1 - WHAT DO WE CAPTURE?
There are four stages of information we capture:
- When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address, email address and payment information. We may send you emails about our store, new products, best practices and other updates.
- When you use the devices, we capture your patient's refractive error. Such information remains anonymized until you associate them with notes identifying the patient or the patient profile itself. The applications capture the location of the exam, date and time of the usage, pictures used to compute the optical powers of the devices, light sensor information, accelerometer information, your EyeNetra phone's information (such as serial number and phone number), the information in range of NFC and Bluetooth devices, and the applications have the power to change your Phone’s Settings information in order to make sure the devices run accurately. You should assume that every activity in the app is being tracked and stored, including when the patient is running through the examination process. That data is again anonymized and submitted to our servers, where we run algorithms to understand the device’s usage and enhance the results.
- When you use the Insight platform to connect the anonymized measurements to a patient profile. On Insight, patients can book appointments, insert the current medical status, have the anonymized measurements be associated with them, be prescribed from the on-line portal and be charged on their credit cards. Insight is a HIPAA compliant data storage for all that information. The data is encrypted in our servers and only the users that you gave access to will be able to see the data.
2 - HOW DO WE USE THE INFORMATION?
We may use your Personal Information for the following purposes:
- To respond to your requests;
- To provide and improve the website, applications and our services;
- To contact you about changes to the website and/or the services;
- To send you notices (for example, in the form of e-mails, mailings, and the like) regarding Services you are receiving, and for billing and collection purposes;
- To market the applications and services;
- For any other purposes disclosed at the time the information is collected and to which you consent;
3 - HOW DO WE SHARE THE INFORMATION?
We may share your Personal Information for the following purposes:
- Service Providers. We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them only with the Personal Information that they need to perform their specific function.
- Legal Requirements. We may disclose your Personal Information if required to do so by law, or in the good faith belief that such action or disclosure is necessary appropriate (i) to operate the Website and/or the Services, (ii) comply with any legal obligation, report unlawful activity, cooperate with law enforcement, or protect against legal liability, (iii) protect and defend our rights, property, personnel, suppliers, sponsors, agents or licensors, or (iv) protect the personal safety of other users of the Website, the Services, and/or the public.
- Business Transfers. If all or all or substantially all of our assets or business are acquired and/or sold, your Personal Information will be transferred along with our other business assets.
- Aggregated Information. We may aggregate and de-identify Personal Information and provide it to our existing or potential business partners, sponsors, advertisers or other third parties, in response to a government request, or to other third parties for lawful purposes.
- Third Party Marketers. We may disclose Personal Information (excluding Health Information) to third party marketers (who may combine such Personal Information with their own records, and records available from other sources), for their own direct marketing purposes, and the direct marketing purposes of other third party marketers. If you wish to opt-out of sharing your Personal Information with third party marketers for their own and third party direct marketing purposes, please send an email with your name and address to firstname.lastname@example.org.
We may share your Patient’s health information to the following purposes:
- Disclose Health Information to designated health care providers for the purpose of preparing a prescription for eyewear, contact lenses and/or related products and services (“Prescription“);
- Along with the Prescriptions, disclose Health Information to designated third party service providers for the purpose of procuring eyewear, contact lenses and/or related products and services, and otherwise assisting with the patient’s vision care needs.
Service Recipients may revoke all or part of the consents granted to us above in writing at any time by sending a signed and dated statement to EyeNetra as set forth in the “How do I withdraw my consent” section below.
Notwithstanding the foregoing, to the extent that we receive and/or collect your Health Information through the Website from a Covered Entity (as defined under the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA“)), in its capacity as a Business Associate (as defined under HIPAA), such information will be subject to protection under the privacy and security requirements of HIPAA and Health Information Technology for Economic & Clinical Health Act of the American Recovery and Reinvestment Act of 2009 (“HITECH Act“) set forth in the Business Associate Agreement which will govern EyeNetra’s use and disclosure of such Health Information, and shall supersede the foregoing in the event of an inconsistency between the two.
4 - CONSENT
How do you get my consent?
When you sign up for the applications, devices or when you purchase the products on-line.
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
When you sign up for the applications, you giving consent to EyeNetra to store yours and your patient's information. We imply that you have authority from the Patient to collect the information system uses.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at email@example.com or mailing us at:
47 Third St, 300. Cambridge, MA. 02141.
5 - SHOPIFY
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more insight, you may also want to read Shopify’s Terms of Service or Privacy Statement.
6 – AMAZON CLOUD
Our Insight Portal is hosted on Amazon AWS servers. They provide us with the hardware to run our applications and store its contents. Your patients data are stored here in an encrypted fashion and cannot be seen by Shopify, for instance. Not even Amazon employees can have access to the data.
If you choose a direct payment gateway inside Insight to enable your patients to pay you for their services, Stripe, the credit card processing company, stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your patient’s purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
7 - OTHER THIRD-PARTY SERVICES
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
We use web beacons, also known as “clear gif” technology, are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. Unlike cookies, which can be stored on a user’s mobile device’s hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.
8 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
9 - COOKIES
Here is a list of cookies that we use. We’ve listed them here so you that you can choose if you want to opt-out of cookies or not.
- _session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc).
- _shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits
- _shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer.
- cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.
- _secure_session_id, unique token, sessional
- storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access.
- _ga, gid, PREF, persistent for a very short period, Set by Google and tracks who visits the store and from where
- intercom-lou-s6vwhk6u, intercom-lou-s6vwhk6u is our Chat function. The code connects your messages to the messages on the phones, emails and other browsers.
- Sdsc is the Linkedin tracker.
- M_pixel_ratio, presence and pl are the Facebook Trackers.
10 - AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at firstname.lastname@example.org or by mail at
[Re: Privacy Compliance Officer]
47 Third St, Ste 300. Cambridge, MA 02141. USA.