Privacy Policy

This Privacy Policy describes how Medicem Inc. (“Medicem”) collects, uses, or discloses personal information we receive through our website (https://dilapans.com) and any mobile applications or other related services we may offer within the United States (collectively, the “Services”). This policy also describes your choices about the collection and use of your information. Note that if you have a business relationship with us, any contractual terms in that relationship will control.

Please read the Privacy Policy carefully before you start to use our Services. By using the Services, you agree to be bound and abide by our posted Terms of Use and Privacy Policy. If you do not agree to both the Terms of Use and our Privacy Policy, or if you violate them in any way, your right to access or use the Services is terminated. Please see Sections 6-7 of our Terms of Use regarding your legal rights in any dispute involving our Services.

1. How We Collect Information

We may collect information about you by various means, including:

  • Directly from you, both online and offline;
  • Through our Services; and
  • From other third party sources and social media platforms that you may use to engage with us, as well as from our affiliates, partners or third parties, including but not limited to public sources, to supplement information we possess.

2. Types of Information We Collect

Medicem is not providing any healthcare services through the Services and is not handling any personal information pursuant to healthcare-specific laws, such as the Health Insurance Portability and Accountability Act (“HIPAA”). However, in order to better provide you with our Services, we may collect the following categories of information:

  • Contact information, such as your name, mailing address, e-mail address, phone number, professional title and organization (particularly for healthcare practitioners), interest in our products, and preferences such as when to receive our communications;
  • Transactional information, including payment information if you process any transactions with us through the Services;
  • Survey information in response to questions we may send you through the Services, such as for research or feedback purposes;
  • Communications between you and us, such as via e-mail, mail, phone or other channels;
  • Offline activity you engage in with us; and
  • Online User Activity described in the next section.

If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this policy.

Job applicants may also provide us information as part of their employment application that includes such things as the applicant’s name, email, social media profile, resume, and cover letter. We do not use this information for any purpose other than to evaluate the individual for employment with us. Job applicants may provide additional information for routine background checks to a third party provider of such services, under specific privacy terms and consents that will be provided at the time of collection.

3. Online User Activity, Cookies and Information Collected by Other Automated Means

Cookies are a commonly-used web technology that allow websites to store and retrieve certain information on a user’s system, and track users’ online activities. We, our service providers, and our business partners may collect information about your use of our websites and mobile apps by such automated means, including but not limited to cookies, pixels, SDKs and other similar technologies.

Cookies and similar technologies can help us automatically detect when you return to our Services. Cookies help us review website traffic patterns, improve the website and determine which aspects of Services are popular. When you use the Services, the information we may collect by automated means includes, for example:

  • Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
  • Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, and mobile network information); and
  • Location information where you choose to permit the Services to access your device’s location information.

We may also ask advertisers or other partners to serve ads or services to your device, which may use cookies or similar technologies placed by us or the third party. If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features our Services provide. We may share non-personal information obtained via cookies with our advertisers and affiliates. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. We and our service providers and business partners may collect information about users’ online activities over time and across third-party websites.

4. How We Use Information We Collect

We may use the information we obtain about you for purposes allowed by applicable laws, including:

  • Provide our Services to you and respond to your inquiries and other communications;
  • Tailor the content we display to you in our Services and communications, including advertising, and offer products and information that we believe may be of interest to you;
  • Operate, evaluate and improve our Services;
  • Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
  • Inform you about changes to this Privacy Policy and our Terms of Use and other policies;
  • Comply with and enforce as needed applicable legal requirements, industry standards, our policies and our contractual rights;
  • Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns; and
  • Diagnose or fix technology problems.

We may also use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing, and advertising, as well as improvement of our Services.

5. How We Share Your Information

We will not disclose your personal information to third parties without your consent, except in the following circumstances.

We may share your information as permitted by law, including, for example, with our corporate affiliates, and service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT services, maintenance and hosting of our Services, payment processors, shipping and returns partners, marketing partners, and other service providers). We only provide such vendors with information so they can perform their required functions on our behalf.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, users or the public.

We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us and applicable law.

6. Your Privacy Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

  • Marketing Emails: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, promotional information and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.
  • Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.

7. State-Specific Notices

For California residents, the California Consumer Protection Act (the “CCPA”) provides various rights to individuals and households with respect to the collection and use of personal information that we have collected about you. Among other rights under the CCPA, you have the right to request that we: (i) disclose to you any personal information that we have about you; (ii) delete personal information that we have about you (subject to certain exceptions); or (iii) not “sell” your information to a third party (excluding qualified service providers), as that term is interpreted under the CCPA. It is unlawful for us to discriminate against you because you exercised any of your rights under the CCPA. If you are a California resident, you can submit such requests to us via the contact information provided below and we will complete the request within the timeframe permitted by law.

For Nevada residents, please note that we do not sell personal information as defined by Nevada law (Ch. 603A, Sec. 1.6). You can submit a request to us regarding the sale of such information via the contact information provided below.

8. Online Advertising & Links to Other Websites and Third Party Content

You may see us advertising on various websites, web pages, social media and other platforms. Please note that online advertising service do not always provide us with complete information about the platforms or website on which our advertising may appear. Please contact us if you believe that our advertising is being displayed through an inappropriate website.

Our Services may contain links to other websites or apps. This can include social media integrations. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or app that collects personal information.

9. How We Protect Information

We endeavor to maintain reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

10. Children

We do not knowingly collect personal data from children under the age of 13 on our Services. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Services, please contact us, and we will endeavor to delete that information from our systems. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will endeavor to delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as directed below.

11. International Data Transfers and Use

Our Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the United States. Any information you provide through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information, potentially including sensitive data, by us from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Privacy Policy.

Please note that our legal affiliates may separately operate websites and other online services, subject to the terms and privacy notices posted therein.

12. Updates to Our Privacy Policy

We may revise or update this Privacy Policy at any time. We will post the updated version on our Services, and may notify you of any significant changes to our Privacy Policy. We will indicate on our Privacy Policy when it was most recently updated. Your continued use of our Services after such updates will constitute (a) acknowledgment of the change and agreement to abide and be bound by the updated Privacy Policy.

13. Contacting Us

If you have any questions, concerns or comments about this Privacy Policy, our privacy practices, or if you would like us to update information or preferences you provided to us, please contact us at Medicem, Attn: Chief Compliance Officer, 125 High St, Ste 1704, Boston, MA 02110, via email at elise.roth@medicem.com or by phone at 973-534-2396.

This Privacy Policy was last updated May 15, 2020.