Privacy Policy

Welcome to Mira!

This website: www.miracare.com (the “Website”) and Mira Fertility and Cycle Tracker mobile application that is available at Google Play Store and Apple App Store (the “Mira Application” or simply “Application” or “App”) are provided, owned, and controlled by Quanovate Tech Inc. (“Mira,” “we,” “our,” or “us”).

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE AND MIRA APPLICATION.

In order to use the Website and the Mira Application, you will be requested to review and agree to the following Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Website, Mira Application, or any of their parts.

ABOUT US

Mira
Quanovate Tech Inc.
Company registered under the laws of the state of California, the United States of America.  
Address: 2010 Crow Canyon Pl, STE 100, San Ramon, CA 94583, the United States of America. 
Email: [email protected]

The company’s primary type of business is: “the development and trading of fertility hormone tracking software and hardware solutions.”

The privacy of our website visitors and users of Mira’s Website and Application is critical to us. This document outlines our privacy guidelines and is devoted to informing you (our user) about how we handle your personal information. Once any update of the Privacy Policy is completed, you may be required to check this policy and agree to it once again. 

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE AND APPLICATION.

In the course of this Privacy Policy, “personal data” (“personal data,” “personal information”) means data relating to a natural person who is identified or can be identified directly or indirectly, in particular by reference to the data which is provided to us by you or collected by us from you and therefore come into the possession of the data controller, i.e., Mira. 

We make our best effort to comply with Data Protection Law (“Data Protection Law”), including without limitation applicable European General Data Protection Regulation (“General Data Protection Regulation,” “GDPR” or “EU GDPR”), the Data Protection Act 2018 (“UK GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), other relevant data protection and privacy rules.

Please take time to read this Privacy Policy carefully and make sure you understand it. Please note that your Mira Website and Application use is possible only upon your acceptance of this Privacy Policy. 

The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us. Mira’s Website and Application are not intended for children, and we do not intentionally collect data relating to children. The Mira’s Website and Application may include links to third-party websites, applications, or plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements.

CCPA COMPLIANCE AND PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

Where Mira is processing personal information for “Customer” as defined under the California Consumer Privacy Act of 2018 (Cal Civ. Code §§ 1798.100 – 1798.199) (“CCPA”) and in connection with California consumers, Mira as a “Service Provider” (as defined in CCPA and to the extent it applies) is receiving personal information from Customer to provide the services according to Mira’s terms and conditions and this Privacy Policy, which constitutes a business purpose. Accordingly, Mira shall not sell any such personal information. Mira shall not retain, use or disclose any personal information provided by Customer except as necessary for the specific purpose of provision of Mira’s products and services for Customer according to Mira’s Terms and Conditions and this Privacy Policy, or otherwise as permitted by the CCPA The terms “Personal Information,” “Service Provider,” “Sale,” and “Sell” are as defined in Section 1798.140 of the CCPA. 

Throughout this Privacy Policy, we aim to provide detailed information about what personal data we collect from and about you. ​​The CCPA is intended to give consumers more control over the personal information that businesses collect about them. If you are a California resident, please be informed that under the CCPA, you have the following privacy rights:  

• The right to know about the personal information Mira collects about you and how your personal information is used and shared;
• The right to delete your personal information collected from Mira (exceptions apply);
• The right to opt out of the sale of their personal information;
• The right to non-discrimination for exercising your CCPA rights. This means that Mira cannot deny goods or services, charge you a different price, or provide an additional level or quality of goods or services just because you exercised your rights under the CCPA.  

If you are a California resident and want to exercise any of your data rights under California law, please email us at [email protected]. Please include your full name, email address, and residential address associated with your use of our products or services, along with the rights you would like to exercise so that we can process your request efficiently.

Sale of Personal Information  The CCPA requires companies that “sell” (as defined in the CCPA) your personal information to provide you with notice and an opportunity to opt-out. At Mira, we always take your privacy seriously and avoid “selling” your personal information to third parties. At the same time, we may disclose some of your personal information to our service providers for specific purposes, such as processing your orders and payments, detecting security incidents, and maintaining or servicing your user account at Mira. When such disclosure happens, it shall fall under “Disclosure for a business purpose” in the meaning of CCPA and does not constitute “selling of personal information.” However, because of CCPA’s broad definitions, some of our collaborations with third parties that provide marketing and advertising services to us, including interest-based advertising services (when these third parties place tags, pixels, cookies, beacons, and other similar tracking mechanisms on our website or/and application and collect your online identifiers) may still be considered a “sale” under the CCPA. To opt out of the sale of your information under the CCPA as a California resident, please contact us at [email protected]. In addition, please be informed that we do not share your personal information with third parties for their direct marketing purposes.  

To meet CCPA requirements, we posted the “Do Not Sell My Personal Information” page on the website, which is available via the following link. 

DATA CONTROLLER

Mira acts as a Data Controller concerning the personal data it processes. If you have any questions about how we collect, store, or use your data, please contact us via: [email protected].

INFORMATION WE COLLECT ABOUT YOU

We collect the following personal data from you:  

• NAME 
• EMAIL ADDRESS 
• COMPUTER’S INTERNET PROTOCOL (IP) ADDRESS  
• PHONE ID AND OPERATING SYSTEM
• ADDRESS 
• AGE 
• PHONE NUMBER 
• LOCATION  
• PAYMENT INFORMATION 

For testing purposes, we also collect your woman cycle information. In addition, during our testing, we derive your hormone level information (i.e., fertility hormone data).

In most cases, your data is only captured when you voluntarily communicate it to us. For example, this may be data you enter when registering your user account with us, using the application, or providing your data within the application. In addition, some data is automatically collected when you visit the website or use the application through our IT systems (for example, the data about your internet browser, IP address, operating system, or time of the page request).   

Registration Information: When you register your user account with Mira, we collect the personal information you voluntarily provide us when registering through your access device (i.e., your mobile Android or iOS phone or tablet).

Website and Application usage: When you use Mira Website or Application, Mira may observe your activities, preferences, transactional data (such as your IP address and browser type), and content you have viewed during your use of Mira’s Website or Application.  

Customer Service:  When you purchase a paid service or product offered by Mira, you may be asked for information needed to complete your request and provide related customer service. This information you provide is used, for example, to process your transactions, to create and share aggregate reports about these transactions, and for any risk management functions relating to transactions. If you purchase a subscription service, your transaction may be conducted through our vendors and suppliers. For example, for order payment management, we use Shopify (www.shopify.com).  

Scientific Research and Public Health: In our mission to better understand fertility cycles and help women make powerful and informed choices around their fertility, Mira may use your fertility data in a de-identified or anonymized format in our research to better understand human fertility and improve our products and services. We may also share anonymized data with third-party researchers for public health purposes. 

Technical and Administrative Support: Mira may allow you to provide registration information to us associated with a particular Mira service or product. Mira may also use the information you provide in online registration forms to communicate with you periodically about significant changes to Mira, its products, and services or provide you with relevant support services as you may request. 

Marketing and Promotions: Mira may communicate with you using personal data to provide information we think may interest you, including marketing and promotional messages. You can always opt out of receiving marketing and promotional messages from Mira anytime.  

Personal Data of Children: You have the right to register a user account with us if you are an adult and are over 18. Mira reserves the right to use Mira services contingent on proof of your identity, age, or representative’s consent.

We do not knowingly collect personal data from children under 18 years of age. If you are under 18 years of age, please do not register, download the application, register an account or send us any personal data. If we learn we have collected personal data from a child under 18 and legal representatives of a child provided no consent, we will delete that information as quickly as possible If you believe that a child under 16 may have provided us with personal data, please contact us at [email protected].

How we collect your data: We collect your data in 2 different ways: (i) automated when you visit our website or use our application; (ii) utilizing your voluntary input.

When processing your personal data, we are governed by the following principles:

• Personal data is processed lawfully, fairly, and transparently concerning you.
• Personal data is collected only for specified, explicit, and legitimate purposes.
• Personal data is always adequate, relevant, and limited to what is necessary concerning the purposes for which it is processed. 
• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, regarding the purposes for which it is processed, is erased or rectified without delay.    

PURPOSES OF PROCESSING OF PERSONAL DATA

We process your personal data for intended purposes associated with the following:

• Provision of our services to you.
• Performance of required fertility hormone testing. 
• Reporting results to you.
• Shipment of our products to you.
• Obtaining payment.
• Complete fertility hormone testing and provide you with results that will be as accurate as possible.

We may also use the data we collect from you to fulfill our regulatory and legal obligations in relation to audits and checking to ensure that our testing equipment is working properly and to comply with applicable legal rules.  

We may also process your personal data for several different purposes, such as marketing; Mira’s content, products, and services personalization; scientific research and public health, customer support, etc. For each objective, we must have a legal ground for such processing.  

Generally, such legal grounds are as follows: 

• You have given us explicit consent to processing your personal data.
• Processing is necessary for the performance of a contract to which you are the party or, in cases, you requested us to process yours before entering a contract. 
• Processing is necessary for compliance with our legal obligation to which we are the subject.
• Processing is necessary to protect your vital interests or of another natural person.
• Processing is necessary for the performance of a task carried out in the public interest or the exercise of official authority laid upon us as controllers.  
• Processing is necessary for the legitimate interests pursued by a third party or by us.  

What do we mean by saying “Legitimate Interest” and “Performance of contract”?

Legitimate interest shall mean our interest as a business in conducting and managing. We hereby affirm that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 

Performance of contract means processing your data where it is necessary to perform a contract to which you are a party or to take steps at your request before entering such a contract. 

INFORMATION FOR JOB APPLICANTS

This Section applies to individuals who are considering the possibility to apply for employment with Mira (“Job Applicants”) by submitting to Mira the CV, resume and certain information such as name, email address, links to social media profile (the “Job Applicants Data”). Please note that before submitting any Job Applicants Data you will be required to review and accept Mira Privacy Policy and Terms and Conditions. 

If you are a Job Applicant please be informed that Mira will only use and otherwise process your information for recruiting and job placement purposes including notification of future job opportunities; background screening purposes; onboarding purposes and employment contract preparation and/or other administrative purposes necessary for the commencing employment with the Company (for successful candidates).  

Mira will retain Job Applicants Data only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws. We retain your data to determine your eligibility for a current or future role with us. The retention periods may vary depending on your location and local legal requirements. For example, in the US we retain Job Applicants Data for 2 (two) years. If you have specific questions about how long we retain your data for other jurisdictions please contact us at [email protected].  

Mira maintains reasonable security measures to safeguard Job Applicants Data from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction. Mira also maintains reasonable procedures to help ensure that Job Applicants Data is reliable for its intended use and is accurate, complete and current. 

THIRD-PARTY SERVICE PROVIDERS

To provide our services to you, we collaborate with third-party service providers to help enhance your user experience with us and make our services useful and valuable. For example, to provide you with our products and services along with the best user experience, we are used to collaborating with Shopify (www.shopify.com), Klaviyo (www.klaviyo.com), Attentive(www.attentive.com); Yotpo (www.yotpo.com); Malomo (gomalomo.com); Demio (www.demio.com) and others.

In cases when we disclose any of your personal information to our third-party service providers, we require all such third-party service providers to respect the security of your personal data and treat it in accordance with the law. Additionally, we do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.  

If you are a European Union (EU) resident, please be informed that some of our third parties may be based outside the EU, which means that processing your personal data will involve a transfer of data outside the EU.

Whenever we transfer your personal data out of the EU, we ensure that at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries deemed to provide adequate protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in the EU. 

If there is neither a good decision nor appropriate safeguards implemented, we still may transfer your personal data out of the EU due to the following justifications: 

• We have informed you about the possible risks of transfers of your personal data, and you have explicitly consented to the proposed transfer of your personal data out of the EU.       
• The transfer is necessary for the performance of a contract concluded between you and us or if you requested us to perform pre-contractual measures.
• The transfer is necessary to conclude or perform a contract between another natural or legal person and us for your benefit. 
• The transfer is necessary for important reasons of public interest.
• The transfer is necessary to establish, exercise, or defend legal claims.
• The transfer is necessary to protect your vital interests or the interests of other persons in cases where you are physically or legally incapable of giving consent. 

MIRA COOKIE POLICY

“Cookies” are small pieces of information stored by your browser on your device. Like most websites, we use cookies to keep track of your activity and enhance your experience with the website. We also use cookies to assist us in the fight against fraud or malice. If you wish not to receive cookies, you can disable them on your browser’s toolbar anytime. However, if you do that, you may not be able to access certain areas or features of the website. Additionally, disabling or removing cookies may require you to log on each time you wish to use the Website or Mira services manually.  

Every time you access the website and its content, our respective third parties (or we) create protocol files that may contain your specific access data. Each protocol file usually includes the following information:

• The website from which you access our website.
• Your IP address.
• Date and time of access.
• The HTTP answer code.
• The amount of transmitted data. 
• The browser and operating system used. 

There are several types of cookies we use on the website:   

• Necessary Cookies
  Necessary cookies are essential for the website to function correctly. These cookies ensure the basic functionalities and security features of the website anonymously.

• Functional cookies
  Functional cookies help perform certain functionalities like sharing the website’s content on social media platforms, collecting feedback, and other third-party features.

• Performance cookies
  Performance cookies are used to understand and analyze the website’s key performance indexes, which helps deliver a better user experience for the visitors.

• Analytical cookies
  Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics: the number of visitors, bounce rate, traffic source, etc.

SECURITY

We use reasonable security precautions to protect the security and integrity of your personal data, both during transmission and once we receive it, in accordance with this Privacy Policy and applicable law. We do our best to use all reasonable industry standards to secure your personal data. However, no method of electronic storage or internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the preceding, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

AGE OF CONSENT 

This Website and the Application may only be used by natural persons who can enter into legally binding contracts under the law applicable in their country of residence. By agreeing to this Privacy Policy, you represent that you are of legal age in your state or country of residence Neither the Website nor the application is intended for children, and we do not intentionally collect data relating to children.

YOUR LEGAL RIGHTS

Under the Data Protection Law, you have certain rights concerning the personal information we hold about you. You may exercise these rights anytime by contacting us using the contact details in this Privacy Policy.

• The right to request access to your personal data.  This means that you may ask us to send you a copy of the personal data we hold about you and to check that we are lawfully processing it.
• The right to request correction of personal data. You may request that any incomplete or inaccurate data we hold about you be corrected.
• The right to request the erasure of your personal data. enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your data to comply with any relevant applicable laws Please note that sometimes we may be unable to comply with your request of erasure for specific legal reasons of which you will be notified, if applicable, at the time of your request. 
• The right to object to processing.  You may object to processing your personal data where you know or have grounds to assume that such processing impacts your fundamental rights and freedoms. Also, you have the right to object to the processing at any time when we are processing your personal data for direct marketing purposes. We may demonstrate that we are processing your data due to legitimate grounds overruling your rights and freedoms in certain circumstances. 
• The right to request the restriction of processing of personal data.  You may request us to suspend the processing when you want us to make the processed data accurate, or the processing of data is unlawful, but you do not want us to erase it, or if you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.  
•  The right to request the transfer of your personal data to you or to third parties.  It means that upon your request, we will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format Please note that this right only applies to data that is processed by automated means and only in cases where you provided us with the relevant explicit consent to such processing or processing is used in the course of the performance of a contract. 
• The right to withdraw consent at any time.  You may withdraw your consent to processing your personal data at any time without affecting the lawfulness of processing based on consent before its withdrawal. 

If you wish to exercise any of the rights set out above, please contact us directly via the email specified in this Privacy Policy. 

DATA RETENTION

We will keep your personal data only as long as it is necessary to fulfill the purposes we collected the personal data for (for example, the provision of our services to you via the application), including without limitation the purposes of compliance with any relevant reporting, accounting, or legal requirements.

When determining how long we will keep your personal data with us, we consider the following factors:

• The nature, the sensitivity of personal data, and its amount.
• The potential risk of harm from unauthorized use or disclosure of your personal data.
• The purposes for which we collected your personal data and processed it.
• The applicable legal requirements.

Where we are processing your personal data for marketing purposes, we may contact you to ensure you are pleased to continue receiving our marketing communications. You may require us not to use your personal data for marketing purposes or object to such processing at any time by sending appropriate requests or statements to our email address. We may use and process your personal data for marketing purposes only if you give us your prior consent and explicit desire to receive marketing materials from us.

CHANGES TO PRIVACY POLICY

We reserve the right to change, amend, or modify this Privacy Policy without notice at any time and from time to time, including as needed to comply with the appropriate laws and regulations. Any changes, amendments, or modifications will be posted on the website and/or in the application. The new terms may be displayed on-screen, and you may be required to read and accept them to continue using the Website, our services, or the application. We also may notify you about any changes, amendments, or modifications to this Privacy Policy by email.

REQUEST FOR INFORMATION

Sometimes, we may need to request specific information from you to confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information concerning your request to speed up our response.

TIME LIMIT TO RESPOND

We will do our best to respond to all your legitimate requests within 1 (one) month. However, sometimes it may take us longer than 1 (one) month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

COMPLAINTS

You have the right to complain with a data protection authority, in particular in the state or country of your habitual residence, place of work, or the place of the alleged infringement if you consider that the processing of your personal data infringes the applicable data protection law. 

However, we would appreciate the opportunity to deal with your concerns before sending your complaint to the supervisory authority, so don’t hesitate to contact us within the first instance.

QUESTIONS AND CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or the collection, use, or handling of your personal information, feel free to contact us by sending your request via email: [email protected].