Last update: July 10, 2020.
WARNING – READ CAREFULLY BEFORE ACCESSING OR USING OUR SERVICES.
1. Collected data
When you visit our Website
You are free to explore the Website without providing any Personal Information. When you visit the Website, we request you to provide Personal Information about yourself, and we also collect Navigation Data.
When you use our Eyer and/or EyerCloud Applications
We use a mobile device management software to better understand our Applications functionality in your smartphone. This software may register information such as the amount of times you use the application, the events occurred within the application, aggregate use, as well as performance data and where the application was downloaded from. Further than the data collected from our Website, when you use our Applications, we may also collect the location in your city, as well as device model and version, the device identifier (or “UDID”), operating system version and your Phelcom subscription service credentials, as appropriate.
We send push notifications at times to keep you informed about events or promotions. Disable them in your device in case you do not want to receive such communication.
We may vinculate data stored in the software to the Personal Information you send through the Applications. We do it to improve the services we provide, as well as the functionality of our marketing, our data analyses and website information.
Refer to any information you voluntarily send us and identify you personally, including contact information, such as name, email address, company name, address, telephone number and other information about you or your company. Personal Information may also include information on eventual transactions, free or paid, that you input to our Website, further than the information about yourself available on the Internet in websites such as Facebook, LinkedIn, Twitter and Google, or even information publicly available we acquire from our service providers.
Personal Information also includes Navigation Data or Payment Data for cases in which such information is enough to identify someone directly or indirectly. Navigation Data refers to the information on your computer and your visits to this website with your IP address, geographic location, type of browser, reference source, visit length and viewed pages. Consult the section “Navigation Data” below.
When you use our services or visualize our offered content, we automatically collect information on your computer hardware and software. This information may also include, further than mentioned above, domain names, Internet service provider (ISP), files viewed on our website (for example, HTML pages, graphs, etc.), operating system and clickstream data. This information is used by Phelcom to keep the quality of our Subscription Service and to generate general statistics regarding the use of Phelcom Website. For such ends, we automatically vinculate these collected data to Personal Information such as name, email address, address and telephone number.
Information on minors
If you are less than 18 years old, you shall not use Eyer and EyerCloud Applications without a written consent from at least one parent or legal guardian, which shall be sent to firstname.lastname@example.org
2. How we use the collected data
Use of Personal Information
We never sell your Personal Information to third parties.
Phelcom collects and uses your personal information to operate a technological service platform. Collected data are used to provide, keep, secure and improve our services, develop new ones and protect Phelcom and its users. We also use this information to offer the user a specific content, targeted to his/her personal needs for the benefit of health.
Once you register to our Webstite or Eyer and EyerCloud Applications and utilize our service platform, we will require you to provide your name, email address, as well as, for patients, some information on your health (for example, biometric data for retina exams, inter alia). By registering to our EyerCloud management Software monthly subscription service, payment data, such as credit card numbers and billing data, may be collected by using external PCI-Compliant service providers.
YOU MAY ALWAYS CHOOSE IF YOU WISH OR NOT TO PROVIDE SUCH INFORMATION. IN FACT, NONE OF YOUR DATA CAN BE COLLECTED WITHOUT YOUR CONSENT.
If you choose not to provide the requested information, you may not be able to use and receive certain benefits, resources or functions from our service platform.
- send you information or content from Phelcom that we believe to be of your interest, through publications, emails and other means, as well as send marketing communication related to our company, always according to your communication preferences;
- improving our software specific functionalities, such as machine learning;
- provide other partners anonymized statistics about our users, provided that such information will not be used to identify any specific user;
- fulfill legal requisites.
BY USING THE WEBSITE, AS WELL AS EYER AND EYERCLOUD APPLICATIONS, YOU AGREE THAT PHELCOM MAY SHARE YOUR INFORMATION WITH HEALTHCARE PROFESSIONALS AND/OR INSTITUTIONS, AND ALSO PHYSICIANS, CLINICS AND HOSPITALS SO THAT THEY CONTACT YOU TO PROVIDE INFORMATION ON EXAMS AND REPORTS MADE THROUGH THE PHELCOM SERVICE PLATFORM, TO OFFER OTHER SERVICES OR CARRY OUT RESEARCHES. THESE THIRD PARTIES ARE FORBIDDEN OF USING YOUR PERSONAL INFORMATION, EXCEPT FOR THESE PURPOSES, AND THEY OUGHT TO PRESERVE THE CONFIDENTIALITY OF YOUR INFORMATION.
Phelcom may follow the websites and pages you visit, as well as other applications you use, in order to determine which healthcare services are the most popular. Phelcom may also track how long you use the telephone. This information is used to show content in our Applications for customers whose behavior indicates interest for specific areas.
Use of Navigation Data
We use Navigation Data to operate and improve our Website and Applications. We will also use Navigation Data isolatedly or in combination with Personal Information to provide you personalized information on Phelcom.
User comments and testimonies
In our Website and Applications, we post testimonies and comments from Users as you, which may contain Personal Information. We obtain consentment via email from each User before posting your name and testimony.
Use of credit card data
If you provide credit card data, for example, to subscribe to our paid content in EyerCloud Application, we will use it exclusively to check your financial qualifications and for payment purposes. We use a service provider to manage credit card processing. This service provider is not allowed to store, retain or use the data you provide, except for the only purpose of credit card processing on our behalf.
Safety of your Personal Information
We use various safety technologies and procedures to help secure your Personal Information against unauthorized access, use or disclosure. We secure the Personal Information you provide in computer servers in a controlled environment, secured and protected against unauthorized access, use or disclosure. All the Personal Information is secured by physical, technical and organizational measures.
Social Media Resources
We offer boards for User messages and community forums for public access to our Eyer Software. Keep in mind that, if you disclose any information directly through our message boards, blogs or forums, this information may be obtained and used by others. In case you request, We will correct or remove any information you have posted on our Website at your request, as described in “Voluntary exclusion and unsubscription” below.
Retention of Personal Information
The period we retain information collected about you depends on the type of information, as described below in further details. After that period we will remove or anonymize your information or, if this is not possible, we will securely store and isolate them so that they are not used until removal is possible.
We retain the Personal Information you provide us when we have a continuous and legitimate commercial need for that (for example, if it is necessary to contact you in order to speak about the paid subscription service or our other services, or, still, according to which is necessary to fulfill our legal liabilities, solve disputes and enforce our contracts).
When we have no continuous and legitimate commercial need to process your Personal Information, we will remove or anonymize your date irreversibly or, if this is not possible, we will securely store and isolate your Personal Information, so that they are not processed until removal is possible. We will previously remove this information from the servers at your request, as described in “How to cancel the subscription to our communications” below.
In case you chose to receive our marketing communication, we will retain information on your marketing preferences for a reasonable period from the last date you expressed interest for our contents, products or services, such as the last time you opened an email message we sent you or stopped using your Phelcom account in our Applications. We retain information derived from cookies and other tracking technologies for a reasonable period from the date when such information was created.
3. How we share the information we collect
We may share aggregate information without personal identification with our partners, such as advertisers and related websites. We may also publicly present information to show tendencies about the general use of our services. We may likewise use aggregate and information without personal identification to carry out quantitative scientific research.
In case we (or our assets) are acquired by another company, either by merger, acquisition, bankruptcy or otherwise, this company will receive all the information Phelcom gathered about the Website and Eyer and EyerCloud Appliications. In this case, you will be notified via email and/or a highlighted warning in our website about any alteration in the company property, use of your Personal Information and the choices you may have towards your Personal Information.
Duty of disclosure
We reserve ourselves the right of use and disclosure of your Personal Information if it is requested by law or if we reasonably believe the use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate frauds or comply with a law, court order or legal process.
International data transfers
International transfers to third parties
4. Cookies and similar technologies
Flash Cookies and other tracking technologies from third parties
Adobe Flash Player and similar applications use a technology to remember settings, preferences and use which are similar to browser cookies, but they are managed by a different interface than the one your browser provides. This technology creates locally stored objects that are frequently called “Flash cookies”. Phelcom does not use Flash cookies.
Tracking technologies from third parties
5. Your rights: how to access and control your Personal Information
Review, correction and removal of your Personal Information
You have the following data protection rights:
- You may request access, correction, update or removal of your personal information;
- You can oppose to our processing of your personal information, request us to restrict your personal information processing or request portability of your personal information;
- In case we have gathered and processed your personal information with your consentment, you may cancel your consent whenever you want. Cancelling your consent will not affect the legality of any processing we conducted before, nor will it affect your personal information processing according to lawful processing, regardless of your consent;
- You have the right to complain to a data protection authority about our gathering and use of your personal information.
How to cancel a subscription to our communications
You may cancel the subscription to our marketing communication by clicking the link “cancel subscription” in the lower part of our emails, updating your communication preferences.
In order to exercise any of such rights, send an email to email@example.com or write to PHELCOM TECHNOLOGIES LTDA. – ME, 820, José Missali Street – Santa Felícia, ZIP CODE 13.562-450 – São Carlos / SP, Brazil.
We will answer your request for changing, correcting or removing your information within a reasonable period and notify you about our course of action.