Last Updated: May 12, 2023
Table of Contents
- 1. Who is Miga?
- 3. Personal Information
- 3.1 What is Personal Information?
- 3.2 What types of Personal Information do we collect?
- 3.3 How do we collect your Personal Information?
- 3.4 How do we use your Personal Information?
- 3.5 How do we share your Personal Information?
- 3.6 Your choices about how we share your Personal Information
- 3.7 How do I access and correct my Personal Information?
- 4. Who may use the Services?
- 5. Children’s Privacy
- 6. Does Miga respond to Do Not Track signals?
- 7. Data Security
- 8. California’s Shine the Light Law
- 10. Contact Us
Who is Miga?
Miga exists to ensure everyone achieves the health they deserve. We do this by connecting our users with independent medical practitioners who offer a virtual cardiometabolic health program that helps our users manage their weight, blood pressure, high cholesterol, diabetes, and tobacco use from home with confidence. This is made possible by a personalized experience that includes a blood pressure monitor, scale, and medications.
Miga is not a medical group or a health care provider. Miga provides its users with the ability to obtain telemedicine consultations provided by independent medical practitioners including, but not limited to, Park Hill Health Services, P.A., Richard Joseph, M.D., P.C., and Park Hill Health Services of New Jersey, P.C. (collectively "Medical Group"), an independent medical group with a network of United States-based health care providers (each, a "Provider"). Medical Group (or your own medical provider if you do not use a Medical Group Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Miga.
- Our "Devices" - Miga devices compatible with our Platform
- "Personal Information" - Any information relating to an identified or identifiable individual
- and any information listed below
- Our "Platform" - Our Website and Devices
- "Products" - Any products available for purchase on our Platform
- Our "Services" - Any services provided through our Platform
- Our "Terms of Service" - Our terms of service located here
- Our "Website(s)" - Our websites, including: www.migahealth.com
- "Miga," "we," "us," or "our" - Enduring Management Services, LLC
- You visit or use our Platform, including our Website;
- You wear our Devices and record Personal Information;
- We communicate via e-mail and through text; and
- We communicate in person, such as on the phone or through a telehealth visit.
What is Personal Information?
Personal information is information from and about you that may be able to personally identify you. We treat any information that may identify you as personal information. For example, your name and e-mail address are personal information.
What types of Personal Information do we collect?
We may collect and use the following categories and specific types of personal information (hereinafter, collectively referred to as "Personal Information"):
- Personal identifiers - a real name, birth date, e-mail address, home address, shipping address, or Patient ID
- Information that identifies, relates to, describes, or is capable of being associated with a particular individual - name, username or online identifier, physical characteristics or description, shipping address, home address, driver’s license number, state ID number, passport number, IP address, email address, date of birth, insurance policy number, telephone number, credit card number, debit card number, health or medical information, weight, body mass index ("BMI"), whether you are a smoker or non-smoker, medical conditions, family medical history, medications currently taking or prescribed, measurement data, average heart rate, heart rate, step count, distance traveled, active and resting energy levels, sleep analysis, blood pressure readings, workout history, your activity levels, and accelerometer data
- Characteristics of protected classifications under California or federal law - Race, Color, Age, National Origin, Genetic Information, Citizenship, Ancestry, Marital Status, Sex (including gender, gender identity, gender expression, pregnancy or child birth), Sexual Orientation, or Disability
- Biometric information - Keystrokes, Sleep Data, Health Data, Exercise Data, Psychological Characteristics (such as mood, sentiment, thoughts, personality type), Genetics, and information related to treatment such as the results of blood and other medical tests
- Internet or other electronic network activity information - IP address, device mode, device ID, OS version, device language, operating system, browser type, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
- Geolocation data - Physical location or movements, local time, and local time zone
- User generated content - Information you provide to be published or displayed (hereinafter, "Posted") on public areas of our Website or transmitted to other users of the Website or other third parties
Some Personal Information we collect may constitute PHI as defined by HIPAA. As set forth above, your Provider will provide you with a Notice of Privacy Practices describing their collection and use of your health information, not Miga. We will only collect and use PHI for the purposes of providing the Services and we only collect the minimum amount necessary to fully perform and provide the Services on our Platform. We may combine your PHI with Personal Information that we have either obtained from you or through a third-party, such as your Provider, health insurer, employee benefits program, or other health care providers. PHI will not be used for any other purpose, including marketing, without your consent.
How do we collect your Personal Information?
We collect most of this Personal Information directly from you. For example, when we speak to you by phone, text message, and e-mail. Additionally, we will collect information from you when you visit our Website and fill out forms, wear one of our Devices, or purchase our Services.
We may also collect Personal Information in the following ways:
- From your mobile device or smart watch.
- From third-party apps you choose to connect your mobile device to, such as Apple Health or Google Fit.
- When You Use A Premium Feature. When you choose to participate in a premium service, we collect additional information from you related to those services. Some premium features are paid services.
- When you make payments through the Platform. Miga and/or it’s third-party payment processor collect credit and debit card numbers for payment purposes only. We use a Payment Card Industry (PCI) compliant vendor to collect payment information.
- When You Contact Us. When you contact Miga directly, such as when you contact our Customer Support team, we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.
We will also collect information automatically as you navigate through our Platform. We use the following technologies to automatically collect data:
- Meta Pixel (Facebook and Instagram). We use Meta Pixel, a web analytics and advertising service provided by Meta Platforms, Inc. (“Meta”) on our Platform. With its help, we and our customers can keep track of what users do after they see or click on a Facebook or Instagram advertisement, keep track of users who access our Platform or advertisements from different devices, and better provide advertisements to our target audiences. The data from Meta Pixel is also saved and processed by Meta. Meta can connect this data with your Facebook or Instagram account and use it for its own and others’ advertising purposes, in accordance with Meta’s Data Policy which can be found at https://www.facebook.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Meta Pixel https://www.facebook.com/settings/?tab=ads#_=_.
- Google Ads (AdWords). Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout- for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.
- Other third party tools. We use other third party tools which allow us to track the performance of our Platform. These tools provide us with information about errors, app and website performance, and other technical details we may use to improve our Platform and/or the Services. For more information related to these third-party analytics providers please review How do we collect your Personal Information?.
How do we use your Personal Information?
We may use your Personal Information for the following purposes:
- Operate, maintain, supervise, administer, and enhance our Platform or the Services, including monitoring and analyzing the effectiveness of content on the Platform, aggregate site usage data, and other usage of the Platform and/or the Services such as assisting you in completing the registration process.
- Provide our Products and Services to you, in a custom and user-friendly way.
- Provide you with information, Products, or Services that you request from us or that may be of interest to you.
- Promote and market our Platform and/or the Services to you. For example, we may use your Personal Information, such as your e-mail address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving these e-mails at any time as described below.
- To provide you notices or about your account.
- Contact you in response to a request.
- To notify you about changes to our Platform and/or the Services or any Products we offer or provide through them.
- Fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Anonymize and aggregate information for analytics and reporting.
- To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
- Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform and the safety of others.
- To administer surveys and questionnaires.
- To provide you information about goods and services that may be of interest to you, including through newsletters.
- Any other purpose with your consent.
How do we share your Personal Information?
We may share Personal Information with third parties in certain circumstances or for certain purposes, including:
- Our business purposes. We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
- Your healthcare providers or family. With your consent, we may share your information, including information collected from your use of our Platform, with your health care providers and/or family members (e.g., immediate family or friends) that you designate to receive your information.
- With your consent. We may share your Personal Information if you request or direct us to do so.
- Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
- Business Transfer. We may share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
- De-identified information. We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes.
- To improve our Platform. We may use your Personal Information for internal testing, research, analysis, and product development, including to develop and improve our website/application, and to develop, improve, or demonstrate our products and services.
- To market our products and services. We may share your Personal Information with affiliates and third parties to market our products and services.
- Third Party Analytics. We use Google Analytics and Mixpanel to understand and evaluate how visitors interact with our Platform and/or the Services. These tools help us improve our Platform and/or the Services, performance, and your experience.
Your choices about how we share your Personal Information.
Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies. Please see below for more information.
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera Mobile
For other browsers, please consult the documentation that your browser manufacturer provides.
If you do not wish to have your e-mail address used by Miga to promote our own Products and Services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to Miga as a result of a product purchase, or your use of our Platform and/or the Services. You may have other options with respect to marketing and communication preferences through our Platform.
How do I access and correct my Personal Information?
You can review and change your Personal Information by logging into our Services and visiting either the "About You" or "Health Details" sections of our Platform. You may also contact us using the information at the bottom of the page to inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Who may use the Services?
Miga operates subject to state and federal regulations, and the Platform and/or the Services may not be available in your state. You represent that you are not a person barred from enrolling for or receiving the Services under the laws of the United States or other applicable jurisdictions in which you may be located. Access to and use of the Platform and/or the Services is limited exclusively to users located in states within the United States where the Platform and/or the Services is available. The Platform and/or the Services are not available to users located outside the United States. Accessing the Platform and/or obtaining the Services from jurisdictions where content is illegal, or where we do not offer the Platform and/or the Services, is prohibited.
Miga understands the importance of protecting children’s privacy in the interactive online world. Our Platform is not designed for, or intentionally targeted at, children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any Personal Information the Platform, and if we learn that we have collected or received Personal Information from a child under 13, we will delete that information. If you are the parent or guardian of a child under 13 years of age whom you believe might have provided us with their Personal Information, you may contact us using the information at the bottom of the page to request the Personal Information be deleted.
We do not knowingly collect or sell Personal Information from children under the age of 18. If you are under the age of 18, do not use or provide any information on or to the Platform or through any of its features. If we learn we have collected or received Personal Information from a child under the age of 18 regardless of any parental consent, we will delete it. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided use with their Personal Information, you may contact us using the information at the bottom of the page to request the Personal Information be deleted.
Does Miga respond to Do Not Track signals?
Some web browsers have a "Do Not Track" feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Platform is set up to respond to those signals.
We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through the Internet. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential.
The sharing and disclosing of information via the internet is not completely secure. We strive to use best practices and industry standard security measures and tools to protect your data. However, we cannot guarantee the security of Personal Information transmitted to, on, or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Platform, in your operating system, or mobile device.
California’s Shine the Light Law.
California Civil Code Section 1798.83 (California’s "Shine the Light" law) permits users of our Platform and/or the Services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please contact us using the information below.
Enduring Management Services, LLC 548 Market St PMB 50727, San Francisco, CA 94104-5401 firstname.lastname@example.org (415) 851-3224