Last updated: 25th of May 2018
At RetinaLyze System A/S (Ltd.) a Danish corporation (“RetinaLyze System”, “Company”, “us”, or “we”), we respect and protect the privacy of visitors to our website, www.retinalyze.com, and the other websites under the retinalyze.com domain (collectively, the “Sites”), and our customers who use our SaaS product, eye screening software, tools, and related services (together with the Sites, the “Service”).
Capitalized terms that are not defined in this Policy have the meaning given them in our Terms of Service.
By using the Service, you do hereby warrant and represent that:
- You have read, understand, and agree to all terms and conditions stated herein, including our Terms of Service, available upon request, incorporated herein by reference, which govern the use of the Service, and
As RetinaLyze System evolves, we may need to update this Policy to keep pace with changes in our Products, our business and laws applicable to us and you; we will, however, always maintain our commitment to respect your privacy.
We will email you (to your most recently provided email address) or post any revisions to this Policy, along with their effective date, in an easy to find area of the Site, so we recommend that you periodically check back here to stay informed of any changes.
We will ask for your consent to such changes if required by applicable law; in other cases, please note that your continuation of your RetinaLyze System account after any change means that you agree with, and consent to be bound by, the new Policy. If you disagree with any changes in this Policy and do not wish your information to be subject to the revised Policy, you will need to close your RetinaLyze System account.
1. What do we mean by Personal Information?
In this Policy, “Personal Information” means information or an information set that identifies or could be used to identify an individual. Except as described in this Policy, RetinaLyze System will not give, sell, rent or loan any Personal Information to any third party.
Personal Information does not include “Usage Data” which we define as encoded or anonymized information or aggregated data we collect about a group or category of services, features or users which does not contain personally identifying information. Usage Data helps us understand trends in usage of the Service so that we can better consider new features or otherwise tailor the Service. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes. We do not share Usage Data with third parties in a way that would enable them to identify you personally.
2. How do we collect, use, and share your Personal Information and other information?
a. Information you provide to us
When you register for the Service, we may ask for Personal Information such as your name, email address, or credit card or other billing information. You may also provide at your own discretion certain related information like your personal/business website name, social media websites, the date you started using the Service and a description of you and your company.
Additionally, as users use the web application, API and algorithm, the software continuously saves changes made by users with the server and will document items such as when users are working and saving changes, when a user last logged in, when images are uploaded, or when a user performs certain tasks. We may also retain the contents of any messages you send to us and/or through the Service, and we may collect information you provide in user content that you upload to the Service (“User Content”).
RetinaLyze System may use Personal Information provided to operate, improve upon, and personalize the Service, for billing identification and authentication, to contact and communicate with you about the Service and your use of the Service, to support use of the Service, to send marketing materials (subject to your opt-out option), for research & and product development purposes, and to generally improve the content and functionality of the Service.
We may also combine your Personal Information with third-party analytics information to build a broader profile of our individual users so that we can serve you better and provide custom, personalized content and information. Additionally, we may use the Personal Information we collect for identification and authentication and fraud prevention, to analyze Site usage and improve the Service, for internal market research, troubleshooting problems, to enforce our Terms of Service, and as otherwise set forth in this Policy. Note that we will never email you to ask for your account information; if you receive such an email, please forward it to email@example.com
. If you would like more information about our policy, please review our Terms of Service.
We use financial information solely as authorized by you in accordance with the Service. While RetinaLyze System does not store your credit card information and will use commercially reasonable efforts to ensure the security of all credit card, bank information and all other Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all personal and/or financial information stored therein, and you agree to hold RetinaLyze System harmless for any damages that may result therefrom.
b. Information we may receive from and share with third parties
We may now or in the future receive Personal Information about you from third parties. For example, if you access our Site or Service through a third-party connection or log-in or connect an application to RetinaLyze System, that third party you connected with may pass certain information about your use of its service to RetinaLyze System. This information could include, but is not limited to, the user ID associated with your account, an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that third-party service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to and using the Service.
RetinaLyze System may also share Personal Information with its third party service providers (such as hosting partners) to provide the necessary hardware, software, networking, storage, and other service we use to operate the Service and maintain a high-quality user experience. We do not permit our service providers to use the Personal Information we share for their marketing purposes.
c. Analytics information
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, and other information that assists us in improving the Service. We may collect and use this analytics information together with your Personal Information to build a broader profile of our individual users so that we can serve you better.
The Site primarily uses the following analytical tools, for which we include relevant privacy information and opt-out options:
Google Analytics and Google Adwords
Google’s ability to use and share information collected by Google Analytics is restricted by the Google
We provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you.
As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.
d. Log files
RetinaLyze System gathers certain information automatically and stores it in log files. This information includes internet protocol addresses as well as browser, internet service provider, referring/exit pages, search terms, operating system, date/time stamp, and click stream data. Occasionally, we may connect Personal Information to information gathered in our log files, as necessary to improve the Service/support for individual customers.
Otherwise, we generally use this information as we would any Usage Data, to analyze trends, administer and maintain the Service, or track usage of various features within the Service.
A cookie is a small software file stored temporarily or placed on your computer’s hard drive. The main purpose of cookie is to allow a web server to identify a user’s computer and web browser, and tailor web pages and/or login information to user’s preferences. Cookies help us promptly display the information needed to use the capabilities on the Service and other information which we consider to be of interest to visitors to the Sites and users of the Service. By gathering and remembering information about website preferences through cookies, we can provide a better web and marketing experience. Cookies don’t give us access to users’ computers, and the information we collect through cookies doesn’t include Personal Information.
We utilize session cookies, which allow us to uniquely identify your browser while you are logged in and to process your online transactions. Session cookies disappear from your computer when the web browser is closed or computer is turned off. We also utilize persistent cookies to make it easier to log into and use the Service. Persistent cookies remain on computers after the web browser is closed or the computer is turned off.
Many jurisdictions require or recommend that website operators inform users as to the nature of cookies they utilize and, in certain circumstances, obtain the consent of their users to the placement of certain cookies. If you require more specific information as to the nature of the cookies utilized in the Service for purposes of fulfilling these obligations, please contact us by email at firstname.lastname@example.org
f. Clear GIFs/web beacons information
When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information is allows for more accurate reporting and improvement of the Service.
g. Device identifiers
When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor, and/or remotely store one or more “device identifiers,” such as a unique device identifier (“UDID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by RetinaLyze System. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
i. Other information sharing
In addition to the purposes described above, we disclose Personal Information to respond to subpoenas, court orders and law enforcement or governmental requests or investigations, or to establish or exercise our legal rights or defend against legal claims.
We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or our Terms of Service, or as otherwise required by law.
We use or may use information such as cookies, log files, device identifiers, and clear GIFs information to:
(a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site
(b) provide custom, personalized content and information
(c) to provide and monitor the effectiveness of our Service
(d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns(e) diagnose or fix technology problems
(f) help you efficiently access your information after you sign in, and
(g) to provide advertising to your browser or device
We may share information, including Personal Information, with any member of the RetinaLyze System team, which includes sales/distribution partners and any entity that controls, is controlled by, or under common control with RetinaLyze System.
3. Links to other websites
The Service contains links to websites and applications other than the Service, including websites and applications operated by affiliates and other third parties. Please be aware that we do not determine and we are not responsible for the privacy practices or content of websites and applications operated by third parties. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies.
We encourage you to be aware when you leave the Service, and read the privacy statements of third-party websites and applications linked to the Service. RetinaLyze System does not endorse and is not responsible for the practices of third parties or their websites or applications.
In addition, you agree that we are not responsible for and we do not control any third parties that you authorize to access your User Content. If you are using a third-party website, software or service and you allow such a third party access to you User Content, you do so at your own risk.
5. Customer testimonials / comments / reviews
From time to time, we post customer testimonials on the Sites which may contain Personal Information. We obtain the customers’ consent to post their names, pictures and logos along with their testimonials.
6. Protection of information
RetinaLyze System is committed to ensuring the security of your Personal Information. We use commercially reasonable technological, physical, and administrative security safeguards, such as firewalls and carefully developed security features, to protect the confidentiality and security of your Personal Information within the Service and the Sites. For example, when you enter confidential information (such as login credentials or information submitted from within the Service) we encrypt the transmission of that information using secure socket layer technology (SSL). These technologies, procedures, and other measures are used in an effort to ensure that your data is safe, secure, and only available to you and to those you authorized to access your data. However, no internet, email, or other electronic transmission is ever fully secure or error-free, so you should take care in deciding what information you send to us in this way. RetinaLyze System is not responsible for the functionality or security measures of any third party.
7. Hosting and data transfer
We are based in Denmark, but, unless we expressly agree otherwise (including through our Terms), we may host, transfer, and process data, including Personal Information, in the Denmark and in other countries through RetinaLyze System and third parties that we use to operate and manage the Service. When you access or use the Service, or otherwise provide information to us, you are consenting, on behalf of you and your authorized agents, (and representing that you have the authority to provide such consent) to the processing and transfer of information in and to Denmark and other countries which may have different privacy laws from your or their country of residence.
We process and store information on behalf of our customers. You may decline to submit any Personal Information through the Service, in which case we may not be able to provide certain services to you. Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Note that disabling cookies on your mobile device or browser may prevent us or our business partners from tracking your browser’s activities in relation to the Service. However, doing so may disable many of the features available through the Service.
You may also opt-out individually for third-party vendors on their websites, but limitations on data sharing may make it difficult or impossible to provide the Service after an opt-out.
9. Correcting and updating your information
Customers may update, delete or change the Personal Information they have provided RetinaLyze System by logging into the Service and providing such additional information or deleting such information where applicable. If you are our customer and would like to gain access to, or request deletion of information we have collected as data controllers, please contact us at email@example.com
. We will use commercially reasonable efforts to respond to such queries within 30 business days but are not liable for any failure to do so.
RetinaLyze System has no direct relationship with the individuals, or companies with whom our customers may interact using the Service. Any such individual seeking access to, or who would like to correct, amend, or delete data which may be stored in the Service should direct his query to the applicable RetinaLyze System customer acting as the data controller for such information.
10. Do Not Track
We do not track or respond to browser “Do Not Track” requests.
11. Data retention
RetinaLyze System will retain Personal Information we process on behalf of our customers or collect directly from our customers for as long as needed to provide Service to our customers, subject to our compliance with this Policy. We may further retain and use this Personal Information as necessary to comply with our legal obligations, maintain accurate accounting, financial and other operational records, resolve disputes, and enforce our agreements.
We may, in our sole discretion, modify or update this Policy from time to time. If we make any material changes to this Policy, we will endeavor to notify you by email or by posting a prominent notice on the Sites prior to the change becoming effective but will not be liable for any failure to do so. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Service constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Service.
13. Business transactions
14. Contact us
If you have questions regarding this Policy or about the privacy practices of RetinaLyze System, please contact us by email at firstname.lastname@example.org, or at:
RetinaLyze System A/S (Ltd.)
Bernstorffsvej 30, 3rd floor
2900 Hellerup, Denmark