Last Updated: 11/7/2023
This Privacy Notice explains how May Health US Inc. (“May Health”, “we”, “us” or “our”) collects, uses, shares, and otherwise processes personal information in connection with our websites, including www.mayhealth.com and other websites we own and operate that link to this Privacy Notice (the “Sites”), your communication with us about our products, services, and status on clinical studies or your interest in participating in such studies, and when you otherwise provide personal information to May Health (collectively, the “Services”). It does not address our privacy practices relating to May Health job applicants, employees or other personnel.
1. HOW WE COLLECT AND USE PERSONAL INFORMATION
We may collect the following personal information submitted to us by individuals through the Services:
- Contact Information, including first and last name, email address, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction and to communicate with you directly.
- Account Information, including first and last name, company name, business email address, user ID and password, and any other information you provide to us. We use this information to administer your account, provide you with the relevant Service and information, communicate with you regarding your account and your use of the Services, and for customer support purposes.
- Inquiry and Communications Information, including information provided in custom messages sent through forms, to one of our email addresses, or via phone. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
- Newsletter and Marketing Emails Information, including email address and applicable interests and communication preferences. We use this information to provide you with our newsletter or manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
- Demographic information, such as your age. We use this information to assess your eligibility for clinical research studies.
- Health information, such as your BMI, interest in immediate fertility, and previous fertility treatments. This information may be collected through questionnaires or by other means. We use this information to assess your eligibility for clinical research studies.
Personal Information Automatically Collected
We, and our third-party partners, automatically collect information you provide to us and information about how you access and use the Services when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:
- Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
- Information about the way you access and use our services, for example, the site from which you came and the site to which you are going when you leave our services, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, installations, and other usage behavior and actions you take on the Services.
- Information about how you use the Services, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, or search behavior.
- Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address.
- Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.
All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Services, advertising, communications, and customer service. We may also use this information the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it. You can also change your cookie preferences through our cookie banner or by clicking on the cookie widget on the May Health Website.
In addition to the above, we may use this information to:
- To provide you with products or services that you request or in which you express interest;
- To communicate with you, including via email, text message, social media and/or phone calls;
- To customize the advertising and content you see;For marketing and advertising purposes, including to market to you or offer you through email, direct mail, phone or text message, information and updates on services we think you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);
- To respond to your emails, comments, or questions;
- To improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
- To test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- For any other lawful purpose, or other purposes that you consent to.
2. SHARING OF YOUR PERSONAL INFORMATION
We may share the personal information we collect with the following recipients:
- Our Affiliates: We may share your personal information with companies that are owned by us, or under common ownership as us so that these companies can perform services (such as data analytics or support) for us, or if certain business units (such as outreach or research) are run by these other entities.
- Data hosting providers: We may share your personal information with companies that host data in the cloud on our behalf.
- Service Providers: In addition to the third parties identified above, we may share your personal information with third-party service providers that perform business or operational services for us or on our behalf, such as infrastructure provisioning, IT services, clinical trial pre-screeners, analytics services, and administrative services.
- Online Advertising Partners: We may also share personal information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, Third-Party Data Collection and Online Advertising below.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement, as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or other agreements or to protect the security or integrity of the May Health services, including to prevent harm or financial loss, or in connection with preventing fraud or illegal activity; (c) to exercise or protect the rights and property of May Health, our users, or others; (d) to protect the health and safety of us or others; or (e) as otherwise required by applicable law.
- With Your Consent or At Your Direction: We may disclose personal information about you to certain other third parties, With third parties or publicly with your consent or direction. For example, with your consent, we may share your demographic and health history information with certain third-party pre-screening services, and our study site partners, in order for them to evaluate your eligibility for the studies and contact you to participate in a study. You may withdraw your consent at any time by contacting us at [email protected].
3. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING
We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites
or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, and similar other information. If permitted by your device settings, they may also collect location data through GPS, Wi-Fi or other methods. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
We may engage in the following:
- Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, LinkedIn, Instagram, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
- Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
- Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at https://optout.aboutads.info/?c=2&lang=EN or https://optout.networkadvertising.org/?c=1or if you are in the European Economic Area, United Kingdom or Switzerland: https://youronlinechoices.eu/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.
4. CONTROL OVER YOUR INFORMATION
You may control your information in the following ways:
- Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
- Sensitive Data: You may withdraw your consent to the processing of sensitive personal information, such as health information, at any time by contacting us at [email protected].
5. DATA RETENTION
Unless a longer period is required by law, we will only hold your personal information on our systems for the following periods:
|Personal information||How long we keep it|
|Comments, inquiries and feedback||We will store this personal information for no longer than necessary for the purposes set out above and in accordance with our legal obligations and legitimate business interests.|
|Contact information||We will store this personal information for no longer than necessary for the purposes set out above and in accordance with our legal obligations and legitimate business interests. Where you have signed up to receive our newsletters and notifications from us, we will store this personal information until you inform us that you no longer wish to receive such communications from us.|
|Communication preferences||Where you have signed up to receive our newsletters and notifications from us, we will store this personal information until you inform us that you no longer wish to receive such communications from us.|
|Demographic information||We do not store this personal information for longer than five (5) years.|
|Health history and information||We do not store this personal information for longer than five (5) years.|
|Information about how you access the Website||We do not store this personal information for longer than 14 months.|
|Log files and information about your device||14 months|
|Analytics information||14 months|
6. CHILDREN’S PERSONAL INFORMATION
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 18. If an individual is under the age of 18, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we have collected has been provided by a child under the age of 18, we will promptly delete that personal information.
7. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
Our Services may include links to third-party websites, plug-ins and applications that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party’s rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any site or service before providing any personal information.
8. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to change this Privacy Notice from time to time at our sole discretion. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice. We will notify you about material changes by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided. It is your responsibility to review this Privacy Notice periodically.
9. CONTACT US
If you have any questions regarding this Privacy Notice, or any of our services, please send an email to [email protected].
10. REGION-SPECIFIC DISCLOSURES
This Privacy Notice is designed to apply to our website visitors, users of our Service, and other companies and users on a global basis. Please refer below for additional disclosures that may be applicable to you:
- Additional Disclosures for California Residents: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
- Additional Disclosures for EU and UK Residents: If you are located in European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein) or United Kingdom, please see the EU and UK Annex to the Privacy Notice for additional European-specific privacy disclosures.
EU AND UK ANNEX TO PRIVACY NOTICE
Who is responsible for your personal information?
May Health is the data controller responsible for the collection and use of your personal information when you use the May Health website, contact us about our products, services and clinical trials, or click on an online advert promoting us or clinical trials of our product. This means that we determine and are responsible for how your personal information is used.
What personal information do we collect and how do we use it?
We collect the following personal information when you use the May Health Website or contact us about our products, services and clinical trials. For further information please see the Personal Information Collected from You and Personal Information Automatically Collected sections of our Privacy Notice.
|Category of personal information||How We Use the personal information||Legal Bases for Processing|
|Personal information you provide to us|
|Contact Information when you make an information request, such as your first name, last name, email address and any other personal information you may disclose in the communications with us.||We use this information to provide you with the information you have specifically requested or to deal with enquiries made by you in relation to the May Health website.||The processing is necessary for our legitimate interests, namely to respond to comments and queries that you send to us via the May Health website.|
|Inquiry and Communication Information||We use this information to respond to the questions or requests that you send to us.||The processing is necessary for our legitimate interests namely to respond to specific information requests made by you via the May Health website.|
|Newsletter and Marketing Emails Information||We use this information to provide notifications and send news alerts to users that have signed up to receive our newsletter or other marketing emails.||The processing is necessary for our legitimate interest, namely ensuring that you receive our newsletter and email alerts (as requested).|
|Demographic information, such as your age.||We use this information to assess your eligibility for clinical research studies.||The processing is necessary for our legitimate interest, namely ensuring that you are connected with relevant clinical research studies.|
The additional condition relied on for the processing of information about your ethnic origin is that the processing is necessary for the purposes of scientific research.
|Health history and information, such as your BMI, interest in immediate fertility, and previous fertility treatments This information may be collected through questionnaires or by other means.||We use this information to assess your eligibility for clinical research studies.||The processing is necessary for our legitimate interest, namely ensuring that you are connected with relevant clinical research studies.|
The additional condition relied on for the processing of information about your health is that the processing is necessary for the purposes of scientific research.
|Personal information we collect automatically when you use the May Health website We also collect the following information about how you use the May Health website through cookies and similar technologies. Cookies are pieces of code that we transfer to your computer's hard disk to store or collect information. To find out more about the cookies we use on the May Health website, please see our cookie consent banner. Other than cookies and similar technologies that are required to operate the May Health website, we will only place cookies on your device or otherwise use these technologies to collect data from your device with your consent. You can also change your cookie preferences through our cookie banner or by clicking on the cookie widget on the May Health website. You also have the ability to opt out by disabling cookies in your browser or mobile settings. These settings will typically be found in the "options" or "preferences" menu of your browser.|
|Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect to the May Health website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the May Health website through the device, your mobile network, your IP address and your device’s telephone number (if it has one). We use third party analytics tools such as Google Analytics to collect this information. You can learn more about Google’s practices here and view its opt-out options here.||We use information about how you use and connect to the May Health website to present the May Health website to you on your device and protect the security and integrity of the May Health website.||Legitimate interests, namely to provide the May Health website to users.|
|We use this information to monitor and improve the May Health website.||We will only process your personal data in this way to the extent that you have given us your consent to do so via our cookie consent banner.|
|Information about how you access and use the May Health website. For example, how frequently you access the May Health website, the time you access the May Health website and how long you use it for, the approximate location that you access May Health from, the site from which you came and the site to which you are going when you leave May Health website, the pages you visit, the links you click, and other actions you take on the May Health website. We use third party analytics tools such as Google Analytics to collect this information. You can learn more about Google’s practices here and view its opt-out options here.||We use information about how you use the May Health website to present the May Health website to you on your device and protect the security and integrity of the May Health website||Legitimate interests, namely to provide the May Health website to users.|
|We use this information to monitor and improve the May Health website and to resolve any issues.||We will only process your personal data in this way to the extent that you have given us your consent to do so via our cookie consent banner.|
|Location information, such as general geographic location that we or our third-party providers may derive from your IP address.||Where relevant and where permitted under applicable law, we use this information to identify potential risk or unlawful behavior including fraud detection, theft prevention, emergency response purposes and legal compliance.||Legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the May Health website and users|
How do we share personal information
We do not normally share your personal information directly with clinical trial providers, unless you have given us permission to do so. If you click on a link in our site locator you will be redirected to the clinical trial provider's website or invited to email them directly.
If you contact us about participating in a clinical trial, we will share your contact details with the clinical trial provide r. We may collect further information such as your location to determine study eligibility (i.e., confirm you will be near a participating study site).
We may, however, share the personal information we collect with the recipients specified in the Sharing of your Personal Information section of our Privacy Notice. The purpose of sharing the personal information we collect with these recipients is also set out in the Sharing of your Personal Information section of our Privacy Notice. These recipients may use your personal information in the following ways:
|Recipients||How these recipients will use your personal information|
|Data hosting providers.||These recipients will use your personal information as processors on our instructions.|
|Other service providers, such as infrastructure provisioning, IT services, clinical trial pre-screeners, analytics services, and administrative services.||The lawful basis we rely on for sharing your personal information with these companies is that it is necessary for our legitimate interests, namely providing the Services.|
|Law enforcement, regulators and other parties for legal reasons.||These recipients will use your personal information in the performance of their regulatory or law enforcement role. The lawful basis we rely on for sharing personal information with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject or is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities.|
|With your consent||The lawful basis we rely on is your consent.|
International Data Transfers
We may transfer, store, or process personal information in a country other than the one in which it was collected.
Where we transfer your personal information to countries outside of the UK or EEA, we ensure that such transfers are subject to appropriate safeguards recognized under applicable data protection laws, including the following:
|Our affiliate||France||This country is considered to provide an adequate level of protection for personal data under the UK Data Protection Act 2018.|
|Our data hosting providers||United States||Standard contractual clauses for transfers of personal data approved by the European Commission and under the UK Data Protection Act 2018. Transfers to recipients certified to the EU-U.S. Data Privacy Framework and (where applicable) the UK extension to the EU-U.S. Data Privacy Framework.|
|Our email service providers||United States|
If you would like to find out more about the transfers we undertake and the safeguards we implement, please contact us as set out in the Contact Us section of the Privacy Notice.
Your Privacy Rights
You have the following rights in relation to your personal information (subject to certain limitations at law):
|Access||The right to access and obtain a copy of personal information about you, as well as information relating to its processing.|
|Rectification||The right to correct or update any personal information about you that is inaccurate or incomplete.|
|Restriction of Processing||The right to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.|
|Erasure||The right to request the deletion or erasure of personal information about you without undue delay if the continued processing of that personal information is not justified.|
|Portability||The right to obtain a copy of personal information about you in an easily accessible format and the right to transmit that personal information to another controller.|
|Objection to Processing||You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.|
|Right to Withdraw Consent||Where we rely on your consent for processing of your personal information, you also have the right to withdraw your consent to such processing, subject to certain limitations at law. Withdrawing consent shall not affect the lawfulness of processing carried out on the basis of that consent before it was withdrawn.|
|Right to Lodge a Complaint||You may also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK, information about how to contact your local data protection authority is available here.|
Please note that if the exercise of these rights limits our ability to process personal information, we may not be able to provide our products or services to you, or otherwise engage with you going forward.
To exercise any of your privacy rights, please contact us as set out in the Contact Us section of the Privacy Notice. We may need to verify your identity before processing your request, which may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the rights described above if we are unable to identify you.