Our privacy commitment: Autoimmune Therapies has never sold your information to someone else for advertising, or made money by showing you other people's ads, and we never will. This has been our approach since we started in 2007.
We took great risks and went to great lengths when the FDA demanded all our Client Records, we refused their requests, destroyed all written tangible records and back ups, keeping only one copy of our client database our laptop and left their jurisdiction in part to avoid having to surrender our client data. We gave them nothing.
We remain committed to just such a policy and if necessary we will destroy all data we hold rather than surrender it to any authority demanding it. There are limits to our durability when it comes to choosing to submit to legal demands and throwing our lives into chaos and “leaving jurisdictions” to avoid having to comply with court orders, but that has been our approach in the past.
The last time I did it it cost me my sanity for the best part of a decade, so I cannot promise would behave in the same way again. Confronted with a choice between jail and freedom, where have to go to jail to protect your privacy may or may not be my choice. I might elect to go that way simply to get a break, but we are a quasi legal enterprise. So if you have read this far understand I don't know how I might behave when confronted with that choice again since the last time my choice cost me everything. Everything.
This policy tells you what information we do collect from you, what we do with it, who can access it, and what you can do about it.
Part I – Information Autoimmune Therapies collects and controls
We only collect the information that we actually need. Some of that is information that you actively give us when you sign up for therapy and we need to retain access to that information in order to advise you properly while your relationship with us continues.
When you visit one of our websites or use our software, we automatically log some basic information like how you got to the site, where you navigated within it, and what features and settings you use. We use this information to improve our websites and services and to drive new product development.
What we do with your information
We use your information to provide the services you've requested, create and maintain your accounts. We also use it to communicate with you about the products you're currently using, your customer support requests, new products you may like or dislike, chances for you to give us feedback, and policy updates.
We analyse the information we collect to understand user needs and to improve our websites and services and how we apply helminthic therapy in your case and for others. We have used this process iteratively to develop our knowledge of helminthic therapy. Simply put in communication with our clients we have used information dervied from their experiences to continuously improve what we do and how we do it to improve outcomes.
We're required to have a legal basis for collecting and processing your information. In most cases, we either have your consent or need the information to provide the service you've requested from us. When that's not the case, we must demonstrate that we have another legal basis, such as our legitimate business interests.
You can decline certain kinds of information use either by not providing the information in the first place or by opting out later. You can also disable cookies to prevent your browser from giving us information, but if you do so, certain website features may not work properly. We completely disable third-party cookies from all Autoimmune Therapies websites and products.
We limit access to your personal information to our employees and contractors who have a legitimate need to use it, and we limit how much of it they can see based on what they need to do.
If we share your information with other parties (like developers, service providers, CRM SaaS providers, Email hosting partners), they must have appropriate security measures and a valid reason for using your information, typically to serve you.
The European Economic Area (EEA) provides certain rights to data subjects (including access, rectification, erasure, restriction of processing, data portability, and the right to object and to complain). Autoimmune Therapies undertakes to provide you the same rights no matter where you choose to live.
We do keep anonymised information about all our clients to track the efficacy of our approach over time, over all response rates, etc., but no personal identifying information is kept.
Part II – General
There are some limitations to the privacy we can promise you. We will disclose personal information if it's necessary to comply with a legal obligation if we have to or if I decide I can no longer bear the price of running from incarceration to make people well and healthy. To prevent fraud, enforce an agreement, or protect our users' safety.
Because your data is stored in so many locations, and not all of it is stored in one location, some is here, some is there, it would be very hard to destroy it if we were confronted with a legal demand to surrender it. At the same time this provides some measure of increased security for you if any of our service providers suffer a data breach as not all of our data is aggregated in one location.
Autoimmune Therapies’s Privacy Commitment
Autoimmune Therapies has worried about customer and user privacy from our first customer and our unfortunate experiences with the FDA only made our paranoia about privacy worse, long before it became fashionable, politically correct, or legally binding to take such a position. We ask for only the least amount of information necessary, gathering only what we believe is essential for doing business, or for the specific transaction at hand.
All computers we use that store data locally run the macos and are kept up to date automatically so that the latest security patches are all applied. Any mobile devices used to access your data are iOS and set to auto wipe if stolen and ten failed attempts to log in are made in succession. The same is true for the computers we use to store your data and to access it. We use bit level encryption of all hard drives used to store your data, including the requirement that besides a username and a password that a hardware token is present when logging into our computers. Without this secure element even physical control of our computers and knowing our usernames and passwords will be insufficient to decrypt or boot our computers.
The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.
Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:
To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
To ask you to participate in surveys, or to solicit feedback on our products and services;
To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
To provide customer support, and to analyse and improve our interactions with customers;
To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Autoimmune Therapies, Autoimmune Therapies’s users, third parties and the public;
To analyse trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
To monitor and improve marketing campaigns and make suggestions relevant to the user.
Legal bases for collecting and using information
Legal processing bases applicable to Autoimmune Therapies: If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of Autoimmune Therapies, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
Withdrawal of consent : Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.
Legitimate interests notice : Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.
Your choice in information use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
Disable cookies : You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information : You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
Who we share your information with
Third-party service providers : We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organisers, web analytics providers and payment processors.
These service providers are authorised to use your personal information only as necessary to provide these services to us.
Your rights with respect to information we hold about you as a controller
If you are in the European Economic Area (EEA), you have the following rights with respect to information that Autoimmune Therapies holds about you. Autoimmune Therapies undertakes to provide you the same rights no matter where you choose to live.
Right to access : You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared
Right to rectification : You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure : You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing on our part to you.
Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
Retention of information
We retain your personal information for as long as it is required for the purposes stated in this
Who we share service data with
Autoimmune Therapies and third party sub-processors : In order to provide services and technical support for our products, the contracting entity within the Autoimmune Therapies engages other group entities and third parties.
Employees and independent contractors : We may provide access to your service data to our employees and individuals who are independent contractors of the Autoimmune Therapies group entities involved in providing the services (collectively our “employees”) so that they can (i) identify, analyse and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Autoimmune Therapies group.
Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information. For example, when you edit a document that you have shared with other persons for collaboration, your name and profile picture will be displayed next to your edits to allow your collaborators to know that you made those edits.
Other cases : Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.
Retention of information
We hold the data in your account as long as you choose to use Autoimmune Therapies Services. Once you terminate your Autoimmune Therapies user account, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.
Data subject requests
If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.
Part III – General
Children’s personal information
Our products and services are not directed to individuals under 18 without the express written permission of their parents or legal guardians. Autoimmune Therapies does not knowingly collect personal information from children who are under 18 years of age without the permission of their parents and their active participation in providing each and every datum of it. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 18 years has provided personal information to us, please write to firstname.lastname@example.org with the details, and we will take the necessary steps to verify that the information is either properly provided or we will delete the information we hold about that child.
How secure is your information
At Autoimmune Therapies, we take data security very seriously. All our data is and information is held on our behalf by Service Providers. Specifically Zoho Corporation and Google, both of whom are compliant with all the governing laws and regulations. You can read those company’s Privacy Policies and Compliance Information at https://www.zoho.com/privacy.html and https://www.google.com/privacy.html.
Data Protection Officer
Being a small company I, Jasper Lawrence, have taken on the role of Privacy Officer and Data Protection Officer and can be contacted at email@example.com or by writing to: Data Protection Officer, 3 Church House, Alexandra Square, Saltash, Cornwall UK PL12 6AN.
Locations and international transfers
We do not share your information with any third party except as described elsewhere in this document specifically and we have only one location at which all our data is stored. Back ups are stored on Google Servers and downloaded from Zoho Servers, encrypted and uploaded to Google Servers. The physical location of Google and Zoho Servers is unknown to us but may include locations in the USA and EU.
External links on our websites
Blogs and forums
We offer publicly accessible blogs and forums on our websites. Please be aware that any information you provide on these blogs and forums may be used to contact you with unsolicited messages by other forum members, and that while we do our utmost to keep these forums completely Private and limited to Clients of Autoimmune Therapies we cannot prevent a Client from sharing information from our Forums or from sharing their log in credentials from unknown third parties. We urge you to be cautious in disclosing personal information in our blogs and forums. Autoimmune Therapies is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with Autoimmune Therapies. To request the removal of your information from our blogs and forums, you can contact us at firstname.lastname@example.org.
Social media widgets
Our websites include social media widgets such as Facebook "like" buttons and Twitter "tweet" buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety and privacy of our users.
We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honour our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Notification of changes