Last Updated: January 23 2016
MoCA TEST Inc. (“MoCA“) is committed to protecting your privacy.
The term “you” designates any physician, a nurse practitioner, social workers or any other healthcare professional visiting or using our Site or Application.
In that respect, it worth mentioning that this Website and Application are exclusively intended to these persons. Any other person wishing to benefit from or take advantage of MoCA services shall do so with the assistance of a health care professional.
The MoCA tests are screening instruments used to facilitate the assessment of mild cognitive impairment. It is essential that people using the MoCA tests be trained and certified. A clinical assessment is necessary to interpret the results of the MoCA test. MoCA test results can be interpreted only by healthcare professionals with expertise in the cognitive field, including, among others, neurologists, neuropsychologists, occupational therapists and psychiatrists. The test results cannot be the only measure used to diagnose a person’s cognitive abilities. Since other factors may come into play in interpreting the results of this test, results considered “normal” do not necessarily mean there is no cognitive impairment and vice versa. MoCA and its officers, directors, employees, affiliates, successors or assigns and its other representatives may not be held liable for any damage, loss, obligation, claim, cost, fine, penalty, charge, contribution or fee that may result from the administration or interpretation of these tests or from any use or interpretation of the results of these tests that may be made by you or third parties.
What Is Collected, and How Do We Use It
Information Disclosed by You
Although you may browse the public pages of our Web site without registering or providing any Personal Information, certain sections of our Site do include forms on which you may choose to supply personalized information that will enable you to make purchases online or receive individualized services or features that we cannot offer anonymous users, and certain other pages of our Web site can be accessed only by registered users. Similarly, the use of our Application will require that any user create its own Application account. You can always choose not to provide information; however, if you do choose not to provide such information, you may not be able to use the Application, to make purchases or take advantage of certain other features of the foregoing.
In order to access pages requiring registration, you will be required to create a User Account by completing the registration form and creating a User ID and password. If you create a User Account, MoCA collects the following Personal Information: your name and surname, your profession and the institution for which you work (or are affiliated). You will also be required to create a password.
Newsletters and Alerts
Our Web site and Application may offer features that allow you to request and receive newsletters or other subscriptions, as well as electronic alerts or notices about updates to our Web site and other information. When you sign up to receive your newsletters or other forms of communication, we will collect certain Personal Information, which may include, without limitation, your name, e-mail address, and other basic contact information.
If you order products through our Web site or Application, we will collect Personal Information, about you such as your name, e-mail address, shipping and other contact information for the recipient of the item (if different than yours), your account number (if applicable) as well as payment information, such as credit card number, billing address, expiration date, and other billing information.
When purchasing a specific test for your patients, you will also be required to create a profile for each patient. In order to do so and with the prior approval of your patient, which you are required to obtain in accordance with applicable laws, you will be required to provide their name and surname, date of birth, gender, education and address and other geographic information as reasonably required. Once the profile is completed, a reference number will be automatically generated and specifically assigned to each patient. You will be provided with this code, so as to allow you to retrieve your patients’ tests, analyze them, compare them wherever required (and applicable) to previous tests and add them to their medical records.
To improve test administration, interpretation, reliability, and decrease test-retest variability, a comprehensive training program was created for health care professionals to guide them through test administration and scoring, neuro-anatomical correlation, video administration demonstration, test interpretation, training and certification. Should you follow such recommended online training via our Web site, then you will be required to provide us with Personal Information about you, such as your name and surname, profession, email address and other contact information, as well as all answers to the questionnaire.
Surveys and Other Voluntary Demographic Information
In addition to the above information, certain forms on various pages throughout our Site and Application may ask users to voluntarily provide a limited amount of demographic information. MoCA may contact you by e-mail, using the e-mail address or other contact information collected when you filled out one of the forms on our Web site or Application, with the option to participate in consumer research studies. In addition, MoCA may conduct online surveys that ask you for demographic data, such as your zip code, age, or product use.
Providing such demographic information and participating in such surveys or other consumer research are always voluntary. MoCA uses the responses on aggregated de-identified basis to improve the products and services it offers. We do not link your individual responses to your personal information at any time. MoCA uses this information only for internal marketing research to help us better serve our users and customers.
Marketing, Promotional, or Other Transactional Communications
If you have opted-in to receive marketing, promotional, new products, or other informational communications from or on behalf of MoCA, we may use your e-mail address or other contact information you gave us from time to time to contact you to announce new features, products, or services that may be available on our Web site or via our Application, or to send news and information regarding MoCA or its products or services. You can opt out of receiving these promotional communications at any time by following the instructions in the e-mail or other form of communication, which will provide for an unsubscribe mechanism that can be readily performed.
We may also use your e-mail address or other contact information to verify and/or update any information related to services, features, or transactions that you have requested via our Web site or Application, as well as to notify you of new software updates.
Request for Information, Comments and other Inquiries
Change in Ownership or Business Transfers
As we continue to develop our business, we might sell or buy assets.
In such a case, MoCA may disclose Personal Information to its potential successor for the purpose of allowing that potential successor to assess and evaluate the operations of MoCA, the whole after entering into an agreement, pursuant to which such success shall undertake to keep all Personal Information confidential and secure and not to retain any of the information longer than is necessary for the purpose of the assessment or evaluation. Should the parties proceed with the transaction, then databanks containing such Personal Information will be transferred to said successors, the whole in full compliance with applicable law.
Information Collected About You
We collect additional information about how you use and access our Web site and Application.
Statistical and analytical purposes
Such information is collected to analyze trends, administer our Web site and Application, track users’ navigation on the Site or use of the Application, and gather broad demographic information for aggregate use, which enables us to improve the Site or Application by making it more accessible and easier to navigate and use. For example, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your Web browser, referrer addresses, and other generally accepted log information. IP addresses are not linked to Personal Information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Web site and Application are being used.
A “referrer” is the information passed along by a Web browser that references the Web URL you linked from and is automatically collected by our Web server. We may collect and use this information to understand the Web sites referring traffic to our Web site and to present appropriate content to our potential users. We may tabulate referrer information on an aggregate basis to identify trends and traffic patterns.
Use of Third Parties or Agents
MoCA may employ third parties or other companies to perform functions on our behalf, such as processing and fulfilling online orders or requests, processing credit card payments, providing customer service, sending print and electronic mail, removing repetitive information from customer and e-mail lists, maintaining and analyzing information collected and/or stored via the Web site or Application, hosting services, measuring the effectiveness of promotions and e-mails, performing analyses of users’ activities, serving images via our Web site, and fulfilling other functions necessary to our business as further described in Section 3.1.
Using Information About You
MoCA respects your privacy. The information you provide will never be rented or sold. MoCA will use the contact information you provide for internal purposes, such as confirming and tracking your order; subscription or registration; analyzing preferences, trends, and statistics; and informing you of our new products, services and offers. MoCA may also use your profile information to create personalized content, offers, and services, but this information will be used only by MoCA.
Sharing of Personal Information
Provision of Services
MoCA also may use third party vendors or other companies to assist in providing certain services, products, and communications to you, such as delivering newsletters, magazines, alerts, and other communications to those users who have opted in to receive them. Likewise, we may work with an outside company to (a) manage our database of customer information, (b) assist us in distributing e-mails, (c) assist us with direct marketing and data collection, (d) provide storage and analysis, (d) provide fraud prevention, and (e) perform other services designed to assist us in maximizing our business potential. Finally, we may disclose information to outside companies that help us bring you the products and services we offer.
In the event that we utilize third party vendors or companies to provide any of the services described above or similar services, we may need to share your Personal Information with them to enable those companies to perform their obligations. However, we will provide these companies only with the information necessary to perform their functions on our behalf, and we will not authorize them to use your Personal Information for any other purpose. In such event, these companies are required to agree, in writing, that they will abide by the privacy statement and privacy standards implemented herein, including the relevant confidentiality and security provisions.
MoCA may disclose any or all of your Personal Information if we are required to do so by law or in the good faith belief that such action is necessary to (a) conform to the law or comply with legal process served on us (for example, under a subpoena, court order, or other regulatory requirement or to maintain or protect the security of the Web site or Application); (b) protect and/or defend our rights or property or other legal interests or of any user; or (c) act in urgent circumstances to protect the safety of the public or other users of the Web site or Application. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. If we receive legal process calling for the disclosure of any Personal Information, we will attempt to notify you via the e-mail address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.
Minors and Protected Persons
MoCA products and services are not specifically intended to, but may be used on minor or protected persons whenever deemed appropriate by the health care professionals. In that respect, health care professionals are expected to use their discretion and professional judgement to dispense any test or other services offered by MoCA. In doing so, they are also expected to obtain valid consent from any minor or protected person in accordance with their ethical obligations and all relevant Applicable Laws.
MoCA undertakes to take steps that are reasonable in the circumstances to ensure that all Personal Information in its custody or control is protected against theft, loss and unauthorized use or disclosure and to ensure that the records containing such information are protected against unauthorized copying, modification or disposal. In that respect, MoCA uses secure connections during the transmission of log in, registration, and membership information, as well as when transmitting to your attention patients’ results. This means that the aforementioned information is encrypted before it is sent over the Internet between your computer and MoCA computers. The technology used is called Secure Socket Layer (SSL). Through the use of this technology, the information collected through those pages is encrypted on your computer, sent through the Internet as jumbled code, and decoded on either MoCA’s secure server or the systems of the third party contracted to provide the service in question. You can verify that the connection is secure because you will see a key or a padlock at the bottom of your browser screen. Another identifier of a secure connection is the URL (or Web site address); the address will change from http to https or a similar page when a secure connection is in place.
Although we employ data encryption technology, you should be aware that there is an inherent risk in transmitting any data electronically. This risk is inherent in all electronic dealings as well as to all other forms of communications. Consequently, we cannot guarantee that any Personal Information transmitted will be prevented from being viewed or used by any particular person and, therefore, you agree to hold us harmless from and against any injury, financial or otherwise, that results from such unauthorized viewing or use. Moreover, e-mails sent to us over the Internet are susceptible to detection, decryption, eavesdropping, and/or tampering. Thus, you agree to hold us harmless from and against any harm, financial or otherwise, that results from such detection, decryption, eavesdropping, or tampering of e-mails.
In addition, you must take steps to maintain the security of your private information by keeping your password and other personal information confidential. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to log out of your account when you finish using a shared computer.
Finally, MoCA processes, stores and retains Personal Information on secure servers. MoCA’s Application is currently being hosted in Parse datacenter, which is located on the East Coast of the United States (https://parse.com/faq). As to the Personal Information obtained when you subscribe to newsletters (or other forms of communication) or when you open an online account on our Web Site, such information will be stored in Mail Chimp datacentres, which are located in Virginia and in New York (http://blog.mailchimp.com/mailchimp-website-updates/). Even if these servers are located in the United States and subject to the laws in force in these States, MoCA has ensured, before contracting with these service providers, that any Personal Information collected, used, stored and destroyed would receive protection equivalent to that afforded under the laws in force in Canada.
Updating Your Information
Users may consult, correct and update at all times Personal Information collected, used and stored via the Website or the Application.
You may update or change your registration information by editing your account profile. In order to do so, you should login to www.mocatest.org with your username and password and enter your profile section. You can also update or amend the foregoing at any time by contacting MoCA as set forth hereunder.
Also, should you wish to be removed from any mailing lists, then you should simply reply to any electronic communication with the word “STOP” or “Unsubscribe” or click on the ready-to-use unsubscribe mechanism provided at the bottom of such communication. You can also specify your desire to be removed from more than one promotional lists by sending us an email (at email@example.com ) setting forth from which list(s) they wish to be removed.
You can also edit your account or any file, correct inaccurate, incomplete or ambiguous information, have outdated or irrelevant information struck out by contacting us using one of the abovementioned means.
Users can readily and freely update their account or profile, or otherwise modify, edit or delete any information they provided via the Website or Application. Likewise, any requests for access, correction of any Personal Information are free of charge. However, a reasonable fee may be charged by MoCA should you wish to obtain a copy of such Personal Information. In such a case, MoCA will notify the amount of these fees if applicable, the whole ahead of time.
Raw Data, Medical Records And Other Information About Patients
Patients may consult, correct and update at all times Personal Information collected, uploaded, used and stored by health care professionals on the Website or the Application, provided that patients may not, in accordance with Applicable Law, modify any raw data obtained from the MoCA standardized tests or professional opinions or observations made in good faith, or otherwise modify, correct and update the content of their medical records, unless legally entitled to do so.