Introduction
Our privacy policy will help you understand what information we collect at EnrichApp, how EnrichApp uses it, and what choices you have.
When we talk about “EnrichApp,” “we,” “our,” or “us” in this policy, we are referring to Enrich Digital Technologies Limited., the company which provides the Services. When we talk about the “App” in this policy, we are referring to our online web and mobile workplace productivity tools and platform. Our Services are currently available for use via a mobile device, and/or web browser depending on your user identity, as further described in our Help Center.

1. EFFECTIVE AS OF APRIL 1, 2017
This privacy policy governs your use of EnrichApp, a software application (referred to as “App”) that was created by Enrich Digital Technologies Ltd. The App includes a method for collaborating amongst healthcare practitioners, teams and healthcare organisations; sharing non-patient specific confidential information; viewing healthcare related information, images, other relevant attachments, all of which generally referred to as communication, information and knowledge; a closed network for sharing proprietary information; a database of healthcare specific information, images and questions, social discussions amongst individuals, groups, teams; a direct messaging feature; a feature to browse and network with other professionals, teams and organisations; reading news and information from third party sources (‘feeds’), and mechanisms for users to upload and download information, files, documents, images to the database and to send direct messages to each other.

What information does the Application obtain and how is it used?

1. Customer Data
Content and information submitted by users to the App is referred to in this policy as “Customer Data.” As further explained below, Customer Data is controlled by the organization or other third party that created the team (the “Customer”). Where EnrichApp collects or processes Customer Data, it does so on behalf of the Customer. Here are some examples of Customer Data (but keep in mind they are only examples and there may be others): messages (including those in channels and direct messages), pictures, videos, edits to messages or deleted messages, and other types of files. A user may also choose to enter information into their profile, such as first and last name, job, workplace, a photo and a phone number.
If you join a team and create a user account, you are a “user,” as further described in the User Terms of Service. If you are using the App by invitation of a Customer, whether that Customer is your employer, another organization, or an individual, that Customer determines their own policies regarding creation, user-access, modification, deletion, sharing, and retention of Customer Data which may apply to your use of the App. Please check with the Customer about their group’s policies, practices and settings that they have in place.
 
2. Other information
EnrichApp may also collect and receive the following information: 
  • Account creation information
  • Users provide information such as an email address and password to create an account. 
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  • Team setup information
  • When a Customer creates a team using the App, we collect an email address, a team name, user name for the individual setting up the team, and password.
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  • Billing and other information
  • For Customers that purchase a paid version of the App, our corporate affiliates and our third party payment processors may collect and store billing address and credit card information on our behalf or we may do this ourselves.
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  • Services usage information
  • This is information about how you are accessing and using the Services, which may include administrative and support communications with us and information about the teams, channels, people, features, content, and links you interact with, and what third party integrations you use (if any).
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  • Contact information
  • With your permission, any contact information you choose to import is collected (such as an address book from a device) when using the App.
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  • Device information
  • We may collect information about the device you are using the App on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings.
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  • Third party data
  • EnrichApp may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which post codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.
 
PERSONAL AND USER PROVIDED INFORMATION
 
The App obtains the information you provide when you download and register for the App.

2. PART 1: PERSONAL USER INFORMATION
When you register with us and use the App, you provide:
  • your username
  • your password
  • your email address
  • your specialty, areas of expertise and interested topics
  • your work related and other professional information
  • your social media account access/ login details
 
We will store your username, country, specialty and all other profile information on an encrypted server.
Your password is hashed and your email address is encrypted. These information elements are referred to collectively as your “Personal User Information.” We collect and hold this information for the purpose of administering your use of the Application.
You are solely responsible for (1) maintaining the strict confidentiality of your Personal User Information, (2) your teams sensitive and confidential information, (3) not allowing another person to use your Personal User Information to access the App and the information, (4) any and all damages or losses that may be incurred or suffered as a result of any activities that occur under your Personal User Information. You agree to immediately notify Enrich Digital Technologies Ltd. in writing by email to privacy@enrichapp.com of any unauthorized use of your Personal User Information or any other breach of security. Enrich Digital Technologies Ltd., is not and shall not be liable for any harm arising from or relating to the theft of your Personal User Information, your disclosure of your Personal User Information, or the use of your Personal User Information by another person or entity.

3. PART 2: USER-PROVIDED INFORMATION

(a) When you use the app, you may:
  • upload information, personal knowledge, opinion
  • create groups and link it with relevant specialties
  • information about your team members and their contact details
  • create questions, titles, answers, image captions and tags
  • discuss, share information and images about any healthcare related activities
  • answer health–related and non-health-related questions 
  • direct message to other users
  • case discussions with and without the key patient identifiers
  • non-patient specific confidential information
 
We will store all the information that you have populated on the app, your questions, answers, comments, uploaded documents and images, captions of discussions, images and documents, date created, number of times the discussion, document and image tag is used, common variations of discussion, document and image tags (such as misspellings) and information on whether the tag appears in searches.

All the data will be encrypted while in transit and when stored in our servers. We do not store IP addresses or location information relating to the discussions, information and files uploaded by users.

(b) When you use the app, you may provide comments. We will store your comments, the date of comments and the username connected to the comments.

(c) When you use the app, you may provide feedbacks. We will store your feedbacks, the date of feedbacks and the username connected to the feedbacks.

(d) When you use the app, you may “bookmark or like” discussion threads, questions and answers, images for easy reference later. We will store these information on EnrichApp, as well as the date on which you carried out those activities, and the username connected to those actions / activities.

(e) When you use the app, you may flag images and information provided by other users as inappropriate or indicate that identifiable information may have been improperly included in a section of the app, or on an image, caption, or comment. We will store the information and the images that you flag, the subcategory of the information and flagged image, the date flagged and the username referenced to the flagged image until or unless the image is deleted.

(f) We will also store the date your account was created, the Application version, and the last login date.

(g) Message Data - The App includes a feature through which users may communicate directly with other users by sending and receiving direct messages. When you send or receive direct messages through the App, we may process or store your messages, phone number, log contact data and other information ("Message Data") in order to deliver the services. All Message Data is subject to the Terms of Service. Message Data will be encrypted as the direct message is sent and while the direct message is in transit. Message Data will be encrypted when stored on our servers. We will not access the Message Data, except in connection with delivering the services. Although we strive to maintain the privacy and security of all Message Data, we cannot guarantee the privacy and security of Message Data and any Message Data that you send is at your own risk. 

These informational elements shall be referred to as “User-Provided Information.” All User-Provided Information that you generate in the App must comply with local, national, provincial, state, and federal privacy legislation and best practice guidelines given by professional and registering bodies, their code of practice and ethics. Identifying information must be removed from any uploaded documents and images and should not be included in any captions or comments.

The App is enabled with Enrich Digital Technologies’ proprietary features, such as ‘Associate with relevant specialties’, a key feature that facilitates users to link their groups with relevant & suitable healthcare specialties, through manual or automatic event-triggers.
Despite the app providing clear choices for choosing open and closed discussion forums, depending on the sensitivity of the data to be shared and handled, the existence of these tools, choices and defined nature of groups does not release you from any obligations under local, national, provincial, state, federal laws and importantly professional ethics and code of practice to maintain the privacy of patients or other users.

(g) Optional User Provided Information
  • You also have the option to ask to be verified as a registered healthcare professional. If you choose this option, you will be asked to provide us with additional information, which we will cross-reference with publicly available data to ensure that you actually are a registered healthcare professional. If you are verified, we will store your status as a “verified healthcare professional.” You are required to update your status as necessary.
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  • You also have the option to invite colleagues to join the groups, so that they can use the App too. If you choose to do this, the App will access the address book on your mobile device to enable you to choose which of your colleagues you would like to invite to the App.
  • You will also have the option to expand your user profile with additional information. If you choose this option, you may complete any of the following fields: real name, state, country, and institution, and you may include a short biography and upload a profile picture. Information you provide will be visible to all the verified healthcare professionals using the App or the website. You are responsible for the accuracy of all of the information you provide.
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  • On occasion, we may survey our users or solicit comments and opinions from our users. You have the option to respond to our inquiries. If you choose this option, the information will be used to learn more about healthcare, your specialty and professional interests to help improve your experience on EnrichApp, and for other purposes of Enrich Digital technologies. We only store this information in the aggregate with the exception of comments, which will be linked to your user profile.
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  • When using the direct messaging feature, you will have the option to allow colleagues to find you and to sync your mobile device’s contacts to find people you know on EnrichApp. If you choose to do this, the App will access the entire address book on your mobile device and sync it to EnrichApp. EnrichApp uses a secure one-way hash to protect the emails and phone numbers in your contacts. 
All information stored on our server will not be accessible by third parties.
We may also use the information provided by you to contact you from time to time to provide you with important information, push notifications and marketing promotions. You will be given the option to opt-out of these notifications.
This Application does not collect precise information about the location of your mobile device.
Do third parties see and/or have access to information obtained by the Application?
We will disclose User Provided and Automatically Collected Information, within or outside your jurisdiction, as described above in the following circumstances:
  • as required by law, such as to comply with a subpoena, or similar legal process;
  • 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;
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  • with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement; 
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  • if Enrich Digital Technologies ltd. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information; and
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  • we disclose user email addresses to third party email service providers in order to deliver users EnrichApp’s informational, service and content emails.
What are my opt-out rights?
You can stop all collection of information by the App easily by uninstalling the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

However, the App will not allow you to opt out of any announcements and messages related to the implementation of this Policy and your obligations thereunder. As such, depending on the type of the user group created, i.e. open / closed groups with use of non-patient identifiable data, should your uploaded information, images, image captions, or comments contain identifying information about a patient (as described in the Terms of Service,) you will receive messages from Enrich Digital technologies ltd. notifying you of a potential privacy violation associated with this content.

Our Cookie Policy
EnrichApp uses cookies and similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies.

Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit our website or use our desktop application. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

Some cookies are associated with your account and personal information in order to remember that you are logged in and which teams you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things. If you access the app through your browser, you can manage your cookie settings there but if you disable some or all cookies you may not be able to use the App.

EnrichApp sets and accesses our own cookies on the domains operated by EnrichApp and its corporate affiliates. In addition, we use third parties like Google Analytics for website analytics. You may opt-out of third party cookies from Google Analytics on its website. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.

4. DATA RETENTION POLICY, MANAGING YOUR INFORMATION
We will retain User Provided Information as described above for as long as you use the App, via support@enrichapp.com.
You may request to have all images and comments associated with your account deleted, however, we cannot guarantee, that we will be able to recall and delete images that have been provided to third parties, such as medical journals or medical education websites.
If you contact Enrich Digital Technologies Ltd. to delete your account, the change will be processed within seven (7) calendar days.

5. SECURITY
We take security seriously. We are concerned about safeguarding the confidentiality of your information. We take various steps to protect information you provide to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. We provide physical, electronic and procedural safeguards to protect information we process and maintain. For example, your password is irreversibly hashed and your email address is encrypted.

We limit access to your information to authorized employees and contractors who need to know that information in order to operate, develop or improve the Application. Please be aware that, although we will take reasonable steps to safeguard and maintain security of Personal User Information, User-Provided Case Information, Optional User Provided Information, Automatically Collected Information and Message Data that we process and maintain, no security system can prevent all potential security breaches. Please refer to the Terms of Service for more details about Enrich Digital Technologies Ltd.’s and your obligations with respect to the proper use of the App and notification obligations thereunder.

6. SHARING AND DISCLOSURE
There are times when information described in this privacy policy may be shared by EnrichApp. This section discusses only how EnrichApp may share such information. Customers determine their own policies for the sharing and disclosure of their Data. EnrichApp does not control how Customers or their third parties choose to share or disclose Customer Data.

1. Customer Data
EnrichApp may share Customer Data in accordance with our agreement with the Customer and the Customer’s instructions, including:
  • With third party service providers and agents
  • We may engage third party companies or individuals to process Customer Data.
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  • With affiliates
  • We may engage affiliates in our corporate group to process Customer Data.
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  • With third party integrations
  • EnrichApp may, acting on our Customer’s behalf, share Customer Data with the provider of an integration added by Customer. EnrichApp is not responsible for how the provider of an integration may collect, use, and share Customer Data.
2. Other information
EnrichApp may share other information as follows:
  • About you with the Customer. There may be times when you contact EnrichApp to help resolve an issue specific to a team of which you are a member. In order to help resolve the issue and given our relationship with our Customer, we may share your concern with our Customer.
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  • With third party service providers and agents. We may engage third party companies or individuals, such as third party payment processors, to process information on our behalf.
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  • With affiliates. We may engage affiliates in our corporate group to process other information.
3. Other types of disclosure
EnrichApp may share or disclose Customer Data and other information as follows:
  • During changes to our business structure. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of EnrichApp's assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).
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  • To comply with laws. To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.
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  • To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.
We may disclose or use aggregate or de-identified information for any purpose. For example, we may share aggregated or de-identified information with our partners or others for business or research purposes like telling a prospective EnrichApp Customer the average number of messages sent within a EnrichApp team in a day or partnering with research firm or academics to explore interesting questions about workplace communications.

7. CHANGES TO THIS PRIVACY POLICY
We may change this policy from time to time, and if we do we will post any changes on this page. If you continue to use the Services after those changes are in effect, you agree to the revised policy. Each time you use the App, the most current version of the Privacy Policy will apply. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes. Unless stated otherwise, the most current version of the Privacy Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of your privacy without the consent of affected users.

8. YOUR CONSENT
By using the App, you are consenting to our processing of Personal User Information, User-Provided Information, Optional User Provided Information, Automatically Collected Information and Message Data as set forth in this Privacy Policy now and as amended by us. “Processing” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information.
Contact us – If you have any questions regarding privacy while using the App, have questions about our practices, or wish to make a complaint about our handling of your personal data, please contact us via email or anonymously here. We will make every effort to investigate and respond to your complaint in a timely way.
Any and all good-faith disclosures of privacy concerns under this Policy will not be used to restrict or prohibit you from continuing to use the App to the extent permitted by law. However, disclosure of any unlawful practices implicating the Privacy Policy to Enrich Digital Technologies Ltd., does not release you from your obligations to notify professional and regulatory bodies in healthcare, local, national, provincial, state, and federal authorities of any violation of law related to your use of the App.

9. ADDITIONAL TERMS FOR UNITED KINGDOM, NORWAY, ICELAND, KAZAKHSTAN, TURKEY, THE RUSSIAN FEDERATION, SOUTH AMERICA, UKRAINE, UZBEKISTAN, AND EUROPEAN UNION RESIDENTS
If you are a resident of the United Kingdom, Norway, Iceland, Turkey, the Russian Federation, Ukraine, the European Union or South America, legislation* permits you to request that we tell you what personal information we hold about you and how we process it and that we provide you with a copy of that information. You are also entitled to access, rectify, change, update, delete, revoke, or improve upon your personal information at any time. You can exercise this right free of charge. We may ask you to provide further information to confirm your identity before considering your request.

To make such a request, please send an email to privacy@enrichapp.com.
If you use the App to invite colleagues to join EnrichApp or to share information and images with a colleague, you must first have their consent to use their email address for this purpose. EnrichApp will rely on your obtaining that consent.
For purposes of providing the App, EnrichApp keeps all your personal data to servers located in the United Kingdom.  EnrichApp will notify you of any changes to this arrangement and will make you aware of any situation where the data would be transferred outside United Kingdom and European Union. By using, and continuing to use the Application, you agree to this arrangement.
The data we hold is used solely for the purposes of operating the EnrichApp site and communicating with you. The information we request from you is mandatory unless indicated otherwise and is necessary to enable EnrichApp to provide you with the EnrichApp Application. You are also entitled to object to any processing of your personal data on reasonable grounds. 
*Legislation
  • Argentina – Personal Data Protection Act N°25.326
  • Austria – The Data Protection Act 2000
  • Belarus - The Information, Informatization and Data Protection Act N°455-З of 10 November 2008
  • Belgium – The Data Protection Act of 08 December 1992
  • Denmark – The Act on Processing of Personal Data 
  • Finland – The Data Protection Act (523/1999)
  • France – The Law n°78-17 on Computers and Data Processing
  • Germany – The Federal Data Protection Act
  • Greece – Law 2472/1997 on the Protection of the Individual from Processing Personal Data, as amended and in force
  • Iceland – The Icelandic Data Protection Act 
  • Italy – Legislative Decree 196/2003
  • Kazakhstan - Law on Personal Data and Its Protection from 21 May 2013 No. 94-V
  • Netherlands – Dutch Personal Data Protection Act 2000
  • Norway – Act of 14 April 2000, No. 31 relating to the processing of personal data (Personal Data Act)
  • Portugal – The Data Protection Act (Law 67/98 of 26 October)
  • The Russian Federation – Federal Law of the Russian Federation “On Personal Data”
  • Spanish Kingdom – Spanish Data Protection Act 15/1999 and Spanish Data Protection Royal Decree 1720/2007
  • Sweden – The Personal Data Act (1998:204)
  • Ukraine – The Personal Data Protection Act of June 01, 2010 No 2297-VI
  • United Kingdom – The Data Protection Act 1998
  • Uzbekistan – Law on Principles and Guarantees of Freedom of Information No 439-II dated 12.12.2002
10. ADDITIONAL TERMS FOR AUSTRALIA, NEW ZEALAND, CHINA, INDIA, ISRAEL, JAPAN AND SOUTH AFRICA RESIDENTS
If you are a resident of the Australia, New Zealand, India, Israel, Japan, the PRC or South Africa privacy legislation permits you to request that we tell you what personal information we hold about you and provide you with a copy of that information. You also have the right to request that we correct your personal information if it is inaccurate, out-of-date or incomplete. We may ask you to provide further information to confirm your identity before considering your request. To make an access and/or correction request, please send an email to privacy@enrichapp.com 

If you use the App to invite colleagues or other members of your team to join Enrichapp or to share information with a colleague, you must first have their consent to use their email address for this purpose. EnrichApp will rely on your obtaining that consent.
It is not mandatory or legally required for you to provide us with any of your personal information. However, if you do not provide the information that we ask for, you may not be able to access and use all of the App’s features available to users.

EnrichApp may transfer your personal data to servers located in other countries for purposes of providing the Application. By using, and continuing to use the Application, you agree to that transfer. If you are an Australian resident, you acknowledge that by providing your consent to the transfer to servers located outside Australia, we are not required to take reasonable steps to ensure your personal information is handled in accordance with Australian privacy law.

If you are a user in the PRC, if you notice any personal information leakage or otherwise have any complaint about the protection of your personal information, please contact privacy@enrichapp.com. We will respond within fifteen days of the receipt of your email. 

Contacting EnrichApp
Please also feel free to contact us if you have any questions about EnrichApp’s Privacy Policy or practices. You may contact us at feedback@enrichapp.com.