The "TL;DR" version:

(“tl;dr” is internet slang for “too long, didn’t read” – a totally reasonable reaction to privacy policies!)

We do not and will never sell or share any user data with 3rd parties; we believe doing so is fundamentally wrong.  If you use Full Code as an individual, any data you provide to us will only ever be used to enhance your experience.

If you are using Full Code through a subscription paid-for by your school or employer — we do make your  detailed usage and scoring available to your educator/employer.  If you have questions about how that information is used, please ask your educator/employer.



This privacy policy is designed to inform users about the use of our simulations available at https://full-code.com including all sub-sites and micro-sites controlled by us, and any related smartphone or mobile applications (collectively, the “Service”), and in connection therewith, about how Minerva Medical Simulation Inc. (the “Company”, “we” or “us”) gathers and uses personal information submitted to the Company through the Service. The Company will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with all applicable U.S. laws. In this policy, “user” or “you” means any person viewing the Service or submitting any personal information to the Company in connection with using the Service.

By accessing our website or using the Service, or by otherwise providing us with your personally identifying information, you are accepting the practices and policies described in the Privacy Policy. If you do not agree to these terms, do not use the Service. Our Privacy Policy may change from time to time, and any changes will be posted on this page, and if the changes are significant, we will provide a more prominent notice. If you have questions or concerns regarding the Privacy Policy, you should first contact us at support@full-code.com.

Our Privacy Policy does not apply to services offered by other companies or individuals, including third party services used by the Company. For these third party services, we encourage you to familiarize yourself with the applicable third party privacy policies.

What Information Do We Collect?

Personal Information: If you sign up to create an account, we may ask you for certain personal information for the account, including the name of the individual creating the account, medical/professional role, institutional affiliations and payment information such as credit card number and credit card billing address. (the “Personal Information”). In addition, if you contact the Company and disclose additional personal information, we may store that Personal Information.

User Data: When you use the Service, you may transmit to the Company certain user-specific data (“User Data”) that we use to provide the Service, including to but not limited to your operating and systems environment, your use of the Service, and additional information that the Service allows you to input, such as scoring and performance within simulation scenarios.

Web Tracking Information: We, and third party service providers that we engage to provide services to us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited the Company website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications, and our Contractors may also do so. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Service, but this may affect the performance of the Service.

How Do We Use the Information We Collect?

Personal Information: We will use and store Personal Information for the purpose of delivering the Service (including to establish or renew your Company account), and to analyze and enhance the operation of the Service. We may enter Personal Information into our contact management database, and may use such database to send you marketing materials and to contact you regarding your interest in the Company products and services.

User Data: We will use the User Data to provide the Service. We may aggregate User Data across all or a subset of users to create statistical information relating to the use of the Service, as described in “Aggregate Information” below.

Aggregate Information: We will also create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data is derived from Personal Information and User Data but in its aggregated form it does not relate to or identify any particular client or individual or any specific user’s data. This data is used to understand our customer base and to develop, improve and market our services.

Web Tracking Information: We use Web Tracking Information to administer the Service and to understand how well our Service is working, to store your user preferences, and to develop statistical information on usage of the Service. This allows us to determine which features users like best to help us improve our Service, to personalize your user experience, and to measure overall effectiveness.

Legal Exception: Notwithstanding the above, the Company may use Personal Information and User Data to the extent required by law or legal process, or if in the Company’s reasonable discretion use is necessary to investigate fraud or any threat to the safety of any individual, to protect the Company’s legal rights or to protect the rights of third parties.

What Information Do We Disclose to Third Parties?

The Company’s Disclosure of Personal Information: The Company will not disclose Personal Information to any third party except to our Contractors who are bound by written obligations of confidentiality, or as described under “Permitted Disclosures” below.

User Data: We only disclose User Data to any the designated administrators of the business entity that you establish via your account. Except as described above, we disclose User Data only to you, the user who submitted the User Data to the Company, to our Contractors who are bound by obligations of confidentiality, and as described under “Permitted Disclosures” below.

Web Tracking Information: We disclose Web Tracking Information to Contractors, in order to analyze the performance of the Service and the behavior of users, and to operate and improve the Service.

Aggregate Information: We may disclose aggregated data that does not contain Personal Information that identifies any particular user or person to any third parties, such as potential customers, business partners, advertisers, and funding sources, in order to describe our business and operations.

Permitted Disclosures: Notwithstanding the foregoing, the Company reserves the right to disclose any information the Company collects in connection with the Service, without further notice to you (a) to any successor to the Company’s business as a result of any merger, acquisition or similar transaction; and (b) to any law enforcement or regulatory authority to the extent required by law or if, in the Company’s reasonable discretion, disclosure is necessary to investigate fraud or any threat to the safety of any individual, to protect the Company’s legal rights or to protect the rights of third parties.

How Can You Opt Out of Use and Disclosure of Your Information?

If you would like your Personal Information removed from our mailing list or database, please contact us at support@full-code.com. In the event of any such removal, the Company may retain copies of information for its archives.

Access and Updating of Information: You can update your Personal Information by using the profile editing tools on the Service. The Company will respond to any reasonable request by a user to review or amend his or her Personal Information held in our mailing list or database. The Company reserves the right to verify your identity in order to provide such access.

Security: We use reasonable security precautions to protect the security and integrity of your Personal Information and User Data in accordance with this policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

Links: The Service may contain links to other websites. The Company is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our site and review the privacy statements of each Web site they visit that collects information. This Privacy Policy applies solely to personal information collected by the Company.

Amendments: The Company may modify or amend this policy from time to time. If we make any material changes, as determined by the Company, in the way in which Personal Information or User Data is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the Service.

Children: The Company does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Website is directed at persons under 18. If you are under 18 years of age, then please do not use the Website. If The Company learns that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then The Company will take the appropriate steps to delete this information. To make such a request, please contact us at support@full-code.com.

California Online Privacy Protection Act Notice:

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to “Do Not Track Signals”; and whether third parties collect personally identifiable information about users when they visit us.
(1) We do not track users who do not interact with sharing functionality across the web, and therefore do not use “do not track” signals.
(2) We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate member consent.

California Civil Code Section 1798.83 also permits our customers 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 send an email to support@minerva-medical.com. Please note that we are only required to respond to one request per customer each year.

Service Visitors from outside the United States: The Company and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access the Service, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

Terms of Use: This policy forms part of, and is subject to, the provisions of the Company’s Terms of Service available at https://full-code.com/terms-of-use/


Effective Date of this policy: Oct. 9, 2018