Privacy Policy

Version 1.0
Effective Date: June 1, 2022
Last Updated Date: June 1, 2022

Your privacy is very important to us. Before we get to the details, check out our Privacy Snapshot to see a summary of our privacy practices. Click on the links to learn more and read the full policy below.

Jump to full Privacy Policy

Privacy Snapshot

Collection and Sale of Data

  • Do we sell your Personal Information? NO

  • Do we share or sell aggregated and anonymized information? YES

  • Do we share your data with third-party API partners? YES (with your consent)

  • Do we collect sensitive data, like health information? YES (with your consent)

  • Do we delete your data when you request account deletion? YES

  • Do we keep your data as long as we need to unless you ask for deletion? YES

Privacy Tools and Controls

  • Can you disable all cookies and still have full use of the website? NO 

  • Can you delete your data? YES (except in certain circumstances)

Tracking

  • Do we use cookies? YES

  • Do we identify your device location to provide TTMdoc Services to you? YES

  • Do we track your browsing activities on other sites? NO

  • Do we listen to your device’s microphone? NO

Communication

  • Do we give you notice when we make material (important) changes to our Privacy Policy? YES

  • Do we send you marketing communications with an opt-out option? YES

 

Privacy Policy

Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy and your rights in connection with our website and any related mobile applications and services (collectively, the “Services”). Please also read our Terms of Service which sets out the terms governing the Services.

Talking To My Doctor is headquartered in Philadelphia and our Services are provided to you by TTMdoc Inc. While our Services are intended principally for residents of the United States, residents of any country may access the website and open an account. 

Where we carry paid-for advertisements on the website that are designed and commissioned for a US audience only, the ads will not be visible elsewhere.

This policy was written in English. To the extent a translated version may conflict with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third-party products or services, or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

Questions or comments about this Privacy Policy may be submitted by mail to the address below or by emailing us at: hello@ttmdoc.mblhealth.co.uk.

Attn: Data Privacy Officer

Mailing address: TTMdoc Inc, 1125 Spruce Street, Suite D, Philadelphia, PA 19107, USA

 

INTRODUCTION

TTMdoc Inc. (“TTMdoc”, “Talking To My Doctor”, “us,” “our” or “we”) takes your privacy and the security of your information seriously. We respect your desire to store and access your information in a private and secure manner. This Privacy Policy (the “Policy”) explains how we handle your Personal Information and your Health Information. 

Your Personal Information is data that could be used to identify you. Your Health Information is information about your condition(s) such as diagnosis. 

This Privacy Policy governs the way in which we collect, use, maintain, and disclose information collected from users of our website(s). These websites may include but are not limited to https://ttmdoc.mblhealth.co.uk/, and any other website or mobile software application owned or operated by Talking To My Doctor (the “Platform”). 

This Privacy Policy applies to the Platform and all our products and services (collectively, the “Services”). We are committed to providing you a secure, user-controlled Platform. At the same time, you share responsibility for maintaining privacy and security. For example, we ask you to keep your account details secure. Do not share them with any third parties. We urge you to read this Privacy Policy carefully.

The Policy applies to all new and existing Talking To My Doctor users. To use our Services, you must agree to the Privacy Policy. You may not use the Services if you do not agree to the Privacy Policy because it is part of the Terms of Service (“Terms”). 

Any capitalized terms not defined in the Privacy Policy have the same meaning as those in the Terms.

Our Terms of Service explains that, by using our Platform and signing up for services provided by Talking To My Doctor or on our behalf by third parties with whom we contract, you are allowing us to collect, use and process your Personal Information and Health Information according to the Terms, and this Privacy Policy. If you have any questions about this Policy, please contact us at hello@tmdoc.com. If you do not agree with the terms of this Privacy Policy, please do not use the Platform or Services.

By voluntarily giving us Personal Information, you are consenting to our use of it in accordance with this Privacy Policy. If you give Personal Information to us, you agree that such Personal Information may be transferred from your current location to the offices and servers of Talking To My Doctor.

PRIVACY PRINCIPLES

We follow the principles listed below to protect your privacy

  • We do not collect any more Personal Information about you than we need.

  • We only use your Personal Information for the purposes we specify in this Privacy Policy, unless you agree otherwise.

  • We do not share your Personal Information with third parties, other than as we specify in this Privacy Policy

  • We do not sell your Personal Information.

INFORMATION WE COLLECT

  • Personal Information (Data)

  • Talking To My Doctor collects specific types of Personal Information. 

  • Personal Information is data that could be used to identify you, either alone or when combined with other information.

    • We gather this information from you when you subscribe to our newsletters, and use the Platform. 

    • You will also provide such information when you create a personal account and complete surveys and forms.

    • When you communicate with us or request information from us we will collect Personal Information from you.

    • Personal Information collected online can be combined with Personal Information collected offline.

    • The Personal Information we collect may include your name, email address, mailing address, date of birth, and gender. 

    • Personal Information may include Registration information, Health Information, Self-Reported Information, User-Provided Content, and Web Behavior Information.

      • Registration Information is information that we collect from you when you sign up for a Talking To My Doctor account. Examples include your name, date of birth, login credentials, and contact information, such as an email address. We use this information to deliver our Services to you, to communicate with you, and to confirm your identity.

      • Health Information includes disease diagnosis and disease subtype

      • Self-Reported Information includes information you provide in a Talking To My Doctor questionnaire or in any other website surveys or forms, such as gender, disease symptoms and treatments, and physician ratings. We may use your Self-Reported Information in a de-identified way for Talking To My Doctor research.

      • User-Provided Content is all information other than Self-Reported Information provided by the users of Talking To My Doctor’s Services and transmitted, whether publicly or privately, to Talking To My Doctor. User-Provided Content may include data, text, software, music, audio, photographs, graphics, video, messages, or other materials; for example, comments made on Talking To My Doctor blogs, articles and training modules, and emails to customer support.

      • Web Behavior Information is information on how you use the Platform (e.g. browser type, domains, page views). We may collect this information through log files, cookies, and web beacon, analytical and advertising technologies.

You can always refuse to supply the Personal Information that we request. If you do refuse to supply information, you may not be able to engage in certain Platform-related activities and receive certain Services and information.

  • Non-Personal Information

    • We may collect non-Personal Information about you when you interact with our Platform. Non-Personal Information may include your browser name, type of computer or device and the files you viewed on the Platform.

    • Clickstream data (ie: a list of pages or URLs visited), and technical information about how you connect to the Platform, such as the operating system and the internet service providers used, are other types of non-Personal Information that we may collect. We may, in some cases, need to review this automatically collected data in combination with specific registration information to identify and resolve issues for individual users, or to detect fraud. To the extent that we link this non-Personal Information with your Personal Information, this Privacy Policy governs our use of such information.

  • Electronic Health Records Disclaimer 

    • At no time shall your Personal Information collected from you in accordance with this Privacy Policy be deemed to be an electronic health record or an electronic medical record for any purpose, including without limitation for the purpose of compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

HOW WE MAY USE YOUR PERSONAL INFORMATION

We may collect and use Personal Information for the following purposes:

  • To provide Talking To My Doctor services. We use your Personal Information, including your Self-Reported Information, to provide you with the most relevant content and Services. 

  • To improve user service. Information you provide helps us respond to your user service requests and support needs more efficiently. We will do this on the basis of our legitimate business interests.

  • To improve user experience. We may use combined, de-identified information to understand how our users as a group use the Services. We will do this on the basis of our legitimate business interests.

  • To improve our Services. We may use combined, de-identified information and feedback you provide to improve our Services. We will do this on the basis of our legitimate business interests.

  • To run a promotion, contest, survey, or other feature of the Platform. With your consent, we will use your Personal Information, preferences to keep you informed by email, text, web app, mobile app, or telephone about our services. You are free to opt out from hearing from us by any of these channels at any time.

  • To respond to your inquiries. We will use your Personal Information to respond to your inquiries, questions and/or other requests. We do this on the basis of our legal obligations and our legitimate interests.

  • To share offers from third parties that may be of interest to you. With your consent, we may use your information to tell you about offers, programs, products, or services from third parties that may be of interest to you.

  • As required by law. To send you communications required by law or which are necessary to inform you about changes to the  Services. These may include updates to this Privacy Policy and other legally required notices or information. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your Personal Information for these purposes, we cannot meet our legal obligations.

  • To comply with our legal or contractual obligations to share data with law enforcement. If we are required to disclose your information, we will do our best to provide you with notice in advance, unless we are prohibited by law from doing so.

  • To fulfill any other purpose for which you provide Personal Information. We may use your Personal Information for purposes that we tell you about at the time we collect the information or later with your consent.

  • For scientific research. We may include your anonymized information and Self-Reported Information in disclosures to third parties for the purpose of research or other applications, but no identifying information will be shared without your prior knowledge and consent. 

  • Talking To My Doctor research is intended to advance knowledge and to create, commercialize, or undertake activities toward the practical applications of this learning to the improvement of health care. 

  • Our research partners may include commercial or non-profit organizations that conduct or support medical research or conduct or support the development of drugs or devices to diagnose, predict, or treat health conditions. We may ask permission to use your de-identified Personal Information and Health Information for research that we hope to publish in scientific publications. If you choose to give this permission, you will agree to a Research Consent document. The Research Consent document is optional and voluntary. You may use the website or services without agreeing to the Research Consent document.

HOW WE PROTECT YOUR INFORMATION

The security of your Personal Information is important to us. We have adopted generally accepted industry standards for our data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your Personal Information, username, password, and data stored on the Platform. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Please remember that protecting your Personal Information is also your responsibility. We ask you to safeguard any authentication information you use to access our Services. If you use third-party services such as Apple or Google to log in to your TTMdoc account, we urge you to keep your credentials for those third-party services secure. You should not disclose your authentication information to any third party. You should also immediately notify us of any unauthorized use of your password. We cannot secure Personal Information that you release on your own or that you request us to release.

In addition, you may choose to disclose, through other means not associated with us, any part of your Personal Information and/or Health Information. You may share this information with friends or family members, groups of individuals, third-party service providers, doctors or other health care professionals, or other individuals. We recommend that you make such choices carefully.

We reserve the right to update our privacy and security policies and practices from time to time at our sole discretion. We will employ commercially reasonable technical and organizational safeguards against unauthorized disclosure or access to your data or other personally identifiable information about you, consistent with our Privacy Policy. 

HOWEVER, YOU ACKNOWLEDGE THAT SECURITY SAFEGUARDS, BY THEIR NATURE, ARE CAPABLE OF CIRCUMVENTION AND TALKING TO MY DOCTOR (TTMDOC INC.) DOES NOT AND CANNOT GUARANTEE THAT PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU WILL NOT BE ACCESSED BY UNAUTHORIZED PERSONS CAPABLE OF OVERCOMING SUCH SAFEGUARDS. IN PARTICULAR, OUR PLATFORM MAY BE USED TO ACCESS AND TRANSFER INFORMATION, INCLUDING PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU OVER THE INTERNET. YOU ACKNOWLEDGE AND AGREE THAT TALKING TO MY DOCTOR (TTMDOC INC.) DOES NOT OPERATE OR CONTROL THE INTERNET AND THAT UNAUTHORIZED USERS (SUCH AS HACKERS) MAY USE VIRUSES, WORMS, TROJAN HORSES, KEYSTROKE LOGGERS AND OTHER UNDESIRABLE DATA AND SOFTWARE TO OBTAIN ACCESS TO OR DAMAGE OUR SITE OR TO ACCESS PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU. 

Furthermore, we cannot be responsible for any personally identifiable information about you that you release on your own, or that you request or authorize us to release.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose aggregated, or other non-Personal Information or information about our users without restriction. We may disclose Personal Information about you in the ways described below and/or to the third-parties mentioned below.

  • Affiliates. To our parents, affiliates, joint ventures, or promotion partners, for their use in a manner consistent with the purposes described in this Privacy Policy.

  • Agents and Service Providers. To contractors, service providers (eg: API providers) and other third parties we use to support our business and provide the Services. 

  • Marketing. With your consent, we may share your personal data to third parties for their own direct marketing purposes, to provide you with information about products that may be of interest to you, and for other purposes as specifically set forth in this Privacy Policy.

  • Legal Process. As required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If we are required to disclose your information, we will do our best to provide you with notice in advance, unless we are prohibited by law from doing so.

  • Certain Business Transfers. As part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. It may also be disclosed in the event of insolvency, bankruptcy, or receivership. We will use reasonable efforts to direct any such transferee to use your Personal Information in a manner that is consistent with our Privacy Policy.

  • Consent. In additional ways upon your consent.

YOUR RIGHTS

  • Request a Copy of your Personal Information. You have the right to request a copy of any Personal Information that we hold about you. If you would like a copy of your Personal Information, please contact us using the contact information below. We may request proof of your identity before sharing such information. If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information by contacting us using the contact information below.

  • Cease Processing or Delete Personal Information. You may ask us to stop processing, or delete, the personally identifiable data we hold about you at any time. In certain circumstances, it may not be possible for us to stop processing or delete all of the information we hold about you, for example, where we have a legal basis to retain the information. However, please contact us using the contact information below to discuss how we can assist you with your request.

  • Withdraw Consent. When we process your information on the basis that you have consented to such processing, you have the right to withdraw your consent, or ask us to stop or restrict processing the Personal Information we have about you, at any time by contacting us using the contact information below.

  • Portability. You may also ask us to transfer your Personal Information to a third party in certain circumstances. If you would like any further information about your rights or how to exercise them, please contact us using the contact information below.

  • Retention. We will retain your information for as long as needed to fulfill your requests, provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.

  • Unsubscribe. If you receive marketing emails from us, you can unsubscribe to our emails by clicking “unsubscribe” within each email. So long as you have a TTMdoc account, you may not opt-out of service-related (non-promotional) communications.

CLOSING OR CORRECTING YOUR ACCOUNT

Your use of Talking To My Doctor is voluntary. It is your choice whether to participate or not. You may cancel your account any time. If for any reason you believe that your use is anything but voluntary, please stop all use of the service.

If you no longer wish to use Talking To My Doctor Services, you may close your account by sending a request to Customer Support at help@ttmdoc.mblhealth.co.uk. When closing an account, we remove all Personal Information within your account. However, Personal Information that you have previously provided will not be removed from ongoing or completed internal or business activities that use the information (as de-identified statistical information). Similarly, if you close your account after you have separately agreed to the Research Consent document, any Health Information that you have previously given consent to use in de-identified form will not be removed from ongoing or completed studies. If you wish to have your data removed from systems held by our business partners, for whom you have given consent to share this data, you must contact them separately. 

If your Personal Information changes, you may correct or update it on your Profile page. You may also correct or reset Personal Information entered into a survey, form, or feature by emailing a request to Customer Support at help@ttmdoc.mblhealth.co.uk, including the name of the specific survey, form, or feature.

THIRD-PARTY WEBSITES

You may find advertising or other content on the Platform that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these websites. We are NOT responsible for the practices employed by websites linked to or from the Platform. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing on and interacting with any other website, including websites which have a link to the Platform, are subject to that website’s own terms and policies. We encourage you to read the Privacy Policies of each website that you visit.

Talking To My Doctor does NOT track your activity on third-party websites. This Privacy Policy applies solely to information collected by Talking To My Doctor.

COOKIES AND OTHER TRACKING TECHNOLOGIES 

 

  • As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Platform (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Platform.

  • Talking To My Doctor uses cookies. A cookie is a small text file that is stored on a user’s computer when visiting certain websites. We use cookies or similar technologies to store session information, analyze trends, run the Platform, track user’s movements on Talking To My Doctor, and gather demographic information about our user base as a whole. These cookies are only applicable within our Platform.

  • The length of time a cookie stays on your device or computer depends on its type. “Persistent” cookies stay on your device or computer until they expire or are deleted. “Session” cookies will only stay on your device or computer for as long as you are on our Platform.

  • We may use first-party cookies as well as third-party cookies (Google Analytics) on our Platform. First-party cookies are directly stored by the website or domain you visit and belong to the website owner. These cookies allow us to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience. 

Third-party cookies are placed on your device or computer by a third party, such as an advertiser, through our Services. Google Analytics is a tool that helps us measure how users interact with our website content. As a user navigates between web pages, Google Analytics provides us JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP cookies to ‘remember’ what a user has done on previous pages / interactions with the website.

  • Please see below  for a list of the cookies used on our site. You can modify your cookie settings by following the instructions provided by your browser. These instructions are usually found in the “Tools”, “Help” or “Edit” tabs. If you set your browser to reject cookies, you may not be able to fully access and use our Platform. You can learn more about the choices provided by advertisers for individuals to decide how their information is collected and used by visiting the Digital Advertising Alliance (www.aboutads.info), the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp).

Cookie: Google Analytics

Name: __utmc, __utmt, __utmb, __utma, __utmz, __unam

Purpose: These cookies are used to collect information about how visitors use our site. We use the information to compile reports and help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This information is shown to us through the Google Analytics tools and is not shared with anyone else. They are first-party cookies.

More information: Click here for an overview of privacy at Google.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout 

  • We do not access your computer’s or device’s microphone or camera.

CHANGES TO THIS PRIVACY POLICY NOTICE

We have the discretion to update this Privacy Policy at any time. When we do, we will revise the update date at the top of this page. If we make material (important) changes to this Privacy Policy, we will notify you on this page, by email, or by means of a notice on the Platform prior to the change becoming effective. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

INDIVIDUALS UNDER THE AGE OF 18 

The Platform and Services are intended for users aged 18 years and over. Individuals  under the age of 18 are not permitted to use the Services. The Platform is not directed to, and we do not knowingly collect or solicit Personal Information from, individuals under the age of 18. If we learn we have collected or received Personal Information from an individual under the age of 18, we will delete that information. If you believe we might have any information from or about an individual under the age of 18, please contact us using the contact information below.

WHERE WE STORE YOUR INFORMATION

TTMdoc Inc. (Talking To My Doctor) is located, and the Platform is hosted, in the United States of America. In order for us to provide the Services to you, we will process and store Personal Data you provide to us in the United States of America, which may have different data protection laws than those in the country in which you reside.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits 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 contact us using the contact information below.

HIPAA

TTMdoc Inc. (“TTMdoc”, “Talking To My Doctor”) is fully compliant with the HIPAA Standards for Privacy, Electronic Transactions and Security (including the HITECH Act and the Omnibus Rule of 2013). We have implemented policies, processes, and procedures designed to ensure compliance with Federal security laws, regulations, and rules, and we monitor ongoing compliance efforts and maintain various reporting mechanisms that are required by law or requested by our customers. We recognize that it is a key responsibility for our business and will continue to provide all of our services in accordance with the relevant requirements of all federal laws and regulations, including, as applicable, HIPAA.

Questions regarding our HIPAA policies or compliance may be directed to the Privacy Officer at: hello@ttmdoc.mblhealth.co.uk

CONTACTING US

If you have any questions about this Privacy Policy, the practices of the Platform, or your dealings with us, please contact us at:

To: Data Privacy Officer, TTMdoc, Inc. (Talking To My Doctor). Address: 1125 Spruce Street, Suite D, Philadelphia, PA 19107, United States.

Email: hello@ttmdoc.mblhealth.co.uk