Privacy Policy

Our commitment to protecting your privacy: This privacy policy applies to the collection, storage, use and disclosure of personal information by or on behalf of Miyagi Health Enterprises LLC, a Wyoming limited liability company (referred to in this policy as “our”, “we” or “us”).  Please read it carefully.

We are committed to protecting your personal information, and ensuring its privacy, accuracy and security. We handle your personal information in a responsible manner in accordance with the Health Insurance Portability and Accountability Act (“HIPAA”) and in accordance with any Business Associate Agreements, as applicable, that we may enter into with any of our healthcare providers. You can learn more about our processing of your information on behalf of our customers in the applicable privacy policies. Your healthcare provider may also have its own privacy practices and/or policies that govern its collection and use of your data. Except for any healthcare providers directly employed by us, we are not responsible for how your healthcare provider treats your information, and we recommend you review their own privacy policies.

By giving us your personal information when you contact us, use any of our services or products, or visit our website (www.miyagi.coach/us/), you agree to your information being collected, stored, used and disclosed as set out in this Privacy Policy.

Personal information: ‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form.

‘Sensitive information’ (a type of personal information), means information or an opinion about an individual’s race or ethnic origins, political opinions and associations, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, trade or professional associations and memberships, union membership, criminal record, health or genetic information or biometric information.

Whose personal information do we collect? We may collect your personal information from a range of sources, including from you, contractors and our business partners.  For example, we may collect your personal information when you request or acquire a product or service from us, provide a service or product to us, apply for employment with us or communicate with us via our website, by e-mail, telephone or in writing.

Wherever reasonable and practicable, we collect personal information from the individual to whom the information relates.  If you provide personal information about someone other than yourself, you agree that you have that person’s consent to provide the information for the purpose for which you provide it to us.  You also agree that you have told the person about this Privacy Policy and where to find it.

What types of personal information do we collect and hold? The personal information we may collect includes:

• name and address;
• telephone/e-mail contact details; and
• bank account/credit card numbers and associated details as reasonably required in relation to processing payments at your request.

We will only collect your sensitive information: if you have consented to us doing so – for example, as part of information collected about Miyagi Health Enterprises LLC.

How do we collect personal information? We only collect personal information by lawful and fair means.  We usually collect personal information from:

• face-to-face meetings, interviews and telephone calls;
• electronic communications – for example, e-mails and attachments (including CVs); forms filled out by people, including as part of acquiring a product or service from us; and
• our website, including if you use it to contact us, engage in discussion forums, give us feedback or to make an enquiry about our programs.
• we may collect personal information using various technologies, such as cookies, pixels, Internet tags or web beacons, and navigational data collection (log files, server logs, and clickstream data).
• we may also use analytical web tools such as Google Analytics to collect visitor information for us to better understand how to improve our products and services for you.
• we may also collect information from other sources, such as lead generation companies, credit bureaus, social networks, and business partners that offer co-branded services or help us sell or distribute our products. 
• we may also collect information from other users of our services or from available sources.
• in addition we may use Facebook or other social media to deliver targeted advertisements using either personal information provided by you or information received through analytical web tools.

Why do we collect personal information?  We collect the personal information: necessary for us to provide you with the services and products you have requested from us; to provide you with information about services and products that may be of interest to you; to improve the services and products we provide; and to enable us to carry out our functions and activities, including meeting our legal and regulatory obligations.  If you do not provide your personal information, we may not be able to supply the requested service or product, employ you or otherwise deal with you.

How do we deal with unsolicited personal information? If we receive personal information about you that we have not requested, and we determine that we could not have lawfully collected that information under the APPs had we asked for it, we will destroy or de-identify the information if it is lawful and reasonable to do so.

Do you have to disclose your identity when dealing with us? Where lawful and practicable, we will give you the option of interacting with us anonymously or using a pseudonym.

Use of personal information: We only use your personal information for the purpose for which it was provided to us, for related purposes or as required or permitted by law.  Such purposes include:

• in the ordinary course of carrying out our functions and activities.  For example, supplying or acquiring services or products, administering our programs and services, responding to your enquiries and feedback, and providing information about our products and services that may be of interest to you;
• market research and product and service development, so that we can tailor our future services and products accordingly;
• performing general administration, reporting and management functions.  For example, invoicing and account management, payment processing, risk management, training, quality assurance and managing suppliers;
• employment-related purposes, such as recruiting and providing services to staff; and
• other purposes related to or in connection with our functions and activities, including meeting our legal and contractual obligations to third parties and for internal corporate governance purposes.

Disclosure of personal information: We may disclose, and you consent to us disclosing, your personal information to third parties:

• engaged by us to provide products or services, or to undertake functions or activities, on our behalf.  For example, providing our IT systems and services, processing payment information and managing databases;
• that are authorized by you to receive information we hold;
• at your request or direction, such as when you choose to share information with a social network about your activities on the Sites;
• that are our business partners, joint venturers, partners or agents such as our external advisers, or that is an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of all or any part of our business, provided that we inform the buyer it must use your information only for the purposes disclosed in this Policy.  Or, for example, where disclosure is reasonably required to obtain advice, prepare legal proceedings or investigate suspected unlawful activity or serious misconduct; or
• as required or permitted by law.

Marketing use and disclosure: We may use and disclose your personal information (other than sensitive information) to provide you with information about our services and products that we consider may be of interest to you.  You may opt out at any time if you do not, or no longer, wish to receive marketing and promotional material.  You may do this by: contacting us via e-mail or in writing at the address below and requesting that we no longer send you marketing or promotional material; or where applicable, clicking the “Unsubscribe” button.

Use or disclosure of sensitive information: We will only use or disclose your sensitive information for the purpose for which it was initially collected or for a directly related purpose, as required or permitted by law, or where you consent to the use or disclosure.

How is my personal information kept secure? We take reasonable steps to protect your personal information from misuse, interference, loss and unauthorized access, modification and disclosure.  Such steps include: physical security over paper-based and electronic data storage and premises; computer and network security measures, including use of firewalls, password access and secure servers; restricting access to your personal information to employees and those acting on our behalf who are authorized and on a ‘need to know’ basis; retaining your personal information for no longer than it is reasonably required, unless we are required by law to retain it for longer; and entering into confidentiality agreements with staff and third parties.

Where we no longer require your personal information, including where we are no longer required by law to keep records relating to you, we will ensure that it is de-identified or destroyed.

Data quality: We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date.  However, we rely on you to advise us of any changes or corrections to the information we hold about you. If you consider that the information we hold about you is not accurate, complete or up-to-date, or if your information has changed, please let us know as soon as possible.

Access: You may request access to the personal information we hold about you by contacting us.  We will respond to your request within a reasonable time.  We will provide you with access to the information we hold about you unless otherwise permitted or required by law. If we deny you access to the information, we will notify you of the basis for the denial unless an exception applies.  Where reasonable and practicable, we will provide access to the information we hold about you in the manner you request. No fee applies for requesting access to information we hold about you.  However, we reserve the right to charge a reasonable fee where we do provide access.

Correction: If you believe that personal information we hold about you is incorrect, incomplete or not current, you may request that we update or correct your information by contacting us.  We will deal with your request within a reasonable time.  If we do not agree with the corrections you have requested (for example, because we consider that the information is already accurate, uptodate, complete, relevant and not misleading), we are not required to make the corrections.  However, where we refuse to do so, we will give you a written notice setting out the reasons.

Identifiers: We do not adopt, use or disclose government related identifiers except as required or permitted by law.

Complaints: If you have a complaint in relation to the collection, storage, use or disclosure of your personal information, please contact our Privacy Officer using the details below.  You will need to provide us with details of your complaint, as well as any supporting evidence and information.  We will review all complaints received and our Privacy Officer will respond to you.  If you are not satisfied with our response, you may discuss your concerns with or complain to:

Wyoming Attorney General’s Office,
Consumer Protection and Antitrust Unit,
109 State Capital, Cheyenne, WY 82002;
Phone: 307-777-6397 or 307-777-8962;
Fax: (307) 777-3435;
Email: ag.consumer@wyo.gov.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: December 2, 2024

Last Updated: December 2, 2024

This Privacy Notice for California Residents (“Notice”) supplements the information contained in this Policy and included above, and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

The disclosures in this notice apply solely to the extent the CCPA applies to the information and data processing activities in question. Please note that the CCPA has a number of exemptions, including for certain personal information that we collect when providing services to our business customers communication (“B2B personal information”). Therefore, you may not have certain rights with respect to your information that we describe below.

Our Information Practices

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

In particular, we may collect the following categories of personal information from our California based users:

In addition:

• We obtain the categories of personal information listed above from the categories of sources described in the “What Information Do We Collect” section above.
• We use personal information for business and commercial purposes in accordance with practices described in the “How Do we Use Your Information” section of this Policy.
• We do not “sell” (as defined in the CCPA) personal information in connection with this Policy.
• We disclose the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences.
• We also use and partner with different types of entities to assist with our daily operations and manage our Sites. Please review the Sharing Your Information section for more detail about the parties we have shared information with.

With respect to deidentified patient information, we disclose such deidentified information to third parties only when permissible pursuant to our contractual commitments with customers and in accordance with Health Insurance Portability and Accountability Act (“HIPAA”) requirements or other applicable law.  We employ the safe harbor method or the expert determination method, as enumerated under HIPAA.  Those third parties to whom the deidentified data is disclosed are third party service providers/vendors with whom we have relationships and/or academic researchers and/or institutions that are contributing to the improvement of healthcare.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

You may have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information in the preceding 12 months. Depending on your request, this may include:

• The specific pieces of personal information we collected about you, including, under certain circumstances, in a portable format.
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• The categories of your personal information that we sold or disclosed for a business purpose.
• The categories of third parties with whom we sold or disclosed that personal information for a business purpose.
• Our business or commercial purpose for collecting or selling that personal information.

You may have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. The CCPA also provides a right to opt out of the sale of your personal information. At this time, we do not sell your personal information, except to the extent that the sharing of cookie information for purposes of targeted advertising constitutes a “sale” under the CCPA. To exercise your options with respect to cookies, please follow the steps “Cookie Preferences” on the banner that is visible at the bottom of our website, or click link on the bottom of (Miyagi web address) labeled, “Cookie Preferences”.

Exercising Your Rights

To exercise the rights described above, please submit a request to us by either:

• Submitting a request via email to:compliance@miyagi.coach;
• Or writing to: 

Miyagi Health Enterprises LLC
Attn: Compliance

30 N Gould St STE R

Sheridan, WY 82801, USA

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

• Name, email address, phone, address (including zip code) and date of birth.
• Description of your request with sufficient detail that allows us to properly understand, evaluate, and respond.

We cannot substantively respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you, except where the CCPA does not require a verifiable request for a response. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only make a consumer request for access or data portability twice within a 12-month period. We will not discriminate against you for exercising any of your CCPA rights.

Response Timing and Format

We endeavor to respond to a consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes in particular: Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make such a request, please write us at: Miyagi Health Enterprises, LLC, Attn: Compliance, (mailing address for compliance/privacy officer). We may require additional information from you to allow us to verify your identity and we are only required to respond to requests once during any calendar year.

Changes to this Privacy Policy: We reserve the right to revise this Privacy Policy or any part of it from time to time. Please review this Policy periodically for changes.  Any revised policy will be placed on our website at (insert web address for privacy policy).  Your continued use of our website, services or products, requesting our assistance, or the provision of further personal information to us after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy.

How to contact us: If you have any questions about this Privacy Policy, please contact Miyagi Health Enterprises LLC:

(a)    by email to compliance@miyagi.coach, with subject line Attn: Privacy Officer

(b)    by writing to: Privacy Officer – Miyagi Health Enterprises LLC, 30 N Gould St STE R, Sheridan, WY 82801, USA

(c)    by telephone +1 844-478-0526.

Effective date: December 2024