Last Updated: April 16, 2019
You understand and agree that Altoida and its authorized business partners, affiliates, subsidiaries or agents (collectively, “Altoida”, “us” or “we”) may collect, maintain, and process information provided by you, on and through the Services. You represent and warrant that you have permission to share any information you elect to provide Altoida, you consent to such information being shared with third parties, including healthcare providers, and that such information is accurate, current, non-misleading, and consistent and relevant for the purpose for which you are providing information. In the event you have prescribed the AMD to a patient, you attest that you have notified your patients that Altoida will be collecting patient Personal Information on your behalf, and the patient has consented to such collection and use.
COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA
Account Information: In order to use the Services, users may be required to have a valid Altoida account to log in to the Website (an “Account”). When you register for the Services, Altoida collects your name, email address, birth date, gender, zip code, your business phone number and business address (“Account Information”). Altoida will also have access to information about your use of the Services such medical appointments made, tests ordered, geo-location data and other information available that is combined with your Account Information. Once you create an account with us and sign in to our services, you are not anonymous to us.
Altoida collects Personal Information (both for our Customers and, in the event our Customers are health care providers, their patients) in the following general ways:
Altoida collects Personal Information you knowingly choose to submit to us through the Services, such as your name and email address, or Personal Information of individuals to whom the AMD class II medical device has been prescribed.
When you access or use the Services, Altoida may automatically receive and record information on our server logs from your browser, including your IP address, cookies, and the pages you request. IP addresses are automatically reported by your browser each time you view a web page. Your IP address is stored by Altoida when you register with Altoida.
Generally, Altoida uses the Account Information (including Personal Information) to deliver the Services to you, to improve the delivery of our Services and related products and services, to conduct our business, to develop analytics and aggregated data that allow us to improve our Services and related products and services, or to correspond with you. Specifically, Altoida uses Personal Information to:
Authenticate access to the Account and provide access to the Services;
Provide, operate, maintain and improve the Services
Send technical notices, updates, security alerts and support and administrative messages
Provide and deliver the Services and features you request, process and complete transactions, and send you related information, including confirmations and invoices;
Respond to comments, questions, and requests and provide customer service and support;
Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partner
Investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
Personalize and improve the Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Services;
Monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes;
Link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
Enable you to communicate, collaborate, and share files with users you designate; and
For other purposes about which we will notify you about and seek your consent.
App Users: Altoida makes its test available for personal devices. In this setting it is emphasized that no diagnostic output of any kind is returned to the user at any time.
The results returned by the app do not replace a clinical diagnosis. Please consult your doctor before making any medical decisions based on this test.
The Altoida NMI test does at no point record, store, or transmit any personally identifiable information (PII) of the test subject. The front facing camera on compatible devices is used through the TrueDepth API to register the eye movement of the user. Only abstract statistical data of the eye movement is analyzed and no images of the user are stored or transmitted at any time. During the Augmented Reality test, no images of either camera are recorded, stored, or transmitted at any time. No device IDs, UDIDs, or any other information capable of re-identifying the user’s device is recorded, stored, or transmitted.
The anonymized abstract statistical data of your test is stored for analysis and will upon your request be deleted. For this purpose, note the examination code provided at the end of the test and contact email@example.com .
Practice Users: Altoida makes its Website and the Services available to medical practices for a variety of uses described in our Terms of Service. In order to provide the Services to our medical practice clients (“Practice Users”), Altoida collects certain Personal Information such as contact and registration information from the Practice User employee signing up on behalf of the Practice User. Altoida collects and uses Practice User information the same way we collect and use Personal Information.
Prospective Customers: We collect names, email addresses and other business contact information about individuals who we consider to be prospective Customers and business partners (“Prospects”). Altoida uses third-party service providers in order to collect, store and process Personal Information about Prospects. We use these third-party service providers to identify Prospects and locate contact information to contact Prospects about our products and services.
As you visit or browse the Website, we collect information about the device and browser you use, your network connection, your IP address, and information about the cookies installed on your device. This information is logged to help diagnose technical problems for analytics and for quality control purposes. We also collect Personal Information submitted by any visitor to our Website through messaging features we make available on our Website and use such information for the purpose of responding to your requests.
A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our Website.
If you prefer, you can turn off cookies in your web browser by changing its security settings. Please note, however, some features of Products and Services may not function properly if your cookies are disabled. You may be able to set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website and/or Services. We do not link any of the information we use in cookies to any personally identifiable information submitted by you when you are on the Website.
Altoida also combines data derived from our usage of cookies with Account Information of registered users for the purposes set out above.
At this time, this Service does not support Do-Not-Track signals.
Log Files: Like many internet and mobile services, we may automatically gather certain information about our Services traffic and store it in log files. This information includes mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Services, to track users’ movements around the Services, and to gather demographic information about our user base.
We also store in our log files information identifying users who have accessed data that we store about patients, and any changes they make to such data. We use this information to comply with legal obligations relating to such data and to keep a record of such changes. We may also use it to improve our Services.
We may link this automatically collected data to Personal Information. Device identifiers may be tied to Personal Information to troubleshoot access issues.
We may use third-party tracking services that use log files, cookies, and possibly other techniques to track non-Personal Information about visitors to the Services in the aggregate. These services capture usage and volume statistics as well as geographical location data to compile usage reports and maps for optimization and troubleshooting purposes.
STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
Altoida processes and stores its data, including Personal Information, on cloud servers located in North America. Altoida also transfers data to the third-party service providers described herein.
By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in the USA. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in the United States under lawful access regimes or court order.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
Your Consent to Share: By providing any Personal Information to us, you fully understand and unambiguously consent to the transfer of such Personal Information and the collection and processing of such Personal Information to third party healthcare providers, credit card processing vendors, or other third parties as described in the Terms of Service. We may share aggregated data to conduct our business, improve the delivery of our Services, to develop analytics, and to enable us and our partners to improve and promote our products and services.
Processing of Medical Practice Data: As a service provider to our Practice Users we collect and analyze data related to our medical practice customers on their behalf. In this role, Altoida is processing data upon instruction from such clients. This data is shared only with the relevant client.
Service Providers and Business Partners: We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. We currently engage third party companies and individuals employed by us to facilitate our Services, including the provision of maintenance services, database management, Web analytics and general improvement of the Services, and businesses who engage our Services (to the extent provided for above).
Business Transfers: If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
As Required by Law: We may disclose Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other end users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce our contracts or user agreement, including investigation of potential violations hereof; and (iii) detect, prevent, or otherwise address fraud, security or technical issues. We may disclose Personal Information if we believe it is necessary to investigate potential violations of our Terms of Service, or to enforce those Terms of Service. The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
To “opt-out” of (1) any consents previously given to us, (2) receiving communications from us, or (3) having Personal Information disclosed to third parties, send an e-mail to firstname.lastname@example.org. Notwithstanding this right to request to cease receiving communications from us and to have us not share Personal Information with third parties, we retain the right to collect, maintain and process information provided by and collected about you on and through the Services, and disclose such information to comply with its reasonable business and legal obligations.
Altoida does not knowingly solicit or collect data from children nor knowingly market to anyone under the age of 18. If you are under the age of 13, you are explicitly not authorized to use this Service. If you become aware that your child has provided us with Personal Information without your consent, please contact us at email@example.com. If we become aware that a child under 18 has provided us with Personal Information, we will take reasonable steps to remove such information from our systems and terminate the applicable account.
TERMS OF SERVICE
Please also visit our applicable Terms of Service, which govern the use of our Services.