Last modified: January 4, 2019
Archetype Solutions, LLC (“Company” “we” “our” or “us”) is committed to protecting your privacy through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website www.minq.com or utilize our MindQ mobile software application (collectively, our “Sites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
- Children Under the Age of 13
Our Sites is not intended for users under 18 years of age. No one under age 18 is authorized to use, or provide any information to, the Sites. Additionally, in accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not request, or knowingly collect, personal information from children under 13. If we learn of any mistaken or inadvertent collection or receipt of personal information from a child under 13 through their misuse of the Sites, we will delete that information from our records. We ask all parents and guardians to assist us in our efforts to comply with COPPA by prohibiting children under the age of 13 from providing the Company with any personal information or using the Sites without parental oversight and assistance. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
- Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Sites, including information:
- by which you are or may be personally identified, such as name, postal address, e-mail address, telephone number, or any other information the Sites collect that is defined as personal or personally identifiable information under an applicable law, including but not limited to your Internet protocol (IP) address (collectively, “personal information”). Personal information will also include information you submit as part of your participation in our Assessments (as defined below) including your responses to specific Assessment items;
- that is about you but individually does not identify you, such as your browser or device type or internet service provider, the websites from which you link to our Sites, and aggregated, non-identifying information that is derived from your personal information (such as the number of users accessing our Sites from a particular ZIP code)
- about your usage of the Sites and other sites which link to and from the Sites.
We collect this information: (i) directly from you when you provide it to us, either through the Sites or directly when you contact us; (ii) automatically as you navigate through the site; and (iii) from third parties, for example, our marketing and sales partners. Information collected automatically may include usage details, IP addresses, and information collected through cookies, pixels, web beacons, and other tracking technologies.
Some of the features and content available through the Sites include interactive wellness assessments and related courses and reports that we provide (the “Assessments”). As part of the Assessments you will be provided a link by your employer, a consultant or a third party business (each, an “Administrator”) for the purpose of completing the Assessments. You understand that participation in completing the Assessments is entirely voluntary and, if you wish to withdraw from completing the Assessments, you may do so at any time without explanation.
- Information You Provide to Us.
The information we collect on or through our Sites may include:
- Information that you provide by filling in forms on our Sites. This includes information provided at the time of registering to use our Sites. We may also ask you for information as part of your participating in one of our assessments or when you report a problem with our Sites.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Your searches on the Sites.
- Information relating to your participation in Assessments
- Any other content you create and share with Company or other users of the Sites
- Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our Sites, including traffic data, logs, and information about your device and internet connection, including your IP address, operating system, and browser type.
We do not share any of the data collected from these technologies with any third parties other than our services providers for the purpose of providing you with services via the Sites. Company does not use your data to conduct any behavioral tracking.
The information we collect automatically is statistical data and may include personal information. It helps us to improve our Sites and to deliver a better and more personalized service, including by enabling us to store information about your preferences and recognize you when you return to our Sites.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Sites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Sites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our the Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Sites statistics (for example, recording the popularity of certain Sites content and verifying system and server integrity).
- How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information: (i) to present our Sites to you, including the Assessments; (ii) to provide you with information, that you request from us; (iii) to display advertisements for our products on the Sites; (iv) to fulfill any other purpose for which you provide it; (v) to notify you about changes to our Sites; (vi) in any other way we may describe when you provide the information, or (vii) for any other purpose with your consent.
In addition to the forgoing please note that we may rely on your personal information, including potentially your responses as part of an Assessment, to direct you to resources that may be available to you via your employer or another Administrator.
We may also use your information to contact you directly about our products that may be of interest to you. If you do not want us to use your information in this way, you can opt out by notifying us of your intent to unsubscribe from such communications either by clicking the “unsubscribe” link contained therein or contacting us at: email@example.com.
- Lawful Basis of Processing
We collect and process your personal information under the following lawful bases:
- With your consent as provided hereunder;
- Performance of a contract with you;
- As necessary to comply with a legal obligation; and
- To fulfill our legitimate interest in conducting our business, where your interests and fundamental rights do not override those interests including, but not limited to:
- providing assessments;
- to keep our records updated;
- to study how customers use our products/services, to develop them and grow our business and inform our marketing strategy;
- for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercises;
- contacting you about our products, or responding to your requests.
- Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we rely on in order to provide you with the Assessments. Such parties shall specifically include, but not be limited to, CoreHealth Technologies Inc., and Multi-Health Systems Inc. (collectively, “Third Party Service Providers”). Such personal information will only be used by Third Party Service Providers for the following purposes: (i) to assist in our provision of services to you, including, but not limited to, scoring, analyzing and interpreting your usage of the Assessments and generating resulting reports; and (ii) for research, analysis, assessment and business purposes but only to the extent that such personal information has been de-identified, anonymized or aggregated such that it will not identify you individually.
- To the Administrator, for purposes of providing you with Assessment results and related reports and content. Under no circumstances will your employer be provided with your specific responses to any Assessment.
- To (i) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Sites users is among the assets transferred; (ii) to fulfill the purpose for which you provide it; (iii) with your consent.
- Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by (i) logging into the Sites and checking or unchecking relevant boxes to adjust your marketing preferences; (ii) by following the opt-out links on any marketing message sent to you; or (iii) by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions.
- Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
- Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, which may include rights to the following:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Users Outside of the United States
If you are visiting the Sites from a location outside of the United States, your connection will be through servers located in the United States. All information you receive from the Sites may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using the Sites or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.
- Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at: 2124 Race St, Ground Floor, Philadelphia, PA 19103. All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or postcard. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
- Data Security
We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers. Unfortunately, no transmission of information via the Internet can be completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.
- Contact Information
2124 Race Street, Ground Floor
Philadelphia, PA 19103