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Privacy Policy

1. About Your Privacy and This Privacy Policy

Your privacy is extremely important to us. BMOXI (“BMOXI,” “we,” “our,” or “us”) is constantly putting thought, effort, tools, resources and procedures in place to protect your privacy. This document is our "Privacy Policy” and contains details on issues related to your privacy when using our Platform. This Privacy Policy applies to visitors to the public websites owned and operated by BMOXI, the registered users of BMOXI’s associated mobile and web applications (collectively with the websites, the "Platform"), and to the Mentors that provide the Mentor Services ("Mentors"). It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Platform.

The Privacy Policy does not apply to the collection and use of certain employment-related information. If you are a current or former BMOXI job applicant, employee, owner, director, officer, or contractor, please contact us at contact@BMOXI.com for the appropriate notice.

The Privacy Policy is part of our Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, "we", "our", "us", "Platform", and "Mentor Services") have the same meaning as in our Terms and Conditions document. When you use our Platform, you accept and agree to both the Terms and Conditions and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Platform immediately or cease to provide or utilize the Mentor Services, as applicable. By accessing and using our Platform or providing the Mentor Services, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them.

By using our Platform, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use the Platform.

 

2. Children Under the Age of 13

The Platform is not intended for children under the age of 13 and children under the age of 13 are not permitted to use the Platform. No one under age 13 may provide any information to or on the Platform. We do not knowingly solicit or collect Personal Data from children under 13. If you are under 13, do not use or provide any information on our Platform or on or through any of its features, use any of the interactive or public comment features of our Platform or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 13, please contact us at contact@BMOXI.com and we will delete that information.

3. Your Rights Regarding Your Personal Data

If you reside in the EU, applicable data protection laws may provide you with certain rights under the GDPR with regards to our processing of your Personal Data.

  • Access and Update. You can review and change your Personal Data by logging into the Platform and visiting your “Profile” page. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

 

  • Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.

 

  • Portability. To the extent the Personal Data you provide BMOXI is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.

 

  • Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.

 

  • Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Platform users.

 

  • Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

 

  • How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under contact information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

See https://www.gdpreu.org/gdpr-requirements/ for more information.

4. Information Collection, Use, and Disclosure

Categories of Information Collected

To let us operate the Platform effectively and to let you use the Platform, including the Mentor Services, we may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

  • Visitor Data: BMOXI collects, uses, and stores data regarding user visits to its Platform ("Visitor Data"), including but not limited to the particular pages visited or viewed by the user, the amount of time the user spent on the Platform, Platform errors experienced by the user, visits to the "FAQ" page, and information about the browser or device used to access the Platform, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages for prospective new customers as well as those who visit pages for prospective Mentors

  • Onboarding Data: In addition to the questionnaire responses provided by users (including Mentors) in the process of initial registration, BMOXI collects, uses, and stores certain additional data from users during the onboarding process ("Onboarding Data"). This data includes but is not limited to the pages viewed by the user, whether the user clicks the "Get Started" link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.

  • Account Registration Data: BMOXI collects, uses, and stores certain information in connection with the account registration process, such as whether users registered using their Facebook, Google or Apple profiles and the like, and whether a user verifies their reported email address or phone number ("Account Registration Data"). 

  • Transaction Data: BMOXI collects, uses, and stores certain information regarding payment for its services by users and related transactions on its Platform, such as whether a user completed payment for BMOXI’s services, signed up for BMOXI’s services using a trial offer, canceled or otherwise ended a trial, or completed a request to receive financial aid for BMOXI’s services ("Transaction Data").

  • Login Data: BMOXI collects, uses, and stores data regarding logins to BMOXI’s Platform by registered users (including Mentors) and activity conducted during that log in such as when a user logs in, the number of messages received or sent through BMOXI’s Platform during that log in, and whether a user has been assigned, started, or completed a Mentoring goal ("Login Data"). Login Data does not include the content of any messages sent or received by users or the content of any Mentoring goals.

  • Mentoring Session Data: BMOXI collects, uses, and stores certain general data regarding user Mentoring sessions such as whether a live session has been scheduled by the user, whether a Mentor or user joins a scheduled session, when a Mentoring session began and ended, and whether a Mentoring session was canceled or re-scheduled.

  • Customer Data: BMOXI collects, uses, and stores certain data from users that have signed up for BMOXI’s services such as a user’s self-reported name or nickname, age, e-mail address, phone number, date of birth, or any other identifier ("Customer Data").

  • Mentor Data: In order to credential, recredential, run checks and pay Mentors, BMOXI collects, uses, and stores certain data from Mentors. This data includes information such as the Mentor’s name, e-mail address, and phone number, address, NPI number (if applicable), CAQH number (if applicable) and education and job history ("Mentor Data").

  • Communications Data: BMOXI collects, uses, and stores communications between users and Mentors on the Platform, and communications between users and BMOXI’s customer service team ("Communications Data").

  • User Contributions Data: You may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information while creating each post (including posting publicly, posting anonymously, and limiting the transmission of posts only to other users in a specific group), please be aware that no security measures are perfect or impenetrable. 

 

Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Protecting this information is important for us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you requested or approved us to do so.

Purposes for Which Information is Used

We may use the information we collect for one or more of the following purposes:

Communication with you

  • To contact you or provide you with information, alerts and suggestions that are related to the Platform.

  • To verify your identity.

  • To complete an activity you requested, such as register for the Platform or obtain more information.

  • To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.

Delivery of services to you

  • To create your account on our Platform and let you log in to your account and use the Platform.

  • To manage your account, provide you with customer support, and ensure you are receiving quality service.

  • For billing and transaction processing purposes.

  • To match users with Mentors and facilitate the Mentor Services.

  • To provide, support, personalize, and develop our Platform and the Mentor Services.

Administration and improvement of services

  • To supervise, administer and monitor the Platform.

  • To measure and improve the quality, effectiveness and delivery of our services.

Customization

  • To personalize the Platform experience and to deliver content and service offerings relevant to individual interests, including targeted offers and ads through our Platform and via email.

Compliance with law

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.

Other uses with consent

  • Any other purpose with your consent.

 

Purposes for Which Information is Disclosed to Third Parties

Information about you may be disclosed to third parties for one or more of the following purposes:

  • For business purposes: Only as necessary for facilitating the Mentor Services, we may share a user’s information with a Mentor and a Mentor’s information with a user. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.

  • With your direction or consent: We may share your information with third parties if you request or direct us to do so.

  • With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group.

  • For advertising: Due to the use of cookies and web beacons, information regarding your activity on our Platform, excluding activity when you are logged in and have started Mentoring, may be disclosed to our advertising partners to optimize marketing. We do not share with any advertising platform private information like member names, email addresses, phone numbers, sessions data, journal entries, messages, worksheets, or any other type of communication you have with your Mentor. 

  • Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.

  • In the context of a transaction: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.

  • For other business reasons: We may share your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Platform and our users.

 

Note that if you make any information publicly available on the Platform, anyone may see and use such information.

5. Opting out of Marketing Communication

You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.

6. Cookies and Web Beacons

Like many websites, we use "cookies" and "web beacons" (also known as pixels) to collect information. A "cookie" is a small data file that is transferred to your computer's hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A "web beacon" is a tiny and sometimes invisible image or embedded code, placed on a Web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.

You can change your browser's settings so it will stop accepting cookies and web beacons or to prompt you before accepting a cookie or web beacon. 

 

Use of Cookies, Web Beacons, and Similar Technology for Analytics

We may use third party cookies or web beacons for the purposes of web analytics, attribution, and error management. Our Platform may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on advertising, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, your response as to the referral source to the Platform, and other data on how and when you use the Platform.

Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain Platform usage.

Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks.

You and others may see certain ads for our services or for the Platform on other websites because we participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites. 

Do Not Track Signals

We currently do not honor do-not-track signals that may be sent by some browsers. California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about your online activities over time. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to the browser DNT signals when you use our services and products or interact with our Platform

 

7. Consent to Processing Data in the United States

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.

If you are a resident of the European Economic Area (“EEA”), in order to provide our Platform services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a profile and click “I agree” to data transfers, irrespective of which country you live in. If you later wish to withdraw your consent, you can request to delete your account.

8. Social and General Information Tools

We use several publicly available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, an Instagram account and others (collectively "Social and General Information Tools"). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.

9. Phishing

Online identity theft and account hacking, including the practice currently known as "phishing", are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

10. Links

The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third-party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services, and we do not have control over their privacy policies and terms of use.

11. Security of Information

Information transmitted over the Internet is not completely secure. We do our best to protect your Personal Data but cannot guarantee the security of your Personal Data transmitted on the Platform. We have implemented industry standards and best practices to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We comply with all applicable federal laws, state laws, and regulations regarding data privacy. However, any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like public message boards. The information you share in public areas may be viewed by any user of the Platform.

12. Service Providers

We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

13. Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Mentors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person.

14. Changes to the Privacy Policy

We may update this Privacy Policy at our sole discretion. The date of the last revision of this policy appears at the end of this page. You are responsible for periodically visiting the Privacy Policy to check for any changes. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.

15. Contacting Us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us at contact@BMOXI.com.

Last Updated and Effective: December 17, 2022.

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