Version 2.0, Last Updated: January 31, 2022
ManagingLife, Inc. (“ManagingLife,
,” or “us
- 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”);
- Offline business interactions you have with us.
Collectively, we refer to the Websites, Apps, Social Media Pages, Communications, and offline business interactions as the “Services
.”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 Services account, and back to offline mode by logging out of your Services account.PERSONAL INFORMATION
” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
- Email address;
- IP address;
- Device information (such as your device’s make and model as well as the version of the Apps you are using);
- Error reports.
In addition, if you choose to use the Apps in online mode
, we collect Personal Information including:
Collection of Personal Information
- Account information (such as, your username and password);
- Profile information you choose to include (such as, name, medications, pain conditions, birthdate, height, weight, gender, and place of residence); and
- Pain records and daily reflections you choose to create (such as, location, associated symptoms, characteristics, aggravating/alleviating factors, timing, environment, severity, meaningful activities and notes).
We and our service providers collect Personal Information in a variety of ways, including:We collect Personal Information through the Services, for example, when you register an account to access the Services, use the Apps, share information via the Apps in online mode, contact customer service. If you choose to create an account on the Services and sign in by using another service provider such as Apple, Google or Facebook, you share certain Personal Information from that service provider with us, for example, your name, email address, or photo, or other information you make accessible to us when you connect your social media account to your Services account.
We and our service providers use Personal Information for the following purposes:
- To provide the Services’ functionality to you, such as adding, editing, or viewing your pain records and daily reflections, generating pain reports, or sharing pain reports with a health care provider of your choice.- 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.
- Providing Services and fulfilling your requests.
- To email you newsletters, with information about our services, company, or partners.We will engage in this activity with your consent or where we have a legitimate interest.
- Sending you our newsletter and/or other marketing materials
- To better understand your preferences, so that we can personalize our interactions with you and provide you with information.We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
- Personalizing the Services.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. We engage in these activities based on our legitimate interest.
- Aggregating and/or anonymizing.
- For data analysis, for example, to improve the Services;- 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
- Accomplishing our business purposes.
We disclose Personal Information:
- These can include providers of services such as website hosting, data analysis, fraud prevention, information technology and related infrastructure provision, customer service or related benefits, email delivery, auditing, and other services.
- To our third party service providers, to facilitate services they provide to us.
- When you choose to share your pain information with a healthcare provider of your choice, this information is made available to that healthcare provider.Other Uses and Disclosures
- If you choose to disclose Personal Information.
We also use and disclose your Personal Information as necessary or appropriate, when we have a legal obligation or legitimate interest to do so:
- This may include laws outside your country of residence.
- To comply with applicable law and regulations.
- To respond to a request or to provide information we believe is necessary or appropriate.- These can include authorities outside your country of residence.
- To cooperate with public and government authorities.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.- To enforce our terms and conditions; and- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- To cooperate with law enforcement.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). OTHER INFORMATION
- In connection with a sale or business transaction.
” 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
- 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
- Pixel tags and other similar technologies.
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 ACCESSYour 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 email@example.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
- 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).
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 “Last Updated
18 King Street East, Suite 1400
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:
Rickert Rechtsanwaltsgesellschaft mbH
- Managinglife -
- Contact our Data Protection Officer (DPO) at firstname.lastname@example.org.
- 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.