Last Revised: May 2023
This Policy describes:
- The types of information we collect from you or that you may provide when you download and use our StayCurrent Mobile Application (our “Application”).
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Policy applies to information we collect on this Application or in emails and other electronic messages between you and this Application, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.
This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by GCMD or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Application (for further information, see below, “Third-party Applications”).
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Application. By using our Application, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Application after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
3. What We Collect and How We Collect It
To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the Application may collect the following categories of Personal Information from users of the Application:
A real name, phone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Sensitive Personal Information
Precise geolocation, Social Security number, driver’s license, state identification card, passport number, financial account, debit card, credit card number with security, or access code or password, racial or ethnic origin, religious/philosophical beliefs, or union membership, contents of mail, email, and text messages, genetic data and processing of biometric information, health and sexual orientation.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Physical location or movements.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Current or past job history or performance evaluations.
Non-public education information.
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other Personal Information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, when you:
- register yourself with the Application;
- post materials on the Application;
- communicate through discussions with members; or
- communicate with us, such as request information.
- Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
- Directly and indirectly from activity on our Application. For example, from Application usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.
The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting GCMD to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.
Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us.
Caution in Material You Upload to Application
Please understand that through your use of the Application, you may have the opportunity to submit information, such as images or health-related information for review by other users. You agree that you will NOT use the Application in any way to facilitate or commit illegal activity, including, but not limited to, using the Application to upload and share images or data that violate criminal law, doctor-patient confidentiality, or any other applicable law or regulation. GCMD shall not be liable for any information that you upload or contribute to the Application.
Information presented or uploaded on the Application is intended to be educational and to facilitate discussion and learning between users. You warrant and represent before submitting any information to the Application that you have all requisite authorization and consent to do so, and any information you upload neither constitutes a violation of any applicable law or regulation, nor amounts to a violation of any recognizable privilege or expectation of confidentiality.
4. Automated Information Collection
In addition to the information that you provide to us, we may also collect information about you during your visit to our Application. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Application. Some of the tools we use to automatically collect information about you may include:
- Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them: (1) session cookies, which do not stay on your device after you close your browser, and (2) persistent cookies, which remain on your device until you delete them or they expire.
- Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
- Third-party Applications and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Application and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Application’s features or lose access to some functionality.
5. How We Use Your Information
The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:
- providing the information, products and services you request;
- security, credit or fraud prevention purposes;
- providing you with effective customer service;
- providing you with a personalized experience when you use this Application;
- contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
- contacting you with information and notices related to your use of this Application;
- inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
- better understanding your needs and interests;
- improving the content, functionality and usability of this Application;
- improving our products and services;
- improving our marketing and promotional efforts; and
- any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.
Duration. The length of time GCMD intends to retain Personal Information, including sensitive information is for as long as reasonably necessary to carry out GCMD’s intended business purpose for such information.
6. How We Disclose Your Information
We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.
Although we do not sell or lease Personal Information, we may sell non-Personal Information such as content views, trend data in healthcare education, and aggregated behavioral data.
In the preceding twelve (12) months, we may have disclosed the following categories of Personal Information for one or more business purposes:
- Protected classification characteristics;
- Commercial information;
- Internet or other network activity information;
- Professional or employment-related information;
- Non-public education information; and
- Inferences drawn from other Personal Information.
We may disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates; and
- Third party vendors who provide services that enhance our Application, products and services to you (such as vendors for credit card processing, advertising and marketing and customer support).
Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:
- Legal Reasons.
- Sale of Business or Merger. There are circumstances where GCMD may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, GCMD will ensure your information is used in accordance with this Policy.
o We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
o To respond to duly authorized information requests from law enforcement or other governmental authorities;
o To investigate and prevent security threats, fraud, or other malicious activity; or
o To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or GCMD employee.
7. Your Choices and Selecting Your Privacy Preferences
We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.
We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
8. Accuracy and Access to Your Personal Information
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.
Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.
9. Information of Minors
We do not target the Application to minors under the age of eighteen (18), and would not expect them to be engaging with our Application or services. If you submit any information relating to minors into the Application, it is your responsibility to obtain all requisite authorizations and consent to share information, Personal Information or otherwise, before submitting it through the Application. If we become explicitly aware of any Personal Information that we have collected about minors without lawful consent, we will take steps to securely remove it from our systems.
10. Third-party Websites & Applications
11. Your Rights Under State Law
- Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
- Do Not Track Signals. Other than as disclosed in this Policy, the Application does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Application does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
- WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.
12. For Application Users or Visitors Outside of the United States
Our Application is designed for use by individuals in the United States only. We do not warrant or represent that this Policy or the Application’s use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.
13. For Application Users or Visitors in the European Union (“EU”)
Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, GCMD operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.
Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.
The Data Controller is:
NAME: Bobbin, LLC dba GlobalCastMD
ADDRESS: 1999 Circle Drive, Suite B, Cleveland, OH 44106
EMAIL ADDRESS: email@example.com
You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:
- Access. You may email us at firstname.lastname@example.org to request a copy of the personal data our Application databases currently contain.
- Automated Processing and Decision-Making. You may email us at email@example.com to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
- Correction or Rectification. You can correct what personal data our Application database currently contains by accessing your account directly, or by emailing us at firstname.lastname@example.org to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
- Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to email@example.com. In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
- Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to firstname.lastname@example.org. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
- Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to email@example.com. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
- Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Application by notifying us via email at firstname.lastname@example.org. Using the same email address associated with your Application account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
- Erasure. If you should wish to cease use of our Application and have your personal data deleted from our Application, then you may submit a request by emailing us at email@example.com. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
- Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.
14. Safeguarding the Information We Collect
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.
15. Changes to this Policy
16. How to Contact Us
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at firstname.lastname@example.org or by telephone at 216-293-5034.