QMENTA Imaging SL with offices at C/ Roger de Llúria 46, Pral. 1ª, 08009 Barcelona, Spain, and Mint Labs, Inc. a Delaware corporation, with offices at 75 State Street, Suite 100, 02109 Boston, MA, United States, trading as QMENTA and its subsidiaries (“QMENTA”, “We”, “Us”, “Our”) understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of Customers and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Notice carefully and ensure that you understand it. We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels (including our website), through written correspondence including e-mail is only used for the purposes set out in this Privacy Notice.

You will be required to read and accept this Privacy Notice when signing up for an Account. If you do not accept and agree with this Privacy Notice, you must stop using Our Services immediately.

1. Definitions and Interpretation

In this Notice, the following terms shall have the following meanings:  

2. Information About Us

Our registration number with the Spanish Data Protection Agency as a data controller is O00007128e2100004296.

1. Our Data Protection Officer is Scott Simpson and can be contacted by email at dpo@qmenta.com.

3. What Does This Notice Cover?

This Privacy Notice applies only to our use of data gathered by Us or uploaded onto our platform in your use of the Services.

4. Your Rights

As a data subject, you have the following rights under the Privacy Legislation, which this Notice and Our use of Personal Data have been designed to uphold:

1. 1. The right to be informed about Our collection and use of Personal Data;

   2. The right of access to the Personal Data We hold about you or your employees (see section 11);

   3. The right to rectification if any personal data We hold about you or your employees is inaccurate or incomplete (please contact Us using the details in section 13);

   4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you or your employees (We only hold personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13). Please note that deletion of certain personal data may prevent the Services from functioning;

   5. The right to restrict (i.e. prevent) the processing of personal data;

   6. The right to data portability (obtaining a copy of personal data to re-use with another service or organization);

   7. The right to object to Us using personal data for particular purposes; and

   8. Rights with respect to automated decision-making and profiling.

2. If you have any cause for complaint about Our use of personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the Spanish Data Protection Agency, the AEPD using any of the below contact methods:

Telephone: +34 91 266 35 17

Website: https://www.aepd.es/es

Post: C/Jorge Juan, 6, 28001 Madrid, Spain. If you live or work outside Spain or you have a complaint concerning our activities outside Spain, you may prefer to lodge a complaint with a different supervisory authority.

5. What Data Do We Collect?

As the Data Controller, we may collect some or all of the following personal and non-personal data:

1. name;

2. business/company name, institution;

3. job title;

4. profession;

5. contact information such as email addresses and telephone numbers;

6. IP address;

7. web browser type and version;

8. operating system;

9. a list of URLs starting with a referring site, your activity on Our Services;

As the Data Processor we may collect some or all of the following personal and non-personal data:

10. medical data/files/images, metadata, and derived data

11. Customer survey feedback

6. How Do We Use Your Data?

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Privacy Legislation at all times. For more details on security see section 7, below.

1. Our use of personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of personal data (e.g. by subscribing to emails or for delivery of the Services), or because it is in Our legitimate interests. Specifically, We may use personal data for the following purposes:

   1. Providing and managing your Account;

   2. Providing and managing your access to the Services;

   3. Personalizing and tailoring your experience in the Services;

   4. Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);

   5. Personalizing and tailoring Our products and services for you;

   6. Replying to emails from you;

   7. Supplying you with emails that you have opted into (you may unsubscribe or opt out at any time by clicking on the unsubscribe link

   8. Market research; Customer feedback surveys where we may use the anonymised information supplied for marketing purposes;

   9. Analyzing your use of Our Services and gathering feedback to enable Us to continually improve Our Services and your user experience;

2. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, and post with information, news, and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Privacy Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003. 

3. For the avoidance of doubt by accepting the terms of this Privacy Notice, you consent to us retaining certain data post termination of the Agreement for marketing purposes in terms of section 6.3 and for reinstating a Customer Account/ Customer Accounts in the event post termination the you decide to enter into a new agreement for the Services, for further information on the data that is retained post termination see section 6.6 below.

4. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it; however, this may adversely affect the delivery, use, and function of the Services.

5. We ensure that the medical data is automatically de-identified/anonymized at the client site or upon uploading to the platform. It is encrypted at transit and at rest.

6. We do not keep personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

 

7. How and Where Do We Store Your Data?

We only keep personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

1. Some or all of your data may be stored or transferred outside of the EEA. You are deemed to accept and agree to this by using the Services and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the Privacy Legislation. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data.

8. Do We Share Your Data?

We may share your data with other companies for administrative and internal management. This includes Our subsidiaries.

1. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. A list of third parties is available upon request.

2. We may compile statistics about the use of products and services including the Services including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you or your employees [or customers]. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

3. The third party data processors used by Us and listed below are located both inside and outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the Privacy Legislation:

   1. Google Cloud Platform, Amazon Web Services, and HubSpot.

4. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use that data only for the same purposes for which it was originally collected by Us.

1. In the event that any of your data is to be transferred in such a manner, you will be contacted and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.

10. How Can You Control Your Data?

When you submit personal data to us, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

11. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at dpo@qmenta.com  or using the contact details below in section 13. 

12. Our Use of Cookies

See our Cookie Policy for information on how we use Cookies.

13. Contacting Us

If you have any questions about Our Services or this Privacy Notice, please contact Us by email at dpo@qmenta.com. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

14. Changes to Our Privacy Notice

We may change this Privacy Notice from time to time (for example, if the law changes). Any changes will be immediately posted on Our Services and you will be deemed to have accepted the terms of the Privacy Notice on your first use of Our Services following the alterations. We recommend that you check this page regularly to keep up-to-date.

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