Privacy Policy

SQUINT METRICSTM PRIVACY POLICY

Effective as of 11th March 2019

Please read this Privacy Policy carefully, it is a material part of the contractual agreement between you and Squint MetricsTM LLC which you agreed to as part of our Terms & Conditions, by creating an account for use of our website www.squintmetrics.com, use of our mobile applications or affiliated websites (collectively the “Sites”).

We take your privacy seriously. This Privacy Policy describes the ways we or our venders collect, protect, use, share, and store your personal information. If you do not agree to this Privacy Policy or our Terms & Conditions, do not use any of the Sites.

Business name and contact information (see also “Contact US” below)

info@squintmetrics.com

Squint MetricsTM LLC
640 W28th St, 9th Fl
New York, NY 10001
+1 (212) 915-7333

Types of personal data we collect

Information You Give Us

We collect information that personally identifies you when you register, sign in, use our Sites and make changes to your account, including your first name, last name and email address. In addition, in the course of your use of the Sites, we collect and associate with your Squint MetricsTM account (or affiliated product account) personal medical, physical and behavioral information that you authorize, such as: patient-reported outcomes, symptoms, moods, and other demographic, biometric and medical information. Our collection of this health-related information is made either directly from you or via your use of wearable devices connected to our Sites, or indirectly from the care givers and/or the physicians and other practitioners that you authorize via the Sites to act on your behalf.

We respect the right to privacy of all users of the Sites. You may restrict the information provided to the Sites. For example, you may decline to provide us with some or all of your information that personally identifies you; however, restricting information will materially reduce and diminish the value of the Sites to you.

In addition, when you contact us with customer service queries or other queries relating to the Sites, Terms & Conditions or this Privacy Policy, we may collect personal information you provide for purposes of addressing your queries and retain this information in accordance with our retention policy.

Information We Collect From Other Sources

Squint MetricsTM, either directly or through its authorized third-party service providers, also collects aggregate information about the use of the Sites, including information about your access and visits to the Sites, such as internet protocol addresses, browser type, browser language, referring/exit pages and URLs, other browser history, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, geolocation, and the date and time, some of which may uniquely identify your browser or your account. We collect this information in a variety of ways, including from web forms, technologies like cookies or other anonymous identifiers, web logging and software on your computer or other devices. When you visit the Sites, we store information based on your usage history. We also use cookies and anonymous identifiers when you interact with the services we may offer to our partners, such as advertising services or certain Squint MetricsTM features that may appear on other sites and in any other manner that we deem necessary for our business purposes.

Either directly or through our authorized third-party service providers, we may also collect non-personal information about your use of the Sites and produce and use aggregated and anonymized information derived from your personal information. This may include de-identified search results and information collected by cookies and similar technologies as described below.

While, as noted above, we collect personal information in connection with our Sites and for purposes of performing our services, we do not collect any more information than reasonably needed to offer our services as described on the Sites.

How We Use Your Data

How we use your personal information will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the personally identifiable information we collect for purposes of:

  • performing our services, including: assisting in measuring health improvement or decline;

  • processing transactions and maintaining your account

  • ensure technical functionality of the Sites,

  • address any inappropriate use of the Sites

  • provide you with customer support services,

  • personalize our services, and

  • respond to court orders and legal investigations, for other litigation purposes, and to comply with audits or other investigations.

We recognize that maintaining the privacy of your information is important. The information that you submit and that personally identifies you or is associated with your Squint MetricsTM account is shared only with (A) those persons that you expressly authorize via the Sites to receive such information and (B) those persons in the Squint MetricsTM organization (such as: employees, affiliates, vendors, partners and third parties) who need to access such information in order to perform the services offered by Squint MetricsTM or who will utilize the information to improve Squint MetricsTM’s operations.

WE DO NOT SELL OR RENT INFORMATION THAT PERSONALLY IDENTIFIES YOU TO ANY OTHER PARTIES. WE DO NOT SHARE YOUR INFORMATION TO SOCIAL NETWORKS OR OTHER PUBLIC OR SEMI-PUBLIC PLACES. Squint MetricsTM may however access, preserve, and disclose any information we may have about you and the contents of your account if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to avoid liability, to comply with legal process, such as a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of our affiliates or the public. Squint MetricsTM is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that it receives.

Any other information that personally identifies you or that is associated with your Squint MetricsTM account is used or shared only on an aggregated and de-identified basis.

We use the other information we collect or personally identifiable information that has been aggregated and de-identified for the same purposes as set forth above and also to:

  • assist in monitoring population health, establishing drug/device efficacy, substantiating label claims, or identifying future health risk,

  • conduct scientific, economic, and other types of analyses for third parties or for internal purposes;

  • improve our services, prediction methodologies and algorithms, the Sites content, and advertising, and

  • produce technical reports internal to Squint MetricsTM.

Squint MetricsTM reserves the right to use such aggregated and de-identified non-personal information collected from its users for any reason in our sole discretion, including but not limited to performing statistical analysis of the aggregated information, including analysis about the behavior of visitors to our Sites on an aggregated, anonymous basis, or to share such information with third parties. Squint MetricsTM may share de-identified personal information with companies, insurance companies, health care providers, Medicare, etc., who provide and develop treatments, approve payment for such treatment, and render other services, such as information processing and assessing the success of certain treatments. Squint MetricsTM may be compensated by its third-party business partners. We do not give our partners an independent right to share this information. However, due to our contractual obligations with these third parties and the need to share information to deliver and support the Sites, we cannot provide you with the opportunity to opt-out of sharing de-identified information with these third parties. Squint MetricsTM may view the content that you upload to the Sites in order to provide the Sites and otherwise perform the tasks set forth in this Privacy Policy.

Cookies

Information (including aggregate, technical or demographic information) can also be collected by us or by our authorized third-party service providers through the standard operation of our internet servers and logs, as well as other automatic data collection tools such as “cookies” and other similar technologies. By using our Sites, you consent to the placement and use of cookies and similar technologies on your hard drive or computing device.

The Sites may send "cookies" to your computer or smartphone when you access them and use such cookies as described here. The Sites use cookies to improve the quality of our service, make recommendations, and make the Sites easier to use for our members. A cookie is a small text file that is recorded either temporarily or persistently on your hard drive and that a website operator can use in order to recognize visitors who revisit a Site so as to facilitate their ongoing access to and use of such Site. Some cookies may identify you as a unique user and contain certain information about your particular login session and/or your use of the Sites.

Our Sites use the following services and related cookies:

  • We use Google Analytics to help us understand how visitors navigate to and through our Sites. These cookies enable the function of Google Analytics. This service helps us evaluate how long customers spend visiting different pages and how often they return to our Sites. Google Analytics also helps our marketing colleagues to work out the effectiveness of our digital marketing campaigns which feeds into the commercial relationship held with Google. These cookies do not collect and are not associated with personal information.

    How Google uses data when you use our site and apps

    You can opt out of Google Analytics HERE.

  • We use IBM Watson Customer Engagement Campaign Automation to help us understand how visitors are referred to our Sites through our email campaigns. These cookies enable the function of campaign tracking. This service helps us to evaluate how users are utilizing our emails and the correlation between email click-through and Sites traffic. IBM Watson Customer Engagement Campaign Automation also helps our marketing colleagues to work out the effectiveness of our digital marketing campaigns which feeds into the commercial relationship held with IBM.

    You can find more regarding IBM’s Watson Customer Engagement Campaign Automation privacy HERE

You may disable cookies in your Web browser but doing so will impact the usability of the Sites. We may also use technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests. For additional information regarding our use of cookies and other unique identifiers, please contact us at info@squintmetrics.com.

To the extent our Sites link to other websites, be sure to review the privacy policy on the Sites you are visiting as many such websites have their own policies regarding cookies and the collection and use of personal information.

Accessing and Updating Personal Information

Our Sites are configured to enable you to give you the means to access your own personally identifiable information for the purposes of deleting it and/or correcting it. If you have created an account on our Sites, you can edit some of your personal data through your account’s customer dashboard on the Site(s). You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate. You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., your personal data is inaccurate or unlawfully held).

In the alternative, you may contact us to access certain personal records we hold about you at info@squintmetrics.com or contact us at the address stated below. A fee may be payable by you if you make any requests that would require a disproportionate effort on our part, but we will not charge you until we have told you how much the fee is and what it is for, and you have told us you still want to proceed. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required.

Portability of your Personal Information

Your information associated with your account may be downloaded for portability through your account for the Sites. You can terminate your account at any time which will remove your profile and other personal information from view. Please be aware that if you delete your personal information, you may not be able to continue to use our Sites.

Data Retention

We will retain your information for as long as your account is active or as needed to comply with our legal obligations, resolve disputes, and enforce our agreements. You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you). We may retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms & Conditions, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed, but will destroy your personal data when it is no longer needed for the foregoing purposes, or we remove your personal information to render it anonymous. Notwithstanding the above, you agree that Squint MetricsTM is not, and will not be, liable for any damages in the event that your information is not retained or otherwise lost or destroyed. Please note that we may not be able to delete all of your data upon request depending on the reasons above and the nature of your interactions.

Disclosure of Personal Information

Squint MetricsTM will not disclose your information except as specifically described in this section. Subject to obtaining from you any consent (or providing you any ability to refuse consent) as required by applicable laws relating to online privacy and electronic marketing, we may disclose personal information and non-personal information about you to agents, contractors, and service providers or others engaged to perform functions on our behalf, such as providing data storage, hosting our Sites, conducting audits and performing web analytics; or to market Squint MetricsTM Sites, products and services to you (for example, to send you messages concerning new Squint MetricsTM features, products or special offers). Any third-party service providers with whom we share personal information are required to keep such personal information confidential and to use it only in a manner consistent with this Privacy Policy and not for their own marketing or other purposes. With your consent and/or at your request, we may also disclose personal information about you to other persons with whom you wish to share information via the Sites.

We may also disclose personal information to third parties if we have a good-faith belief that such disclosure is reasonably necessary (a) to enforce or apply our Terms & Conditions, including investigations of potential violations thereof, (b) to comply with legal or regulatory requirements or a governmental request, (c) to protect the rights, property or safety of Squint MetricsTM, other users or other third parties, (d) to any law enforcement authority, such as a police department or regulatory authority in connection with an investigation, or (e) to detect, prevent or otherwise address fraud, security or technical problems that may arise. We may disclose non-personal information to any third party for any reason in our sole discretion.

Squint MetricsTM may also transfer any information in its possession to a third party in the event of a reorganization, spin-out, sale, merger, or transfer of some or all of the assets of Squint MetricsTM LLC, or in the unlikely event of a bankruptcy, liquidation or receivership of our business. If we are involved in a merger, acquisition or asset sale, or in the unlikely event of a bankruptcy, liquidation or receivership of our business, we will provide affected users notice through the Sites that your information becomes subject to a different Privacy Policy.

WE DO NOT SELL OR RENT YOUR PERSONAL INFORMATION TO THIRD PARTIES. WE DO NOT SHARE YOUR INFORMATION TO SOCIAL NETWORKS OR OTHER PUBLIC OR SEMI-PUBLIC PLACES.

Protecting Your Privacy

We use reasonable security measures to protect the confidentiality of your personal information under our control and appropriately limit access to it. We monitor for and try to prevent security breaches. We use a variety of information security measures to protect your online transactions with us. If you have any questions regarding which measures and techniques we use, feel free to contact us. However, no data transmission over the Internet and no method of data storage can be guaranteed to be secure. Squint MetricsTM does not guarantee the security of any of your private transmissions against unauthorized or unlawful interception or access by third parties.

Minors

The Sites are not intended for use by anyone under the age of 13. If you are under 13, please do not attempt to create an account or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information to us, and we do not knowingly collect personal information from anyone under the age of 13. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us immediately.

California Online Privacy Protection Act

CalOPPA requires a person or company in the United States that operates websites collecting personally identifiable information from individual consumers residing in California to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

California Customers may request further information about our compliance with California’s privacy law, and may request to review and request changes to their personal information collected and stored by Squint MetricsTM by e-mailing info@squintmetrics.com or contacting us as stated below.

According to CalOPPA, Squint MetricsTM agrees to the following:

You can visit this website anonymously. The Privacy Policy is available at www.squintmetrics.com, by clicking on www.squintmetrics.com/privacy-policy. Users will be notified of any Privacy Policy changes:

  • On our Privacy & Confidentiality page

Users are able to change their personal information:

How does this website handle do not track signals?

Squint MetricsTM honors do not track signals and does not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does this website allow third party behavioral tracking?

Yes, Squint MetricsTM uses Google Analytics and IBM Watson for third-party behavioral tracking, as described above.

What are the third parties with whom Squint MetricsTM may share personal information?

Currently, we do not share your personal information with third parties for direct marketing purposes. Information may be shared to our service providers, exclusively for purposes of the performance of their services.

What is the effective date of this Privacy Policy?

This Privacy Policy’s effective date is indicated above before its first paragraph.

Fair Information Practices

Further, in order to comply with Fair Information Practices principles articulated by the Federal Trade Commission (https://www.ftc.gov/reports/privacy-online-fair-information-practices-electronic-marketplace-federal-trade-commission), Squint MetricsTM will notify users of this website who have provided an email address to us via this website via email within 7 business days, should a data breach occur.

Squint MetricsTM also agrees to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

Special Note for EU Individuals

The information we collect through the Sites is controlled by Squint MetricsTM LLC, which is headquartered in the United States at 640 W28th St, 9th Fl - New York, NY 10001. As described above, we also act as a service provider (or data processor) on behalf of and in accordance with our customer’s instructions. When we act as a service provider, if you have questions about the processing of your information or to exercise any applicable legal rights, please contact us via the means to do so provided below.

The legal bases for using your personal information

We collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

  • You have affirmatively given us consent;

  • Our use of your personal information is in our legitimate interest as a commercial organization (for example, in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the section below titled Your legal rights;

  • Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and/or

  • Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).

If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.

We will retain your personal information for as long as is necessary for purposes for which it was collected. The precise period will depend on the reason why it was collected. Those periods are also based on the requirements of applicable data protection laws, applicable legal and regulatory requirements and periods relating to the commencement of legal actions.

Your legal rights

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information:

Right to access, correct, and delete your personal information:

You have the right to request access to the personal information that we hold about you and: (i) the source of your personal information; (ii) the purposes, legal basis and methods of processing; (iii) the data controller’s identity; and (iv) the entities or categories of entities to whom your personal information may be transferred.

You also have the right to request that we delete your information.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

Right to restrict the processing of your personal information:

You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data.

We can continue to use your personal information following a request for restriction, where:

  • we have your consent; or

  • to establish, exercise or defend legal claims; or

  • to protect the rights of another natural or legal person.

Right to data portability:

To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.

Right to object to the processing of your personal information:

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction:

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Economic Area (EEA).

Right to lodge a complaint with your local supervisory authority:

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

How to Exercise Your Rights:

If you would like to exercise any of the rights described above, please send us a request at info@squintmetrics.com. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Cross-border Transfer of Information

Squint MetricsTM generally maintains servers and systems in the United States hosted by third-party service providers. We also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries other than your country of residence. As a result, where the personal information that we collect through or in connection with our Sites is transferred to and processed in the United States or anywhere else outside the EEA for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification mechanisms such as the EU - US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA.

Links to Other Websites

Our Sites may link to other websites, many of which have their own policies regarding cookies and the collection and use of personal information. Be sure to review the Privacy Policy on the website you're visiting.

Privacy Policy Updates

We may need to update our Privacy Policy as technology changes and Squint MetricsTM evolves. If we make significant changes to the Privacy Policy, we'll post a prominent message on our Sites. This Privacy Policy was last updated as of the date indicated above before the first paragraph of this Privacy Policy.

We encourage you to periodically review this page for the latest information on our privacy practices. You can always check the “last updated” date at the top of this document to see when the Privacy Policy was last changed.

Your continued use of our Sites and/or services following the effective date of an updated Privacy Policy constitutes your consent to the contents of such policy. However, we will not apply any material changes retroactively to any information we collected from you before such changes took effect, without your affirmative consent to do so. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICE AFTER THE EFFECTIVE DATE OF SUCH CHANGES. Please note that upon your departure from our services, any Privacy Policy in effect immediately prior to your departure shall continue to be binding on you and applicable to the data collected from you prior to such departure.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, you should contact us at info@squintmetrics.com.

 

Squint MetricsTM LLC
640 W28th St, 9th Fl
New York, NY 10001
+1 (212) 915-7333

We offer you additional choices about how to manage how we communicate with you.

  • Email/Direct Mail. You may opt out of receiving marketing emails from us at any time by sending an email to info@squintmetrics.com or by clicking on the unsubscribe link in our emails. You will continue to receive service-related emails (e.g., order status). To opt out of direct mail, please send your request to info@squintmetrics.com and include your postal address in the body of the email.

  • Targeted Advertising. If you do not want information about your activity on our sites to be used for tailored advertising, please visit the page hosted by the Network Advertising Initiative and follow the instructions there.

  • Updating Your Profile. You may update or correct your personal information related to your account through your dashboard of your account or by contacting Customer Support at info@squintmetrics.com. If you wish to request deletion of your personal information, then please contact us at info@squintmetrics.com.

We will respond to requests within a reasonable timeframe. We retain and use your information as necessary to comply with our legal obligations, contractual statute of limitations, resolution of disputes, and enforcement of our agreements. Please note that we may not be able to delete all of your data upon request depending on the reasons above and the nature of your interactions.