Last Updated June 1, 2023.
Mohana ("us," "our" or "we") recognizes the importance of privacy. We respect your desire to store and access your information in a private and secure manner. This Policy explains how we handle your Personal Information and Health Information. Your Personal Information is data that could be used to identify you. Your Health Information is data related to your health status.
We follow the principles listed below to protect your privacy:
- We do not collect any more Personal Information about you than we need.
INFORMATION WE COLLECT
Personal Information (Data)
Mohana collects several 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 buy our Services, 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 registration information, health information, self-reported information, user content and web behaviour
Registration Information is information that we collect when you register for Mohana. We use it to deliver our services to you, communicate with you, and to confirm your identity
- your name
- email address
- mailing address
- date of birth
Health Information is information that we collect when you enroll in our alpha, upload lab tests, and participate in surveys. You may upload pre existing lab test results from tests ordered by your doctor or insurance provider. We use your health information to make recommendations to you as part of our Services. We may use your health information in a de-identified, aggregated way for Mohana research. For research that we hope to publish, we will request separate permission through a Research Consent document. Any Research Consent is optional and voluntary. You are not required to agree to a Research Consent document to use the Platform or Services.
- biological data (biomarkers)
- heart rate
- self-reported symptoms
- pre-existing diagnoses
- period cycle length
Self-Reported Information includes information you provide in the Mohana questionnaire or in any other website surveys or forms. We may use your Self-Reported Information in a de-identified way for Mohana research.
- Sleep Quality
- Stress Levels
- Personal Energy Levels
User Content is all information other than Health Information or Self-Reported Information provided by the users of the Mohana Services and transmitted, whether publicly or privately, to Mohana. User content may include data, text, software, music, audio, photographs, graphics, video, messages, or other materials. For example, user content includes comments made on Mohana blogs, Platforms, and emails to customer support.
Web Behavior 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 marketing 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.
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, and the files you viewed on the Platform. Clickstream data, (i.e. 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.
Electronic Health Records Disclaimer
HOW WE MAY USE YOUR PERSONAL INFORMATION
We may collect and use Personal Information for the following purposes:
To provide Mohana services.We use your Health Information, along with your Self-Reported Information to produce your Mohana analysis.
To process transactions. Registraiton Information you give to us lets us process transactions made on the Platform or otherwise as necessary to perform our contractual obligations to you, including confirming your order, billing, and delivering products or services.
To improve customer service. Information you provide helps us respond to your customer service requests and support needs more efficiently. We will do this on the basis of our legitimate business interests.
To personalize your 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, survey, or other feature of the Platform. With your consent, we will use your Personal Information, preferences and details of your transactions to keep you informed by email, text, web or telephone about our products and services. These products may include tailored special offers, discounts, promotions, events, competitions and so on. We do not use your Health Data for marketing. Of course, 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 contractual obligations to you, our legal obligations and our legitimate interests.
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 Health 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. Mohana research is intended to advance wellness and health 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 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, transaction information, and data stored on the Platform. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Please recognize that protecting your Personal Information is also your responsibility. We ask you to safeguard your account, account recovery, and other authentication information you use to access our services. You should not disclose your authentication information to any third party. You should also immediately notify us of any unauthorized use of your account. 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. 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.
If you do choose to share Health Information with your doctor or other health professional, those data may become part of your medical record. Other health professionals and health insurance companies may be able to access the genetic data in your health record.
We will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with a third party. It is your responsibility to share Personal Information only with people you know and trust.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose aggregated, or other non-Personal Information or information about our users without restriction. While we may disclose Personal Information about you in the ways described below and/or to the third-parties mentioned below, we will not share Health Information and Self-Reported Information:
- Agents and Service Providers. To contractors, service providers, and other third parties we use to support our business and provide the Services. These providers may complete transactions or perform services on our behalf or for your benefit.
- 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.
- In additional ways upon your consent.
- 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 in certain circumstances. It may not be possible for us to stop processing or delete all of the information we hold about you where we are fulfilling a transaction or have a legal basis to retain the information, however please contact us 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.
- Complaints. If you are in the European Union, you have the right to make a complaint at any time to the relevant data protection authority in your country.
- 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. You may not opt-out of service-related communications, which are not promotional in nature.
- Closing or correcting your account Your use of the Mohana service is voluntary. It is your choice whether to participate or not. You may cancel the service at 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 Mohana Services, you may close your account by sending a request to Customer Support at email@example.com. 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 R&D 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 our business partners, you must contact them separately. In addition, we keep limited information related to your order history (e.g., name, contact, and transaction data) for accounting and compliance purposes.
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 support at firstname.lastname@example.org and including the name of the specific survey, form, or feature.
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.
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.
You can modify your cookie setting by following the instructions provided by your browser. These instructions are usually found in the "Tools", "Help" or "Settings" 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) or the European Digital Advertising Alliance (www.youronlinechoices.eu).
CHILDREN UNDER THE AGE OF 18
The Platform and Services are intended for adults. Users 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, children under the age of 18. If we learn we have collected or received Personal Information from a child under the age of 18, we will delete that information. If you believe we might have any information from or about a child under the age of 18, please contact us using the contact information below.
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.