- Purpose. Find Your Ditto LLC (the “Company,”
“we,” “us,” or “our”) is committed to maintaining robust privacy
(“Policy”) is designed to help you understand how we collect, use and
safeguard the information you provide to us and to assist you in making
informed decisions about and when using our Platform.
- Agreement. For purposes of this Agreement,
“Platform” refers to the Company’s service, which can be accessed
through our mobile application, in which users can connect you with
other users based on shared chronic illnesses and location information.
The Platform may be provided to you by a third-party employer or
organization and that third party is referred to in this Policy as
“Sponsor.” This Policy identifies the personally identifiable
information (“PI”) and other anonymous information (“AI”) gathered by us
(collectively, “Information”) and the use by us of such Information.
Please contact us using the information below if you have any questions
about this Policy.
- HIPAA Disclaimer. The Company is only using
Information voluntarily provided to us by you and other users of the
Platform in a public manner. PI is only shared with your consent
and through your affirmative use of Platform-related services.
Such use constitutes a voluntary disclosure. Further, because the
services do not make us a health care provider, health plan, or a
healthcare clearinghouse (as those terms are defined by (the Health
Insurance Portability and Accountability Act of 1996 (“HIPAA”)) we are
not subject to HIPAA and any use and disclosure of your information,
even if related to your health, is not subject to HIPAA and the
protections it creates.
- Acceptance of the Policy. You accept this Policy
by using any part of the Platform, including by setting up or
registering a user account.
- Changes to Policy. If we make any significant
changes to this Policy we will notify you by email, post a notice of
such changes within the Platform or flag this Policy on the Platform as
updated. You agree to our use of electronic communications with
you for purposes of this Policy. If you do not agree to the
changes to this Policy, we will continue to maintain and use PI
previously collected in accordance with the Policy in force as of that
date, but we reserve the right to terminate your further use of your
account and your access to any Platform functionality.
- What We Collect; Your Access.
- PI. We collect PI that you or Sponsor provide to
us in connection with your creation of an account (or Sponsor’s creation
of an account on your behalf.) This Information includes your
name, email address, username, password, demographic information (such
as your gender and age range), zip code, and chronic conditions, as well
as other information you directly give us on our Platform. We
primarily use PI to communicate with you about the Platform and our
services, to help you manage your access to the Platform, to help you
communicate with others, to analyze activity on the Platform, to assess
and address security issues, and to generally administer and improve the
Platform. We may also use your PI to provide you with newsletters
or our own marketing materials. We use Information in the
aggregate for our business purposes and other than as specified in this
Policy, we do not use aggregated information in a manner that allows
identification of an individual user. We may share your
Information with your Sponsor. You can stop all collection
of Information by ceasing your use of the Platform.
- Geolocation Data. The Platform uses commercially
available technology residing on your mobile device to collect certain
location-related information. We also may use these technologies
to collect information about your activities over time and across
third-party websites, apps or other online services (behavioral
tracking). By using the Platform, you consent to the use of such
tracking technologies and if you wish to opt-out of such tracking,
please discontinue your use of the Platform. Please note that
the Platform does not recognize or respond to
browser-initiated Do Not Track signals and you alone are responsible
for your interactions with the Platform and requests to delete or
stop using the Platform in order to avoid Information collection and
storage by us.
- AI. We may automatically log information about you and
your computer. We send a “cookie” or “pixel tag” to your computer
which contains an identification number that is unique to the computer
you are using. You may decline, through your browser’s settings, to
provide such cookies or other information to us, although some of the
Platform’s features or services may not function properly as a result,
and some services may not be available at all. We may collect AI
regarding your use of the Platform, such as computer-related information
(the device or browser type you used to access the Platform, your
Internet Protocol address, the date and time of your login, and the
duration of your session). We use this information to enhance the
Platform experience, to tailor our Platform to its users, to understand
how our Platform is used, to investigate and verify proper use of the
Platform, and to monitor the security and integrity of the Platform.
- Your Access to PI. You may request access or
updates to your PI or request a correction be made to an inaccuracy in
your PI by contacting us as set out below or by using the functionality
available on the Platform. For security purposes, we may request
PI from you in connection with such access.
- Use of Personal Information.
- We may use PI as required or permitted by law, including in
response to service of legal process (court order, summons,
subpoena, and the like). We may disclose PI to law
enforcement or regulatory authorities as part of an
investigation into activity at the Platform (such as a suspected
breach) or in connection with your account. We shall use
reasonable measures to limit disclosure and use of such PI.
We may use PI in connection with the establishment or defense of
- We also use your PI as follows:
- To match you with other local users who suffer from
- To contact you through the mobile application regarding
- To operate, maintain, and improve our sites, products,
- To process and deliver contest entries and rewards;
- To respond to comments and questions and provide
- To send information including confirmations, technical
notices, updates, security alerts, and support or
- To communicate about promotions, upcoming events, and
other news about products and services offered by us and
our selected partners;
- To link or combine user information with other PI;
- To protect, investigate, and deter against fraudulent,
unauthorized, or illegal activity; or
- To provide and deliver products and services customers
- You may request that we not share your Information for marketing
purposes via email, at [email@example.com].
- Data Security and Retention; Access and Use.
- Security. Although no electronic method
of transmission or storage is completely secure, we have, or
have caused to be, implemented technical, physical and
administrative safeguards designed to protect PI against loss
and against unauthorized access, use, and disclosure. This
includes our use of a HIPAA-complaint cloud service provider
that encrypts the Information (which does not make us or the
service subject to HIPAA). Account passwords are stored in
encrypted form, but you are also responsible for the
confidentiality of your user information and account password
and should act accordingly. If you lose your password, you can
generate a new password using the Platform once you have
authenticated yourself as the authorized user. We may retain PI
as necessary for the purposes stated in this Agreement or to
otherwise meet legal requirements. However, these measures
do not guarantee that your Information will not be accessed,
disclosed, altered or destroyed by breach of such firewalls and
secure server software. By using our Platform,
you acknowledge that you understand and agree to assume
- Third Party Agents – Access to and Use of PI.
We contract with third parties to assist us in administering the
Platform, including a third party hosting services provider.
This may require you or us to share Information in order to make
the Platform available for your use. Such third parties
shall agree with us in writing to maintain your privacy at least
with the level of protection set forth in this Policy.
- Deleting and Retention of PI. You may request
that we delete or deactivate your account or otherwise delete
PI, and we shall attempt to accommodate such requests.
However, we may retain and use PI for such periods of time as
required or permitted by law or our business practices.
- Transfer of Information. We may transfer any
information we have about you as an asset in connection with a merger or
sale (including transfers made as part of insolvency or bankruptcy
proceedings) involving all or part of a company reorganization or other
change in company control. The new entity or owner of our business
shall maintain your PI as set forth in this Policy.
- Children. We do not use the Platform to knowingly
solicit data from or market to children under the age of 18. If a parent
or guardian becomes aware that his or her child has provided us with
information without their consent, he or she should contact us at [firstname.lastname@example.org].
We will delete such information from our files within a reasonable time.
- Third-Party Links and Information. Our Platform
may contain links to other websites or other information and materials
provided by third parties, including, but not limited to, links to
third-party content. We do not own or control such other websites or
third parties and are not responsible for the information or services
provided by those third parties. As such, we are not responsible
collected at such third-party websites.
- Consent. By using the Platform, you are
consenting to our processing of your Information as set forth in this
Policy now and as amended by us. “Processing,” means using cookies on a
computer/hand held device or using or touching information in any way,
including, but not limited to, collecting, storing, deleting, using,
combining and disclosing information, all of which activities will take
place in the United States. If you reside outside the United States your
information will be transferred, processed and stored there under United
States privacy standards.
- Effective Date of Policy. The effective date of
this Policy is March 1, 2018.
- Applicable Jurisdiction. This Policy applies to our
customers, and to visitors to our Platform, which for purposes of this
Agreement is located in the State of Michigan, USA. We do not
represent that it complies with privacy laws outside the United States.
- Contact. Please contact us with any questions
and/or comments you may have.
Find Your Ditto
301 E. Liberty St. #701, Ann Arbor, MI 48104