Our Commitment To Privacy
- (II) REPRESENT AND WARRANT THAT YOU ARE 18 YEARS OF AGE OR OLDER;
Collection of Information
The Website and the App are intended to be used by organizations such as clinics, schools and hospitals that purchase the Equipment ("Organizations") and their Authorized Employees (as defined herein) in connection with collecting, storing, and sharing data obtained from administering the Tests. Individuals who take the Tests are referred to herein as "Subjects" and third-parties authorized by Subjects and/or Subjects' legal guardians are referred to herein as "Authorized Third Parties."
We collect or are provided with several types of information from and about users of our Website and our App and their Subjects, including information:
- that is about you or your Subjects but individually does not identify you, such as your organization name, job title, industry, demographic data, gender, date of birth, school, and Test related data and information including, but not limited to, your or your Subjects' baseline eye-movement score and focus test scores (the "Test-Related Data"); and
- about your internet connection, the equipment you use to access our Website and/or App and usage details.
We may collect:
- Your Personal Data and other information directly from you if you submit it to us so that (i) you can obtain a username and password to access specialized portions of the Website and/or the App; (ii) we can contact you to respond to inquiries about the Website and/or the App and/or related to purchasing products and services offered by EyeGuideincluding but not limited to, pricing, special promotions and discounts; and (iii) we can communicate with you in connection with feedback or other messages you submit to us;
- Subjects' Personal Data and other Personally identifiable Information (including Test-Related Data) when Organizations or their Authorized Employees directly submit such information to us as well as Subjects' Test-Related data and information automatically after Subjects have taken a Test so that we can allow Authorized Employees and Organizations to view, store, and organize such data and information, and generate spreadsheets based thereon;
- Subjects' and Authorized Third-Parties' Personal Data when Authorized Employees directly submit such information to us so that we can send Subjects and Authorized Third-Parties time-limited links and passcodes via e-mail so that they may view certain Test-Related Data;
- Website and/or App usage details, IP addresses, mobile device information, location information, traffic information , and other information collected through cookies, web beacons, and other tracking technologies automatically as you navigate through the Website and/or the App (See Tracking Technologies below);
- Information about your device used to access the Website or the App, including the device's unique identifier, IP address, operating system, browser type, mobile network information, and the mobile device's telephone number; and
The Website and the App Are Not Intended For Use By Individuals Under 18 Years of Age
Through the Website and the App, we do not knowingly collect personal information, including Personal Data, directly from anyone under 18. If you are under 18, do not: (i) use or directly provide any information on the Website or the App or (ii) directly provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. Notwithstanding the foregoing, we do collect Personally Identifiable Information concerning Subjects who are under the age of 18 (and who are possibly under the age of 13) via Organizations and their Authorized Employees when such Organizations and/or Authorized Employees perform Tests of Subjects and provide us with User-Provided Data.
INFORMATION INDIRECTLY COLLECTED FROM CHILDREN UNDER THE AGE OF 18
The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents and legal guardians (as used in this section, " Parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 (" Children"). It also requires us to obtain verifiable consent from a Child's Parent for certain collection, use, and disclosure of the Child's personal information. Likewise, the Family Educational Rights and Privacy Act requires EyeGuide to obtain valid consent from Parents of students under the age of 18 ("Students").
While we do not knowingly, directly collect Personally Identifiable Information from Children or Students through the Website or the App, the Equipment may be used, and Tests may be performed, on Children and Students, and Organizations or their Authorized Employees can provide EyeGuide with certain Personally Identifiable Information concerning Children and Students in connection with such Tests. As a result, we may indirectly obtain through Organizations or their Authorized Employees Personally Identifiable Information about a Child or a Student. In order for an Organization or Authorized Employee to create a profile for a Child or Student on an Account or Subaccount, a Child, Student, or his or her respective Parent must provide the following information: the Child's or Student's first and last name, birth date and gender, school information, as well as a Parent's e-mail address and phone number. Additionally, when a Test is performed on a Child or Student, the Child's or Student's Test-Related Data (namely, eye-movement tracking data) is automatically uploaded to the associated Organization's Account and/or Authorized Employees' Subaccounts on the Website and/or the App.
The information we collect from a Child or Student is used to organize and store the Child's or Student's Test-Related Data and Personally Identifiable Information, to allow Organizations and Authorized Employees to view, access, store, and organize Test-Related Data and Personally Identifiable Information on their Accounts and Subaccounts, and to send certain Subjects, Parents and other Authorized Third-Parties time-limited links and passcodes to view the Child's or Student's Test-Related Data. The information collected from children under 18 years of age through the App or the Website are intended only with the consent and the supervision of a parent or guardian, or, in the case of an Organization, with the consent and supervision of such Organization acting with authority and consent from the parent or guardian.
We do not share, sell, rent, or transfer Children's or Students' Personally Identifiable Information other than as described in this section. We may disclose de-identified, aggregated information about our users and Subjects (including Children and Students), provided that such information does not identify any individual and that such information cannot be re-identified with any individual. In addition, we may disclose Children's or Student's Personally Identifiable Information: (a) if we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request; (b) to law enforcement agencies or for an investigation related to public safety; and (c) to third parties we use to support the internal operations of our Website and/or the App and who are bound by contractual or other obligations to use the Personally Identifiable Information only for such purpose and to keep the Personally Identifiable Information confidential ("Third-Party Operators").
Below please find a list of our Third-Party Operators and their contact information, as well as the types of Personally Identifiable Information provided to such Third-Party Operators:
- Google, LLC, 1600 Ampitheatre Parkway, Mountain View, California 94043, [email protected] Google, LLC, as the operator of "Google Cloud Platform" is provided with all Personally Identifiable Information collected by EyeGuide for purposes of storage and related services.
In addition, if EyeGuide is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EyeGuide's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.
Parental Rights. We will not require a Child or Student to disclose more information than is reasonably necessary to administer a Test and correlate the Test to the Subject. If you are a Parent, you may agree to the collection and use of your Child's or Student's Personally Identifiable Information, but still not allow us to disclose to third parties unless such third-party disclosure is required in order to administer a Test and store associated Personally Identifiable Information. If you are a Parent, you may, at any time, review your Child's or Student's Personally Identifiable Information maintained by us, require us to correct or delete such information, and/or refuse to permit us from further collecting or using the Child's or Student's Personally Identifiable Information.You can review, change, or delete your Child's or Student's Personally Identifiable Information by sending us an email at [email protected] or writing to us at our address (see "EyeGuide's Contact Information" below). To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits customers of EyeGuide who are California residents to request certain information regarding EyeGuide's disclosure of Personally Identifiable Information to third parties for their direct marketing purposes. To make such a request, please contact us as set forth above.
Security of Information
In the event that we determine that there has been a security breach resulting in the unauthorized disclosure of Personally Identifiable Information to a third party, we will notify individuals whose Personally Identifiable Information has been so disclosed as required by law.
Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect Personally Identifiable Information you submit to us, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
Use and Sharing of Information
We will release information, which may include Personally Identifiable Information, as required by law to comply with any valid legal inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information, which may include Personally Identifiable Information, in special cases, such as if there is an attempted breach of the security of the Website or the App or a physical or property threat to you or others. We may also transfer user information, including Personally Identifiable Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate change. We may provide access to the Personally Identifiable Information you submit to us, and other information to our contractors who are performing services for us in connection with our Website or App or in connection with the products or services that you have requested, which contractors are indicated above as being Third-Party Operators.
On occasion, we may collect Personally Identifiable Information from you in connection with optional special offers or promotions. We will share such information with necessary third parties for the purpose of carrying out the special offer or promotion. Your participation in the special offer or promotion constitutes your consent to such disclosure and use of such Personally Identifiable Information.
Electronic Communications and Opting in and Opting Out
As you navigate through and interact with the Website and/or the App, we may use automatic data collection technologies to collect certain information about your equipment or device, browsing actions, and patterns, including (i) details of your visits to our Website and/or the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website and/or the App, and (ii) information about your computer, your device and/or your internet connection, including your IP address, operating system, browser type, the device's unique identifier and phone number, and mobile network information.
The information we collect helps us to improve our Website and/or the App and to deliver a better and more personalized service, including by enabling us to: (i) estimate our audience size and usage patterns, (ii) store information about your preferences, allowing us to customize our Website and App according to your individual interests;; and (iii) recognize you when you return to our Website and/or the App.
Additionally, we may use IP address information to count and track aggregate visits to the Website and/or the App, to help diagnose problems with our server, and to administer the Website and/or the App. We do not link IP addresses to anything personally identifiable, so while a particular user's session can be tracked, the user remains completely anonymous.
Responding to DO NOT TRACK Signals
Please note that EyeGuide does not currently respond to DO NOT TRACK requests sent from a user's web browser, such as Internet Explorer, Chrome, and Safari.
Other Website and/or the App and Links
The Website and/or the App may include links to pages on third party websites, such as EyeGuide's social media pages, that we think will be of interest to you and are not operated by EyeGuide. These third party websites have separate data collection and privacy practices independent from ours, and EyeGuide is not responsible for the policies or activities of such other websites. Please contact such third parties directly if you have questions about their privacy policies.
Reviewing, Correcting or Requesting that We Discontinue use of Your Personal Data
If you would like to review the current details of your Personal Data or the Personal Data submitted by you, or if you would like us to either change, or discontinue use of, your Personal Data or other Personal Data submitted by you, please contact us at [email protected] .
March 31st, 2019
EyeGuide's Contact Information
EyeGuide, Inc. 1 West 3rd Street Media, PA 19063 Telephone: (866) 931-9418 Email: [email protected]