Myndlift App Privacy Policy

Last Revised: September 27th, 2018

Myndlift Ltd. (“Myndlift", or “we”) respects the privacy of the users of its mobile application (the "App"), and is committed to protect its users' information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our App.

This Privacy Policy ("Privacy Policy") applies to (i) our customers who have executed a Purchase Order for the use of Myndlift's product ("Product"), which includes inter alia the App, (ii) end users or patients of our customers who use App, and/or (iii) end users or patients who have purchased our Products in any other manner (collectively, a "User" or "you").

 

Providing us with your personal information is a choice you make. We appreciate that and thank you for making this choice. You are not legally obligated to provide us with this information, but we do need in order to provide you and your caregiver with the App’s functionality.

 

PLEASE NOTE THAT YOUR REGISTRATION INFORMATION ORIGINATES FROM YOUR THERAPISTS. WE ASSUME NO LIABILITY OVER FALSE INFORMATION PROVIDED BY THIRD PARTIES TO US. YOU CONFIRM THAT YOU AUTHORIZE YOUR THERAPIST TO PROVIDE US WITH YOUR HEALTH AND PERSONAL INFORMATION.

 

1. Your Consent (PLEASE READ CAREFULLY!)

BY INSTALLING THE APP ON YOUR MOBILE DEVICE, ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE APP, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE POSSIBLE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). PLEASE NOTE: IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT INSTALL, ACCESS AND/OR USE THE APP IN ANY MANNER AND YOU ARE REQUESTED TO PROMPTLY ERASE THE APP FROM YOUR DEVICE.

 

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2. Which information we may collect on our Users?

We may collect two types of data and information from our Users:

• Registration Information. In order to use the App, your therapist has to sign you up to the App, using your personal data such as your: name, email address, telephone number, date of birth and gender (“Registration Information”). Providing the Registration Information is not mandatory.

• Analytical Information. The first type of information is  analytical information (“Analytical Information”). We are not aware of the identity of the User from whom we have collected the AnalyticalInformation. AnalyticalInformation is any unconcealed information which does not enable direct identification of an individual User, and which is available to us while such User is installing the App and/or entering and/or using the App. AnalyticalInformation 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 User's device and its operating system and version, User's 'click-stream', the hardware specifications of such device (including screen resolution), time spent on various screens of the App, etc.

The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

• • 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.

  • Personal Information may be collected from the details the User may provide us while contacting us via the support e-mail address available on the App.

  • Personal Information such as your name, date of birth, email, medical results and other information may be provided to us through the App by your therapist,

  • In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User during his/her use of the App.

For avoidance of doubt, any Analytical Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

• ​Health Information. When using the App together with our devices (muse headset and electrodes), we will also collect and record Electroencephalography (EEG) data, cognitive performance data (depending on the various training you conducted via the App), clinical assessment of your therapist, symptoms to monitor. You should bear in mind that the EEG data is transmitted to the App through Bluetooth connection.

• Geolocation information. We collect your geolocation information, even when the App runs in the background of your mobile device.

• Chat information. If you contact us for questions or complaints, or for technical support, we will collect the information related to your inquiry. This may include your email address and other contact information, depending on the nature of your inquiry.

 

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3. How Do We Collect Information on Our Users?

There are a few methods we use:

1. We collect information through your entry, connection, installation, access and/or use of the App. In other words, when you are using the App we are aware of it and may gather, collect and store the information relating to such usage, either independently or through the help of third-party service providers as detailed below.

2. We collect information which you provide us voluntarily.  For example, we collect information during registration to the App and through your use of the App. We may gather, collect and store the Personal Information either independently or through the help of authorized third-party service providers, as detailed below.

3. We collect information which your therapist provides to the App, as detailed above.

4. We collect information about you which is transmitted by our Product to the App (for example, EEG data which may be transmitted by our headset).  

4. What are the Purposes of the Collection of Information?

 

• Analytical Information is collected in order to:   

  • Use it for statistical, analytical and research purposes and for customization and improvement of our App and services.

  • Generating reports and alerts based on your performance, aimed at providing your therapist information about your cognitive and behavioral performance.

• Personal Information is collected in order to:

  • Generating reports and alerts based on your performance, aimed at providing your therapist information about your cognitive and behavioral performance.

  • Operating the App and providing its features and functionalities.

  • Provide and improve our App and services.

  • Customize and enhance the User's experience.

  • Sending you updates and other communications related to the App.

  • Providing you or your therapist with support, handling complaints and contacting you when we believe it is necessary.

  • Verify the User's identity when he/she signs in to the App, as well as verifying User's identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of the App.

  • Determine general geo-location information from which the User's device is connected to the Internet in order to provide the App as well as for security purposes.

  • Enforcing the Terms of Use and this Policy and preventing misuse of the App.

  • Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified.

  • Taking any action in any case of dispute involving you, with respect or in relation to the App

5. Sharing Information with Third Parties

Myndlift may share the information gathered during your use of the App with your therapist that provide you with healthcare services. Myndlift may also share any Personal Information it collects with third parties in the following cases: (a) to operate, maintain, develop and enhance the App (to this end, we may share your information with third-party service providers such as Google, Intercom, etc.); (b) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (c) to enforce this Privacy Policy, including investigation of potential violations thereof; (d) to detect, prevent, or otherwise address fraud, security or technical issues; (e) to respond to User's support requests; (f) to respond to claims that any content available on the App violates the rights of third-parties; (g) 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; (h) to protect the rights, property, or personal safety of Myndlift, its Users, or the general public; (i) when Myndlift is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets (while such transaction may include a transfer of information to an entity which may be located in a country that does not have the same data protection laws as the User's jurisdiction); (j) to collect, hold and/or manage your Personal Information through Myndlift'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; (k) to store or process your Personal Information through Myndlift's affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction. Myndlift requires its affiliated entities to agree to processing your Personal Information in compliance herewith; and/or (l) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, Myndlift may collect, use, process, transfer and disclose Analytical Information to third parties at its own discretion.

6. Deletion or Modification of Personal Information

If for any reason you wish to delete or modify the Personal Information collected about you through the App, you can do so by sending us an e-mail of your request to (hello@myndlift.com) and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you or our therapist instruct us otherwise we may retain and use your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations, to resolve disputes, to enforce this Privacy Policy and/or to enable Users to reinstate  Accounts, all as permitted under any applicable privacy laws.

Aggregate and/or anonymous information derived from your use of the App may remain on Myndlift's servers indefinitely.

Personal Information that was shared by you or your therapist with others  cannot be amended or deleted by Myndlift, as such information is not under Myndlift's control.

7. Security

We take reasonable measures to maintain the security and integrity of our App and User 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. Myndlift SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION THEREOF.

8. Third Party Service Providers

We may be using other third party software or service in order to collect, host, store and/or process the information detailed herein. Myndlift uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such service include without limitation, Google Analytics and the Google Cloud Platform which privacy policy can be found at: http://www.google.com/intl/en/policies/privacy/.

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9. Cookies and Other Tracking Technologies

When you access or use the App, Myndlift and/or our third party service providers may use industry-wide technologies such as "cookies" or other similar technologies, which store certain local information on your device ("Cookies"), which may enable, inter alia, automatic activation of certain features and make the User’s experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored on your device. Myndlift and/or our authorized third party service providers may access such information. Myndlift and/or our authorized third party service providers may use both session cookies (which expire once you close the App) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Cookies included in the App may store non-personal information (such as the different pages viewed by a User within the App). It is easy to prohibit and/or delete the Cookies, inter alia, via uninstalling the App from your device and/or through the Settings option of your device. Most platforms will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Cookies you may use the settings option of your device or according to the specific instructions provided by the third party service provider's privacy policy and terms of use. However, if you block or erase cookies, or change the settings of your device, your online experience may be limited. Third-party cookies usually store only a Non-personal Information, such as the pages you have visited, the duration of your browsing, etc. Myndlift does not control such third party service providers.  

 

10. Minors

The App is intended for Users over the age of thirteen (13). Therefore, Myndlift does not intend and does not knowingly collect directly Personal Information from children under the age of thirteen (13) 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 thirteen (13) are not using the App. If we learn that we unlawfully collected Personal Information from children under the age of thirteen (13) we will delete that information as quickly as possible. Please contact Myndlift at (hello@myndlift.com) if you have reasons to suspect that Myndlift unlawfully collected Personal Information from children under the age of thirteen (13) and we will delete that information as quickly as possible.

11. Links to Third Party Sites

Certain links provided in the App permit Users to leave our App and enter non-Myndlift sites or services. These linked sites and services are not under the control of Myndlift.  Most of such linked sites 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 sites and services, inter alia, in order to know what kind of information they are collecting.

12. International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers 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.

13. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the App and any information collected therein. Myndlift reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the App and/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.

14. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to (hello@myndlift.com) and we will make an effort to reply within a reasonable timeframe.