PRIVACY POLICY
Last Updated: October 28, 2021
CereHealth Corp. (“CereHealth”) considers the privacy of your personal data as a matter of the utmost importance and is committed to processing your information in accordance with the law, the present Privacy and Cookie Policy (herein after the “Privacy Policy”), and the highest standards of fair information practices.
Please read this Privacy Policy carefully, whereas it describes how CereHealth collects your personal data as a guest or a registered user, on or through (i) www.iLLUMEAi.com (the “Website”), and (ii) CereMetrix®, concurrent software licenses, software support services, training, online customer forums, as well as other services provided by CereHealth (collectively referred to herein as “Services”), in the context of our customer, vendor, and partner relationships. The scope of this Privacy Policy does not include the medical data uploaded through the Website or exchanged through our Services.
This document offers you a description of how CereHealth uses your personal data, as well as the manner in which you can assert control over CereHealth doing such. Accessing or using the Website implies your express approval of this Privacy Policy either by providing us your personal information or by opting in. This means you consent to how CereHealth collects, uses, and processes your personal information. If you do not accept this Privacy Policy, you are no longer allowed to use the Website. CereHealth may access or use your personal data for Services either with your express approval or for any lawful basis.
CereHealth may periodically update this Privacy Policy by posting a revised version on the Website. Therefore, we recommend you regularly consult this Privacy Policy to make sure you are aware of any changes.
Article 1 – GENERAL
1.1 CereHealth incorporated under the laws of the State of Delaware, with a registered office at 251 Little Falls Drive, Wilmington, Delaware 19808 (USA), takes responsibility for the processing of your personal data as a “data controller.”
1.2 This Privacy Policy for the protection of your personal data is strictly compliant with the laws applicable in the United States (“U.S.”) and the applicable data protection law in the European Union (“EU”), including but not limited to:
- The Health Insurance Portability and Accountability Act of 1996, as amended by the Health Information Technology for Economic and Clinical Health Act, Title XIII of Division A of the American Recovery and Reinvestment Act of 2009, and the regulations promulgated thereunder (collectively, “HIPAA”);
- The Federal Trade Commission Act (15 U.S.C. §§41-58) (“FTC Act”); and
- The EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC (“GDPR”).
Article 2 – PERSONAL DATA CEREHEALTH COLLECTS
2.1 CereHealth does not collect the sensitive information of its users (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation). CereHealth shall, where necessary, obtain your express consent to collect and use such information.
2.2 The Website and our Services collect only personally identifiable information that is specifically and voluntarily provided by you.
2.3 The personal data CereHealth may collect includes:
- Category 1: Your internet protocol address (“IP-address”).
- Category 2: In general, when you subscribe to our emails, fill out questionnaires, or ask us to contact you, you may provide us with your contact details (e.g., your name, email address, your contact details including telephone number, address, country and social media information).
- Category 3: Data obtained by placing cookies (see Article 7).
- Category 4: Information about your use of the Website, such as the sections of the Website you visited, the date and time you have accessed the Website, and the materials posted to or downloaded from the Website.
- Category 5: Information about your use of our Services, such as your contact details (e.g., your name, email address, your contact details including telephone number, address, country).
- Category 6: Data acquired through your participation in a trade show or event through which consent is secured by the organizer of the event for the purpose of use by vendors.
2.4 You are not obligated to provide us with your personal data; however, choosing not to may make the delivery of several Services not possible.
Article 3 – HOW WILL MY PERSONAL DATA BE USED?
3.1 General Purpose
CereHealth collects and processes your personal information in order to offer you a safe, comfortable, and personalized experience each time you visit the Website or use our Services.
The information we collect about you is primarily processed to help us ensure proper technical functioning and to improve the quality and content of the Website and our Services, all of which is based on the lawful purposes of consent for the Website, legal obligations and contractual necessity for our Services, or legitimate interest as allowed under GDPR.
- With that said, your personal data will be processed for the following (internal) purposes:
- To provide Services or to enable CereHealth to execute an agreement which you initiated. (Categories 1, 2, 3, 4, 5)
- To retain certain data such as your IP-address for purposes of troubleshooting, medical records auditing, and ensuring security. (Category 1)
- To reach out to potential new CereHealth employees. As such, CereHealth processes your personal data to employ recruitment strategies taking optimum advantage of opportunities to create a first-rate CereHealth workforce. (Categories 1, 2, 3, 4)
- To inform you about CereHealth ‘s product offerings, via targeted advertising, promotional offers, or updates. (Categories 2, 3, 4, 6)
- To capture your opinion, and for statistical purposes, to maintain and enhance our Services. (Categories 1, 2, 3, 4, 6)
- To create your account to have access to certain Services. (Category 5)
- For electronic communications, click on the unsubscribe function in the communication;
- Email CereHealth at privacy@cerehealth.com; or
- Call CereHealth at 866-722-4806.
- Send you newsletters;
- Capture your opinion on our products and services;
- Optimize your experience on our Website;
- o The Website uses Google Analytics to analyze user activity in order to improve web performance, and ultimately, user experience.
- Facilitate recruitment of potential new CereHealth employees;
- Operate the Website.
- o The Website operates on the WordPress platform (https://wordpress.org/about/security/) to provide a secure, protected computing environment for users to view the Website.
It is however possible that CereHealth will disclose your personal data:
- If CereHealth is obligated to do so, following a court order or to comply with imperative laws and/or regulations, or to safeguard and defend our rights.
- In case of whole or partial reorganization or cession of CereHealth’s activities, whereby CereHealth reorganizes, transfers, ceases business activity or in case CereHealth goes bankrupt, your personal data may be transferred to new entities or third parties.
Article 4 – HOW LONG WILL WE HOLD YOUR PERSONAL DATA?
CereHealth only processes your personal information for as long as necessary. This means that we do keep a record of your data for as long as it is required or justified by the law or by another legal obligation, or for the period for which this would be necessary for the aforementioned purposes. Based on the categories of data described in Section 2.2, we hold your data as follows:
- Category 1: Your IP-address will be stored for the functioning of the Website for a short period of time.
- Category 2, 5 and 6: Your name, email address, telephone number, and country will be stored for the duration of your relationship with CereHealth and for 10 years thereafter.
- Category 3: Data obtained by placing cookies for the duration of the browsing session (see Article 7).
- Category 4: Information about your use of the Website will be stored indefinitely for further statistical research without being linked to your identity. Personal data will be anonymized, so it becomes impossible to identify you based on this data.
Article 5 – YOUR RIGHTS AS A DATA SUBJECT
5.1. Right of access and right to obtain a copy
You have the right to freely obtain access to your personal data, as well as to be informed about CereHealth’s purpose for processing such data.
5.2. Right to rectification, erasure, or restriction
You have the choice to share your personal data with CereHealth. You also have the right to request CereHealth rectify your personal data or have it erased. You can also request the processing of your personal data to be restricted.
When you choose not to share data, or when you request that we erase your personal data, it may prevent us from providing you with several Services and access to the Website.
5.3. Right to object
You have the right to object to the processing of your personal data when you have legitimate reasons to do so. You also have the right to object to the use of your personal data for purposes of direct marketing. In such case, specific reasoning will not be requested.
5.4. Right to data portability
You have the right to obtain your personal data which is processed by CereHealth in a structured, commonly used, and machine-readable format and/or to transfer this data to another data controller.
5.5. Right to withdraw consent
When the processing is based on prior consent, you have the right to withdraw this consent.
5.6. Automated decisions and profiling
The processing of your personal data does not include profiling, nor will you be subjected to automated decisions.
5.7. Exercising your rights
You can exercise the above-mentioned rights by sending an email with an enclosed copy of your government-issued identification card to privacy@cerehealth.com.
Article 6 – SAFETY AND CONFIDENTIALITY
6.1 CereHealth undertakes all reasonable efforts to prevent (i) unauthorized access to your personal information, and (ii) loss, abuse or alteration of your personal data, by using physical, administrative and technological measures to protect the information maintained.
Unfortunately, no one – including CereHealth – can guarantee 100% security when it comes to transmitting or forwarding any personal information over the internet, or any other methods of electronic storage. If you have particular security concerns about the unauthorized disclosure of certain personal information, it is your responsibility to not transmit that information over the internet.
Nevertheless, you are responsible for providing CereHealth with accurate information. If the information you provide is incomplete or seemingly incorrect, CereHealth reserves the right to postpone indefinitely certain actions or other Services.
6.2 You shall be solely responsible for your own User Content, such as content you upload to the Website, and the consequences of posting, submitting, and/or publishing it. CereHealth does not endorse any User Content or any opinion, recommendation, or advice expressed therein. CereHealth may, but is not obligated to, review and monitor, before and/or after User Content has been submitted. It is impossible for us to monitor or review all User Content. CereHealth is not responsible or liable to any third party for the content or accuracy of any User Content posted by you or any other user of the Website or our Services, and CereHealth expressly disclaims any and all liability in connection with User Content to the fullest extent permitted by applicable law.
6.3 You will maintain your CereHealth account(s) to be accurate and current. You are solely responsible for maintaining the confidentiality of your password(s). You are solely responsible for restricting access to your computer(s). You agree to accept responsibility for all activities occurring under your accounts that are due to your conduct, inaction, or negligence. If you become aware of any suspicious or unauthorized conduct concerning your account, or if you suspect someone has stolen your password, you must contact CereHealth immediately by email at the email address privacy@cerehealth.com. CereHealth may, at its own discretion, bar registration from the Website or any specific Service. You are responsible for maintaining and protecting your login and password information. Do not lose your password, and do not share it with any other person.
6.4 Please note that CereHealth assumes no responsibility regarding the privacy policy of the other websites or digital platforms that are linked on the Website. Moreover, CereHealth is not liable in any way for direct or indirect damages caused by a wrongful or improper use of your personal data by any third parties.
Article 7 – HOW DOES CEREHEALTH USE COOKIES?
7.1 What is a cookie?
A “cookie” is a small text file that can be sent from a web server to your computer that is then stored on your computer. When a cookie is stored on your computer, each subsequent request to the same domain name will also send along the data stored in the cookie until the cookie expires or is deleted. A server can only give you a cookie if you make a request to that server. The cookie is only stored if your browser/client is configured to store cookies.
7.2 Why do we use cookies?
Cookies are used primarily for session management on the Website. This means once you are logged into the Website, a cookie remembers your account information, so you do not have to log in after each request. We also use cookies to remember user preferences and other settings, which allows us to offer a better experience when you visit the Website.
7.3 Kinds of cookies we use:
- Strictly necessary cookies – As the name suggests, these cookies are strictly necessary to enable you to move around or remain logged into the Website or to provide certain information you have requested.
- Tracking cookies – These cookies are used to record information such as how you initially came to a website and how long you stayed and which pages you viewed. These tracking cookies are also third-party cookies (see below).
- Third-party cookies – For cookies set by third parties, we kindly refer you to the statements set forth by these parties on their respective websites. Beware, we do not have any influence on the content of these statements nor on the content of the cookies of these third parties. Though, these cookies can also be disabled by browser settings.
- o CereHealth uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) on the Website. Google Analytics uses cookies that help us analyze how users use the Website. The information generated by these cookies are transmitted to and stored by Google on servers located in the U.S. Google uses this information to help us evaluate usage patterns on the Website and provides us with other services related to your activity on the Website and/or your other internet usage. By using the Website, you consent to Google processing data about you in the manner and for the purposes set out above.
- o CereHealth uses Google Ads, which offers a remarketing function by creating remarketing lists of the people visiting the Website. By using this function, CereHealth is able to contact you through ads once you have visited the Website or while you are visiting other websites or platforms that form part of the Google Display Network.
Article 8 – APPLICABLE LAW AND JURISDICTION
This Privacy Policy is managed, interpreted, and executed in accordance with either the laws of the State of Delaware and will exclusively apply to every potential dispute.
The competent courts of the registered office of CereHealth shall have exclusive jurisdiction in relation to any kind of disagreement that could arise from the interpretation or execution of the then current version of this Privacy Policy.
