Privacy Policy

This Privacy Policy describes how Medeloop, Inc. (“Medeloop,” “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). Medeloop may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

This Privacy Policy governs the patient portal, which is offered by Medeloop, and is separate from any other notice, policy, or consent provided to you directly by any other applicable medical facility, research institution, etc. If you have questions or concerns regarding your personal information related to any other applicable medical facility, research institution, etc., please direct your concerns to that relevant entity.

INDEX

• Personal information we collect
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• Changes to this Privacy Policy
  
• How to contact us

PERSONAL INFORMATION WE COLLECT

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
  
• Demographic data, such as your city, state, country of residence, postal code, and age.
• Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, photographs or pictures, and any other information that you add to your account profile.  
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Relationship data, such as familial or other relationships to third parties whose personal information you may provide to us, such as legal guardian, child, or emergency contact information. Please do not share information about others with us unless you have the legal right or their permission to do so.
• Health insurance data, such as your insurance carrier name and account details; and
• Health related data, such as medical conditions, symptoms, dietary information, lifestyle preferences, exercise habits, mental health concerns, genetic testing results, and any other information that you voluntarily provide via the Services or when you choose to share activity data from your device (e.g., your phone’s accelerometer) or link other third-party platforms or activity trackers to the Services, such as Apple Health.
• Government-issued identification number data, such as national identification number (e.g., Social Security Number, Social Insurance Number).
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Research institutions, such as the entity that referred you to the Service (e.g., your contact information, health insurance information, and other similar information).
• Electronic Medical Records, such as the relevant electronic medical record database(s) that you choose to connect to the Services.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Precise geolocation data when you authorize our mobile application to access your device’s location.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

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Service delivery and operations. We may use your personal information to:

• Provide, operate and improve the Service and our business;
• Personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• Establish and maintain your user profile on the Service;
  
• Enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• Communicate with you about events or research studies in which you participate;
• Understand your needs and interests, and personalize your experience with the Service and our communications; and
• Provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

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Marketing. We and our service providers may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below

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Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

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Compliance and protection. We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• Enforce the terms and conditions that govern the Service; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

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To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

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Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements

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When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

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Affiliates. Our corporate parent, subsidiaries, and affiliates.

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Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, consumer research and website analytics).

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Research institutions. We may share your personal information with research institutions or life sciences companies for their own research purposes with your consent. Note that, when practicable, we will share information with these research institutions in an aggregated and/or deidentified format.‍

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Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.‍

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Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., the sale, transfer or merger of all or part of our business, assets or shares). We may disclose your personal information to an acquirer, successor, or assignee of Medeloop as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

YOUR CHOICES

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account

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Opt-out of communications. You may opt-out of emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.

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Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

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Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

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Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

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Privacy settings. We make available certain privacy settings on the Service, including options to control what personal information is viewable to researchers and other users of the Service.

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Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

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Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

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Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

SECURITY

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

HOW TO CONTACT US

• Privacy Officer: Josh Walonoski
• Email: privacy@medeloop.ai
• Mail: 1010 rue Sherbrooke O, Suite 716, Montreal QC H3A 2R7