Privacy Policy
Publication date:
January 1, 2020
+Introduction
MedClub Is a unique app dedicated
for Doctors, property of Future Experts Company and also referred to as “our”, “us” and “we” understands the importance of user privacy and
takes privacy matters very seriously.
By visiting MedClub existing and future application(s) and/or domain name(s) http://MedClub.App , including its sub-domains and mobile optimized version
(collectively, the “APP”), or otherwise accessing any
linked pages, features, content, products, services, mobile properties and
mobile device applications for iPhone, iPad, Android or other smartphone or
tablet device (each, a "Service") owned
or operated by Future Experts Company, you acknowledge and accept the terms in
this Privacy Policy (“Policy”).
This Policy is a legally binding agreement between MedClub and, you, a user of our
Services and/or prescriber of our App; and your acceptance of this Policy
arises upon your simple use of the Services, your use of the App, or when you
otherwise click on the “I accept” checkbox on our registration page (or similar
box or means). If you do not agree to the terms of this Policy, please close
this page tab and immediately stop browsing our App and/or using the Services.
A separate agreement and/or terms and conditions governs delivery, access and
use of the Services (the “Customer Agreement”),
including the processing of any messages, files or other content submitted
through Services accounts. This Policy shall be incorporated by reference into
the Customer Agreement. The organization (e.g., your employer or other entity
or person) that entered into the Customer Agreement (“Customer”) controls the terms governing the Services
and any associated Customer Data. If you have any questions about specific
settings and privacy practices, please contact us.
This Privacy Policy does not apply to any third party applications or software
that integrate with the Services (“Third Party Services”),
or any other third party products, services or businesses.
This Privacy Policy describes the following information about collected by MedClub:
·
With Whom We Share Information
·
Regional and International Provisions
·
Contact
+Information We Collect
We collect a variety
of personally identifiable information ("PII") about users of our
Services to ensure a quality user experience. "PII" means information
that we can use to identify or contact you, such as your name, address,
telephone number, email address or other contact information. You are
responsible for ensuring the accuracy of all PII that you submit to us.
Inaccurate information may affect your experience when using the Services
and/or our ability to contact you as described in this Policy. PII collected by
us is protected as personal data under applicable data protection law.
PII does not include "Aggregated Information" which is information or
data we collect where individual user identities have been removed, including
metadata on your use of the Services, IP address logs, device and location
information. Aggregated Information helps us understand trends, user needs and
other information to provide improved Services and may be used by us for any
purpose.
We may also collect other non-personally identifiable information about your
use and interaction with our Services. "Non-personally identifiable
information" means information where we cannot determine the identity of a
natural person. Non-personally identifiable information is not treated as PII
unless we combine it with or link it to PII that you give to us.
If you do not wish to disclose any required information, then your sole
remedies shall be to close this web tab, delete your MedClub. account and/or exit
the APP .
+How We Collect Information
Information You Give Us
We collect information that you give to us when you register or use our APP.
When you register for a MedClub. user account ("Account") on
the Android devices, iPad or iPhone XDrs
application, you will be assigned a unique account identifier which will be
associated with any information you give to us under your Account. You may also
give us information to allow us to contact you or use certain features
available through our Services without signing up for an Account, such as when
you fill out a request form, provide feedback, email us, or engage in
communications with our team.
Customer Support Information
Your emails, calls and other correspondence to and from us may be recorded for
various purposes including: monitoring customer service quality or compliance,
checking accuracy of the information you provide us, preventing fraud or
providing training for our staff or customer service representatives. Any
information obtained from you through Customer support will be treated in
accordance with the provisions of this Policy.
Information We Collect
Automatically
Even if you do not provide information to us, we automatically collect certain
information about your use and interaction with our APP and/or Services. For
example, when you visit our APP, our systems automatically maintain logs to
record data about all visitors who use our App and stores this information in
our database. These web logs may contain information about you including the
following: IP address, type(s) of operating system you use, type of device you
use, date and time you viAPP d the webAPP , your activity and/or referring webAPP
s. We use your log information to troubleshoot problems, gather demographic
information, customize your experience when accessing our app, Services and
other business purposes.
Information Collected From
Other Sources
We may receive information about you from outside sources, such as commercially
available demographic or marketing information, and add or combine it with your
information to provide better service to you and inform you of Services or
other information that may be of interest to you.
+How We Use Information
In order
for us to provide and maintain our app and Services, and
to improve your user experience, we will use your information in
accordance with your instructions, including any applicable terms in your
Customer Agreement and applicable law. XDrs. uses your information
in furtherance of our legitimate interests in operating our App,
Services and business. Additionally, XDrs. uses your information:
·
Develop, research, process, safeguard, modify and improve our
communications, the App and Services.
·
Send correspondence to your e-mail address, including sending
password verification and retrieval links, billing, account management
information, newsletters, answers to queries/suggestions and other notices
related to the APP and Services.
·
Improve your user experience and provide you with customer
support.
·
Investigate and help prevent security issues, abuse, and
breaches.
·
As required by applicable law, legal process, or regulation.
+With
Whom We Share Information
Disclosure with Your Consent
Customers determine their own policies and practices for the sharing and
disclosure of information, and XDrs. does not control how a Customer or any
other third parties choose to share or disclose information. We may disclose
your information with your consent, which we may obtain in several ways,
including:
·
In writing.
·
Verbally.
·
Online, by clicking on a link or button; or
·
Other mechanism.
Our Services permit
you to submit information which may be displayed to other authorized users in
the same or different Customer Account. The sharing and other controls applied
to such information may be determined by you, other users and/or an
administrator of your Account.
We may share your
information with third parties as necessary to provide Services to you or to
support the technical operation and/or maintenance of our Services, including
third party application that you may engage within the Services. We may also
share information with our affiliates, agents, outside vendors or service
providers to perform functions on our behalf. When a third party acts solely on
our behalf and otherwise as applicable, we use reasonable commercial efforts to
require that party to follow the privacy practices stated in this Policy or
have complementary privacy protections to protect your information. We do not
share your information with unaffiliated third parties except as permitted to do
so in this Policy.
Disclosure Without Your Consent
In general, we may disclose your information without your consent to disclosure
when we reasonably believe disclosure is appropriate to:
·
Comply with the law (e.g., lawful subpoena or court order).
·
Cooperate with or report to law enforcement agencies in
investigations that involve users who use our Service Offerings for activities
that are or seem illegal or illegitimate activities.
·
Enforce or apply agreements for our Service Offerings; or
·
Protect our rights or property or that of our affiliates,
including respective officers, directors, employees, agents, third party
content providers, suppliers, sponsors, or licensors (e.g., to address
allegations about fraudulent or unlawful activity related to a XDrs. account).
·
In connection with a merger, acquisition, public offering, sale
of company assets, insolvency, bankruptcy, or receivership, subject to standard
confidentiality requirements.
·
To defend XDrs. and our affiliates, licensors, officers, agents
and representatives from legal claims and processes brought to us by third
parties (including takedown notices);
·
Use or disclose aggregated or de-identified data in our sole
discretion.
+How We Protect Information
We use industry
standard protocols and technology to protect your registered user information
and personal data in order to guard and encrypt data for transmission in a
format that prevents data theft by unauthorized third parties, including
internal reviews of our data collection, storage and processing practices,
security measures, and physical security measures. However, please take into
account that the Internet and email transmissions are not secure or error free
communication means.
We also urge you to take additional steps on your own to safeguard and maintain
the integrity of your information. For example, you should never share your
Account or login information with other people and be sure to sign off when
finished using a shared or public computer. We urge you to be aware that if you
use or access our Services through a third party computer network (e.g.,
internet café, library) or other potentially non-secure internet connection,
such use is not recommended and is solely at your own risk. It is your
responsibility to check beforehand on the privacy and/or security policy of
your network prior to accessing the Services. We are not responsible for your
handling, sharing, re-sharing and/or distribution of your information except as
set forth in the Policy.
+What Choices Do You Have
Control of your
information
Customers will generally be able to edit, select or delete the amount and type
of personal data they disclose to us when using our APP and services. This will
be managed through your Account with us, the settings section of your account,
the APP, and through the means mentioned in this Policy.
Personal data owners’ rights
and revocation of consent
Any user of our App shall have the right to make a request to us to enforce
such user’s rights to:
·
Access the user’s personal data.
·
Rectify the user’s personal data, when inaccurate or incomplete.
·
Cancel the process of the user’s personal data.
·
Object —with legitimate reasons— the process of the user’s
personal data; and/or
·
Revoke the user’s consent for the use, storage, treatment,
process and/or disclosure of the user’s personal data.
The enforcement and
upholding of your privacy rights should be requested to us in writing and must
include, at a minimum, the following information: (i) your complete name,
address and/or email address in order for us to notify you the response to your
privacy request; (ii) attached documents establishing your identity; and (iii)
a clear and concise description of the personal data with regard to which you
seek to enforce any of your privacy rights. If you request rectification,
please indicate amendments to be made and attach documentation to back up your
request.
Upon receipt of your
privacy request, and after due review of its merit, we may then edit, deactivate,
and/or delete your personal data from our App or services. We may not be able
to delete all of your data from some of our databases and that, if such is the
case, we will then mark such data as permanently inaccessible.
+Cookies and Beacons
We may place ‘cookies’
and similar technologies in your computer or mobile device to track and collect
data regarding your use of our App and Services. Cookies are small text files
that our APP transfers to you and that
allow us to permit us to recognize you and obtain data such as how, when and
how long you browse pages in our APP . Either we or our affiliates and
authorized service providers may also use ‘beacons’, which are small files,
sometimes only a pixel in size, embedded onto the pages of our APP. Beacons are
used to identify each of our pages in order to be analyzed by our system tools.
You can always configure your browser to refuse cookies and beacons. For more
information, please visit www.allaboutcookies.com.
+Privacy Shield
XDrs. complies with
the EU-U.S. Privacy Shield Framework, as set forth by the U.S. Department of
Commerce regarding the collection, use, and retention of personal information
transferred from the European Union, as applicable to the United States. XDrs.
has certified to the Department of Commerce that it adheres to the Privacy
Shield 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 https://www.privacyshield.gov/. When XDrs. receives personal information subject
to the Privacy Shield Principles and subsequently transfers such information to
a third-party service provider acting as an agent on XDrs.’s behalf, XDrs.
maintains certain liability under the Privacy Shield Principles if both the
agent processes the information in a manner inconsistent with the Privacy
Shield and (ii) Xdrs is responsible for the event giving rise to the damage.
In compliance with the
Privacy Shield Principles, XDrs. commits to resolve complaints about our
collection or use of your personal information. EU individuals with inquiries
or complaints regarding our Privacy Shield policy should first contact our Data
Protection Officer by sending an email to info@xpertsmed.com
XDrs. has further
committed to cooperate with the panel established by the EU data protection
authorities (DPAs) regarding unresolved Privacy Shield complaints concerning
data transferred from the EU.
European residents may
elect to arbitrate unresolved complaints pursuant to the Privacy Shield’s
Recourse, Enforcement and Liability Principle and Annex I of the Privacy
Shield. Prior to initiating such arbitration, you must: (1) contact us and
afford XDrs. the opportunity to resolve the issue; (2) seek assistance from the
panel established by the EU DPAs above; and (3) contact the U.S. Department of
Commerce (either directly or through a European Data Protection Authority) and
afford the Department time to attempt to resolve the issue. Each party shall be
responsible for its own attorney’s fees. Pursuant to the Privacy Shield, the
arbitrator(s) may only impose individual-specific, non-monetary, equitable
relief necessary to remedy any violation of the Privacy Shield Principles with
respect to the individual filing the complaint.
XDrs. is also subject
to the investigatory and enforcement powers of the Federal Trade Commission
(FTC).
Data Protection Agreement
European Union Model Clauses
XDrs. offers a Data Protection Agreement based on the European Union Model
Clauses, also known as Standard Contractual Clauses, to meet the adequacy and
security requirements for our Customers that operate in the European Union, and
other international transfers of Customer Data. A copy of our standard Data
Processing Addendum, incorporating Model Clauses, is available here. Please contact
info@xpertsmed.com for a copy of our current sub processors.
Data Protection Officer
To communicate with our Data Protection Officer, please email info@xpertsmed.com
+Your Rights
Individuals located in certain countries, including the European Economic Area,
have certain statutory rights in relation to their personal data. Subject to
any exemptions provided by law, you may have the right to request access to
your information, as well as to seek to update, delete or correct this
information.
To the extent that XDrs.’s processing of your personal data is subject to the
General Data Protection Regulation (GDPR), XDrs. relies on its legitimate
interests, described above, to process your data. XDrs. may also process
information that constitutes your personal data for direct marketing purposes,
provided that you have a right to object to XDrs.’s use of your personal data
for this purpose at any time.
Amendments
XDrs. may change this
Policy from time to time as laws, regulations, industry standards and/or our
business evolves. We will post the changes to this page and encourage you to
review our Policy periodically to stay informed. If we make changes that
materially alter your privacy rights, XDrs. will provide additional notice,
such as via email or through the Services. If you disagree with the changes to
this Policy, you should deactivate your Services Account. Contact your Account
administrator if you wish to request the removal of your personal data under
their control.
Contact
If you have any
questions about us, our App, our Service, or this Privacy Policy, please
contact us: