PRIVACY POLICY
Last updated: February 8, 2021.
This Privacy Policy outlines how Mobio Interactive Inc. (“MI,” “we,” “us”, or ”our”) may gather and use personally identifiable user information (“Personal Data”), and non-personally identifiable user information (“Anonymous Data”) when you access our websites, located at www.midigitaltherapeutics.com (the “Site”), or download and interact with MI iOS or Android applications, “Wildflowers Mindfulness, Am, Actify Mindfulness” (the“Apps”). Please read this policy carefully before accessing and using the Site or downloading and using the Apps.
Data collected by MI will not be shared or processed for any other reason than outlined in this policy. Should the purpose of data collection change, MI will inform all users of Am Mindfulness by email and re-obtain consent for change in data collection.
This Privacy Policy does not apply to third party websites which may be linked to Am Mindfulness or other MI products and services. Please consult the third party’s Privacy Policy in all cases.
What We Collect
Anonymous Data
Anonymous Data refers to data that by itself does not permit the identification of a specific individual. We collect such information only insofar as is necessary or appropriate to fulfill the purpose of your interaction with the Apps or the Site. We may collect the following types of Anonymous Data when you use the Apps or the Site.
Personal Data
Personal Data is data that can be used to identify or contact you. MI is strongly committed to protecting the privacy of its user community.
The Apps require access to the camera on your device in order to measure your heart rate. Images from the camera feed are processed locally on your device and cleared immediately afterwards. We do not collect any images obtained from the camera feed.
We do require registration to access MI Apps, allowing you to access and use the Apps by providing Personal Data. Depending on your use of the Services, that may include:
How We Use Your Data
Anonymous Data
The Anonymous Data you provide allows us to perform analysis and generate the appropriate statistics relevant to you. We use the Anonymous Data to better understand our users as well as to improve the content and functionality of the Apps. For example, collecting the waveforms related to the heart signal allows us to perform research and development, improve the Apps, and develop new features or services. If we do collect information regarding your GPS location with your permission, we will not share such information without your express consent.
We may conduct research on our end user's demographics, interests, and behavior based on the Anonymous Data. This research may be compiled and analyzed on an aggregated basis. MI may share with its affiliates, agents, and business partners this “aggregated” data compiled from the information that it collects from users. These aggregate data do not identify you personally. We may also disclose aggregated data in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Personal Data
If you contact us by email, we may use the email address you provide to answer your question or resolve your problem. MI also may use that email address to tell you about new features, solicit your feedback, or just keep you up-to-date with MI and our products. You can always opt out of email marketing by clicking on the “Unsubscribe” link appended to the end of a promotional email from us.
MI deems Personal Data confidential and does not disclose such information without the express informed consent of the user. User consent shall be secured through an express action by the user such as clicking a check-box, providing an electronic signature, or other substantially similar method, after clear and conspicuous disclosure immediately above such check-box or electronic signature indicating that the user is agreeing to the disclosure of his or her information by MI. A pre-checked box will not be considered evidence of consent. MI will not release Personal Data to any person or organization not specifically authorized by the individual user, unless such disclosure is required pursuant to a lawful request from a federal, state, local, or foreign law and civil enforcement agencies. If MI discloses Personal Data pursuant to such a request, it shall notify users. We will not rent or sell Personal Data to anyone.
We may need to employ third-party service providers (“Contractors”) to help us provide and maintain our services and business (such as database hosting companies, email service providers, and other similar service providers). These Contractors may have limited access to Personal Data to perform services on our behalf or to comply with legal requirements, and are contractually obligated to safeguard any Personal Data received from us. Allowing Contractors access to Personal Data is not considered a disclosure of such information under this Privacy Policy. By consenting to this Privacy Policy, you agree to permit these Contractors to have access to your Personal Data.
The Apps may allow you to share content with third-party social networking Site (e.g. Facebook, Twitter) and apps (e.g. Apple Health, Google Fit). If you choose to do this, your interactions with these third parties are governed by the privacy policy of the company providing them, not by MI’s Privacy Policy. Personal health information collected and stored by MI, and subsequently shared by the user via the Apps, may not be protected under the Health Insurance Portability and Accountability Act (“HIPAA”), the Personal Information Protection and Electronic Documents Act (PIPEDA) or the General Data Protection Regulation (GDPR).
European Union Users
Am Mindfulness is compliant under the EU General Data Protection Regulation (EU GDPR).
Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:
For example, we use identity information to prevent fraud and abuse and to keep the Services secure. We may also send you promotional communications about our Services, subject to your right to control whether we do so.
We analyze how users interact with our app so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the mobile experience we offer all our users.
For UK residents seeking independent advice about data protection, privacy, data sharing issues and your rights you can contact:
Information Commissioner’s Office
Wycliffe House, Water Lane Wilmslow Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745
Email: casework@ico.org.uk
Security Policy/Procedures and Standard of Care
The security of your personal data is of paramount importance to us. We take all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of Personal and Anonymous data.
While all data is encrypted in transit and in storage, no method of transmission over the Internet or electronic storage is completely secure, so MI cannot guarantee its absolute security. By using the Site or the Apps, you accept this risk.
Your account information is protected by a password, which you should choose carefully and keep secure.
All Personal and Anonymous data is stored on encrypted servers hosted by Amazon Web Services (AWS).
Data Retention
Personal information is collected inside of the Am app through forms and drop down menus where individuals actively consent to share their personal information. The information is immediately de-identified and securely stored until the user account with which it is associated is deleted. Accounts can be deleted upon written request to mi@mobiointeractive.com. Accounts are also deleted after 2 years of inactivity. Data associated with deleted all user accounts are anonymized and retained for an indefinite amount of time for research and development purposes. Anonymisation is the process of removing personal identifiers, both direct and indirect, that may lead to an individual being identified.
If you contacted us via email, your email will be retained for communication purposes for a reasonable time thereafter.
All data is encrypted in storage.
Data Transfers
While MI is a Singapore-based company, your information will be collected and processed in the country or geographical region in which it is registered by the user. Each country has its own laws governing data protection and government access to information. If you choose to use the Services, you need to agree to our Terms of Use, which set out the contract between MI and its users.
All data is encrypted in transit.
Data Breach
Upon discovery of a data breach, notice shall be made to all affected users of MI products no later than 72 hours after the discovery of the breach. Incidents will also be reported to relevant stakeholders and to the relevant authorities.
Your Rights
Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information. While these rights are not applicable globally, all MI users can manage their personal information.
To enforce your data rights, modify or delete the personal information you’ve provided to us, please contact us as described below (see "Contact Us"). We may retain certain information as required by law or as necessary for our legitimate business purposes.
MI strives to respond to all requests to exercise user rights as quickly as possible, and no longer that within 2 months of receiving the request.
Children
We do not knowingly collect Personal Data from children under the age of 13, unless consent is given or authorised by the parent or legal guardian. If you are under 13, you should not provide any data to us without the permission of your parent or legal guardian. If you have reason to believe that a child under the age of 13 has provided Personal Data to us without the consent of the parental or legal guardian, please contact us (mobio@mobiointeractive.com), and we will endeavor to delete that information from our databases.
Cookies
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We may use cookies to help us identify and track visitors, their usage of the Site, and their website access preferences. If you do not wish to have cookies placed on your computers, you should set your browsers to refuse cookies before using MI’s websites, with the drawback that certain features of MI’s websites may not function properly without the aid of cookies.
Google Analytics cookies. Google Analytics uses first-party cookies to track visitor interactions and collect information about how visitors use the Site. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. We then use the information to compile reports and to help us improve our site. You can opt out of Google Analytics – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.
Business Transfers
All data generated by users of the Apps or created with the Apps shall be owned by MI. If MI, or substantially all of its assets, were acquired, or in the event that MI goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of MI may continue to use your Personal Data and Anonymous Data as set forth in this Privacy Policy.
Privacy Policy Changes
Although most changes are likely to be minor, MI may change its Privacy Policy from time to time and at our sole discretion. MI will present the revised Privacy Policy when you open the Apps and will secure your express consent that requires you to physically scroll through the entire policy and, before using the Apps, click on a button that states: “I have read and agree to the Privacy Policy for the Apps.” For visitors to the Site, your continued use of the Site after any change in this Privacy Policy will constitute your acceptance of such change. We recommend that you revisit this policy from time to time to ensure you are aware of any changes.
Contact Us
If you have any questions about this Privacy Policy, please email us at mi@mobiointeractive.com
To modify or delete the personal information you’ve provided to us in one of our Apps, please write to us using the Contact form available inside of the App in which you have registered an account.
Data Protection Officer
MI has a Data Protection Officer who ensures the laws protecting personal data are applied and adhered to. MI's DPO is:
Ms. Ramya Loganathan
Email: ramya@mobiointeractive.com
Complaints or questions
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring concerns to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
Please contact us at mi@mobiointeractive.com.
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