Medicalholodeck Privacy Policy

December 2021

Your privacy is important to Medicalholodeck. This privacy statement explains what personal data Medicalholodeck (“Medicalholodeck”, “us”, “Medicalholodeck’s”) collects from you, when you use Medicalholodeck’s websites that link to this Privacy Policy (each, a “Site”), Medicalholodeck’s products and software applications (each, a “Product”), and Medicalholodeck’s training simulations and other services that Medicalholodeck provides via the Site and Products (collectively, the “Services”) and how Medicalholodeck uses that data.

1. Principles

Medicalholodeck is committed to complying with applicable data protection laws and principles, which means that your personal data will be:

2. Purpose of Data Collection

Medicalholodeck collects personal data to deliver Medicalholodeck’s Site, Products and Services, including providing the training experiences, feedback, performance analyses, and metrics enabled by the Products. Medicalholodeck, with its primary place of business located at Technoparkstr. 1, 8005 Zurich, Switzerland, acts as the data controller for personal data you have provided, and for personal data collected by Medicalholodeck in accordance with the terms of this Privacy Policy.

3. Types of Personal Data

The types of personal data Medicalholodeck obtains throughout your use of Medicalholodeck’s Services and Products is as described herein. Information you voluntarily provide Medicalholodeck collect personal data you voluntarily provide to us in connection with the Site, Products and Services. For example, Medicalholodeck collects the personal data you provide during app download, such as:

This basic information is necessary to complete your user registration. If you decline to provide this information, you may not be able to create an account and use Medicalholodeck’s services. Medicalholodeck reserves the right to confirm the accuracy of registration data using third-party sources, including your sponsoring organization, or other data in the public domain.

4. Information Automatically Collected

Medicalholodeck may automatically collect certain personal data when you use Medicalholodeck’s Site, Products and/or Services.

Log files and identifying data

Like many online service providers, Medicalholodeck may collect certain log file information when you use Medicalholodeck’s Site, Products and/or Services. For example, Medicalholodeck may collect your IP address, as well as information about your device, including the model, platform, locale code and UUID (universally unique identifier). This information can assist us in maintaining and improving Medicalholodeck’s services, including during customer support diagnostics.

Usage and participation data

When you use Medicalholodeck’s Services, Medicalholodeck records your training and test runs, generates performance metrics, and monitors feature usage and participation on Medicalholodeck’s platform. This includes, but is not limited to, page visits, training content viewed, procedure durations, scores, functional assessments and progress snapshots. Medicalholodeck may share this data with the organization that provides access to Medicalholodeck’s Products and Services on your behalf (e.g. your employer) and, if the training procedure you have used and/or participated in has been created by and/or sponsored by one of Medicalholodeck’s partners (a “Sponsoring Partner”), Medicalholodeck may share the results of such training with such partner.

Third party aggregate data

Medicalholodeck and Medicalholodeck’s partners may use digital properties to improve aggregate analytics, such as Azure analytics and Google Analytics.

5. Cookies

If you are using an Medicalholodeck Site, Medicalholodeck may collect certain information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. Medicalholodeck does not collect information using cookies if you are accessing or using Medicalholodeck Products or Services on Windows or Meta Quest. Medicalholodeck may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on Medicalholodeck’s Site, Product(s), and/or Services. Medicalholodeck uses two broad categories of cookies:

COOKIES Medicalholodeck USES:

Essential Cookies

‍ These cookies are essential to provide you with services available through Medicalholodeck’s site and to enable you to use some of its features. For example, they allow you to log in to secure areas of Medicalholodeck’s site and help content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and Medicalholodeck only uses these cookies to provide you with those services.

Functionality Cookies‍

These cookies allow your site to remember choices you make when you use Medicalholodeck’s Site, such as remembering language preferences, remembering your login details and remembering the changes you make to other parts of Medicalholodeck’s Site that you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit Medicalholodeck’s Site.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to Medicalholodeck’s Site and how users use Medicalholodeck’s Site. The information gathered does not identify any individual visitor. It includes the number of visitors to Medicalholodeck’s Site, the websites that referred them to Medicalholodeck’s Site, the pages they visited on Medicalholodeck’s Site, what time of day they visited Medicalholodeck’s Site, whether they have visited Medicalholodeck’s Site before, and other similar information. Medicalholodeck uses the information to help operate Medicalholodeck’s Site more efficiently, to gather broad demographic information and to monitor the level of activity on Medicalholodeck’s Site. Medicalholodeck uses Google Analytics for this purpose. Google Analytics uses its own cookies. These are only used to improve how Medicalholodeck’s Site works. ‍

You can find more information about Google Analytics cookies here.
You can read more about how Google protects your data here. here.
You can prevent the use of Google Analytics relating to your use of Medicalholodeck’s Site by downloading and installing the browser plugin available at this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Disabling Cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept Medicalholodeck’s cookies, you may experience some inconvenience in your use of Medicalholodeck’s Site. For example, Medicalholodeck may not be able to recognize your computer or mobile device and you may need to log in every time you visit Medicalholodeck’s Site.

6. How Medicalholodeck uses Personal Information

Medicalholodeck uses your personal data for the following reasons: To operate effectively as a business and perform essential business operations, including providing and improving Medicalholodeck’s Products.

To deliver communications of personal interest including performance assessments and reports, product and content releases, training prompts and in response to product queries or support requests. To inform Sponsoring Partners of engagement and interactions on branded content hosted on Medicalholodeck’s platform. To enable your participation in an educational course, training, or conference offered by a Sponsoring Partner To track and report your performance on relevant Medicalholodeck training tools to a Sponsoring Partner, including the curriculum owner and residency program director. Medicalholodeck may create anonymous data from personal data Medicalholodeck receives about you and other individuals whose personal data Medicalholodeck collects.

7. Sharing your Personal Data

Medicalholodeck may share your personal data as follows, and as otherwise described herein: Third Parties Who Provide your Access to the Services. Medicalholodeck may share your personal data with the third party or parties that provide access to the Product(s) and Services on your behalf, such as your employer or academic institution. Medicalholodeck’s Third Party Service Providers. Medicalholodeck may share your personal data with Medicalholodeck’s third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their service to us. They are required to follow Medicalholodeck’s express instructions and to comply with appropriate security measures to protect your personal data.

Sponsoring Partners

As described above, Sponsoring Partners may create and/or sponsor the creation of certain curricula, training programs and other training materials (collectively, “Sponsored Programs”), which Medicalholodeck may host and provide via Medicalholodeck’s Products and Services. Medicalholodeck may share the results you obtain from any Sponsored Program with the relevant Sponsoring Partner.

Affiliates

Medicalholodeck may share some or all of your personal data with Medicalholodeck’s affiliates, in which case Medicalholodeck will require Medicalholodeck’s affiliates to comply with this Privacy Policy. In particular, you may let us share personal data with Medicalholodeck’s affiliates where you wish to receive marketing communications from them.

Corporate Restructuring

Medicalholodeck may share personal data when Medicalholodeck does a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of Medicalholodeck’s business or assets. These deals can include any merger, financing, acquisition or bankruptcy transaction or proceeding.

Other Disclosures

Medicalholodeck may share personal data as Medicalholodeck believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce Medicalholodeck’s Privacy Policy; and (d) to protect Medicalholodeck’s rights, privacy, safety, or property, and/or that of you or others.

8. Your Rights

In this section, Medicalholodeck has summarized rights that you may have under data protection laws. The information Medicalholodeck provides in this section is a brief summary. You should still read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under EU data protection law include: Access: You can request more information about the personal data Medicalholodeck holds about you. You can also request a copy of the personal data. Providing the rights and freedoms of others are not affected, Medicalholodeck will supply to you a copy of your personal data, or do one of the following:
- Medicalholodeck may ask you to verify your identity, or ask for more information about your request; or
- Where Medicalholodeck is legally permitted to do so, Medicalholodeck may decline your request, but Medicalholodeck will explain why if Medicalholodeck does so.
Rectification: If you believe that any personal data Medicalholodeck is holding about you is incorrect or incomplete, you can request that Medicalholodeck correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
Objection: You can contact us to let us know that you object to the collection or use of your personal data for certain purposes. Erasure: You can request that Medicalholodeck erase some or all of your personal data from Medicalholodeck’s systems. There are exclusions of the right to erasure. The general exclusions include where processing is necessary, for example: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
Restriction of Processing: You can ask us to restrict further processing of your personal data.
Portability: You have the right to ask for a copy of your personal data in a machine-readable format. You can also request that Medicalholodeck transmit the data to another entity where technically feasible.
Withdrawal of Consent: If Medicalholodeck is processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of Medicalholodeck’s Products. Withdrawal will not affect the lawfulness of processing before the withdrawal.
Right to File Complaint: You have the right to lodge a complaint about Medicalholodeck’s practices with respect to your personal data with the supervisory authority of your country or EU Member State.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Medicalholodeck’s training simulations provide data and feedback to sponsoring partners, which those partners can use as an element of their overall evaluations of proficiency.
To contact us in relation to any of these requests, please use the email address privacy@medicalholodeck.com.

9. Retaining your Personal Data

Medicalholodeck retains personal data for as long as necessary to provide Medicalholodeck’s Products and Services and fulfill the transactions you have requested, or for other essential purposes such as complying with Medicalholodeck’s legal obligations, and enforcing Medicalholodeck’s agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The general rule that establishes a baseline for data retention is the length of time required to store and analyze the data for the purpose it was collected (as described in section 3). Moreover, Medicalholodeck is required to maintain appropriate business records, including records of assessments used for training and compliance.

10. Protecting your Personal Data

Medicalholodeck is committed to protecting the security of your personal data by endeavoring to use reasonable and appropriate technologies and processes to avoid unauthorised access or disclosure. Medicalholodeck utilizes cloud storage services, like Microsoft Azure, for data storage and processing purposes. Medicalholodeck’s storage containers and databases may be located in data centers and systems around the world, including in the US or Europe. Medicalholodeck recommends you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser.

11. Changes to this Privacy Policy and Further Information

Medicalholodeck may revise this Privacy Policy from time to time. The most current version of the policy will govern Medicalholodeck’s use of your information and will always be at https://www.medicalholodeck.com/privacy-data-protection/privacy.html. If Medicalholodeck makes a change to this policy that, in Medicalholodeck’s sole discretion, is material, Medicalholodeck will notify you via application notification or email to the email address associated with your account. By continuing to access or use Medicalholodeck’s services after those changes become effective, you agree to be bound by the revised Privacy Policy. If you would like further information about privacy at Medicalholodeck, please contact us at privacy@medicalholodeck.com.