Effective Date: September 30th, 2020
This Privacy Policy (“Privacy Policy”) explains the privacy practices and procedures of miR Scientific, LLC (“miR Scientific,” “we,” “us,” or “our”), regarding the collection, use, and disclosure of information we collect in connection with our website, www.mirsentinel.com (the “Website”). The Privacy Policy applies solely to information collected by or in connection with the Website. This Privacy Policy does not apply to the websites and services of companies that miR Scientific does not operate.
Your access and use of the Website is subject to this Privacy Policy and to our Terms of Use.
Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it. By visiting the Website, you are accepting and consenting to the practices described in this Privacy Policy.
NOTICE OF INFORMATION WE COLLECT AND HOW WE USE IT
Information We Collect
Personal Information and Non-Personal Information
“Personal Information” is information that can be used to identify you by itself or when it is combined with other information, such as a name, address, cellphone number, account information, financial insurance, credit card information, or e-mail address.
We may collect Personal Information from you in a variety of ways, including through a registration form, by you filling in forms or submitting information on the Website, or by corresponding with us by phone, email, or otherwise.
In order to use certain aspects of our Services, we may require you to complete a registration form, which may require you to provide certain Personal Information and create a user name and password. Upon registering for our Services, additional information may be automatically generated such as preferences you indicate.
We may also provide you with the opportunity to provide additional information and/or suggestions to us. In connection with any such submissions, you agree to give truthful information (such as name and email address).
Our primary purpose in collecting Personal Information is to provide you with a smooth, efficient, and customized experience using our Website, and to develop our products and services to meet your needs or to otherwise conduct our business as described in the Terms of Use.
We also collect and process Non-Personal Information that cannot identify you either alone or in combination with other information, such as your general location and use of our products, features, and services that is automatically generated when you use the Website. We collect this information through the use of third-party service providers, including, without limitation: Google Analytics. We use this information to conduct internal research on the nature of our users to better understand, protect and serve you.
Device Identifiable Information
When you use our Website, we may collect, receive, and record information on our servers that is linked to your computer or device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of operating our Website. When you visit our Website, we may collect information about your computer that your browser sends, such as the Internet domain and Internet protocol (IP) address (which is stored by miR Scientific when you register with miR), your login information, browser type, operating system, date and time of page views, the particular web pages accessed, your login information, and, if you linked to our Website from another website, the address of that other website.
As it relates to your mobile device, we may collect additional information such as the type and model, operating system (e.g., iOS, Android), carrier name, mobile browser (e.g., Chrome, Safari), applications using our Website, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID.
We may also collect your location information, such as your zip code or the approximate geographic area provided by your Internet service provider (ISP) or location positioning information provided by the location services and GPS features of your mobile device when locating services have been enabled.
Cookies
When you use our Website, we or our third-party vendors may store cookies and other tracking mechanisms on your computer in order to facilitate and customize your use of our Website. A cookie is a small data text file, which a website stores on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Certain pages of the Website and/or html email correspondence may use session cookies, persistent cookies or web beacons to anonymously track unique visitors, save website preferences and to allow us to recognize visits from the same computer and browser.
There are several types of cookies. Cookies that are essential for the operation of our Website (“Essential Cookies”) enable services you have specifically asked for. These cookies remain on your device only until you close your browser after visiting our Website. Some cookies are used to collect anonymous information on the pages visited (“Performance Cookies”). For example, we might use Performance Cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. These cookies remain on your device only until you close your browser after visiting our Website. Some cookies remember choices you make to improve your experience (“Functionality Cookies”). These Functionality Cookies remain on your device for an extended period of time. When you revisit our Website we recognize Functionality Cookies and remember your preferences or can automatically log you on to the Website. Personal Information on our system may be associated with Functionality Cookies but the cookies themselves do not contain any of your Personal Information.
In general, the cookies on our Website make your use of the Website easier, makes the Website run more smoothly and help us to maintain a secure Website. You are always free to decline our cookies if your browser permits, but some parts of our Website may not work properly in that case.
Please be advised that our third-party vendors, including Google Analytics, may use cookies or similar technologies on our Website. By agreeing to use the Website, you are expressly agreeing to allow Google Analytics and other third-party vendors to use cookies and/or similar technologies to collect information about you as described in their respective policies.
Information We Receive From Other Sources
We work with third parties who may also provide us information regarding you, including your Personal Information for example, business partners, sub-contractors in technical, payment, and delivery services, analytics providers, and search information providers.
Some of the Personal Information received by miR Scientific in connection with the Website may be provided by healthcare providers that are subject to laws and regulations, such as rules issued under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”), that govern providers’ use and disclosure of certain individually identifiable health-related Personal Information (“Protected Health Information”).
Although the Device Identifiable Information and Non-Personal Information that we collect, including the Device Identifiable Information that is not linked to your mobile device, does not identify you personally, there is a risk that third parties who receive such information from us may be able to re-identify you through other information they gather.
You can choose not to provide us with any of the information described above or requested by miR Scientific, but by doing so, you may not be able to take advantage of all features and functionalities of our Website.
How We May Use or Disclose Your Information
We will not use, disclose, or share your information except as described in this Privacy Policy.
We may use the information we collect in the following ways:
We may share your information in the following ways:
We may share aggregated demographic information about our user base with select third parties. This information does not identify individual users. We may use and publicize aggregate information in any manner that does not identify you, without your consent.
We do not sell, trade, or otherwise transfer to outside parties Personal Information we collect from you without your consent, except as described below:
How Long Do We Keep Your Information
We keep your Personal Information only for as long as we continue to have a business purpose for it. If you cease using the Website, we will keep your Personal Information in a form that allows identification of your Personal Information for no longer than is necessary for our business purposes (or as otherwise required by law).
California residents have a right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. More information can be found in the “For California Residents Only” section below, which you can access by clicking here.
COMMUNICATIONS FROM US AND OTHER THIRD PARTIES
When you send email or other communications to miR Scientific, we may retain those communications in order to process your inquires, respond to your requests, and improve our services. When you send and receive messages, we may collect and maintain information associated with those messages.
We may send you information by email on our Website only if you have consented to receive such communications. We may also send you service-related announcements on rare occasions when it is necessary to do so. For instance, if our Website is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of service-related announcements, which are not promotional in nature.
Based upon the Personal Information you provide us, we may send you a welcome email to verify your username and password. We will communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your preferences. You may contact customer services at info@mirscientific.com
LEGAL DISCLAIMER
We may disclose the information we collect from you in the following circumstances:
By using the Website, you consent to having any Personal Information you provide to us transferred to and processed in the United States. BECAUSE SOME JURISDICTIONS DO NOT PERMIT CERTAIN LIMITATIONS OR DISCLAIMERS OF LIABILITY, THESE LIMITATIONS MAY NOT APPLY TO YOU.
WHERE YOUR PERSONAL INFORMATION IS STORED
The data we collect from you is stored in the United States by use and/or our business partners for the purposes of providing services and other uses outlined in this Privacy Policy and our Terms of Use. By submitting your Personal Information, you agree to this storage. miR Scientific will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
All information you provide to us online is stored on our secured servers with are located in the United States. Where we have given you (or where you have chosen), a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
INFORMATION SECURITY
miR is committed to protecting the security and privacy of your information stored by us. We will take all steps reasonably necessary to restrict access to Personal Information to those of our employees, agents, contractors or representatives who require access to such information to perform tasks assigned to them by us.
We use reasonable security efforts to protect the data in our possession. However, no method of transmission or storage of data is 100% secure and we will not be responsible for any damage that results from a security breach of data or the unauthorized access to or use of information, whether Personal Information or Device Identifiable Information. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information. If you create copies of information from the Website, we cannot protect the security and privacy of the information contained in such copies.
All data gathered by our Website are stored by us in a password-protected database. Only we and our hosting provider, if any, have access to this database. We will protect Personal Information provided to us by using security safeguards against loss, theft, access, disclosure, copying, use, or modification. Although we and our hosting provider(s) implement standard security protections, the internet is not completely secure, and we cannot guarantee the physical or electronic security of the servers and database on which the Website is hosted.
CHANGING YOUR INFORMATION
If you wish to change any of your Personal Information that you have previously submitted via the Website, you may correct or update it using the Website or by emailing our Customer Support at info@mirscientific.com or by contacting us by telephone or postal mail at the contact information listed below.
THIRD PARTY LINKS
We may include in our Website links to websites with third-party products or services. These third-party websites have separate and independent privacy policies. Please check these policies before you submit any personal data to these websites. We therefore have no responsibility or liability for the content and activities of these linked websites. This Privacy Policy applies only to information collected by the Website or use of our Website. Nonetheless, we seek to protect the integrity of our Websites and welcome any feedback about these websites.
FOR CALIFORNIA RESIDENTS ONLY
This section of our Privacy Policy applies solely to visitors and users who reside in the State of California.
California Shine the Light Law
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please send an e-mail to privacy@mirscientific.com or write to us at Privacy Officer, miR Scientific, 7 World Trade Center, 250 Greenwich Street, 46th Floor, New York, NY 10002. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.
California Consumer Privacy Act (CCPA)
The CCPA provides California residents with specific rights regarding their Personal Information. This section of our Privacy Policy describes those CCPA rights and explains how to exercise those rights.
The categories of Personal Information that we collect from you can be found in the “Information We Collect” section above, which you can access by clicking here.
The business or commercial purposes for which we use the categories of Personal Information we collect can be found in the “How We May Use or Disclose Your Information” section above, which you can access by clicking here.
Your California Rights under CCPA
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (“Right to Know”). You have the Right to Know (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our business or commercial purpose for collecting that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; (v) the specific pieces of Personal Information we collected about you.
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable request, we will delete your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us to: (i) complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another party to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) comply with a legal obligation; or (vii) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights
To exercise your Right to Know or Right to Delete, please submit a verifiable request to us by either calling us at {enter toll free number here}; or by sending an email to privacy@mirscientific.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may need to contact you to request additional information in order to verify you are the person about whom we collected Personal Information or that you are an authorized representative. We will not use any information provided as part of a request, including any contact information you provide or that we request in order to respond to or verify a request, for any purpose other than to respond to or verify your request.
We will make an effort to respond to your verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing either by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period before our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights by (i) denying you goods or services; (ii) charging you a different price or rates for goods or services; or (iii) providing you a different level of quality of goods or service.
For additional information regarding your rights under the CCPA, or how to exercise them, you may contact us at privacy@mirscientific.com
Response Time
We will handle request under applicable law in California. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 45 days following receipt at the e–mail or mailing address listed. If we receive your request at a different e–mail or mailing address, we will respond within a reasonable period of time. Please note that we are only required to respond to each customer twice per calendar year.
SPECIAL NOTICE FOR RESIDENTS OF THE EEA, UK, OR SWITZERLAND
This section applies to individuals using or accessing our Website while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “Designated Countries”) at the time of data collection.
We may ask you to identify which country you are located in when you use or access some parts of the Website, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.
Our Relationship to You
miR Scientific is a data controller with regard to personal information collected from individuals accessing or using its Website. We act as a Processor with regard to personal information collected as part of tests or diagnostics rendered pursuant to a contract with a controller (i.e., a medical professional) in accordance with the GDPR.
Legal Basis for Processing Your Personal Information When miR Scientific is the Controller.
We rely on the following Legal Bases under the EU General Data Protection Regulation in processing your personal information:
Individual Rights
Individuals located in Designated Countries have the following rights:
If you would like to exercise your rights under applicable law where miR Scientific is acting as the Controller (for example, for personal information collected on our Website), please contact us at privacy@mirscientific.com. We may limit your individual rights requests: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic.
If we have collected your personal information as a Processor in conjunction with our tests or diagnostics, you must contact the Controller to exercise your individual rights under the GDPR should and refer to the controller’s privacy policy for more information.
If you believe we have infringed or violated your privacy rights, please contact our Privacy Officer at privacy@mirscientific.com so that we may resolve your dispute directly. We will investigate and attempt to resolve complaints regarding use and disclosure of personal information by reference to the principles contained in this Policy.
1. Privacy Shield. miR Scientific participates in and has certified its compliance with both the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA, UK, and Switzerland to the United States, respectively. miR Scientific is committed to subjecting all personal information received from the EEA, UK, and Switzerland, in reliance on the Privacy Shield Frameworks, to the Framework's applicable Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov/welcome
miR Scientific is responsible for the processing of personal information it receives, under the Privacy Shield Frameworks, or subsequently transfers to a third party acting as an agent on its behalf. miR Scientific complies with the Privacy Shield Principles for all onward transfers of personal information from the EEA, UK, and Switzerland to the United States, including the onward transfer oiability provisions.
miR Scientific commits to resolve complaints about the processing of EEA, UK or Switzerland data subjects’ personal information in compliance with the Privacy Shield Principles. Individuals with inquiries or complaints regarding this Privacy Policy should first contact miR Scientific at privacy@mirscientific.com.
If you have an unresolved complaint or dispute arising under the requirements of Privacy Shield, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism. Our independent dispute resolution mechanism is ICDR-AAA, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR- AAA are provided at no cost to you. You also have a right to lodge a complaint with the appropriate supervisory authority.
With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, miR Scientific is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, miR Scientific may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
NOTICE TO MINORS
Our Website is not directed at and is not intended for use by anyone under the age of 18. Visitors under the age of 18 should not provide any Personal Information through the Website. If you are under the age of 18, do not send any type of Personal Information about yourself to us or our Website.
INTERNATIONAL
Our Website is based in the United States, and operates under United States Law. We make no representation that information provided by the Website is appropriate or available for use outside the United States or complies with laws outside of the United States. If you are located outside of the United States, the information we collect may be transferred to and processed in the United States and in other countries where the privacy laws may not be the same as the laws where you reside. Those who choose to access the Website from outside the United States do so on their own initiative and at their own risk and are responsible for compliance with all applicable laws and regulations outside the United States. By using the Website, you hereby consent to having any information you provide to us transferred to and processed in the United States.
TERMS OF USE
Please also visit our applicable Terms of Use, which establish the use, disclaimers, and limitations of liability governing the use of our Website.
CHANGES TO OUR PRIVACY POLICY
miR Scientific may update this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date at the top of this page and, where appropriate, notify you of any changes we make to the Privacy Policy by email. Please check back frequently to see any updates or changes to our Privacy Policy.
CONTACT US
If you have any questions regarding this Privacy Policy, please contact us at:
Attn: Privacy Officer
miR Scientific, LLC
250 Greenwich Street, 46th Floor
New York, NY 10001
