© 2024 Miracle Corporation
This page was last updated on May 14, 2026.
This privacy notice for Miracle Corporation (”we”, “us”, or “our”), describes how and why we might collect, store, use, and/or share (”process”) your information when you use our services (”Services”), such as when you:
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at security@miracleml.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information. However, if you use certain AI-powered features of our Services that may process health-related or other sensitive inputs, please see Section 12 (HIPAA and Health-Related Data) of this notice for important information.
Do we receive any information from third parties? We do not receive any information from third parties. How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting http://www.miracleml.com/contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Do we respond to Global Privacy Control (GPC) signals? As required by applicable law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), we honor Global Privacy Control (GPC) opt-out preference signals. When we detect a GPC signal from your browser or device, we will treat that signal as a valid request to opt out of the sale or sharing of your personal information for that browser and device. See Section 10 for further details
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Sensitive Information. We do not process sensitive information. If you voluntarily submit information through AI-powered features of our Services that may constitute sensitive personal information under applicable law (such as health or medical information), please review Section 12 (HIPAA and Health-Related Data) of this notice. We strongly recommend that you do not submit sensitive personal information through general features of our Services unless that feature is specifically designated as compliant with applicable law and your submission is expressly required for the Service.
Platform Clinical Trial Data. Where Miracle processes clinical trial operational data on behalf of a customer pursuant to a License Agreement and Data Processing Agreement (DPA), such data typically consists of blinded subject identifiers and read-only operational data integrated from customer systems (e.g., EDC, RTSM/IRT, laboratory systems). This data does not constitute personal information about platform users and is processed by Miracle solely as a data processor acting on behalf of the applicable customer as data controller. Such processing is governed by the applicable License Agreement and DPA and is not subject to the general terms of this privacy notice.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: http://www.miracleml.com/legal/cookie-policy.
We also recognize and honor browser-based Global Privacy Control (GPC) signals as opt-out requests from the sale or sharing of personal information, consistent with requirements under California, Colorado, Connecticut, and other applicable state laws. See Section 10 for further details.
The information we collect includes:
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
Under the frameworks of the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, Miracle acknowledges that it is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC). This includes compliance with the principles required by these frameworks for the protection of personal data transferred from the European Union, the United Kingdom, and Switzerland to the United States. We commit to adhering to these principles and to being accountable for the processing of personal data received under these frameworks. In case of any conflict between the policies in this privacy notice and the DPF Principles, the DPF Principles shall govern.
Data Processor Role. Where Miracle processes personal data on behalf of a customer pursuant to a License Agreement and DPA, Miracle acts as a data processor and the applicable customer acts as the data controller with respect to that data. In such cases, Miracle's processing is governed by the instructions of the data controller and the terms of the applicable DPA. The legal bases described in this section apply to Miracle's processing activities as a data controller in its own right — primarily in connection with the public marketing website, sales and marketing communications, and platform user account management.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Miracle Corporation complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Miracle Corporation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Miracle Corporation has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/
EU AI Act Transparency Notice. Where Miracle Corporation deploys AI systems that are placed on the EU market or put into service in the EU within the meaning of the EU AI Act (Regulation (EU) 2024/1689), we are committed to transparency regarding our use of AI and automated decision-making. Where our Services use AI systems that produce outputs that affect you, we will disclose this and, where required by applicable law, provide information about the logic involved, the data used, and the significance of such processing for you.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. For vendors processing personal data on our behalf in the EU or UK, these contracts include data processing agreements (DPAs) meeting the requirements of GDPR Article 28 and, where applicable, incorporate standard contractual clauses (SCCs) approved by the European Commission for international data transfers. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
The categories of third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We use cookies and similar tracking technologies including web beacons, pixels, local storage, session storage, and server-side event tracking to collect and store information. Non-essential cookies are only set after you have provided valid consent through our cookie consent banner.
Full details of all cookies in use — including cookie names, providers, durations, legal bases, and third-party transfer information — are set out in our Cookie Policy at https://www.miracleml.com/legal/cookie-policy.
Global Privacy Control (GPC) Signals. We honor GPC opt-out signals as legally required. When we detect a GPC signal from your browser or device, we will process it as an opt-out from the sale or sharing of your personal information. See Section 10 for full details.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Retention of Platform Data Governed by Customer Agreements: Where Miracle processes clinical trial operational data or other data on behalf of a customer pursuant to a License Agreement and DPA, the retention and deletion of that data is governed by the applicable agreement. Miracle acts as a data processor with respect to such data and retains it only for as long as directed by the applicable customer agreement or required by law. Blinded subject identifiers and read-only clinical trial data integrated from customer systems are retained solely for the purposes specified in the applicable License Agreement and are not used for Miracle's own business purposes beyond what is permitted under that agreement.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include, as appropriate: encryption of data in transit and at rest, access controls, employee training, and regular security assessments. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
Data Breach Notification. In the event of a data breach that affects your personal information, we will notify you and applicable regulators as required by applicable law, including GDPR Article 33-34, applicable US state data breach notification laws, and any other legal requirements. Notification will be provided within the timeframes required by applicable law.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect personal information from individuals under the age of 18. If we learn that personal information from a person under 18 has been collected, we will promptly delete it. If you become aware of any data we may have collected from children under age 18, please contact us at security@miracleml.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. Residents of certain U.S. states also have specific privacy rights. See Section 11 (U.S. STATE PRIVACY RIGHTS) for state-specific rights. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (vi) if applicable, to data portability; and (vii) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Miracle Corporation commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the "unsubscribe" link in any marketing email, replying "STOP" to any SMS messages that we send, or by contacting using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice: http://www.miracleml.com/legal/cookie-policy. You may also manage your cookie preferences at any time by clicking the "Cookie Settings" link in the footer of our website, or by activating a Global Privacy Control (GPC) signal on your browser as described in Section 10.
If you have questions or comments about your privacy rights, you may email us at security@miracleml.com.
As a last resort and under limited circumstances, if your DPF complaint cannot be resolved through the above channels, EU, UK and Swiss individuals may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.
See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do honor GPC opt-out signals as legally required. When our Services detect a GPC signal transmitted by your browser or device, we treat this as a valid request to opt out of the sale or sharing of your personal information, consistent with the requirements of the California Consumer Privacy Act (CCPA/CPRA), Cal. Civ. Code § 1798.135(b), and any other state law requiring recognition of GPC signals (currently including Colorado and Connecticut). This opt-out applies to the specific browser and device sending the signal. Note that GPC opt-out does not automatically opt you out of all data processing — it applies specifically to "sale" and "sharing" of personal information as defined under applicable state law. If additional standards for online tracking are adopted that we must follow, we will update this notice accordingly.
11. EU, UK, AND SWISS PRIVACY RIGHTS
In Short: If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have specific rights under applicable data protection law regarding your personal information. This section describes those rights, how to exercise them, our legal bases for processing your data, and how we ensure lawful cross-border data transfers to the United States.
APPLICABILITY: This section applies to you if you are located in:
Where this section refers to "GDPR," it encompasses the EU GDPR, UK GDPR, and Swiss revFADP unless a distinction is expressly noted.
LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA: We process your personal data only where we have a valid legal basis under applicable law:
Consent: Where you have given specific, informed, freely given, and unambiguous consent for a defined purpose. You may withdraw consent at any time by contacting security@miracleml.com without affecting the lawfulness of prior processing.
Performance of a Contract: Where processing is necessary to perform a contract to which you are a party, or to take steps at your request prior to entering into a contract, including providing access to and use of our clinical trial data platform and Services.
Legitimate Interests: Where processing is necessary for our legitimate business interests — including improving and securing our Services, communicating with customers about product updates, and conducting internal analytics — provided those interests are not overridden by your rights and freedoms. You have the right to object to such processing as described in Section 10A.3.
Legal Obligations: Where processing is necessary to comply with a legal obligation, including cooperation with regulatory authorities and compliance with court orders.
Vital Interests: Where processing is necessary to protect your vital interests or those of another natural person.
Special Category Data: We do not intentionally collect or process special category personal data through our general Services. Where designated HIPAA-compliant features of our platform involve health-related data processed pursuant to a Business Associate Agreement (BAA), that processing is governed by the applicable BAA and your organization's License Agreement with Miracle. See Section 12 for further information.
Automated Decision-Making: Where AI/ML features of our platform produce decisions with legal or similarly significant effects on you, you have the right to: (a) not be subject to such solely automated decision-making; (b) obtain human review of such decisions; and (c) receive a clear explanation of the logic involved and its likely consequences. Contact security@miracleml.com to exercise these rights.
YOUR RIGHTS UNDER GDPR, UK GDPR, AND SWISS revFADP: Subject to applicable law and certain exceptions, you have the following rights:
Swiss-Specific Rights (revFADP): Under the Swiss revised Federal Act on Data Protection (revFADP), in force since September 1, 2023, you have substantively equivalent rights to those described above. Additionally:
UK-Specific Notes (UK GDPR / DPA 2018): UK GDPR rights are substantively equivalent to those described in the table above. The following UK-specific points apply:
HOW TO EXERCISE YOUR RIGHTS: To exercise any of the rights described in Section 10A.3, please contact us using the methods set out in Section 14 (How Can You Contact Us About This Notice?) of this privacy notice. When submitting your request, please use the subject line "GDPR / UK GDPR / Swiss revFADP — Data Subject Request" and clearly identify: (a) the right or rights you wish to exercise; (b) sufficient information to allow us to identify you in our systems; and (c) any specific personal data to which your request relates.
Response Timeframe: We will respond within one (1) calendar month of receipt, as required by GDPR Article 12(3). Where complexity or volume justifies it, this period may be extended by a further two (2) months, with notice to you within the initial one-month period stating the reasons for the extension.
Platform Data Governed by a Customer DPA: Where Miracle processes your personal data as a data processor on behalf of one of our customers under a License Agreement and Data Processing Agreement (DPA), we may need to refer your request to that customer as the data controller rather than acting on it directly. We will inform you of this without undue delay and, where possible, provide you with the relevant contact information for the applicable data controller.
RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY: You have the right to lodge a complaint with your competent data protection supervisory authority at any time if you believe our processing of your personal data infringes applicable law. We would appreciate the opportunity to address your concern first, please contact us at security@miracleml.com before approaching a supervisory authority.
In compliance with the EU-U.S. DPF, UK Extension, and Swiss-U.S. DPF, Miracle Corporation commits to cooperate with and comply with the advice of the EU DPAs, UK ICO, and Swiss FDPIC with regard to unresolved complaints concerning personal data received under the applicable DPF framework.
INTERNATIONAL DATA TRANSFERS: Miracle Corporation is headquartered in the United States. Personal data received from individuals in the EEA, UK, or Switzerland is transferred to and processed in the United States. We rely on the following lawful transfer mechanisms:
A. Data Privacy Framework (DPF): Miracle Corporation complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF as set forth by the U.S. Department of Commerce, and has certified its adherence to the applicable DPF Principles for each framework. In the event of any conflict between this notice and the applicable DPF Principles, the DPF Principles govern. Miracle Corporation is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to its DPF obligations. To view our DPF certification, visit: https://www.dataprivacyframework.gov/
B. Standard Contractual Clauses (SCCs) / IDTA: Where the DPF does not apply or does not cover a particular transfer, we rely on the Standard Contractual Clauses (SCCs) approved by the European Commission under Implementing Decision (EU) 2021/914 for EEA transfers, and the International Data Transfer Agreement (IDTA) approved by the UK ICO, or the UK Addendum to the EU SCCs, for UK transfers. Where required, we conduct Transfer Impact Assessments (TIAs) and implement supplementary measures before any transfer takes place.
C. EU AI Act: Where Miracle deploys AI systems on the EU market within the meaning of Regulation (EU) 2024/1689, we commit to transparency regarding our use of AI, including disclosing where our Services use AI systems that produce outputs affecting you and providing information about the logic and significance of such processing where required by law. Our AI-powered features are not intended to replace clinical or professional judgment and should not be relied upon solely for patient care, trial management, or regulatory submission decisions.
DATA PROTECTION OFFICER / DESIGNATED PRIVACY CONTACT: For all GDPR, UK GDPR, Swiss revFADP, and DPF-related inquiries and data subject requests, please use the contact details set out in Section 14 (How Can You Contact Us About This Notice?) of this privacy notice, using the subject line "Privacy / DPO Inquiry."
EU Representative: Adam Brogden, Instant EU GDPR Representative Ltd, contact@gdprlocal.com, +353 15 549 700, Ireland
UK Representative: Adam Brogden, GDPR Local Ltd, contact@gdprlocal.com, +44 1772 217800, England
Swiss Representative: Adam Brogden, GDPRLocal Ltd., contact@gdprlocal.com, +353 15 549 700, Switzerland
12. U.S. STATE PRIVACY RIGHTS
In Short: If you are a resident of a U.S. state with a comprehensive consumer data privacy law (including but not limited to California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and others that may become effective), you may have specific rights regarding your personal information. These rights generally include the ability to access, correct, delete, or obtain a copy of your data; opt out of the sale or sharing of your personal information, targeted advertising, or certain profiling; and other protections as provided by applicable state law. We do not sell personal information and honor opt-out requests accordingly.
Applicability: This section applies to residents of states with comprehensive privacy laws in effect as of April 29, 2026. Rights and obligations vary slightly by state, but we endeavor to provide the strongest protections available under applicable law and treat all U.S. customers similarly.
Where Miracle processes clinical trial operational data on behalf of a customer as a data processor under a License Agreement and DPA, such processing is governed by the applicable customer agreement and applicable law. Miracle's obligations as a data processor with respect to such data are distinct from its obligations as a data controller with respect to platform user personal information addressed in this section.
Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by applicable law.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” in Section 4.
Your Rights (common across most applicable states, subject to verification and legal exceptions):
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contact us by email at security@miracleml.com, by visiting http://www.miracleml.com/contact, or by referring to the contact details in Section 14 below. If you have a complaint about how we handle your data, we would like to hear from you.
California-Specific Rights (CCPA/CPRA): In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in Section 14 below (or by visiting http://www.miracleml.com/contact).
If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided in Section 14 below (or by visiting http://www.miracleml.com/contact) and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
http://www.miracleml.com/contact
The California Code of Regulations defines a “resident” as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as “non-residents.”
What categories of personal information do we collect? We have collected the following categories of personal information in the past twelve (12) months:
We will use and retain the collected personal information as needed to provide the Services or for as long as the user has an account with us.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
13. HIPAA AND HEALTH-RELATED DATA
In Short: Miracle's platform primarily processes blinded operational clinical trial data on behalf of enterprise customers. This data consists of blinded subject identifiers and read-only data integrated from customer clinical systems (e.g., EDC, RTSM/IRT, laboratory systems) and does not constitute Protected Health Information (PHI) under HIPAA, 45 C.F.R. § 164.514, as it does not identify individual patients and Miracle does not possess the means to re-identify subjects from this data.
Miracle Corporation is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations. Where a customer specifically uses designated features of our platform to create, receive, maintain, or transmit identifiable Protected Health Information (PHI) on behalf of a HIPAA covered entity, a valid Business Associate Agreement (BAA) must be executed with Miracle prior to any such use. Miracle does not act as a HIPAA business associate with respect to blinded or de-identified clinical trial data that does not constitute PHI. To inquire about BAA eligibility or designated HIPAA-compliant features, please contact security@miracleml.com. We offer BAAs for certain designated AI-powered features upon request, contact security@miracleml.com to discuss.
Users should not submit identifiable patient data, Protected Health Information, or other regulated health data through general features of the platform that are not expressly designated as HIPAA-compliant. Any such submission is at the user's own risk. Miracle strongly recommends that all health-related data submissions be made only through features expressly designated and contracted for HIPAA-compliant use. We may de-identify such data where feasible and use it solely for the purposes described herein, consistent with applicable law. We do not use PHI for AI model training without explicit consent or as permitted under a BAA.
In the event of any conflict with HIPAA requirements, HIPAA shall govern with respect to PHI. We maintain appropriate safeguards and will notify you and regulators of any reportable breach involving PHI as required by law. For more information or to request a BAA, please contact us at security@miracleml.com.
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at security@miracleml.com or contact us by post at:
Miracle Corporation
2261 Market Street #5076
San Francisco, CA 94114
United States
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Miracle Corporation commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Miracle Corporation at:
Miracle Corporation, security@miracleml.com
EU Representative: Adam Brogden, Instant EU GDPR Representative Ltd, contact@gdprlocal.com, +353 15 549 700, Ireland
UK Representative: Adam Brogden, GDPR Local Ltd, contact@gdprlocal.com, +44 1772 217800, England
Swiss Representative: Adam Brogden, GDPRLocal Ltd., contact@gdprlocal.com, +353 15 549 700, Switzerland
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: http://www.miracleml.com/contact.