PRIVACY POLICY


LAST UPDATED MAY 13, 2021

 

WE RESPECT YOUR PRIVACY. THIS PRIVACY POLICY DESCRIBES HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION. PLEASE READ IT CAREFULLY.

The websites and services provided through the websites (the “Site”) are provided by Mandorla Learn (“We,” “Us” or “Our”). You (“You” or “Your”) have a limited right to access and use the Site for Your noncommercial, personal use and information only.

We may change the Privacy Policy from time to time. Our use of the information described in this Privacy Policy is subject to the Privacy Policy in effect at the time of Our use.

By using the Site, You agree with this Privacy Policy and the way We collect, use, and secure information as described below. IF YOU DO NOT AGREE, YOU ARE NOT AUTHORIZED TO USE THE SITE.

What Information Do We Collect? 

Some areas of the Site are available without opening an account. Other areas of the Site cannot be accessed without registering, which requires you to provide personal information to us. This personal information may include your: 

Information collected automatically may be referred to in this Privacy Policy as “Usage Information.”


Cookies

We use “cookies,” which are small text files stored on Your computer/device (and maintained by Your browser), and often include a randomized unique identifier so that Our Site can ‘recognize’ this cookie again. We primarily use cookies that are considered ‘mandatory’ or ‘technically necessary’ to provide Our Site and its core functionality to You (e.g., cookies that store Your log-in information or remember other settings, so You don’t have to re-enter them each time You return to Our Site), and Google Analytics for audience measurement purposes (as described below). Please note that We do not use, or engage other operational service providers or entities to use on Our behalf, retargeting cookies (e.g., cookies that track You on our Site and across other websites in order to serve You a targeted advertisement) or other cookies that may track Your experience on Our Site in order to build user profiles. Should Our use of cookies change in the future, We will update this Privacy Policy and attempt to notify You appropriately before such use (including obtaining Your consent, as applicable).

Google Analytics Notice. We also use Google Analytics, which uses cookies, to obtain high-level “audience measurement” data such as the referral web domain, type of operating system/browser used, date and time of visit, and other information relating to activities on Our Site to understand its usage better, analyze trends, and optimize the Site experience. To help ensure such data within Google Analytics cannot be linked back to an identifiable user, the last octet of all IP Addresses collected have been anonymized, ‘Sharing With Google,’ ‘Remarketing and Advertising,’ and ‘Demographics and Interests’ features have been disabled, and retention of analytics has been set to 14 months. For more information on Google Analytics, including how to opt-out please click here.

We do not use cookies to retrieve information from Your computer or device for purposes that are unrelated to Our Site or Your interaction with Our Site. You may stop or restrict cookies on Your computer or purge them from Your browser by adjusting Your web browser preferences and You should consult the operating instructions that apply to Your browser for instructions should You wish to do so and in general to determine how best to configure Your browser settings to meet Your requirements. Note that if You “turn off,” purge, or disable cookies, although You may still use Our Site, You may not be able to use all of the features, functions, or services available on Our Site.


How We Use Information

We may use the information described in this Privacy Policy:

We may use Your information to provide the services You request or generate suggested resources for Your use.

We may use information You and other Users provide to Us to understand how our Users individually and/or as a group use the Site.

We may use Your information to help us identify and correct problems with the site, or use feedback You provide to improve the Site.

We may require personal information to confirm You are the user You say You are.

There may be other purposes that are specified when the information is collected.

There may be times when the law permits or requires Us to use information for other purposes, such as to comply with Our legal obligations.


How Can We Share Information?

We will not sell, trade, or rent the information described in this Privacy Policy to anyone, but We may share such information with others, such as Our subsidiaries, affiliates, and service providers as necessary to operate Our business, and as permitted by law.

We may share information about Users of the Site:

We may aggregate Usage Information in a non-identifiable manner and use it for Our business purposes unrelated to Your use of the Site. For example, We may aggregate data for product development and improvement activities and disclose such aggregated data to third parties.

We may also share any information as required by law or by a court order, or to prevent or investigate a crime. Also, We may share any information when We believe, in good faith, that sharing is necessary to protect Your safety or the safety of others, to protect Our rights, to investigate or prevent fraud, or to respond to a government request. We may share information, if necessary, to enforce this Privacy Policy or Terms of Use of the Site. We reserve the right to report to appropriate law enforcement or government agencies activities that We, in good faith, believe to be harmful or unlawful, with or without providing notice to You.

We expect that all collection, use and disclosure of Your information will occur in the United States and will be governed by United States law; however, some information may travel over the Internet outside of the United States. Even if some information does travel outside the United States, You agree that the laws of the United States will apply.


Third-Party Links

The Site may contain links to websites or other content We do not control. These links are for Your convenience only, and We do not endorse or make any promises or guarantees about such other websites. We encourage You to review the privacy policies and terms of use posted on these websites carefully. We are not responsible for the privacy policies or the content of any other websites.


What About Aggregated Data?

We may aggregate (combine) data about visitors to Our Site in a non-identifiable manner and use it for Our business purposes unrelated to Your use of the Site. 


What About Governmental and Legal Disclosures?

Except as described above, We do not disclose the identities of visitors or users of the Site unless legally required to do so, or unless We believe, in good faith, that sharing is necessary:

We will respond to any subpoena received from a government agency (i.e., the Securities and Exchange Commission or law enforcement agencies) without prior notice to You. Unless prohibited by law or by a valid court order, We will attempt to notify You of any subpoena received from any other party (i.e., for civil litigation) which requires Us to disclose Your identity, and will wait ten (10) days, or a lesser amount of time as required by the deadline in the subpoena, before providing the information requested by the subpoena.


What About Other Information and Websites?

Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or along with other tracking technologies to collect information about You when You use Our Site. The information they collect may be associated with Your personal information or they may collect information, including personal information, about Your online activities over time and across different websites and other online services. They may use this information to provide You with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. You should review the privacy policies posted on these websites carefully before providing any information. We are not responsible for the privacy policies or the content of any other websites. If You have any questions about an advertisement or other targeted content, You should contact the responsible provider directly.


Children’s Data

The Site is intended to be used only by individuals over the age of 18. We do not intentionally collect information from children under 13 years old. Parents, please use the “Contact Us” information below to give permission.

If a parent or guardian becomes aware that a child under 13 years old has provided Personal Information to Us without their consent, please contact Us as specified in “Contact Us” below. We will promptly permanently delete any information from children under 13 years of age.


California Do-Not-Track Notice

Many internet browsers have “Do Not Track” features which, when turned on, send a signal (the “DNT signal”) to websites and applications a user visits that indicates the user does not want to be tracked. Because there is not yet a common understanding of how to interpret DNT signals, and there is no common definition of “tracking,” we do not currently respond to DNT signals. You can learn more about Do-Not-Track at https://allaboutdnt.com/.


Your California “Shine the Light” Privacy Rights

Upon Your request, submitted to info@mandorla.org, We will advise You of any categories of personal information that We disclose to third parties, and (to the extent We know) whether those third parties use that information for their direct marketing purposes. If We provide Your personal information to a third party, We do not allow that third party to use that information for marketing their services, unless You have consented to that use.


Updating Your Information

If Your information needs to be updated, corrected, or deleted, please notify Us using the contact information provided below. Your personal information can only be deleted in accordance with Our data retention policy, and as permitted by law. Further, personal information may remain in databases, access logs, backup media, and other records. We cannot update or remove information from records of third parties.


What About International Privacy Laws? 

If you are visiting our websites from outside the United States, please be aware that you are sending information (including personal data) to the United States, where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries.

All data collected by through the Site will be stored exclusively in secure hosting facilities provided by Us or Our service providers. We have data processing agreements in place with Our service providers consistent with applicable privacy and data security laws.

Mandorla and its affiliates are located in, and provide services in, the United States, and are governed by United States law. For visitors from the European Union, countries outside of the EU (such as the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence. The United States has not been issued an adequacy decision finding the data privacy laws to provide an adequate level of protection, and no other basis for transfer exists. Therefore, the collection and transfer of data will occur on one of the following bases, depending on the type of transfer and the surrounding factual situation:


How Secure is the Site?

We recognize that health is a sensitive topic. We protect information about You by using reasonable security measures that help assure that We commit to collect, process and use personal information in accordance with applicable laws, including HIPAA. These security measures include physical security measures, like a locked data center, administrative security measures, like policies and rules about how Our employees use data and who is permitted to handle sensitive data, and technological measures, like encryption. If applicable, no patient information, or PHI, collected by the Site will be stored outside of Our systems that store sensitive data using strict processes and procedures to mitigate unauthorized access and activity, including access security controls. By using several different kinds of security measures, We try to protect information in Our control. However, no security is perfect, and no security system can prevent all security breaches. It is not possible to keep data encrypted when it is in use, and it is not possible to guarantee that any transfer of information over the Internet or electronic data storage is 100% secure. As a result, We cannot guarantee the absolute security of Your information. While We have implemented security measures, You transmit information, including Your health information, to Us at Your own risk. Carefully consider the type of information You wish to provide to the Site. If You are accessing the Site as a member of a health plan with which We are associated, the Notice of Privacy Practices applies to certain information shared through the Site.


How Can You Contact Us?

We welcome Your comments regarding this Privacy Policy. If You believe that We have not adhered to this Privacy Policy, please contact Us at:

Ascension Health Alliance d/b/a Ascension
Attn: Privacy Officer
4600 Edmundson Road
St. Louis, MO 63134

We will use commercially reasonable efforts to promptly respond to Your inquiry, and if necessary determine and remedy any problem.


Can I Get a Copy of My Information?

You may write to Us at the contact address above to request a copy of the information You have submitted or We have collected about You through the Site. If We are able to collect and provide the information, We will do so. In some cases, We may not be able to collect and provide the information because of the way the data is used and stored.