Ianacare Privacy Policy

Effective Date: February 21, 2024

About this Privacy Policy and Our Commitment to Your Privacy

Ianacare, Inc. (“ianacare”, “we”,”us”, “our”) provides online products and services (collectively, the “Services”) through our mobile applications and ianacare.com (collectively, the “Site”) that may, among other things, provide you with tools to engage in supportive care management for persons that require care assistance (for chronic illnesses and other situations). We provide this privacy policy (“Privacy Policy”) to outline the information ianacare collects from users of the Site (“Users”,“you”), Ianacare Partners (defined below) and how we may use and disclose this information when the Site is accessed through any device. It also describes the choices available to you regarding our use of your information and how you can manage and update this information. Some online services offered by or affiliated with ianacare may be governed by a separate privacy policy. We suggest you review each of the privacy policies for the services you are wishing to receive.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.

Third-Party Advertising on Our Site

We do not allow third parties to advertise to Users on our Site.

How to Contact Us 

Please read this Privacy Policy carefully. If you have questions or complaints regarding our Privacy Policy or privacy practices, please contact us at: Attn: Chief Privacy Officer, ianacare, Inc., 716 Beacon St., #590713, Newton Center, MA 02459 or info@ianacare.com.

Information Addressed by this Privacy Policy

We want you to have a clear understanding of the information addressed by this Privacy Policy. We will collect information about you (“Information”) in a variety of ways, including directly from you, through automatic means, or from third parties.

Personal Information and Privacy

When you use our Service, you may be creating and maintaining a personal, private area of the application (“Individual Team”) on behalf of yourself and/or one or more persons within your care team (“Care Team”), or visiting and posting to an Individual Team created by someone else within your Care Team. By their very nature, these Individual Teams contain personal information about the subject of the Individual Team and other Users on the Care Team. Our goal is to balance our Users’ need to find each other and communicate information and support against our Users’ desire for privacy.

Site Access

The Individual Team is accessible “By Invitation Only.” Once established, every member of a Care Team, including the creators of Individual Teams and all Users are responsible for maintaining the confidentiality of the Individual Team in accordance with the care recipient’s wishes.

Information You Provide Directly to ianacare

When you use the Site, you may provide certain information directly to us.

  • Contact data. When you choose to register a user account, you will be required to provide, among other things, your e-mail address, name, and phone number.
  • Profile data, such as the username and password that you may set to establish an account on the Services, date of birth, biographical details, profile photograph. 
  • Care status. When you create a Care Team, we may collect identifying information about members of the Care Team and the caregiver, including the caregiver’s work status and living situation. We also collect information about how the supporter can help the care recipient. 
  • Communications data based on our exchanges with you, including when you contact us through the Service.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.  
  • Medical history. Where you use our caregiver navigator services and you are a care recipient, we may collect information regarding your past and present medical history (i.e., diagnosis, medical events, medications, etc.). 
  • Financial data. Where you are a care recipient, we may collect financial information in order to determine eligibility for certain programs and benefits.
  • Insurance data. Where you are a care recipient, we may collect information regarding your insurance coverage and benefits.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. 
 

Certain Information in the Services is Visible to Other Users

  • Care actions, including information regarding the care recipient’s needs, actions taken and updates may be shared among and be available to Care Team members, but is not publicly visible to other Users outside of the Care Team.
 

Information that is Automatically Collected

We and third parties may use automated means to collect information about you, your computer or other device that you used to access the Site, and your use of the Site, such as: 

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
 

Some of the automatic collection described above is facilitated by cookies and similar technologies. For more information on how we use cookies, please see our Cookie Notice. 

Information We Collect from Third Parties

Ianacare enters into business relationships with business partners including: healthcare providers and/or networks of healthcare providers (“Providers”), health plans or health insurers, including, without limitation, employer-sponsored health plans (“Health Insurers”), and companies that contract with Providers, Health Insurers, and/or Ianacare (“Contractors”) to make ianacare’s products and services available to Users who are patients of such Providers or enrollees, members, or participants of such Health Insurers or Contractors. Ianacare’s business partners such as Providers, Health Insurers, and Contractors are collectively referred to in this Privacy Policy as “Ianacare Partners.” When you use the Services, we may collect information about you, directly or indirectly, from or through applicable Ianacare Partners as well as other Users of the Services. With your consent, we may also collect Information from other third parties.‍

Our Use of Information

To Provide You with the Site and Services

Ianacare, and any third party vendors acting on ianacare’s behalf, may use and store your Information to perform activities associated with providing you with the Site and related services such as: (i) registering you to use the Site and otherwise logging you into the Site, including the authentication of your identity, where applicable, and otherwise enabling your access to the Site; (ii) resolving disputes and/or troubleshooting problems including logging into your account to troubleshoot problems or otherwise help you navigate the Site; (iii) verifying your compliance with your obligations in our Terms of Service or other ianacare policies; (iv) improving the quality of the Site, (v) fulfilling any request you make; (vi) communicating with you; (vii) connecting you with and providing you with information about services, providers of services, resources or programs to which you may have access; (viii) providing you with Site content, including, without limitation, generating recommendations (such as recommended Site activities or services), providing caregiver navigation services, creating action plans for caregivers, helping caregivers anticipate the needs of the care recipient, and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Site, including through the delivery of tailored content and communications; and (x) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by ianacare’s agreements with applicable Ianacare Partners, we may also use your Information in connection with any other services we make available to you.

To Communicate with You and Your Friends (including Marketing)

If you choose to tell a friend about our Service or share an Individual Team through our Site, we will ask you for your friend’s name and email address or phone number. We will automatically send your friend a one-time email or text message inviting him or her to visit the Site. We retain this information to identify the User as part of the care team when they sign in. You represent that you will obtain the consent of your friend to allow us to send the email or text message inviting him or her to visit the Site. 

Ianacare, Ianacare Partners, and any third-party vendors acting on ianacare’s behalf, may also use your Information to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Site and/or our products and services (and related features and functionality) or those of any Ianacare Partner that is providing services to you. Our communications to you will include, without limitation, contacting you by SMS text message or at the email address(es) that you use to register for our Site to communicate with you regarding the Site and actions that you take in connection with the Site.

To Conduct Research and Development

We may use your Information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

To Create and Use of Combined Data, De-Identified Data, and Aggregated Data

As permitted by law and by ianacare’s agreements with applicable Ianacare Partners, ianacare, and any third-party vendors acting on ianacare’s behalf, may aggregate and/or de-identify your Information and/or combine your Information with other information maintained or available to ianacare and use or disclose such information as follows:

We may use aggregated or combined data to communicate with you about the Site and/or our products and services and disclose such aggregated or combined data to Ianacare Partners in connection with providing the Site.

We may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Site and developing additional benefits, programs, and services, and disclosing to Ianacare Partners for analytics purposes.

For Compliance and Protection

We may use your Information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

Disclosure of Information

We may share your Information in the following circumstances:

·   Disclosures to Service Providers and Ianacare Partners

With the limited exceptions discussed in this Privacy Policy, we do not share your Information with third parties, unless you tell us to. 

With Third Parties That Provide Requested Benefits: As stated above, we primarily share your information, including your Information, with third parties for the purpose of providing certain benefits that you request. Specifically, at your direction, we will submit your information to the appropriate third parties for purposes of filling your third-party service requests. For example, if you are interested in transportation or caregiver navigation services, then we will share your information, at your direction, with third parties that work with ianacare to provide transportation or caregiver navigation services, which may fit your particular needs. The third party, not ianacare, will evaluate your eligibility to obtain service from its program. The third party’s use of your Information will be governed by the third party’s own terms of service and privacy policy, not ianacare’s; ianacare does not have any control over your information once it is submitted to a third party for receipt of benefits. While we work with reputable third-party service providers, we cannot represent how any of them will use your Information in connection with their services, and recommend that you review their terms of use and privacy policies before requesting their services.

To Perform Services on Our Behalf: We may hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and to assist us in providing the products and services that you request from us. We only provide those service providers with the information necessary to perform the requested service.

·   Additional Disclosures with Your Consent

With your consent outside of this Privacy Policy, we may share your Information with third parties or allow them to collect information from the Site in some ways not specifically described in this Privacy Policy.

·   Safety, Security and Compliance with Law

Your Information and the contents of your communications through the Site may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request. ‍

·   Subsidiaries and Affiliated Companies

Except where prohibited by law or precluded by contract, we may share your Information with any subsidiaries or other affiliated companies under the control of, or under common control with, ianacare for the purposes set out in this Privacy Policy.

·   Sale, Merger or Similar Transaction

We may share your Information in connection with any proposed or actual merger, reorganization, a sale of some or all our assets, a financing or acquisition of all or a portion of our business by another company, or to a receiver, trustee or successor in interest in bankruptcy, in which case such company may continue to process your Information as set forth in this Privacy Policy (except where prohibited by law) or otherwise with your consent.

Your Choices Regarding Our Communications with You

In accordance with applicable law, we will offer you the opportunity to opt out of certain communications, such as, for example, communications that deal with any of our products or services you are not using but that we think might be of interest to you. Where applicable, you can opt out by emailing us at info@inanacare.com. However, even if you opt out of such communications, you may continue to receive other transactional, relationship, and/or administrative communications from or through ianacare that are important or related to your ianacare account or the products and services you are using (such as, for example, a notice that there has been a change in one of your services or a change to this Privacy Policy). Please also note that you, not ianacare, have control over certain settings for how communications such as emails and push notifications are displayed on your devices, and the settings you select will affect how ianacare’s communications are displayed.

We Do Not Control the Privacy Policies of Third Parties

Our Site may contain links that enable you to visit or use other third-party websites, resources or programs. However, we do not have control over the other websites, resources, or programs that you choose to visit, so this Privacy Policy does not apply to information collected or that you provide while visiting such other websites, resources, or programs. You should refer to the privacy policies, if any, applicable to the other websites, resources, or programs.

Data Security and Integrity

The security of your Information is important to us. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We also maintain procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

Managing and Updating Information

To access, review, update and/or delete certain Information, you may contact us at info@ianacare.com, and you may update and/or delete certain Information by logging into the Site and updating your account. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. Please remember, however, if we have already disclosed some of this Information to third parties, we cannot access that Information any longer and cannot force the deletion or modification of any such Information by the parties to whom we have made those disclosures. Additionally, if you modify certain Information on our Site that we received from a third party, we reserve the right, but are not obligated, to share the updated information back to that third party. As a result, you will need to provide updated information to those third parties if you want to be sure they have your updates.

Certain Information is necessary in order for us to provide the Site and our related Services; therefore, if you delete such necessary Information you will not be able to use the Site or receive our Services. If you wish to have your account deactivated, you may contact us at info@ianacare.com. After we receive your request, within a reasonable timeframe under the circumstances of your request, we will deactivate your account; provided, however, that: 1) ianacare (and our third-party vendors acting on our behalf), our Ianacare Partners, and any other applicable third parties may continue to use and share for any purpose de-identified data and aggregated or combined data developed using your Information that has been de-identified and 2) ianacare may continue to use Information in your deactivated account for compliance with applicable regulations. Also, please note that even though you may deactivate your account or request the deletion of your Information, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to retain this information, in which case we will comply with your deletion request only after we have fulfilled such requirements. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Site or your agreement to our Terms of Service, as permitted or required by applicable law.

For more information about rights in relation to European users, please see the Notice to European Users below. 

California Do-Not-Track Disclosure Requirements (for California Users)

We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.

Your California Privacy Rights (for California Users)

California law permits customers of ianacare who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us:

ianacare, Inc.

716 Beacon St., #590713

Newton Center, MA 02459

email: info@ianacare.com.

We will provide a list of the categories of Information, if any, disclosed to third parties during the immediately preceding calendar year for third-party direct marketing purposes, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or postal address specified above. You should put “California Privacy Rights” in the subject line and in your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.

Children; Special California Notice

The Site and Services are not directed to children under the age of 18, and children under the age of 18 years of age are not eligible to use them. Protecting the privacy of children is very important to us. Through the Site and Services, we do not collect Information from people we actually know are under 18 years of age, and no part of the Site or Services is designed to attract people under 18 years of age. If we later learn that an individual has provided us with their information through the Site or Services and they are under 18 years of age, we will take steps to remove that User’s Information from our databases and to prevent the User from utilizing the Site or Services.

If you are a California resident under the age of 18 and are a registered User of our Site, you may request that we remove from our Site any content you post to our Site that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Site may still remain on our servers and in our systems. To request removal of content under this provision, please send an email to info@ianacare.com and provide us with a description of the content and the location of the content on our Site, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Site by you.‍

Uses and Disclosures as Required or Permitted by Law, Including Research, Health Care Operations, and Public Health

To the extent not prohibited by law or precluded by Ianacare’s agreements with the applicable Ianacare Partner, Ianacare, and any third party vendors acting on Ianacare’s behalf, may use and disclose your Information: (a) as required or permitted by law, including, where applicable, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may include disclosures to the applicable Ianacare Partner; (b) for Research purposes; (c) for purposes of Health Care Operations of the applicable Ianacare Partner; and (d) for Public Health, as each is defined and in accordance with HIPAA.‍

Retention of Personal Data

Personal data will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Policy, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of our Site and Services. Information may persist in copies made for backup and business continuity purposes for additional time.

Modifications to this Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Site, and all changes will be effective upon such posting or upon any later date specified by us in writing. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this Privacy Policy was last revised by referring to the “Effective Date” legend at the top of this Privacy Policy. By continuing to use the Site or any services following the effective date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.

Notice to European Users

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” and Information in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.   

Controller. ianacare is the controller in respect of the processing of your Information covered by this Privacy Policy for the purposes of the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the so-called ‘UK GDPR’). See the ‘How to contact us’ section at the beginning of this Privacy Policy for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

 Our Representative in the EU. Our EU representative appointed under the EU GDPR is [insert]. You can contact them:

  • By email to: [insert].
  • By postal mail to: [insert] 

Our Representative in the UK. Our UK representative appointed under the UK GDPR is [insert]. You can contact them:

  • By email to: [insert].
  • By postal mail to: [insert] 

Our legal bases for processing 

In respect of each of the purposes for which we use your Information, the GDPR requires us to ensure that we have a “legal basis” for that use. 

Our legal bases for processing your Information described in this Privacy Policy are listed below.

  • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Information for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).  

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your Information – for more information on these purposes and the data types involved, see the ‘Our use of Information’ section above.

Purpose

Categories of Information involved

Legal basis

To provide you with the Site and Services

  • Contact data
  • Profile data
  • Care status
  • Communications data
  • Financial data
  • Insurance data
  • Care actions
  • Device data
  • Contractual Necessity 
  • Where Contractual Necessity does not apply, Legitimate Interests

We have a legitimate interest in processing the Information in order to provide the Services to our users

To communicate with you and your friends (including marketing)

  • Contact data
  • Communications data
  • Marketing data
  • Contractual Necessity
  • Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given communications

To conduct research and development

  • Profile data
  • Care status
  • Communications data
  • Care actions
  • Device data
  • Online activity data
  • Legitimate Interests

We have a legitimate interest in learning about how our users use our Site and Services in order to improve our Site and Services

To create and use combined data, de-identified data and aggregated data

Any and all data type(s) relevant in the circumstances

  • Legitimate Interests

We have a legitimate interest in applying privacy enhancing techniques to learn more about how our users user our Site and Services whilst making efforts to maintain their privacy

For compliance and protection

Any and all data type(s) relevant in the circumstances

  • Compliance with Law

Special categories of personal data

You may choose to provide us with certain health-related data. We will only collect such health-related data where you have provided us with your explicit consent to its use for the specific purpose of providing you with certain aspects of the Services, including recording medical events and medication schedules. If you do not want us to process your health-related data, please do not provide it to us.  

Retention

We retain Information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.  

To determine the appropriate retention period for Information, we consider the amount, nature, and sensitivity of the Information, the potential risk of harm from unauthorized use or disclosure of your Information, the purposes for which we process your Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Third Party Cookie Inventory

Ianacare provides the list below of third parties that set cookies on our websites. These third parties include service providers acting on our behalf. 

Ianacare and our third-party partners use cookies to remember your preferences and settings, help you sign in and analyze how well our websites are working. For more information, including updates, about the third party’s privacy practices with respect to any of the cookies below, please consult the third party’s website or privacy notice.

Service

Purpose

Related Cookies

Branch

To handle invitation links and deferred deep links. Branch’s privacy policy is located here.

_s

Firebase

To handle web pushes and analytics logs. Firebase’s privacy policy is located here.

_ga

_ga_164TJ0NCLV

Google Recaptcha

  • To verify human actions using Google reCAPTCHA v3. Google’s privacy policy is located here.

_GRECAPTCHA

NID

1P_JAR

AEC

APISID

DV

HSID

SAPISID

SEARCH_SAMESITE

SID

SIDCC

SSID

__Secure-1PAPISID

__Secure-1PSID

__Secure-1PSIDCC

__Secure-1PSIDTS

__Secure-3PAPISID

__Secure-3PSID

__Secure-3PSIDCC

__Secure-3PSIDTS

 

To handle authentication and authorization. The vendor’s privacy policy is located here.

csrf-state-legacy

Csfr-state

cognito

XSRF-Token

ianacare

To store cookie consent approval or decline. The vendor’s privacy policy is located here.

ianaCookieConsent

Your rights

The GDPR gives you certain rights regarding your Information. If you are located in Europe, you may ask us to take the following actions in relation to your Information that we hold:

  • Access. Provide you with information about our processing of your Information and give you access to your Information.
  • Correct. Update or correct inaccuracies in your Information.
  • Delete. Delete your Information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your Information where you have exercised your right to object to processing (see below). 
  • Transfer. Transfer a machine-readable copy of your Information to you or a third party of your choice.
  • Restrict. Restrict the processing of your Information, for example if you want us to establish its accuracy or the reason for processing it.
  • Object. Object to our processing of your Information where we are relying on Legitimate Interests – you also have the right to object where we are processing your Information for direct marketing purposes.
  • Withdraw Consent. When we use your Information based on your consent, you have the right to withdraw that consent at any time.  

You may submit these requests by email to info@ianacare.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your Information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.  

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your Information, you can make a complaint to the data protection regulator in your habitual place of residence. 

 

Data Processing outside Europe  

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your Information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.  

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for Information, which is equivalent to that provided by relevant European laws. 

Where we share your Information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented: 

  • Transfers to territories with an adequacy decision. We may transfer your Information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
  • Transfers to territories without an adequacy decision.
    • We may transfer your Information to countries or territories whose laws have not been deemed to provide such an adequate level of protection.  
    • However, in these cases:
      • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or 
      • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your Information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
 

You may contact us if you want further information on the specific mechanism used by us when transferring your Information out of Europe.