Privacy Policy

 

Last modified: January 13, 2023

 

Introduction

 

This privacy policy (the “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you access and use the Site or the Shyro mobile application (“App”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy is incorporated by reference into the Terms of Use.

 

This Privacy Policy describes:

 

·      The information that we collect from you in any form, including when you interact with the Site or App.

·      How we collect, use and disclose the information that we receive, including sharing that information with third parties.

·      How we store and secure such information.

 

This Privacy Policy does not apply to information collected by:

 

·      Us offline or through any other means, including on any other website operated by any third party (including our affiliates and subsidiaries); or

·      Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information. By using the Site or our App, you accept and agree to be bound and abide by the Privacy Policy. If you do not want to agree to the Privacy Policy, you must not access or use the Site or the App. Any capitalized term used but not defined in this Privacy Policy shall have the meaning in our Terms of Use.

 

About the Site

 

Company offers a range of services and products to individuals (“Individuals”), non- and for-profit companies (“Sponsors”), and healthcare providers (“Healthcare Providers”) including a platform where Individuals can choose to store their health and wellness data (“Health Data”), and where Sponsors and Healthcare Providers can interact with Indivduals based on Health Data. We are not a medical service provider, health insurance company, or licensed to sell health insurance.

 

Children’s Privacy 

Our Site is not intended for use by children.  Children under thirteen (18) should not send any information about themselves to us. We do not collect personally identifiable data from any person that we know to be under the age of eighteen (18). If we learn that a child under eighteen (18) has submitted information to us through any part of our Site or App, we will attempt to delete this information as soon as practical.  If you believe that we many have information on a child under the age of 18, please contact us at hello@shyro.health.

 

Information We Collect

 

We collect several types of information from and about users of the Site or App , including the following:

 

Personal Information

 

When you access the Site or Shyro app, we may ask you to voluntarily provide us with certain information that personally identifies or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information:

 

  • Contact information, such as your name, address, e-mail address and phone number;

  • Demographic data, such as your gender, date of birth and address including zip code and country;

  • Payment information, such as your credit card number, billing address, and cryptocurrency wallet (“Wallet”) public key; and

  • Wellness, medical data, and health information you choose to share.

 

We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent.

 

Billing, Collection and Payment Information

 

When you make a payment through the Site and the Shyro app to (as further described in our Additional Terms), your payment card information may be processed by our payment processing partner, Stripe (https://stripe.com). Stripe collects your voluntarily provided payment card information necessary to process your payment. Stripe’s use and storage of information it collects is governed by Stripe’s applicable terms of service and privacy policy. The information we store includes your payment card type and the last four digits of the payment card. We may provide to you the option to remove your stored payment card information through your account settings. Payment on this site may also be requested in cryptocurrency and that transaction would occur within your Wallet and processed by a distributed blockchain ledger such as but not limited to the Ethereum blockchain. Your cryptocurrency payment and transaction details may be public.

 

Traffic Data

 

We also may automatically collect the following types of data when you use the Site:  (1) IP address; (2) domain server; (3) type of device(s) used to access the Site; (4) web browser(s) used to access the Site; (5) referring webpage or other source through which you accessed the Site; (6) geolocation information; and (7) other statistics and information associated with the interaction between your browser or device and the Site (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.

 

Information Subject to Additional Protections

 

Certain information receives additional protections under the law:

 

Protected Health Information and HIPAA

 

Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some of the contact, demographic, payment, and health and/or healthcare-related information that Company collects may be considered “Protected Health Information” or “PHI,” most specifically if this data comes from your Healthcare Providers. HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Company may only use and disclose PHI in the ways permitted by the Healthcare Provider(s) and HIPAA. Healthcare Providers may provide Individuals with their own Notice of Privacy Practices.

 

We may use and disclose PHI for our own management and operations, to meet our legal obligations, as set forth in the business associate agreement with Healthcare Providers, or for any other purpose for which you have given consent. 

 

 

How We Collect Information

 

We collect this information:

 

·      Directly from you when you provide it to us.

·      When you use the Site’s and the App’s interactive tools and services.

·      If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant services, such as information that lets Company know when you are logged on and available to receive update or alert notices.

·      If you download our App, we may receive information about your location and mobile device.

·      Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

·      From third parties, for example, our business partners, Sponsors, or Healthcare Providers.

 

Information You Provide to Us 

 

The information we collect on or through the Site or App may include:

 

·      Information that you provide by filling out forms on the Site or App. This includes information provided at the time of registering to use the Site, App, subscribing to a service, or requesting further services. We may also ask you for information when you report a problem with the Site or App.

·      Records and copies of your correspondence (including email addresses), if you contact us.

·      Your responses to surveys that we might ask you to complete for research purposes.

·      Details of transactions you carry out through the Site or App. You may be required to provide financial information before placing an order through the Site or App.

·      Your search queries on the Site or App.

·      Your User Content.

·      Information you authorize third parties to release to us such as data from wearable devices or electronic medical records.

 

Information We Collect Through Automatic Data Collection Technologies 

 

As you navigate through and interact with the Site or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

 

·      Details of your visits to the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

·      Information about your computer and internet connection, including your IP address, operating system, and browser type.

·      Details of your use, movement, and patterns in the App.

 

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

 

Do Not Track: The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.

 

The information we collect automatically does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve the Site and App, and to deliver a better and more personalized service, including by enabling us to:

 

·      Estimate our audience size and usage patterns.

·      Store information about your preferences, allowing us to customize the Site according to your individual interests and speed up your searches.

·      Recognize you when you return to the Site.

 

The technologies we use for this automatic data collection may include:

 

·      Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.

·      Flash Cookies. Certain features of the Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

·      Web Beacons. Pages of our the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain Content and verifying system and server integrity).

·      Website Analytics. We may use third-party website analytics services in connection with the Site, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the Site. These website analytics services generally do not collect Personal Information or PHI through text that you type while using the telemedicine related services, but may collect usage data, such as whether or not you provided a response. We use the information collected from these services to help make the Site easier to use and as otherwise set forth in this Privacy Policy.

·      Mobile Device Identifiers. Mobile device identifiers are data stored on your mobile device that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data. As with other Tracking Tools, mobile device identifiers help us learn more about our users’ demographics and internet behaviors.

 

Third-Party Use of Cookies and Other Tracking Technologies

 

Some content or applications, including advertisements, on the Site or App are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Site or App. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

 

While we may provide the opportunity to opt in or opt out of your data being accessible to third party advertisers, we do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 

How We Use Your Information

 

We use Personal Information you provide to us or we collect from you as follows:

 

·      To present the Site and the Content to you.

·      To provide you with information, products, or services that you request from us.

·      To fulfill any other purpose for which you provide it.

·      To provide you with notices about your account, including expiration and renewal notices.

·      To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

·      To notify you about changes to the Site or any products or services we offer or provide though it.

·      To allow you to participate in interactive features on the Site or App.

·      To customize and tailor your experience of the Site or App, which may include sending customized messages or showing you Sponsored Offers related to goods or services that may be of interest to you based on information collected in accordance with this Privacy Policy.

·      In any other way we may describe when you provide the information.

·      For any other purpose with your consent.

 

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. For more information, see Choices About How We Use and Disclose Your Information.

 

We may use your information to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

We may use information that is not Personal Information or PHI (including information that has been de-identified and aggregated) to better understand who uses the Site and how we can deliver a better experience, or otherwise at our discretion. Our use of PHI is limited as discussed above.

 

How We Share Your Information

 

We may share Personal Information that you provide to us or we collect from you as follows:

 

·      To fulfill the purpose for which you provide it.

·      With your consent.

·      To the Healthcare Providers or Sponsors.

·      To contractors, service providers, and other third parties we use to support our business.

·      To another company in connection with a merger, sale, acquisition or other change of ownership or control by or of Company (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy policies and practices.

·      If we determine in good faith that such disclosure is needed:

o   To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

o   To prevent or lessen a serious and imminent threat to the health or safety of you, another person or the public.

o   To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

o   If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

Third parties and Sponsors that receive this information may or may not have a legal obligation to keep your personal information private.

 

We may disclose information that is not Personal Information or PHI (including information that has been de-identified and aggregated) at our discretion. Our disclosure of PHI is limited as discussed above.

 

Choices About How We Use and Disclose Your Information

 

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

 

·      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can manage your cookie settings on your browser. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.

·      Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data or in the relevant location in the App.

·      Promotional Offers from Company. If you do not wish to have your email address used by Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or in the relevant location in the App. If we have sent you a promotional email, you may use the unsubscribe button or send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Company as a result of a purchase, product service experience or other transactions.

 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads by following the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services.

 

Data Security

 

We use a combination of technical, administrative, and physical controls to maintain the security of your data. If you have a security-related concern, please contact us. Always be sure to secure your login credentials for on-line access, including never sharing your Wallet private key or seed phrase. In order to protect you and your information, we may suspend your use of any of the on-line service, without notice, pending an investigation, if we suspect any breach of security.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Site. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

 

Links to Third Party Websites

 

The Site may contain links to third party websites and services (e.g. Stripe for payment processing) and some of those third-party websites may be co-branded with our logo (the “Third-Party Services”).  These Third-Party Services are not our services. We do not control (and are not responsible for) third party content or privacy practices. Any personal information you provide to them is not covered by this Privacy Policy. We encourage you to review carefully the legal and privacy policies of all other digital services that you visit.

 

Changes to Your Information

 

All users may review, update, correct or delete the Personal Information in their user account by contacting us at hello@shyro.health. If you completely delete all of your information with us, then your user account will be deactivated. We may retain an archived copy of your records. 

 

Changes to Our Privacy Policy

 

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Site home page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the email address specified in your account or through a notice on the Site home page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you in order to receive such notices.

 

Contact Information

 

If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us at hello@shyro.health.


Cookie Statement

 

Like many online services, we use cookies to collect information.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website, https://shyro.health (“Site”).  This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. 

 

Device and Browser Information, including Mobile Devices.  We may also collect non-personal, technical information from your mobile device if you access the Site on your device’s browser.  For example, we may collect your device’s IP address, Cookies string data and your device type and mobile device’s unique identifier.

 

Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs).  Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users.  In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages.  Pixel Tags also allow us to provide personalized advertising of our products and services and send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users.  We may use this information to reduce or eliminate messages sent to a user.

 

How We Respond to Do Not Track Signals.  We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.

 

Analytics Services.  In addition to the tracking technologies we use, other companies may set their own cookies or similar tools when you visit our Site.  This includes third party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Site, as well as third parties that deliver content or offers.  We may receive reports based on these parties’ use of these tools on an individual or aggregate basis.  We use the information we get from Analytics Services only to improve our Site and Services.  The information generated by the Cookies or other technologies about your use of our Site and Services is transmitted to the Analytics Services provider.  For a full list of Analytics Services, please contact us at hello@shyro.health.  

 

Your Choices.  Your browser or device may allow you to block or otherwise limit the use of cookies. But cookies are an important part of how our services work, so removing, rejecting, or limiting the use of them could affect the availability and functionality of our services. 

 

Browser Cookies

 

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. For more information about how to manage browser cookies, please follow the instructions provided by your browser.

 

Mobile Device Identifiers

 

Your mobile operating system may let you opt-out from having certain device identifiers used for interest-based advertising. You should refer to the instructions provided by your mobile device’s manufacturer; this information is typically available under the “settings” function of your mobile device.


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Questions.  If you have any questions, you can contact us by emailing us at hello@shyro.health.