Publication date: January 1, 2020
and also referred to as “”, “” and “” 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 “
A separate agreement and/or terms and conditions governs delivery, access and use of the Services (the “ ”), 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 (“ ”) 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.
+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
We collect information that you give to us when you register or use our APP. When you register for a MedClub. user 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.
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.
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.
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
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.
· 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.
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
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
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.
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
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 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 . 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 [email protected]
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
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 . Please contact
[email protected] for a copy of our current sub processors.
To communicate with our Data Protection Officer, please email [email protected]
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.
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.