Effective November 1, 2019

Privacy

Overview

Your access to, and use of the TalktoMira, Inc. (d/b/a Mira) (“Mira”) services which include this web site (www.Talktomira.com) and the information, products and services that we provide to you and other users through this web site, as well as the mobile applications (“Mira App(s)”) provided by us in connection with our products and services (collectively, the “Mira Services”) is subject to the Mira Services Terms of Service and this Privacy Policy.

Mira has created this Privacy Policy to explain what information we gather from you when you use the Mira Services, how we may use this information, the security approaches we use to protect your information, and how you can access and request modification of certain information that we may store about you. Please note that this Privacy Policy applies only to information collected via the Mira Services – it does not apply to information you disclose to Mira through other means. This Privacy Policy is incorporated and made part of the Mira Services Terms of Service.

Your Acceptance of This Privacy Policy and Changes to It

By accessing, viewing or otherwise using any Mira Service, you consent to the collection and use of your information by Mira in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you may not use any Mira Service. Mira reserves the right to change, modify, add or remove portions of this Privacy Policy at any time, without prior notice. Changes take effect on the date that appears on the revised Privacy Policy. If you use the Mira Service following a change in this Privacy Policy, your use will be understood to signal that you accept and agreed to be bound by the changes. Accordingly, we urge you to review this Privacy Policy frequently for changes.

What information do we collect?

We collect personally identifiable information (“Personal Information”) and other non-individually identifiable information from you when you register on the Mira Services, respond to communication such as e-mail, or otherwise use the Mira Services in any manner.

To participate in certain features of the Mira Services, you will be required to provide certain Personal Information. For example, when registering as a user on any Mira Service, we may ask you for your name, e-mail address, birth date, mailing address, zip code, phone number, credit card information or other Personal Information. You may, however, visit portions of the Mira Services without providing any Personal Information.

We may collect and use mobile device identifiers, IP addresses and session identifiers to analyze trends, to administer the Mira Services, to track user activities, to infer user interests, and to otherwise induce, deduce, and gather information about individual users and market segments.

Like many web sites and certain mobile apps, we use and may allow third party service providers to use "cookies" or other tracking technologies to enhance your experience and gather information about visitors and visits to the Mira Services. Please refer to the "Do we use 'cookies'?" section below for information about cookies and how we use them.

We may also collect and store certain other personally non-identifiable information. This information is collected passively using various technologies, and cannot presently be used to specifically identify you.

How do we use your information?

We may use the Personal Information and other data we collect from you when you register, purchase services, respond to a survey or marketing communication, access or view the Mira Services, or use certain other Mira Service features in the following ways:

·       To provide any legitimate business service or product.

·       To personalize your Mira Service and to allow us to deliver the type of content and product offerings in which you are most interested.

·       To allow us to better service you in responding to your customer service requests.

·       To contact you when necessary or requested.

·       To quickly process your transactions.

·       To verify and validate your identity.

·       To administer a promotion, survey or other Mira Service features.

·       To send you information about Mira or our products or the Mira Services.

·       To show you advertisements, including interest-based or online behavioral advertising.

·       To troubleshoot problems with the Mira Services, or any services, as requested.

·       To enforce the Mira Service, Terms of Service, and to detect and protect against error, fraud and other unauthorized or illegal activities.

You understand and agree that if you are using any Mira Service from a country outside the United States and provide Personal Information to the Mira Service, you will be authorizing and consenting to the transfer of Personal Information about yourself to the United States. You understand that the privacy laws of the United States may be different from and not as comprehensive or protective as those in your country, and you agree that the transfer of your Personal Information to the United States occurs with your consent. Personal Information collected on the Mira Service may be stored and processed in the United States or abroad.

Do we disclose the information we collect to outside parties?

You understand and agree that we can disclose your Personal Information and other data to third parties, as follows:

·       To our subsidiaries or affiliates, strategic partners and to third parties we engage to provide services, such as medical services, web site hosting, credit card payment processing, order processing, analytics services etc.

·       In the event of the sale or transfer of Mira, of one or more of our business units or of some or all of our assets, or in the context of some other business acquisition transaction.

·       In response to a subpoena or court order, or a request from a law enforcement or other government agency; to establish or exercise our legal rights, or to defend against claims; or to protect the safety or security of the public or of users of the Mira Services.

·       We can disclose aggregate information and other non-individually identifiable information about users of the Mira Service to our service providers, partners, advertisers or others.

Correcting and Updating Your Personal Information

You can correct or update your Personal Information by re-registering or by contacting us by e-mail at [email protected]. It may take us up to 30 days to process your request.

Do we use "cookies"?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser or mobile device that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. Cookies help us in many ways to make your use of the Mira Services more enjoyable and meaningful, such as understanding usage patterns and improving functionality of the Mira Services. For instance, we use cookies to help us understand your preferences based on previous or current Mira Services activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about Mira Services traffic and Mira Services interaction so that we can offer better Mira Services experiences and tools in the future.

We may contract with third-party service providers to assist us in better understanding our Mira Service visitors. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use the Mira Services and enhance your experience when you use the Mira Services. For more information on how Google uses this data, go towww.google.com/policies/privacy/partners/.

If you are using our website, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you are accessing our mobile app, you can choose to change your permissions and settings on your mobile device. Each browser and device is different, so look at your browser or devices Help or Settings menu to learn the correct way to modify them. If you turn cookies off or disable certain permissions, you won't have access to many features that make your Mira Service more efficient and some of our services will not function properly.

“Do Not Track”

Our Mira Services currently do not respond to “Do Not Track” (DNT) signals.

Safeguarding Your Personal Information Privacy and Third Party Links

Mira follows generally accepted industry security standards to safeguard and help prevent unauthorized access and maintain data security of Personal Information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of any Personal Information submitted to or otherwise collected during your use of any Mira Service. Accordingly, you understand and agree that you transmit all data, including Personal Information, to us at your own risk.

Privacy and Third Party Links

This Privacy Policy applies solely to information collected by the Mira Service through our web site located at Talktomira.com and the mobile application(s) we make available. In an attempt to provide you with increased value, we may include third party links on the Mira Services. This Privacy Policy does not apply to the third party sites and services that are accessible through these links and we suggest that you contact the operator of the third party service to obtain details about their privacy policies. We have no responsibility or liability for the content and activities of these linked sites or services. Nonetheless, we seek to protect the integrity of the Mira Services and welcome any feedback about these linked sites (including if a specific link does not work).

Exclusions

This Privacy Policy shall not apply to any unsolicited information you provide to us through the Mira Services or through any other means. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children’s Privacy

The Mira Service is intended only for use by adults, either for themselves or on behalf of their minor children. We do not knowingly collect information directly from children under the age of thirteen. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Mira Service, please contact us, and we will endeavor to delete that information from our databases.

Retention of Your Personal Information

We will store the Personal Information you provide for as long as we believe is necessary or appropriate (i) to carry out the purpose(s) for which we collected it, or (ii) to comply with applicable laws, contracts, or other rules or regulations.

Questions and Feedback

We welcome your questions, comments, and concerns about the Mira Services. Please send us any and all feedback pertaining to the Mira Services to [email protected].

The information contained in this Privacy Policy is subject to change without notice.