Digital Therapeutics Alliance

Privacy Policy

Digital Therapeutics Alliance ™
Privacy Policy Notice

 

1. PURPOSE

This Privacy Policy (“Policy”) covers our treatment of Personal Information that may be collected or submitted when you are using our website or services. This Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. The terms “DTA,” “we,” and “us” include Digital Therapeutics Alliance, Inc. and our affiliates and subsidiaries

2. SCOPE

This Policy applies to Personal Information that is Processed by DTA in the course of our business, including on DTA websites (each a “Site”), mobile applications, forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of DTA, the “Services”). This Policy does not apply to companies that DTA does not own or control. All individuals whose responsibilities include the Processing of Personal Information on behalf of DTA are expected to protect that data by adherence to this Policy.

3. TRANSPARENCY/NOTICE—TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with DTA and the requirements of applicable law. Some of the ways that DTA may collect Personal Information include:

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 Types of Personal Information We Collect

DTA collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (collectively “Individuals”).

3.2 How DTA Uses Your Information

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as described in Section 6.

3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “Device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Our uses of such Technologies fall into the following general categories:

3.4 Third-Party Websites AND Social Media Platforms 

Although this Policy applies to the all information obtained by you for the purpose of accessing or using content controlled and owned by DTA, it does not apply to businesses or entities that are not owned or controlled by us.

The Site contains links to other Third-Party websites. Please be aware that DTA does not claim any responsibility for the privacy practices of these Third-Party sites. We encourage you to be aware when you leave our Site and to take reasonable precautions, including reading the privacy policies of Third-Party websites when sharing your personal Information on Third-Party websites.

DTA’s Services may include publicly accessible blogs. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.

4. HUMAN RESOURCES DATA

DTA collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.

We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:

5 ONWARD TRANSFER—DTA MAY DISCLOSE YOUR INFORMATION

5.1 Information We Share

It is DTA’s policy not to disclose, sell, or rent your Personal Information to any individual, business, government entity, or outside parties except as needed to provide the Services you’ve requested through us or as outlined below.

5.2 Data Transfers

All Personal Information collected via or by DTA may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to DTA, you consent to the storage of your Personal Information in these locations.

6. OPT-OUT (RIGHT TO RESTRICT PROCESSING)

6.1 General

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to DTA’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting info@dtxalliance.local. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites.

6.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding DTA and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to or this Privacy Policy).

6.3 Human Resources Data

With regard to Personal Information that DTA receives in connection with the employment relationship, DTA will use such Personal Information only for employment-related purposes as more fully described above. If DTA intends to use this Personal Information for any other purpose, DTA will notify the Individual and provide an opportunity to opt out of such uses.

6.4 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

7. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION

You may inquire as to whether DTA is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to info@dtxalliance.local or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by DTA. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although DTA makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which DTA is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If DTA determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, DTA will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

8. DATA RETENTION

DTA retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

10. INTERNATIONAL USERS

By using the Site, DTA will transfer data to the United States. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the United States and the adjudication of any disputes arising in connection with DTA or the Site will be in accordance with the Terms.If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

11. REDRESS/COMPLIANCE AND ACCOUNTABILITY

If you have any questions about our privacy practices or this Privacy Policy, please contact DTA by email at info@dtxalliance.local. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

12. OTHER RIGHTS AND IMPORTANT INFORMATION

12.1 Changes To Our Privacy Policy and Practices

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

12.2 California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. DTA does not share Personal Information with Third Parties for their own marketing purposes.

13. DEFINITIONS

The following capitalized terms shall have the meanings herein as set forth below.

14. REVISION HISTORY

DTA Privacy Policy: Effective 10/24/17

Updated DTA Privacy Policy: Effective 5/24/18

 

Copyright © 2021 Digital Therapeutics Alliance™