1. Purpose .  Find Your Ditto LLC (the “Company,” “we,” “us,” or “our”) is committed to maintaining robust privacy protections for our users (“user” or “you”). This Privacy Policy (“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.

 

1. 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. 

 

1. 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.

 

1. Acceptance of the Policy .  You accept this Policy by using any part of the Platform, including by setting up or registering a user account.

 

1. 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.

 

1. What We Collect; Your Access.

 

1. 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.
2. 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 .
3. 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.
4. 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.

 

1. Use of Personal Information.
   1. 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 legal claims.
   2. We also use your PI as follows:
      1. To match you with other local users who suffer from chronic illness;
      2. To contact you through the mobile application regarding user matches;
      3. To operate, maintain, and improve our sites, products, and services;
      4. To process and deliver contest entries and rewards;
      5. To respond to comments and questions and provide customer service;
      6. To send information including confirmations, technical notices, updates, security alerts, and support or administrative messages;
      7. To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
      8. To link or combine user information with other PI;
      9. To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; or
      10. To provide and deliver products and services customers request.
   3. You may request that we not share your Information for marketing purposes via email, at [].

 

1. Data Security and Retention; Access and Use.
   1. 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 these risks.
   2. 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.
   3. 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.

 

1. 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.

 

1. 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 []. We will delete such information from our files within a reasonable time.

 

1. 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 for their privacy policies, terms of use or service, or the information collected at such third-party websites.

 

1. 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. 

 

1. Effective Date of Policy .  The effective date of this Policy is March 1, 2018.

 

1. 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.

 

1. Contact .  Please contact us with any questions and/or comments you may have.

 

 

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