Privacy and Communication Policy
Prollenium® Rewards App
Prollenium® Medical Technologies Inc. (“Prollenium”, “we”, or “us”) is the provider of the Prollenium® Rewards App (the “App”).
In order to provide services, offers, rewards and discounts to you through our App, we need to collect some personal information about you, and about the offers and rewards that you earn, redeem or claim. We aim to collect the minimum amount of information required to operate the App effectively.
We take your privacy seriously. We do our best to protect the confidentiality of the information that we collect. Prollenium® will never disclose the information that we collect about you to anyone other than as permitted by this Privacy Policy. We will never share your information with third-party advertisers under any circumstances.
This Policy describes the types of information that we collect about you, and how we may use, store, retain and secure this information. By using the App, you consent to the collection, storage, retention and use of your information as set out in this Policy.
If you do not consent to this Policy in its entirety, you cannot use the App.
Please also review the Prollenium® Rewards App Terms of Use https://prollenium.com/terms-of-use/
The Information We Collect from you Directly:
Most of the information we collect about you is collected from you directly, in ways that are open and transparent to you. For example, when you use the App, we ask you to provide some information about yourself (your “Account Information”), including the following:
- Your name
- Your email address
- Your date of birth
- Your postal code or zip code
- Your gender
- Your chosen clinic location
We require this information in order to enable your use of the App, and in order to provide App services to you. This information is used to identify you as an individual user of the App, to determine your approximate location, to locate clinics near you, to determine your eligibility to receive and redeem offers and rewards, and to track the rewards and offers that you have redeemed. When you visit your clinic location to redeem offers and rewards, this information is used to identify you and to confirm that you are the person entitled to redeem the offers and rewards.
If you refer others to the Prollenium®App, we store the email address of users that you have referred. We use this information to send an invitation on your behalf to the person you have referred, and to determine your eligibility for referral rewards. To protect the privacy of people you may refer, we will provide you with no information about the other user or their use of the App. If they become sufficiently active users of the App to qualify you to receive a referral reward, we will simply notify you that you are eligible for a referral reward, but we will give you no further details. If your referral does not result in eligibility for a referral reward, you will receive no notification or explanation.
If you have been referred to the App by another person, you consent to the collection and use of your email address and other relevant information which we may require in order to determine the eligibility of the person who referred you to the App for a referral reward.
As you use the App, we may also collect technical, demographic, and statistical information relating to your use of the App.
This information may include:
- The IP address of the device(s) you use to access the App
- Information about the device you use to connect to the App
- Information about when you access the App, and the offers, pages, offers, content or links that you may click on or view while connected to the App
- For the purpose of detecting fraudulent use of the app, we collect location information about where you are when you redeem Offers or Rewards, or record transactions in order to establish eligibility for Offers or Rewards.
- A record of Clinic Offers and Prollenium® Offers which have been made available to you through the App.
- Other technical information relating to the device(s) or network that you use to connect to the App, or your activity while using the App
- While you are connected to the App, this information is used to enable the App to communicate with you, and to personalize your experience while using the App. This information may also be used, stored and retained for the purposes of recording and analyzing the ways that you and other users use the App; detecting and preventing fraudulent uses of the App; providing a record to establish that Offers and Rewards were validly earned and redeemed; or to conduct internal market research. We may use third party analytics services to collect, monitor, and analyze this technical information.
CTI: Clinic Translation Information
Whenever you visit your Clinic and redeem an Offer or Reward, or request that a transaction be recorded in the App in order to earn or establish your eligibility for any Offer or Reward, we need to collect certain information about relevant Clinic transactions. This information must be collected in order to allow us to determine and keep a record of your eligibility for Offers or Rewards; to keep a record of Offers and Rewards that you have redeemed; to allow us to detect and prevent fraudulent uses of the App.
Every time we must collect any information about Clinic transactions, a message will appear in the App to notify you and request your consent to the disclosure of this information by your Clinic to Prollenium®, and to permit Prollenium® to collect, store, and use this information as set out in this Privacy Policy. No Clinic transaction information will be disclosed to us unless and until you provide your consent.
Since you will be at your Clinic location whenever this information is requested, you will have an opportunity to ask for details of the information is being sought, or to ask other questions about this policy or the collection of this information.
You are free to decline to consent if you like, and your Clinic will not disclose any information about this transaction to us. Note, however, that if you do not consent to provide the requested transactional information, Offers and Rewards cannot be applied to the transaction, and the transaction cannot be recorded in the App to earn or establish your eligibility for loyalty rewards or other Offers.
PROLLENIUM® IS NOT A HEALTH CARE PROVIDER OR A HEALTH INFORMATION CUSTODIAN, AND IS NOT ACTING AS AN AGENT OF YOUR CLINIC. THE INFORMATION COLLECTED BY PROLLENIUM® IS COLLECTED IN ORDER TO PROVIDE YOU WITH OFFERS AND REWARDS, AND NOT FOR THE PURPOSE OF PROVIDING HEALTH CARE TO YOU.
WHEN YOU CONSENT TO THE DISCLOSURE OF CLINIC TRANSACTION INFORMATION TO PROLLENIUM®, YOU IRREVOCABLY ACKNOWLEDGE AND AGREE THAT PRIVACY LEGISLATION THAT MAY APPLY TO HEALTH CARE PROVIDERS (SUCH AS YOUR CLINIC) AND OTHER HEALTH INFORMATION CUSTODIANS DOES NOT APPLY TO PROLLENIUM®.
PROLLENIUM® AIMS TO PROTECT THE CONFIDENTIALITY OF ALL INFORMATION THAT WE COLLECT ABOUT YOU, BUT OUR ONLY OBLIGATIONS WITH RESPECT TO THE COLLECTION, STORAGE AND USE OF ALL INFORMATION, INCLUDING INFORMATION ABOUT CLINIC TRANSACTIONS, ARE THOSE OBLIGATIONS WHICH ARE SET OUT IN THIS PRIVACY POLICY, IN OUR TERMS OF USE, AND/OR IN PRIVACY LEGISLATION OF GENERAL APPLICATION.
You may decline to consent to the disclosure of Clinic transactional information in the future, but CONSENT PREVIOUSLY GRANTED TO DISCLOSE CLINIC TRANSACTIONAL INFORMATION CANNOT BE REVOKED.
CTI: Clinic Translation Information
CTI may be collected if you have requested that the purchase be recorded within the App to earn or establish your eligibility for any Offer or Reward (for example: if you wish to record a purchase of Prollenium® Product in order to earn eligibility for a loyalty reward which requires a certain number of purchases of Prollenium® Products); or
You have requested to apply a Reward or Offer to the transaction (for example, where you are eligible to claim a discount on the purchase of a Prollenium® Product, and you wish the discount to be applied against this purchase).
Information that we record about relevant transactions may include:
- The date, time and location of the transaction;
- The number of, type of and/or the total price paid for products or clinic services that you wish us to record in order to earn or establish your eligibility for an Offer, Reward or loyalty program;
- A record of and reference to any Offer or Reward that has been applied to the transaction, which may include a reference to any Clinic transaction records previously recorded within the App to establish your eligibility for the Offer or Reward;
- A record of the offers and rewards that you have redeemed.
- A record of Clinic transactions which establish your eligibility to claim any Offer or Reward
- Confirmation from an employee of your clinic that the claim to eligibility for a reward was legitimate.
- Other information relating to your eligibility to receive or redeem offers and rewards
This information is connected to your Account Information, and is required for the following reasons:
- to determine which Offers and Rewards have been offered to you;
- to determine which Offers and Rewards you have redeemed;
- to determine and maintain a record of your eligibility to redeem any Offer or Reward;
- to detect and prevent fraudulent uses of the App by Clinics and/or users of the App;
- to maintain a record of Offers and Rewards for which the Clinic may be reimbursed by Prollenium®;
- to analyze the popularity and effectiveness of Offers and Rewards, to conduct market research, and to assist in the development of more effective Offers and Rewards.
Because this information provides an indispensable record of the legitimacy of Offers and Rewards redeemed in the past, this information may be stored and used by Prollenium® indefinitely, and may be retained and used by Prollenium® even if you terminate your Account.
Who has Access to your Information?
The information that we collect about you may be accessed by Prollenium®, and by Prollenium® employees, service providers and contractors. We may share some or all of the information that we collect about you with your selected Clinic and its designated personnel. All Prollenium® and Clinic personnel with access to your information are bound by strict confidentiality agreements requiring them to handle your Account Information confidentially and in accordance with this Policy.
Your information may be disclosed or transferred in the event of a change in ownership of Prollenium®, in part or in whole, through any form of business acquisition, merger, or otherwise. Any party acquiring such an interest in Prollenium® may be granted access to your Personal Information pursuant to terms governing collection, use and disclosure consistent with those set out in this Policy.
How and Why is Your Information Used?
Prollenium and your Clinic may use the information that we collect about you for any purpose set out in this Privacy Policy, or for any of the following reasons:
- to enable the functionality offered by the App, or to provide App services, Offers, or Rewards to you or to other users of the App;
- to determine and to maintain a record of eligibility to redeem Offers and Rewards. To identify, detect, analyze, prevent and maintain a record of fraudulent or improper uses of the App, including fraudulent or improper attempts
- to redeem, claim or earn Offers and Rewards;
- if and where required, to be serve as evidence in support of a legal claim against clinics or users who attempt to use the app fraudulently, improperly, or in breach of any applicable Agreement;
- to analyze the ways that the App is used, to monitor performance of the App, or to improve the App;
- to evaluate user engagement with Offers and Rewards, to develop or improve Offers or Rewards, to research or develop products, services or marketing strategies and opportunities, to analyze consumer interest in products or services, or to conduct market research and analysis;
- to improve or provide customer service, and to communicate with you about Prollenium®products or Clinic services;
- to communicate with you about the App, Prollenium Products, or Clinic services
- to improve the App, Prollenium® Products, or Clinic services
- to evaluate user engagement with Prollenium®and Clinic Offers and Rewards, to develop or improve Clinic offers or rewards, to develop services or marketing strategies, to analyze consumer interest in Prollenium® products, to conduct market research and analysis, and to provide you with offers and rewards.
- For any other purpose set out in the Terms of Use, this Privacy Policy, or any other applicable agreement.
Your information may also be used and disclosed, if required, to enable us to comply with applicable legal and regulatory requirements. For example, we may be required to disclose this information in order to comply with a court order or subpoena. Where reasonably possible, and provided we are not precluded from doing so, we will make a reasonable effort to inform you if we are ever required to disclose your personal information pursuant to a court order.
Storage and Security of Your Information:
Prollenium® endeavors to take every step necessary to safeguard your information from loss, unauthorized access, duplication, manipulation, use or disclosure. However, Prollenium® shall have no liability to you or any other party in the event of unauthorized access to or inadvertent disclosure of any personal information.
Prollenium® currently stores your information on servers located in the state of Nevada, in the United States. You consent to the transmission of your information through United States computer networks, and to the storage of your information on a server located in the United States.
Your Password:
It is your responsibility to choose a secure password, and keep it secret. Prollenium shall have no responsibility or liability for any disclosure of your personal information resulting from an insecure password or disclosure of your password. We do not store your password in plain text on our servers.
Communication:
Prollenium® and your chosen clinic may communicate with you from time to time via email or through App notifications for the purpose of providing you with offers or rewards, to inform you about Prollenium® products or clinic services, to notify you of changes to the App or any related terms of use (including this Policy), or to enable App functionality (for example, to reset a lost password).
If you refer another person to the App, you consent to our sending an invitation email to that person on your behalf.
Terminating Your Account:
You may terminate your account and cease using the App at any time. However, we may, at our sole discretion, retain and use some or all of the information that we collected about you while your account was active indefinitely after termination of your account, for any of the purposes set out in this Privacy Policy. In particular, we must retain all records which may be of assistance in (1) establishing and maintaining a record of your eligibility for any Offers or Rewards you may have redeemed; (2) retaining a record of user account information in order to prevent malicious users from maintaining more than one account, or closing and opening accounts in order to illegitimately take advantage of offers that may be made to new users of the App from time to time; or (3) retaining a record of Offers and Rewards for which Prollenium® has or will reimburse a Clinic; or (4) detecting, preventing, deterring or maintaining a record of fraudulent or improper use of the App, including any Offers and Rewards improperly redeemed.
Updates to This Policy:
We may update this Policy from time to time by posting an amended version of this Policy on our website at https://prollenium.com/privacy-policy/. Any amendments will be effective from the date on which they are posted. Your continued use of the App constitutes agreement to the amended Policy.
Our Privacy Officer:
Inquiries related to this Policy or concerns relating to the accuracy, use or retention of records relating to you, and requests for access to your Personal Information should be directed to the Prollenium® Privacy Officer, who can be reached via email at [email protected]
Please be advised that we may require specific information or identification in order to enable us to confirm your identity and rights of access, as well as to enable us to search for and provide the personal information we retain about you. In accordance with industry standards and applicable legislation, we may charge a reasonable fee for collecting and delivering this information to you. If such a fee applies, we will notify you in advance, and confirm that you wish to proceed with your request.
Your right to access the personal information that we maintain in respect of you is not absolute. Under certain circumstances, applicable laws and regulations may allow or require us to refuse to provide some or all of the personal information that we hold about you. Or, due to our record retention practices and obligations, Personal Information may have been destroyed, erased or made anonymous prior to your request. In the event that we are unable to provide you with access to your Personal Information, we will endeavor to inform you of the reasons why.
