MPI-GEN 2 LLC. Last Modified: 2018-09-24

MPI-GEN 2 LLC. (“MPI-2,” “we,” or “us”) is committed to protecting your privacy. This Privacy Policy governs your use of all software applications created or used by MPI-2 (each, an “Application”) to enable the delivery and operation of the MPI-2 Stuttering Treatment Program.

1. User Consent. By using our Application, you are consenting to our processing of your Personal Data, De-identified Data, and Anonymous Data as set forth in this Privacy Policy now and as may be amended by us from time to time. Processing means using data collected on an electronic device or using or handling information in any way, including but not limited to, collecting, storing, deleting, using, combining, enhancing, enriching and disclosing information. “Personal Data” means data that allow someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that are not associated with or linked to your Personal Data and cannot be used to identify or contact you as described above. Anonymous Data do not, by themselves, permit the identification of individual persons. “De-identified Data” means data that include or encompass genetic data and cannot be completely anonymous.

2. Types of Data We Collect. We collect Personal Data, Anonymous Data, and De-identified data.

3. Use of Your Personal Data

  • a. General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. Personal Data are never sold nor shared with 3rd parties or used for advertising purposes. Ways we use your Personal Data include, but is not limited to:
    • i. facilitate the creation of and secure your Account on our network;
    • ii. identify you as a user in our system;
    • iii. improve the quality of experience when you use our Applications;
    • iv. send you a welcome email to verify ownership of the email address provided when your Account was created;
    • v. send you a welcome email to verify ownership of the email address provided when your Account was created;
    • vi. send you administrative email notifications, such as security or support and maintenance advisories;
    • vii. send newsletters, surveys, offers, and other promotional materials related to our Applications and for other marketing purposes of MPI-2.
  • b. Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Applications. MPI-2 reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties, including but not limited to our research partners, in its sole discretion.

4. Children and Data Collection. We do not use the Applications to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at support@MPI-2.com. We will delete such information from our files and databases within a reasonable amount of time.

5. A Note to Users Outside of the United States. Your Personal Data may be processed in the country in which they were collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.

6. Each Application obtains information that you provide when you download and register the Application. You may not be able to use some of the features offered by the Applications unless you register with us. When you register with us and/or use an Application, you generally provide:

  • i. your name, email address, and other registration information;
  • ii. your age and sex;
  • iii. information you provide us when you contact us for help; and
  • iv. information that is entered into our system when you use the Applications, such as your speech rate data (“User Provided Data”). We may also use the information that you provide to us to contact you from time to time to provide you with important information, required notices, and marketing promotions. Important information can range from changes in our terms of service to changes that may affect your data. Users can opt-out of marketing promotions.

7. Automatically Collected Data. In addition, the Application may collect certain information automatically, such as the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application. The Application may also collect precise information about the location of your mobile device. We may also use Cookies and navigational data like Uniform Resource Locators (“URL(s)”) to gather information regarding the date and time of your usage. “Cookies” are small pieces of information that a website sends to your smartphone while you are viewing a website. We may use both session Cookies (which expire once you close your browser) and persistent Cookies (which stay on your smart phone until you delete them) to provide you with the product features and to enable us to collect certain data. If you choose to disable Cookies, our Applications may not work properly. Like most companies, we automatically gather the information described above (“Automatically Collected Data”) and store it in log files each time you use the Applications.

8. Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that provide our Applications by way of a co-branded or private-labeled website or companies that advertise their products and/or services through our Applications. We may add this information to the information we have already collected from you.

9. Information Collected from Social Networking Sites. Our Applications may collect Personal and/or Anonymous Data about you from one or more social networking sites (“SNS”), in accordance with the terms of use and privacy policy of the third-party provider of such SNS, if you log on with your login credentials from the SNS. We may add this information to the information we have already collected from you.

10. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

  • a. Third Party Service Providers. We may share your Personal Data with third party service providers who work on our behalf. These third-party service providers are required not to use your Personal Data other than to provide the services requested by MPI-2.
  • b. Affiliates and Acquisitions. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy. In the unlikely event of an insolvency, bankruptcy or receivership, your Personal Data may also be transferred as a business asset, during which the Privacy Policy will still apply.
  • c. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), MPI-2 may disclose Personal Data if it believes in good faith that such disclosure is necessary
    • i. in connection with any legal investigation;
    • ii. to comply with relevant laws or to respond to subpoenas or warrants served on MPI-2;
    • iii. to protect or defend the rights or property of MPI-2 or users of the Services; and/or
    • iv. to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or any applicable Terms of Use. Users will be notified when MPI-2 is legally able to.

11. Third Party Data Collection

  • a. Automatic Data Collection and Advertising. We may work with analytics companies to help us understand how the Applications are being used, such as the frequency and duration of usage. These third parties may also obtain information about other applications you have downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., you zip code), and other non-precise location information in order to help analyze the usage and performance of the Applications. If you would like to opt-out from third party use of this type of information, you can stop all collection of information by an Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
  • b. Third Party Websites. When you click on a link to any other website or location, you will leave our Application and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

12. Data Retention Policy; Your Choices Regarding Your Personal Data. We will retain User Provided Data for as long as you use the Applications and for a reasonable time thereafter. If you would like us to delete User Provided Data, please contact us at support@MPI-2.com and we will respond within a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Applications to function properly, and we may be required to retain certain information by law.

  • a. Choices. We offer you choices regarding the collection, use, and sharing of your Personal Data.
    • i. We will periodically send you free newsletters and emails that directly promote the use of our Applications. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Unsubscribe instructions will be included in every email.
    • ii. Despite your indicated email preferences, we may send you service related communication, including notices of any updates to our Privacy Policy.
  • b. Changes to Personal Data. You may request deletion of your Personal Data by us by sending an email to the email address set forth above, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives and backups. We may retain your information for fraud prevention or similar purposes.

13. Security of Your Personal Data. MPI-2 is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. For example, we limit access to your Personal Data to employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information that we process and maintain, no security system can prevent all potential security breaches. Therefore, while MPI-2 uses reasonable efforts to protect your Personal Data, MPI-2 cannot guarantee its absolute security.

14. Contact Information. MPI-2 welcomes your comments or questions regarding this Privacy Policy. Please email us at support@MPI-2.com or contact us at the following address: MPI-GEN 2 LLC., 202 N 9th Street, Ste 201, Boise, ID 83702

15. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our Site and/or deploying an alert within our Applications. Any changes to this Privacy Policy will be effective ten (10) calendar days after we post the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, changes will nonetheless be effective. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Applications, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. Please consult our Site regularly for any changes to this Privacy Policy.