App (“User(s)” or “you”) and are committed to protect the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you use our App and Services. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at [insert a link to Terms of Use] (“TOU”), into which this Privacy Policy is incorporated by reference.
Your Consent (PLEASE READ CAREFULLY!)
BY DOWNLOADING AND/OR INSTALLING THE APP ON YOUR DEVICE AND/OR ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE APP AND/OR THE SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT DOWNLOAD, INSTALL, ACCESS AND/OR USE THE APP, AND YOU ARE REQUESTED TO PROMPTLY UNINSTALL THE APP FROM YOUR MOBILE DEVICE.FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, DISCLOSING, DISPOSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO THE COMPANY.YOU MAY UPLOAD TO THE APP CERTAIN PERSONAL INFORMATION AND MATERIALS RELATING TO YOUR MEDICAL AND/OR MENTAL CONDITION (SUCH AS MEDICAL CONDITION, PRESCRIPTIONS, MEDICAL TESTS AND RESULTS, TEXT, DIAGNOSES, TREATMENTS, DOSAGES, OUTCOMES, CHARTS, TESTIMONIALS, APPOINTMENTS, IMAGES, VIDEOS, SCANS, DOCUMENTS, ETC.). YOU HEREBY ACKNOWLEDGE THAT SUCH INFORMATION AND MATERIALS ARE NOT INDEPENDENTLY VERIFIED BY US AND THAT UPLOADING OUTDATED, INCOMPLETE OR INACCURATE INFORMATION AND MATERIALS TO THE APP MAY AFFECT THE RESULT OF OUR SERVICES. AS SUCH, YOU HEREBY ACKNOWLEDGE THAT YOU ARE SOLELY RESPONSIBLE FOR THE INFORMATION AND MATERIALS THAT YOU UPLOAD TO THE APP, INCLUDING FOR THEIR LEGALITY, ACCURACY AND COMPLETENESS, AND YOUR RELIANCE ON SUCH INFORMATION AND MATERIALS IS ENTIRELY AT YOUR OWN RISK.PLEASE NOTE THAT THE APP MAY ALLOW YOU TO EXPORT CERTAIN DATA AND RECORDS, INCLUDING PERSONAL INFORMATION, FROM THE APP AND TO SEND IT TO THIRD PARTIES. SUCH EXPORTING OF DATA IS AT YOUR OWN DISCRETION AND AT YOUR OWN RISK. PLEASE MAKE SURE THAT YOU TAKE ALL NECESSARY PRECAUTIONS WHEN EXPORTING DATA FROM THE APP. WE ARE NOT RESPONSIBLE FOR ANY THIRD PARTY’S USE OF ANY DATA AND RECORDS THAT YOU MAY PROVIDE TO SUCH THIRD PARTY. IF YOU USE A THIRD PARTY APPLICATION TO SEND DATA FROM THE APP TO THIRD PARTIES, THE COMPANY RECOMMENDS THAT YOU EXAMINE THE PRIVACY POLICIES OF EACH SUCH THIRD PARTY APPLICATION.
Which information we may collect on our Users?
We may collect two types of data and information from our Users: The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering and/or using the App and/or installs the App. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the App, type of operating system, type of the User’s device and its version, User's ‘click-stream’ on the App, product interaction, type of browser and keyboard features, the hardware specifications of such device (including screen resolution), time spent on various screens of the App, User demographics, traffic patterns, etc. (collectively, “Technical and Behavioral Information”).The second type of information is personally identifiable information, namely any information that may identify an individual or may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”).Information you provide voluntarily when you use the App [Please review and confirm the below and confirm that it is accurate and complete]Account: Personal Information is collected from the details the Users provide in the registration form in order to open an Account on the App which includes, inter alia, the User's full name, phone number, e-mail address. To this end, we may require additional information from time to time. Medical related information and documents: as part of your use of the App you may, at your discretion, upload to the App certain information and materials, including your medical and/or mental information (such as name, medical condition, prescriptions, medical tests and results, text, diagnoses, treatments, dosages, outcomes, charts, testimonials, advice, recommendations, messages, appointments, images, videos, scans, documents), in order for us to be able to provide you the Services. Demographic Information: you may provide us with your age, gender, and other demographic information. Mailing lists: you may voluntarily join our mailing list by providing us with your email address. Communications with the Company: we will collect any Personal information you provide to us as part of any communications with the Company, by any means, including by approaching our customer service (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences). Personal Information collected via technology [please review and confirm]
IP address: Users of the App may automatically provide their IP address (or Mac Address, as applicable) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below. Geolocation data: during your use of the App, the Company will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of Internet Protocol (IP) addresses and other similar information to determine your location for providing our services and for analytics, advertising and security purposes. [Please advise whether the App includes targeted advertising]Identifiers: during your use of the App, we will access, collect, process, monitor and/or remotely store online identifiers, such as Internet Protocol (IP) address, AD-ID or other unique identifiers, for the purpose of providing you with targeted advertising and for security, statistical and metric purposes. Technical and Behavioral Information: to the extent that the Technical and Behavioral Information will be linked to or associated with a specific individual then such information will be considered as Personal Information. Wearables and devices: any data derived from wearables and devices, including medical devices, which you may pair with the App, at your discretion [please confirm].We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists. For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information, as long as such connection or linkage exists. We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Privacy Policy.
How Do We Collect Information on Our Users?
There are a few main methods we use: We collect information through your entry, connection, installation, access and/or use of the App. In other words, when you are using the Services, we are aware of it and may gather, collect and store the information relating to such usage. We collect information which you provide us voluntarily. For example, we collect Personal Information when you create an Account and when you are uploading any Personal Information to the App.[Please confirm that you shall not collect any personal information from third parties]We may gather, collect and store such information either independently or through the help of our authorized third-party service providers, as detailed below.
What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to: Create statistical information and learn about the preferences of Users and general trends on the App (e.g. understand which features are more popular than others).We may process Non-Personal Information in order to recognize general trends and preferences that are not tied to any specific individual. Keep the App safe and secured against fraudulent and criminal activity. Enhance the User’s experience while using the Services. Personal Information is collected in order to: [Please confirm the list below]Enable the overall operation of the App. Personalize your experience on the App. Improve the quality of the App and the Services by formulating, customizing and enhancing the User's experience. Allow us to contact Users with proposals and tailored information regarding new services, products, events, offers, features, enhancements, special offers, upgrade opportunities, and events of interest etc. Send push notifications to Users. Users of the App can deactivate push notification by changing their settings within our App or by using their web browser/device’s settings. Verify the User's identity when they sign into the App. Be able to contact Users for the purpose of providing them with technical assistance and support. Keep the App safe and secured and for prevention of fraud and crime. Maintain our data processing records and general administrative purposes. Determine the User’s geo-location to safeguard the App. Provide the Users who subscribed to our newsletter with updates about the Company’s developments, new offerings, news regarding the Services, etc. Enable our third-party advertising service providers to present you with our advertisements on websites and apps across the Internet and across devices. You may opt-out from such advertising activities by following the directions detailed below. Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes, including in order to improve our services. Please note that in general we analyze aggregate data for such purposes, rather than specific user data, however we may need to analyze a specific case to address a specific problem. Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests. Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Sharing Information with Third Parties
The Company does not share Personal Information, other than in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce the Terms, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s App support requests; (e) to respond to claims that any Content violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of the Company, its Users, or the general public; (h) when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets (while such purchaser or investor may be located in a country that does not have the same data protection laws as your jurisdiction); (i) to collect, hold and/or manage your Personal Information through the Company’s authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to store or process your Personal Information through the Company’s affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction; (k) for legitimate business purposes, including without limitation, enhancing the User’s experience; and/or (l) pursuant to your explicit approval prior to the disclosure. For avoidance of doubt, the Company has the unrestricted right to use Non-personal Information for any purpose and to transfer and disclose Non-personal Information to third parties at its own discretion.
How You Can View, Update or Delete Your Personal Information
The Company acknowledges that under circumstances you may have the right to access and to request an amendment or deletion of the Personal Information we collect and process about you. If you wish to access or to correct, amend, or delete Personal Information, and you are unable to do so through the App, please send us an email to: [Insert Email Address] and we will enable you to fulfill such rights, to the extent it is required under applicable laws. Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws. Aggregate and/or anonymous information derived from your use of the App may remain on the Company servers indefinitely.
Minors
The App is intended for Users only (as defined above). Minors under the age of eighteen (18) are not allowed to use this App [please confirm age restriction]. Therefore, The Company does not intend and does not knowingly collect Personal Information from minors under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Services. If we learn that we collected Personal Information from minors under the age of eighteen (18) we will delete that information as quickly as possible. If you have reasons to suspect that The Company collected Personal Information from minors under the age of eighteen (18), please notify us through the means indicated in the “Contact Us” section below, and we will delete that information as quickly as possible.
Security
We take reasonable measures to maintain the security of our App and your Personal Information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur. THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA.
Third Party Service Providers
We may be using third party software or service in order to collect, host, store and/or process the information detailed herein for the purposes specified herein. Such third parties may be located in countries that do not have the same data protection laws as the laws applied in your jurisdiction. The Company engages with third parties that abide by the same lawful obligations as the Company and that post a privacy policy governing their collection, processing and use of non-personal and personal information. However, the Company does not control such third party service providers. Please read their terms of use and privacy policies to understand their privacy practices. Such service provider may include, without limitation:[Please insert list of all categories of third parties service providers that may access personal data and provide at least one third party that provides you such service, such as, cloud storage services - AWS, CRM services - Salesforce, analytics services – Google, etc.]
International Data Transfer
We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.
Links to Third Party Websites
The App may contain links to third-party websites, applications or services, which permit Users to leave our App and enter non-Company services. Most of such linked websites and services provide legal documents, including terms of use and Privacy Policy governing the use thereof. It is always advisable to read such documents carefully before using those websites and services, inter alia, in order to know what kind of information about you is being collected. The Company is not responsible for the privacy practices or the content of such resources.
Cookies and Other Tracking Technologies
When you access or use the App, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, "Cookies"), which store certain local information on your device (“Local Storage”) which may enable us, inter alia, to recognize your device from those of other Users of the App, to improve the App’s performance, to deliver a better and more personalized service according to the User’s individual interests and the device or browser used, to track Users’ use of the App, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our App and to serve targeted advertisements. Such information is locally stored in the User’s device. The Company and/or our authorized third party service providers may access such information. The Company and/or our authorized third party service providers may use both session cookies and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the App may store non-personal information (such as the different pages viewed by a User within the App) as well as User persistent identifier, which will be collected in accordance with the terms specified herein. Most devices will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the App may be limited. Please note that unless you block the acceptance of cookies, the App will utilize cookies upon your use of the App. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the App from placing further cookies on your device unless and until you adjust your settings as described above. For detailed instructions regarding the blocking of cookies, please see http://www.allaboutcookies.org/manage-cookies/.It is possible to opt-out of having your browsing activity within the App recorded by performance cookies. Please note that we use third parties as our service providers in order to track Users' activities on the App. You may obtain information about how you can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings. You can visit the Internet Advertising Bureau’s consumer advice site at http://www.youronlinechoices.com/uk/your-ad-choices , which will provide you further information, a list of all Cookies that are currently set on your device and instruction on how to opt-out of each of them.
Direct Marketing
You hereby agree that we may use your contact details for the purpose of informing you of products, services and other updates and new features which may be of interest to you, as well as for sending you other materials to the e-mail address provided by you in the registration process. You may withdraw your consent by following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you, or by contacting us as provided in the “Contact Us” section below.
Changes to the Privacy Policy
The terms of this Privacy Policy will govern the use of the App and any information collected with respect thereto. The Company reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the App or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our App or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the App after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice. Changes to this Privacy Policy will not be applied retroactively
Contact Us
If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: [Please complete support email address] and we will make an effort to reply within a reasonable timeframe.