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Privacy Policy
ManagingLife Inc.'s Privacy Policy
Version 2.2, Last Updated: February 22, 2024
ManagingLife, Inc. (“ManagingLife,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes how we handle information that we collect through:
OFFLINE AND ONLINE MODE
You can use our Apps in offline and online mode. In the offline mode, which is the standard setting, your information is stored only on your device, and is not accessed by us. In the offline mode, the Apps allow you to manage your own information on your own device. Certain functionalities of the Apps require that information is shared and are therefore not available in offline mode. This is, for example, the sharing of your pain records with a health care provider of your choice, or generating pain reports. You can switch from offline mode to online mode by creating an account and logging into your Apps account, and back to offline mode by logging out of your Apps account.
PERSONAL INFORMATION
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
The Apps collect crash reports, which can be turned off in the “Settings” menu and include the following Personal Information:
When you contact us via any of our Services, we collect the following Personal Information:
If you choose to use the Apps in online mode, we collect Personal Information including:
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
We need to collect Personal Information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide all the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Use of Personal Information
We and our service providers use Personal Information for the following purposes:
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online or in-app contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Services.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
We will engage in this activity with your consent or where we have a legitimate interest.
We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
We engage in these activities based on our legitimate interest.
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For maintaining, or modifying our current Services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; and
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, when we have a legal obligation or legitimate interest to do so:
- These can include authorities outside your country of residence.
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
OTHER INFORMATION
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from receiving marketing-related emails from us by using the unsubscribe option included in each marketing email or by sending an email to privacy@managinglife.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to access, correct, update, or delete information you included in the Apps, you can use the self-service functionality within the Apps.
If you would like to request to access, correct, update, or delete other Personal Information, or suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes.
RETENTION PERIOD
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16).
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including Canada, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). If we transfer Personal Information from the EEA to countries not considered adequate by the European Commission, we will put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us”.
SENSITIVE INFORMATION
The Apps enable you to record pain information, including health related information. We ask you not to send us, and you not disclose, other sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us, unless we request you to do so.
THIRD PARTY PAYMENT SERVICE
The Services may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
UPDATES TO THIS PRIVACY POLICY
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.
CONTACTING US
ManagingLife, Inc., located at 18 King Street East, Suite 1400, Toronto, Ontario, Canada, M5C 1C4, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us at privacy@managinglife.com, or:
18 King Street East, Suite 1400
Toronto, Ontario,
Canada, M5C 1C4
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION REGARDING THE EEA
You may also:
- Managinglife -
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-managinglife@rickert.law
Version 2.2, Last Updated: February 22, 2024
ManagingLife, Inc. (“ManagingLife,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes how we handle information that we collect through:
- Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
- Software applications, such as the Manage My Pain app, made available by us (the “Apps”);
- Our pages on LinkedIn, Facebook, and Twitter, (collectively, our “Social Media Pages”);
- Emails we send to you that link to this Privacy Policy or other communications with you (collectively, our “Communications”); and
- Offline business interactions you have with us.
OFFLINE AND ONLINE MODE
You can use our Apps in offline and online mode. In the offline mode, which is the standard setting, your information is stored only on your device, and is not accessed by us. In the offline mode, the Apps allow you to manage your own information on your own device. Certain functionalities of the Apps require that information is shared and are therefore not available in offline mode. This is, for example, the sharing of your pain records with a health care provider of your choice, or generating pain reports. You can switch from offline mode to online mode by creating an account and logging into your Apps account, and back to offline mode by logging out of your Apps account.
PERSONAL INFORMATION
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
The Apps collect crash reports, which can be turned off in the “Settings” menu and include the following Personal Information:
- User ID
- Device information (such as your device’s make and model)
- App version
When you contact us via any of our Services, we collect the following Personal Information:
- Email address
- User ID
- Device information (such as your device’s make and model)
- App version
If you choose to use the Apps in online mode, we collect Personal Information including:
- Account information (such as, your email address, IP address, and password);
- Profile information you choose to include (such as, name, medications, pain conditions, birthdate, height, weight, gender, and place of residence);
- Pain records and daily reflections you choose to create (which may include information such as, location, associated symptoms, characteristics, aggravating/alleviating factors, timing, environment, severity, meaningful activities and notes); and
- Responses you choose to submit for questionnaires assigned to you.
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services.
- From Other Sources.
We need to collect Personal Information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide all the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Use of Personal Information
We and our service providers use Personal Information for the following purposes:
- Providing Services and fulfilling your requests.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online or in-app contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Services.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Sending you our newsletter and/or other marketing materials.
We will engage in this activity with your consent or where we have a legitimate interest.
- Personalizing the Services.
We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
- Aggregating and/or anonymizing.
We engage in these activities based on our legitimate interest.
- Accomplishing our business purposes.
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For maintaining, or modifying our current Services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; and
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
- To our third party service providers, to facilitate services they provide to us.
- If you choose to disclose Personal Information.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- To cooperate with public and government authorities.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For other legal reasons.
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
OTHER INFORMATION
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- App usage data
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Your browser or device.
- Your use of the App.
- Cookies.
- Pixel tags and other similar technologies.
- Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from receiving marketing-related emails from us by using the unsubscribe option included in each marketing email or by sending an email to privacy@managinglife.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to access, correct, update, or delete information you included in the Apps, you can use the self-service functionality within the Apps.
If you would like to request to access, correct, update, or delete other Personal Information, or suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes.
RETENTION PERIOD
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16).
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including Canada, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). If we transfer Personal Information from the EEA to countries not considered adequate by the European Commission, we will put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us”.
SENSITIVE INFORMATION
The Apps enable you to record pain information, including health related information. We ask you not to send us, and you not disclose, other sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us, unless we request you to do so.
THIRD PARTY PAYMENT SERVICE
The Services may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
UPDATES TO THIS PRIVACY POLICY
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.
CONTACTING US
ManagingLife, Inc., located at 18 King Street East, Suite 1400, Toronto, Ontario, Canada, M5C 1C4, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us at privacy@managinglife.com, or:
18 King Street East, Suite 1400
Toronto, Ontario,
Canada, M5C 1C4
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION REGARDING THE EEA
You may also:
- Contact our EU representative:
- Managinglife -
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-managinglife@rickert.law
- Contact our Data Protection Officer (DPO) at privacy@managinglife.com.
- Lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.