Join Privacy Policy

Table of contents:

• Introduction
• Scope
• Data Controller and Processor Roles
• Information We Collect
• a. Information You Provide
• b. Information Collected Automatically
• Use of Your Information
• Children's Privacy
• Legal Basis for Processing
• Sharing of Your Information
• Google Analytics
• Retention
• Security
• Cross-border transfers
• Your Rights
• Brazil (LGPD)
• EEA - European Economic Area (GDPR)
• United States
• Other Regions
• Privacy Certification
• Updates to This Privacy Policy
• Contact Us

Introduction

Welcome to Join! We understand the importance of privacy and are committed to protecting your personal information. This Privacy Policy describes how Allm Inc. ("we," "us," or "our") collects, uses, maintains, protects and discloses your personal information when you use our mobile application and web browser platform (the "Service").

Scope

This Privacy Policy applies to all users of the Service, encompassing doctors and other healthcare professionals (collectively, "Users").

Please note: This Privacy Policy does not apply to any of the personal information about patients that we process on behalf of Users through their use of our Service. Any questions or requests relating to such information should be directed to Users or organizations to which the Users belong.

Data Controller and Processor Roles

We act as the data controller for the personal information you directly provide through the Service. This means we determine the purposes and methods for processing your information. We may use third-party service providers to process your information on our behalf. These service providers function as data processors, and we take measures to ensure they process your information in accordance with this Privacy Policy and applicable law.

We also act as a data processor when processing patient health information, which means we act under the instructions of the data controllers. In this case, the data controllers are the Users (or organizations you are affiliated with or employed by). They maintain overall responsibility for creating and storing information about patients and their health, such as in a patient record.

Information We Collect

We collect two categories of information through the Service:

a. Information You Provide

Registration Information: During Service registration, we collect information such as your name, email address, and telephone number.

Patient Medical Information: You may upload and share patient medical information through the Service, including DICOM images, EEG (Electro Encephalo Graphic) recordings, and other medical information such as patient symptoms and doctor's diagnosis.

Please note: You are responsible for obtaining all necessary patient consent before uploading or sharing any patient medical information.

b. Information Collected Automatically

Device Information: We collect information concerning the device you use to access the Service, such as device type, operating system, IP address, and browser type.

Usage Data: We collect information regarding how you use the Service, such as the features you access, the duration and time of your use, and the content you share.

Cookies: We use cookies and similar tracking technologies to collect information about how you use our Service and to improve your experience. For more information and instructions on how to disable cookies and stop tracking technologies, please see our Cookie Policy. Please note: Disabling cookies may result in the Service not working properly.

Use of Your Information

We use the information we collect for the following purposes:

• To provide and operate the Service effectively.
• To process your registration and manage your account efficiently.
• To facilitate secure communication between Users regarding patient care (limited to patient medical information uploaded with verifiable patient consent).
• To continually improve the Service and develop new features.
• To comply with legal and regulatory requirements, particularly those regarding patient privacy (e.g., HIPAA in the US).
• To send you Service-related information, including updates and necessary announcements.
• To provide customer support.
• To analyze how the Service is used (usage data) to improve user experience and Service functionality.

Children's Privacy

We are committed to protecting the privacy of children. Our Service is not directed at children and we do not knowingly collect personal information from children. If you are a parent or guardian and you believe your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children, we will take steps to delete that information.

Legal Basis for Processing

The legal basis for our processing of your personal information will depend on the specific information and how it is used. The legal bases we rely on include:

• Contract: In certain instances, we need to process your information to fulfill our contractual obligations to you, such as providing you with access to the Service.
• Consent: In certain instances, we will request your consent to process your information for a specific purpose, such as sending you marketing communications.
• Legal Obligations: We may also need to process your information to comply with legal and regulatory obligations, particularly regarding patient medical information.
• Legitimate Interests: In certain instances, we may process your information based on our legitimate interests, such as improving the Service, providing support, or undertaking data analytics to enhance Service security.

Sharing of Your Information

We may share your information with:

• Other Users of the Service, such as when you participate in group chats or share patients' medical images.
• Third-party service providers who help us operate our Service, such as hosting providers and analytics providers.
• Our affiliates for operational purposes.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to better understand how our Users interact with the Service. Google Analytics employs cookies and similar technologies to collect and analyze information about Users activity. This helps us improve the functionality and performance of the Service, as well as enhance the overall user experience. For more detail on how Google collects and processes information, please refer to the Google Privacy Policy.

Retention

We store your information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law (e.g., legal or regulatory requirements for patient medical information).

Security

We are committed to ensuring the security of your personal information. As part of our commitment, our company has obtained ISO/IEC 27001 certification for our Information Security Management System (ISMS). This certification demonstrates our adherence to international standards for managing and protecting information.

Cross-border transfers

Your information is primarily stored locally on our servers. However, your information may be transferred to, stored at, or accessed from countries outside your country of residence. These countries may have different data protection laws than your country of residence. We take steps to ensure that your information is transferred in accordance with applicable law and adequately protected. This includes entering into standard contractual clauses with service providers located in countries outside your country of residence.

Your Rights

Depending on your location, you may possess certain rights with respect to your personal information. These rights may include:

Brazil (LGPD)

Your Rights Under LGPD (Lei Geral de Proteção de Dados Pessoais - Law No. 13,709/2018):

• Access: You have the right to request a copy of the personal information we hold about you.
• Correction: You have the right to request the correction of any inaccurate or outdated personal information.
• Deletion: You have the right to request the deletion of your personal information, subject to certain exceptions.
• Data Portability: You have the right to request the transfer of your personal information to another service provider.
• Information about Data Sharing: You have the right to be informed about the entities with which we have shared your personal information.
• Withdrawal of Consent: Where processing is based on consent, you have the right to withdraw your consent at any time.
• Complaint: You have the right to lodge a complaint with the National Data Protection Authority (ANPD).

To exercise these rights, please contact our Data Protection Officer at "Contact Us" below.

EEA - European Economic Area (GDPR)

Your Rights Under GDPR (General Data Protection Regulation - Regulation (EU) 2016/679):

• Access: You have the right to request a copy of the personal information we hold about you.
• Rectification: You have the right to request the correction of any inaccurate or incomplete personal information.
• Erasure (Right to be Forgotten): You have the right to request the deletion of your personal information, subject to certain conditions.
• Data Portability: You have the right to request the transfer of your personal information to another data controller.
• Restriction of Processing: You have the right to request the restriction of processing of your personal information under certain circumstances.
• Objection: You have the right to object to the processing of your personal information for direct marketing purposes or on grounds relating to your particular situation.
• Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe that our processing of your personal information infringes GDPR.

To exercise these rights, please contact our Data Protection Officer at "Contact Us" below.

United States

Depending on your state, you may have certain rights regarding your personal information. If you are a California resident, for example, you have the following rights granted by the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: You have the right to know what personal information we collect about you, how we use it, and who we share it with.
• Right to Access: You have the right to access your personal information and obtain a copy of it.
• Right to Correct: You have the right to correct inaccurate personal information about you.
• Right to Delete: You have the right to request that we delete your personal information.
• Right to Opt-Out of Sale or Share: You have the right to opt-out of the sale or share of your personal information.
• Right to Limit Use: You have the right to request that we limit the use of your sensitive personal information.

The rights described above may also be available to residents of other states. Please contact us for more information about your specific rights.

Other Regions

If you live in a country or region other than those listed above, please contact us for your privacy rights granted under the applicable laws.

Privacy Certification

We are certified under the Privacy Mark System, a Japanese privacy certification program. The Privacy Mark is a symbol of our commitment to protecting your personal information. You can learn more about the Privacy Mark at https://english.jipdec.or.jp/activities/pmark.html.

Updates to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. When we make changes, we will update the "Last Updated" date at the beginning of this policy. Please review this policy periodically to stay informed about how we protect your personal information.

Contact Us

For any questions, concerns, complaints or to exercise your rights under the applicable privacy laws, please contact our Data Protection Officer (DPO) or HIPAA Privacy Officer at: privacy@allm.jp or by mail to Allm Inc. Shibuya Mark City West 16F, 1-12-1 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan.

[Last updated] This Privacy Policy was last updated on January 31, 2025.