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Self Therapeutics Privacy Policy

Self Therapeutics, LLC recognizes that privacy of information is of great importance to you.

Self Therapeutics Notice of Privacy Practices can be found here.

Self Therapeutics, LLC, on its own behalf and on behalf of its affiliates and/or wholly owned subsidiaries (collectively referred to as “Self Therapeutics”, “we”, “us”, or “our”), makes certain telehealth related information available to you and/or facilitates your access to telehealth and expert medical services (“Mirror Care Services”) provided by physicians and other qualified and licensed medical professionals (“Medical Providers”). Self Therapeutics owns and operates (i) various publicly available websites, including without limitation, https://mirror.care (collectively, “Websites”) and (ii) various web-based and mobile applications that require you to create an account in order to use a Mirror Care Service (collectively, “Platforms”).

Applicability of This Privacy Policy

This Web and Mobile Privacy Policy (“Privacy Policy”) describes what information Self Therapeutics collects about you on the publicly available portions of the Websites and how that information is used.

This Privacy Policy does not apply to information collected from those who register and log-in (“Members”) to the password protected and secure portions of our Websites and Platforms. These portions of our Websites and Platforms allow Members to perform certain transactions and use Mirror Care Services. Information stored and collected by Self Therapeutics or added by Members into Websites or Platforms is personal health information (“PHI”), including your identifying information, records of your health and health care, and information related to payment for the provision of healthcare, generated by Self Therapeutics or received by Self Therapeutics from you or others, including via the Mirror Care Platform, whether in the form of written or electronic records or spoken words and related billing activity, and is therefore governed by the Health Insurance Portability and Accountability Act and related regulations (“HIPAA”). How Self Therapeutics uses and discloses such PHI shall be in accordance with our Notice of Privacy Practices. The use and disclosure of such PHI are also subject to the notices of privacy practices of the Medical Providers and their medical practice entities who provide medical care services for you.

Modifications to This Privacy Policy

Self Therapeutics may revise this Privacy Policy at any time. Should this Privacy Policy change materially, Self Therapeutics will give notice to you by posting a notice regarding the new policy on the Websites and Platforms. The revised Privacy Policy will be effective as of its posting unless otherwise stated.

By accessing or using the Websites or Platforms after such changes are posted you agree to all such changes.

Collection, Use, and Disclosure of Information

Self Therapeutics or a third-party vendor on behalf of Self Therapeutics may automatically collect information while you browse the Websites or Platforms. We may collect such information by tracking, or asking a third-party vendor to track, your click-stream activity when such information is not tied to a user ID through the use of “cookie” technology or by tracking internet protocol (IP) addresses, as explained below.

Because we want our Websites and Platforms to better serve your needs, we collect some basic information about you and your devices, including, but not limited to:

IP address (the computer’s address on the Internet)
Operating system (e.g., Windows)
Browser type and language (e.g., Google Chrome, Firefox)
Internet Service Provider (e.g., AT&T)
Geographic location (e.g., Boston, MA)
Type of device (e.g., iPad, desktop)
Mobile device information, including the hardware model, operating system and version, unique device identifiers, mobile network information and information about your use of our Websites and Platforms
Locale and language of device and whether it has fingerprint/face sensors
Dates and times you access and use the Websites and Platforms, features you use in the Websites and Platforms, and how long you use the Websites and Platforms overall
Links you click and pages you view within the Websites and Platforms
Pages you view before and after you leave the Websites and Platforms
Other information about your activities on the Websites and Platforms

We use this information to continuously enhance our Websites and Platforms and to better serve your needs. Some of the information we collect from you, such as IP address, may be considered identifiable personal information (“Personal Information”). Additionally, there are times on our Websites that you are able to voluntarily submit Personal Information, such as your name, phone number, email address, and/or geographic location in which you are located to obtain more information from Self Therapeutics. We may remove personal identifiers from your Personal Information and maintain and use it in a de-identified form (“De-Identifiable Information”). De-Identifiable Information and Personal Information are collectively referred to throughout this Privacy Policy as “Information”.

The Information collected from you on our Websites and Platforms may be shared with our suppliers and vendors and used in the aggregate to create summary statistics that help us analyze the Websites’ and Platforms’ usage trends, recognize you across different services/devices, assess what information is of most and least importance, determine technical design specifications, arrange the Websites and Platforms’ in the most user-friendly way, and identify system performance or problem areas.

We may allow others to provide analytics services on our behalf. These entities may use cookies, web beacons and other technologies to collect information about your use of the Websites and Platforms, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. For example, we may use analytics partners (such as Google Analytics) to help us analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Websites, Platforms, and Mirror Care Services and better understand your online activity. For more information about how you may control the collection and/or use of information for analytics purposes, please see the Cookies and Other Tracking Technology section below to learn about how we use cookies on the Websites and Platforms and your choices in relation to the use of cookies.

No data transmission over the Internet can be guaranteed to be 100% secure. Once your information leaves our Websites or Platforms, Self Therapeutics is no longer able to control further disclosure of your information. Additionally, if you choose to share your PHI or Personal Information over email, you acknowledge the risk of unsecured communication.

By continuing to use the Websites and Platforms, you hereby consent to the use and disclosure of your Information as set forth below.

Self Therapeutics uses your Information for various purposes, including to:

Provide, maintain and improve our Websites, Platforms, or the Mirror Care Services and provide you with relevant information;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Communicate with you about products and services offered by us and others, and to provide news and information we think will be of interest to you;
Plan, administer and coordinate events, community groups and outreach activities;
Process financial assistance applications and donations;
Monitor and analyze trends, usage and activities in connection with our Websites, Platforms, or the Mirror Care Services;
Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Self Therapeutics and others;
Maintain appropriate records for internal administrative purposes; and
Carry out any other purpose described to you at the time the information was collected.

Self Therapeutics may also share your Information, including Personal Information, as follows or as otherwise described in this Privacy Policy:

within Self Therapeutics or with our vendors, consultants or service providers, such as a cloud service provider in Canada or the United States for data storage, who need access to such information to carry out work or perform services on our behalf;
with Medical Providers in connection with Mirror Care Services;
with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
to respond to a subpoena, order, legal process, or government request;
if we believe your actions are inconsistent with our user agreements or policies;
to protect, establish or exercise our legal rights, property and safety, or to defend against legal claims;
to investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, harassment, situations involving potential threats to the reputation or physical safety of any person, or other violations of any law, rule or regulation, or the rights of third parties or to investigate any suspected conduct which we deem improper;
if we are to be sold, merged, or amalgamated or substantially all of our assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information;
between and among Self Therapeutics and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
with your consent or at your direction;
to comply with transparency or other public reporting obligations; or
as otherwise permitted or required by law.

We may also develop and share aggregated or De-identifiable Information, which cannot reasonably be used to identify you. Self Therapeutics does not sell Personal Information.

We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Websites or Platforms or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy Policy.

Children’s Policy

Self Therapeutics is committed to protecting the privacy of children. You should be aware that the Websites and Platforms are not intended or designed to attract children. In addition, we do not collect personal information from any person known by Self Therapeutics to be a child under the age of 13.

Links to Third-Party Websites

Our Websites and Platforms may reference or provide links to third-party websites. Other websites may also reference or link to our Websites, Platforms or the Mirror Care Services. Because these websites are not controlled by Self Therapeutics, we are not responsible for the third-party websites. We encourage our users to be aware when they leave our Websites or Platforms to review the privacy policies posted on each and every website that collects personally identifiable information. Please be aware that Self Therapeutics does not control, endorse, screen or approve, nor are we responsible for, the privacy policies or information practices of third parties or their websites or mobile applications. Visiting these other websites is at your own risk.

Cookies and Other Tracking Technology

Like many companies, we use various tracking technologies, including “cookies” and web beacons to help you better navigate the Websites and Platforms, to enhance and personalize the experience, to understand usage patterns, and to improve the Websites, Platforms, and Mirror Care Service. A “cookie” is a small piece of information or data file that is stored by your web browser on your hard drive or device memory and that your browser provides to the Websites or Platforms each time you return. Web beacons are electronic images that may be used in the Websites or Platforms and help deliver cookies, count visits and understand usage and campaign effectiveness.

Tracking technologies enhance your online experience by saving your preferences while you are visiting or using a particular website or application. The tracking technologies do not contain any identifiable information and cannot profile your system or collect information from your hard drive or device memory. A number of tracking technologies we use will last only for the duration of your web session and expire when you close your browser. Other tracking technologies last longer and are used to recognize your computer when you return to the Websites or Platforms. The tracking technologies you receive from the Websites or Platforms are served by Self Therapeutics. However some tracking technologies served by us use code provided by a third party delivering analytical services on our behalf.

Most Internet browsers automatically accept cookies, but you can set your browser to refuse them or to alert you when they are being sent. You can review your Internet browser settings, typically under the sections “Help” or “Internet Options”, to exercise choices you have for certain cookies. Please note that by blocking or deleting cookies used on the Websites or Platforms, you may not be able to take full advantage of the Websites or Platforms. You can also learn more about how to manage all tracking technologies across different types of browsers by visiting www.allaboutcookies.org. The site includes additional useful information on tracking technologies, such as cookies. Cookie management tools are device and browser specific and may not work on all devices. You can opt out of our use of Google Analytics by downloading the browser add-on here: https://tools.google.com/dlpage/gaoptout.

This Privacy Policy covers the use of tracking technologies, such as cookies, by Self Therapeutics only and does not cover the use of tracking technologies by any third party.

Security

We seek to use reasonable physical, technical, and administrative measures designed to protect Personal Information within Self Therapeutics. Unfortunately, no data transmission or storage system can be guaranteed to be 100 percent secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account or Personal Information has been compromised), please immediately notify us in accordance with the “Contact/Notices” section below.

Your Rights Regarding Your Personal Information

You have a right to request that Self Therapeutics amend or delete the Personal Information it collects from your use of the Websites if you believe it is incorrect or incomplete, and you may request an amendment or deletion for as long as the Personal Information is retained by Self Therapeutics. You must submit your request in writing to Self Therapeutics and provide a reason to support the requested amendment. Self Therapeutics may, under certain circumstances, deny your request by sending you a written notice of denial.

Subject to applicable law, you may withdraw your consent to uses and disclosures of Personal Information as outlined in this Privacy Policy. You must submit your request in writing to Self Therapeutics. Withdrawing consent does not invalidate consent to any collection, use or disclosure of Personal Information to which you consented before consent was withdrawn. If you withdraw consent, or refuse further consent, Self Therapeutics’ ability to offer services to you may be limited.

Upon your request, we may send you information about Self Therapeutics or the Mirror Care Services via email. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email. However, even if you opt-out of receiving such communications, we retain the right to send you non-marketing communications (such as important transaction information, or changes in website or mobile application terms).

Some features of our Websites or Platforms may require access to certain native applications on your mobile device, such as the camera and photo storage applications (e.g., to take and upload photos) and the phonebook application. If you decide to use these features, we will ask you for your consent prior to accessing the applications and collecting information. Note that you can revoke your consent at any time by changing the settings on your device.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our Platforms.

Additional Information for California Residents

If you are a California resident, you have the right to request the general categories of and specific Personal Information that Self Therapeutics collects, uses and discloses, and you have additional rights with respect to your Personal Information. California-specific privacy requirements that are not addressed in other sections of this Privacy Policy are described in this section.

This Privacy Policy for California Residents (“Notice”) supplements and is expressly made part of the information contained in the Self Therapeutics Privacy Policy and applies solely to visitors (“Visitors”) on the publicly available portions of our Websites and Platforms and who reside in the State of California “You” or “Visitors”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this Notice.

Consistent with the “Collection, Use, and Disclosure of Information” section above, we collect certain categories and specific pieces of information about individuals that are considered Personal Information. We may collect this Personal Information from you and other third parties, and use and disclose this Personal Information for the business and commercial purposes described in the “Collection, Use, and Disclosure of Information” section above.

For purposes of this Notice, Personal Information does not include:

Publicly available information from government records.
De-Identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data (which means if you are a Member and you log into the secure portion of the Websites or Platforms, this Notice does not apply to the information collected or used on the secure portals);
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

As a California resident, you have the right to request:

Information about the Personal Information that Self Therapeutics has collected, used and disclosed about you over the previous 12 months, including:
- the categories of Personal Information collected;
- the categories of sources from which your Personal Information was collected;
- the business or commercial purposes for which Self Therapeutics collected your Personal Information;
- the categories of your Personal Information that was disclosed for a business or commercial purpose; and
- the categories of third parties with whom Self Therapeutics shared your Personal Information;
The specific Personal Information that Self Therapeutics has collected about you over the previous 12 months; and
To have your Personal Information deleted.

Should you exercise any of your privacy rights as a California resident, Self Therapeutics will not discriminate against you by offering you different pricing or services, or by providing you with a different level or quality of services, based solely upon this request. Certain Websites, Platforms, or Mirror Care Services, however, may require your consent to have your Personal Information shared with Self Therapeutics to provide the service or to allow us to use and disclose your Personal Information to provide the Websites, Platforms, and Mirror Care Services. When you exercise your rights, you may lose access to certain aspects of the Websites, Platforms or Mirror Care Services that require your Personal Information.

Please see the “Your Rights Regarding Your Personal Information” section if you have questions or would like to make a request to exercise any of your rights described in this section. After you make your request, we will use the information we have to verify your identify, and to match the Personal Information we have collected about you, if any, to your verified identify. Our verification process may include a request for additional information, if needed, to confirm your identify or your authorized agent’s identify, or obtain proof that gave your authorized agent permission to act on your behalf. If our verification process is successful, we will respond to your request within the time and in the manner required by applicable law. If we cannot validate the identity of you and/or your authorized agent or obtain proof that you gave your authorized agent to act on your behalf, we will attempt to contact you to inform you.

Additional Rights under European Union Data Protection Law

The Websites, Platforms, and Mirror Care Services are intended only of residents of the United States. However, if you are located in the European Economic Area (“EEA”), Self Therapeutics is required to provide certain information to you about your Personal Information.

Our processing of Personal Data of users of the Websites or Platforms who are in the EEA is governed by the General Data Protection Regulation (the “GDPR”), which applies from May 25, 2018. Under the GDPR, you may be entitled to request access to and/or rectify, block, or delete your Personal Information, transmission to another controller, withdraw your consent at any time (this does not affect the lawfulness of previous data processing activities), or object to any use of Personal Information.

If Self Therapeutics will not be able to provide the requested information or make the change you request, you will be provided with reasons for such decision. Under local law you are also entitled to lodge a complaint with your local data protection authority. You have the right to object to the processing activities described in this Privacy Policy that are based on our legitimate interests.

Please submit your privacy inquiries to Self Therapeutics according to the contact details in the Contact/Notices section

Contact / Notices

If you have any questions about this Privacy Policy, or need to provide notice to, or communicate with, Self Therapeutics under the Privacy Policy, please contact Self Therapeutics using the following contact details:

Self Therapeutics, LLC
Mirror Care Privacy Officer
17W535 Butterfield Road, Suite 001
Oakbrook Terrace, IL 60181
support@mirror.care

Self Therapeutics may provide notices or communications to you on the Websites and/or Platforms and you agree that such notices shall constitute notice to you whether or not you actually access the notice.