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Privacy Policy of memoryclinic.com (¡§Policy¡¨)
1. Definitions
1.1 In this Policy, unless the context otherwise requires:
Ask the Expert means the enquiry and information exchange system supported by the Site which permits Users to submit queries regarding their own or third parties¡¦ memory impairment to which the Company (or another person authorised by the Company) may post a response in a public area accessed by other Users;
Bulletin Board means the messaging system supported by the Site which permits Users to exchange views and information between them;
Company means Memoryclinic.com Limited, Scottish company number SC223967, having its registered office at 302 St Vincent Street, Glasgow, Scotland G2 5RZ;
DPA means the UK¡¦s Data Protection Act 1998;
Memory Test means the modular on-line memory assessment (¡§MO-LMA¡¨) or any other memory assessment undertaken by the User using the Site;
Site means the website owned, operated and maintained by or on behalf of the Company and accessed by the domain name ¡§memoryclinic.com¡¨; and
User means any person accessing, viewing, downloading, or using the Site or any part of the Site.
2. Collecting Information
The Company is the sole owner of the information collected on the Site, and for the purposes of the DPA is the data controller. The Company will not sell, share, lend, lease or rent this information to any third party in any way different from that set out in this Policy. The Company collects information from Users at several different points on the Site:
Registration
2.1 In order to use the Site, a User must first complete the registration form. During registration a User is required to give contact information (such as name, telephone number, postal address, email address, a picture, occupation, and their hospital/surgery name, telephone number and address). The Company uses this information to contact the User about services on the Site in which the User has expressed interest.
2.2 It is optional for the User to provide demographic information (such as gender), and unique identifiers (such as, username and password), but the Company encourages Users to do so in order that the Company can provide a more personalized experience on the Site.
Memory Test
2.3 To undertake the Memory Test effectively, the User is requested to give detailed personal information concerning their age and gender which is linked to their User profile. The results of the Memory Test which are also linked to the User's profile.
Ask the Expert and Bulletin Board
2.4 If a User makes use of the Ask the Expert and/or Bulletin Board and/or the Memory Test facilities, the User may be submitting to the Company personal information concerning the identity and health of the User or a third party, which may be viewed by the Company and by other Users.
3. Information Use
The Company uses the information it collects in a number of different ways:
Profile
3.1 The Company stores information that we collect through cookies, log files, clear gifs, and/or third parties to create a profile of Users. A profile is stored information that kept by the Company on individual Users that details their viewing preferences. Consequently, collected information is tied to each User¡¦s personally identifiable information to provide offers and targeted information, and to improve the content of the Site for the User. This profile may be used to tailor a User¡¦s visit to the Site, and to direct pertinent marketing promotions to a User.
3.2 The Company may from time to time share a User¡¦s profile with third parties. Users¡¦ profiles are shared with third parties together with Users¡¦ personally identifiable information in the ways set out in this policy (see in particular section 5 below)
Cookies
3.3 A cookie is a piece of data stored on the User¡¦s computer tied to information about the User. Usage of a cookie is in no way linked to any personally identifiable information while on the Site. The Company uses both session ID cookies and persistent cookies. For the session ID cookie, once Users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the User¡¦s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions.
3.4 By setting a cookie on the Site, Users would not have to log in a password more than once, thereby saving time while on the Site. If Users reject the cookie, they may still use the Site. The only drawback to this is that the User will be limited in some areas of the Site. Persistent cookies enable the Company to track and target the interests of Users to enhance their experience on the Site. (See the ¡§Profile¡¨ section, above)
Third Party Advertising
3.5 Advertisements appearing on the Site are delivered to Users by the Company¡¦s web advertising partners. Information about a User¡¦s visit to the Site, such as number of times a User has viewed an advertisement (but not the User¡¦s name, address, or other personal information), is used to serve advertisements to Users on the Site.
3.6 The Company has no access to or control over cookies used by third parties. This Policy covers the use of cookies by the Site only and does not cover the use of cookies by any third parties (including without limitation advertisers.)
Log Files
3.7 Like most standard web site servers, the Company uses log files for the Site. These may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track the User¡¦s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. IP addresses are tied to personally identifiable information to enable the Company¡¦s service provided through the Site. The Company may use a tracking utility that uses log files to analyze User movement.
Clear Gifs (Web Beacons/Web Bugs)
3.8 The Company and its third party advertiser employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that helps the Company better manage content on the Site by informing the Company what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the full stop at the end of this sentence. Clear gifs may be tied to Users¡¦ personally identifiable information.
3.9 In addition, the Company may use clear gifs in its HTML-based emails to confirm which emails have been opened by the recipients. This allows the Company to gauge the effectiveness of certain communications and the effectiveness of its marketing campaigns. If Users would like to opt-out of these emails, please see the Data Protection and Opting-out section, below.
4 Communications from the Site
The Company will communicate with the User directly or via the Site in the following circumstances:
Newsletter and Updates
4.1 The Company sends all new Users a welcoming email to verify password and username. Registered Users will occasionally receive information on products, services, special deals, and a newsletter. Users may opt not to receive these types of communications (please see Data Protection and Opting out, below.)
Service Announcements
4.2 On rare occasions it is necessary to send out a strictly service-related announcement. For instance, if the Site¡¦s service is temporarily suspended for maintenance the Company might send Users an email. Users may opt-out of these communications. Please see our Data Protection and Opting-out, below.
Customer Service
4.3 We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the users wishes.
5. Sharing Information
The Company shares information about Users in the following circumstances:
Sharing Information for Legal Reasons
5.1 The Company may need to disclose personal information when required by law and where the Company has a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our the Company or the Site.
Aggregate Information (which does not identify individuals)
5.2 The Company shares aggregated demographic information with our carefully selected partners and advertisers (see above). This is not linked to any personally identifiable information.
Third Party Advertisers
5.3 The Company may share usage information about Users with reputable third parties for the purpose of targeting the Company¡¦s advertisements on the Site. The information collected by the Company through the Site and shared in this manner does not identify living individuals.
Sponsors
5.4 The Company may share Users' names and email addresses with the sponsors of the Site (currently Shire Pharmaceuticals Group plc) to allow these sponsors to send Users emails containing information about memory impairment and memoryclinic.com. These emails will only be sent on behalf of the Company, and the sponsors are not authorised to contact Users directly for
the sponsors' own purposes.
Sharing Users personal information:
5.5 The Company does not normally share Users¡¦ personal information with other third parties except in the ways set out in this Privacy Policy.
6. Business Transitions
In the event that the Company goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, Users¡¦ personal information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on the Site for 30 days prior to a change of ownership or control of their personal information.
7. Data Protection Act and Opting out
7.1 The Data Protection Act 1998 may give Users legal rights to see the information about them held by the Company, and the User may have the right to correct any inaccuracies.
7.2 Users may ¡¥opt-out¡¦ of having their information used for the purposes of direct marketing and promotional communications.
7.3 The Company takes its responsibilities as a data controller very seriously, and if any User wish to exercise any of these rights, or has any queries generally about data protection, please contact us (see below).
8. Links
The Site contains links to other internet sites. This Policy applies solely to information collected by the Site, and the Company is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.
9. Notification of Changes
If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.
10. Contact Information
If users have any questions or suggestions regarding our privacy policy, please contact us at:
„h info@memoryclinic.com
„h c/o WJM, 302 St Vincent Street, Glasgow, G2 5RZ.
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