Privacy Policy

This Privacy Policy outlines how we utilize your personal information, which we gather when you engage with our services, visit our website (https://imago.tg), use our mobile applications accessible through third-party app stores, or interact with us in any way, whether online or offline.
If you are uncomfortable with the ways in which your information is employed as described in this Policy, discontinuing your use of Imago services is recommended.

The Site is operated by Imago - Transition Clinic & Concierge Limited ("Imago," "we," "our," and "us"). We are not a medical organization. Any telemedicine consultations you access through our website are conducted by independent medical practitioners. We are registered as a company in Malta under registration number C 105964, with our main office located at Level G, (Office 1/1040), Quantum House, 75 Abate Rigord Street, Ta'Xbiex XBX 1120, Malta.

General

Imago is entrusted with safeguarding the personal information we utilize and making determinations concerning its usage. As per applicable data protection laws, Imago serves as the "controller" of the collected and utilized personal information and is responsible for adhering to the European General Data Protection Regulation ("EU GDPR" or "Data Protection Laws"). We adhere to the legally prescribed standards of security and confidentiality.

How We Utilize Your Information

We utilize the information we gather about you or that you provide to us, including any Personal Data, for the following purposes:
To present our website and its contents to you.
To deliver our products and services to you.
To offer you information, products, or services that you request from us or that may be of interest to you.
To process, fulfill, support, and manage transactions and orders for products and services you request.
To send you notifications regarding your Imago account.
To respond to your inquiries or requests.
To conduct quizzes, surveys, and sweepstakes.
To fulfill any other purpose for which you provide your information.
To fulfill our obligations and enforce our rights under contracts between you and us, including billing and collection.
To notify you about changes to our website, products, or services.
For any other purpose with your consent.
We may also use your information to contact you about goods and services that might interest you, including through newsletters. If you want to opt out of receiving such communications, you can do so anytime by clicking the unsubscribe link at the bottom of these messages. We may merge your information with other data available to us, including information from other sources like your Providers, insurers, or benefits program, to maintain an accurate participant record. PHI will not be used for any other purposes, including marketing, without your consent.

Information We Gather About You and How We Gather It

In general, we collect various types of information from users of our Website, collectively referred to as "Personal Data." This information may include: Personally identifiable information, such as your name, address, email address, phone numbers, government identification number, date of birth, credit or debit card number (strictly for payment purposes), images and videos of you, your medical history, sexual orientation and preferences, and health-related details; Information regarding your internet connection, the devices you use to access our Website, and usage details such as traffic data, logs, referring/exit pages, the date and time of your visits to our Website, error information, clickstream data, and other communication data, as well as the resources you access and utilize on our Website. We collect this information through the following means: Directly from you when you provide it to us; Automatically as you navigate our Website; Automatically collected information may encompass usage details, IP addresses, and data collected through cookies and similar tracking technologies; From third parties, including our business partners.
The information we gather on our Website includes data you provide by completing forms. This involves information you provide when registering on our Website, using our Provider consultation services or gender care navigation services, purchasing products, or requesting additional services. We may also request information when you report issues with our Website. Additionally, we maintain records and copies of your correspondence (including email addresses) if you reach out to us. Details of transactions you conduct through our Website, as well as the fulfillment of your orders, may also be collected. For certain orders, you might need to supply financial information. You may also choose to share information for publication or display on public areas of our Website or to send to other users of our Website or third parties, such as through our therapist-led online group sessions and events (collectively referred to as "User Contributions"). Please be aware that your User Contributions are posted on and transmitted to others at your own risk. Although we restrict access to specific pages, it's important to note that no security measures are entirely foolproof. Furthermore, we cannot control the actions of other Website users with whom you may choose to share your User Contributions. Consequently, we cannot guarantee that your User Contributions will remain inaccessible to unauthorized individuals. We reserve the right to remove you from a group therapy session or other event and cancel your subscription if you engage in inappropriate conduct, such as the use of unlawful, offensive, harassing, or inappropriate language, during a group therapy session or event or if you engage in any other unlawful, offensive, harassing, or inappropriate behavior. During group discussions, please avoid sharing personally identifying information about others.
As you navigate our Website and interact with it, we may employ automatic data collection technologies to gather specific information about your devices, browsing activities, and usage patterns. This includes: Particulars of your visits to our Website, like traffic data, logs, referring/exit pages, the date and time of your visit, error information, clickstream data, and other communication data (this also encompasses the resources you access and utilize on our Website); Information regarding your computer, mobile device, and internet connection, such as your IP address, operating system, and browser type; The automatically collected information may contain Personal Data, or we may connect it with Personal Data collected through other methods or from third parties. This information helps us enhance our Website and provide you with improved and more personalized services. It allows us to: Estimate the size of our audience and examine usage patterns; Offer, improve, and develop our products and services; Save data related to your preferences, enabling us to customize our Website based on your specific interests; Recognize you when you revisit our Website.
The technologies we utilize for this automatic data collection may involve: Cookies (or browser cookies): We, along with our service providers, may use cookies, web beacons, and other technologies to receive and store specific types of information when you interact with our Website using your computer or mobile device. A "cookie" is a small piece of data sent from a website and stored on a user's computer by their web browser during browsing. You may be able to refuse browser cookies by adjusting your browser settings or, on your mobile device, in your operating system or browser preferences. However, selecting this option may limit access to certain parts of our Website. Unless you have configured your browser or operating system to block cookies, our system will issue cookies when you visit our Website. Google Analytics: We utilize Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to collect specific information related to your Website usage. Google Analytics employs cookies to assist in analyzing how users interact with the site. For more details on how Google uses data when you visit our Website, please visit "How Google uses data when you use our partners' sites or apps" (available at google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide interest-based advertising based on your online activity. For additional information regarding Google Analytics, please visit Google's website and pages describing Google Analytics, such as www.google.com/analytics/learn/privacy.html.

Sharing of Personal Information

We routinely engage in the sharing of personal information with the following entities:
Imago Providers – to provide services effectively we must share your personal information with the Providers. These specialists collaborate with Imago as independent contractors.
Partner Organizations – we also share information with partner organizations that assist in managing Imago accounts and various aspects of our services. Such partner organizations encompass entities which offer essential services like hosting, security, data storage, cloud services, testing services, and non-critical services, such as third-party review platforms.
Payment Processors (further details below).
Partners - they process your data on our behalf to facilitate our Services. This may encompass appointment booking, contacting us, utilizing our online platforms, and interactions with pharmacies.
Other healthcare professionals, in cases where we collaborate to deliver a Service.
Regulatory and Compliance bodies.
Additional partners, professionals, and service providers necessary for the provision of our services.
We only permit third-party organizations to manage your personal information under the following conditions: We are satisfied that they implement appropriate measures to safeguard your personal information; We have imposed contractual obligations on them to ensure that they use your personal information solely for providing services to us and to you, following our instructions, and not for their own purposes; We have assessed these organizations to confirm that they will handle your personal information responsibly.
On occasion, we may share your personal information: with relevant regulatory authorities; with your consent, with your caregivers, relatives, partners, or friends (we will only share information after the designated individual has provided proof of their identity, we may also share information with anyone you have designated as an emergency contact, such as your next of kin); with anyone you have authorized us to share your personal information with, such as employers, insurers, or other third parties; with relevant police, fire, and rescue services in cases of immediate risk to you or others or in compliance with legal requirements; with public health bodies responsible for managing infectious diseases like meningitis, tuberculosis (TB), or measles, as well as handling public health incidents; with our professional advisors, including lawyers and accountants, when necessary for obtaining or providing professional advice (including legal advice) or for initiating or defending a legal claim; with our insurers, brokers, and the insurers and brokers of other organizations when necessary for investigating insurance coverage and processing claims or threatened claims; with individuals or organizations as required by legal mandates, such as specified in a warrant or court order (in the event that we, or substantially all of our assets, are merged or acquired by a third party, in which case your information may become part of the transferred or merged assets); with other organizations contributing to medical or social care, and these organizations encompass: your doctor, allowing them to maintain a record of your online appointment and/or consultation (if you seek more information about how your GP practice handles the information we share with them, refer to your GP practice's patient privacy notice, typically available on their website.); hospitals; organizations delivering medical services outside of hospitals; private sector healthcare providers like private hospitals, dentists, opticians, and pharmacists; out-of-hours service providers, offering medical services outside regular hours; voluntary sector organizations involved in healthcare, such as charities; local councils, if social workers are part of your care team, including services related to education, children, housing, or benefits; organizations conducting diagnostic tests; providers of ambulance or patient transport services; other organizations participating in the delivery of medical care, social care, or public health protection; with marketing organizations, if you have consented to receiving information about our services and promotions. For instance, we may share your contact information with companies we use for sending marketing emails. Although we will not disclose information about your health to these organizations, they may infer such details based on the content of marketing emails. For instance, if we send you information about managing diabetes, our partners could deduce that you have this condition.

Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us, and we require that all users create password encrypted accounts with two factor authentication enabled. The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we work diligently to try and protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or in your operating system.

Rights over personal information

Under certain circumstances, you have rights under Data Protection Laws in relation to your personal information. Specifically:
Your right of access
You have the right to ask us for copies of your personal information. There are some exemptions, which mean you may not always receive all the information we have about you.
Your right to rectification
You have the right to ask us to rectify information you think is incomplete or inaccurate. We will not usually amend medical records. This is because it is important that we have a copy of the information available to practitioners at the time they are treating you. Instead, we usually add a note to your record to highlight the information you consider to be incorrect.
Your right to erasure
This enables you to ask us to delete or remove personal data 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 personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, we will not normally delete information from medical records. This is because it is important that we have a copy of the information available to doctors at the time they are treating you.
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances, e.g. if you contest the accuracy of the personal information. Your right to object to processing
You have the right to object:at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.
Your right to data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that personal information to a third party.
Your right to withdraw consent
Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time. However, if you withdraw consent, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you.
Your right to not be subject to automated individual decision making
You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

Changes to Our Privacy Policy

We retain the right to modify this Privacy Policy at any given time. Our practice is to post any alterations made to our Privacy Policy on this page, accompanied by a notification indicating that the Privacy Policy has been updated, prominently displayed on the Website's homepage. In instances where we make substantial changes in how we handle our users' Personal Data, we will inform you via email to the address you provided in your account and/or through a notice featured on the Website's homepage. The date of the last revision to this Privacy Policy is specified at the top of the page. It is your responsibility to ensure that we have an accurate, active, and deliverable email address for you and to periodically visit our Website to review this Privacy Policy for any updates.

Contact Information

For any inquiries, concerns, complaints, or suggestions related to our Privacy Policy or if you need to get in touch with us for any reason, please feel free to contact us using email address hello@imago.tg.

Complaints

You retain the right to file a complaint if you are dissatisfied with how we have handled your personal information or responded to your privacy-related requests. In the initial instance, we encourage you to reach out to us using the provided contact information so we can address your concerns directly.