Effective Date: January 1, 2020
These Properties are Not Intended for Children: Our sites are meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or legal guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at email@example.com. You can also write to us at the address listed at the end of this Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.
We and third-party service providers may collect information from you when you interact with the Properties including when you, for example, post on a public space on our Properties, make a request, register for newsletters or other communications through the Properties, participate in surveys or in a blog, submit a job application, as part of employee onboarding or when you contact us. We may also collect information from you if you attend our trade shows or events.
We and third-party service providers may collect and share information including:
|Category of Information||Source of information and Business Purpose||Categories of Third Parties with whom we share|
|Identifiers such as a real name, postal address, unique personal identifier, email address, social security number, or other similar identifiers||
Directly from you in the case of sign-ups for newsletter or events, or applications for employment
From publicly available sources such as social media where permitted by law for research purposes
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, browser and device information including mobile device type, mobile network, IP address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions and operating system
Information about how you use the Properties.
Geographic location information – identifying only city level, state and country.
Collected when you interact with our internet properties, or the internet properties of W2O Clients, for the purposes of research and direct marketing
From publicly available sources such as social media where permitted by law for research purposes
From Service Providers and Vendors for the purposes of direct marketing such as online advertising
As part of our Research Services, including our health ecosystem mapping business, MDigital Life – http://mdigitallife.com/ – we provide market research and insight to life sciences, pharmaceutical and medical devices companies. To do this, we collect and retain publicly available information relating to doctors, other medical professionals, experts and influencers, patients, advocacy organizations and reporters from various sources, including social media platforms like Twitter and LinkedIn, third party . This information typically comprises:
- In relation to medical professionals, their name, contact detail, hospitals, universities or other institutions they work for or are affiliated with, their area of specialization and, where publicly available, their prescribing record and other elements of their professional practice.
- In relation to any individual, including patients, the information they decide to make available online, including through social media (and in particular Twitter and LinkedIn), and typically comprising their name, social media handle, medical condition and/or treatment (where a patient), relevant public posts and views on matters relevant to health, medical treatment, procedures and responses and reactions to them and their digital footprint (the range, subject matter focus and other details of their influence and visibility online)
- W2O does not collect or use the data of anyone under the age of 18 without the affirmative action of a parent or guardian or as otherwise permitted by law.
We and third-party service providers may use information:
- To respond to your inquiries and fulfill your requests.
- To administer sweepstakes, contests and other promotions.
- To send you administrative information, including information regarding the Properties.
- To send to you, through us or third-party service providers, marketing communications that we believe may be of interest to you.
- For our business purposes including, without limitation, data analysis, product development, enhancing the Properties, improving our services, processing applications and determining the effectiveness of promotional campaigns.
- As we believe necessary or appropriate: (1) under applicable law; (2) to comply with legal processes; (3) to respond to requests from public or government authorities; (4) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; or (5) to allow us to pursue available remedies or limit the damages that we may sustain.
- In providing the Research Services, we analyze the public postings and comments of individuals whose data we process and extract observations and learnings about trends, sentiment, and changes in health practice which are generally used by our clients to assist in their marketing and medical communications, clinical trial recruitment, risk and reputation management and investor relations.
- For other reasons we may describe to you.
Information may be disclosed:
- To providers who facilitate you making online applications for jobs with us via our Properties, including Greenhouse Software (https://www.greenhouse.io) and EnBoarder (https://enboarder.com). They use your data under their own privacy policies accessible at https://www.greenhouse.io/legal and https://enboarder.com/privacy respectively.
- When permitted by law, to our affiliates (including within our W2O Group of companies), business partners and clients, to permit them to send communications such as marketing content, information on co-sponsored programs and details on events and products (subject always to users’ rights to control our sending of promotional communications where required by law).
- With third party social media, analytics and digital advertising partners whose technologies interact with our Properties and who support our operation of the Properties and who also collect non-identifiable information about you and use it for their own purposes and those of their other clients (including to support interest-based advertising). Please our Ad & Cookies Policy to understand more about these relationships and how you can opt-out of this data sharing.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding).
- As we believe necessary or appropriate: (1) under applicable law; (2) to comply with legal processes; (3) to respond to requests from public or government authorities; (4) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (5) to allow us to pursue available remedies or limit the damages that we may sustain; (6) to investigate potential fraud, including fraud we think has happened during a sweepstakes or promotion; or (7) to share your information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
We use standard security measures. The Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords.
You have choices about how we use your information. You may opt-out from receiving marketing-related emails from us and our affiliates: If you do not want to receive marketing-related emails from us and our affiliates on a going-forward basis, you may opt-out from receiving such emails either by using the unsubscribe mechanism provided in the email or through the form below. We will try to comply with your request(s) as soon as reasonably practicable.
Please note that, if you opt-out as described above, we will not be able to remove your information from the databases of unaffiliated third parties with which we have already shared your information as of the date that we implement your opt-out request.
You can change or remove your Information and Posted Content. If you would like to review, correct, update, suppress or delete the information that you have previously provided to us or have made available on a Property, you may contact us using the general contact form below.
Please make clear what information or posted content you would like to have changed or removed. We will try to comply with your request as soon as reasonably practicable, and as required by applicable law. Please note that such request does not ensure the complete or comprehensive removal of information or content posted on a Property as we may need to retain certain information or content for recordkeeping purposes, and there may also be residual information or content that will remain within our databases and other records that will not be removed. We are also not responsible for changing, removing or suppressing information or content from the databases of unaffiliated third parties with which we have already shared your information or content.
Your California Privacy Rights: If you reside in California, you have several statutory privacy rights under the California Consume Privacy Act (CCPA).
- Right to Know: The categories of personal information we collect is listed on this page in the Information We Collect section. W2O does not process or sell the information of minors under 18 without affirmative authorization of a parent or legal guardian.
- California residents have the right to request that we disclose what personal information we have collected, used and sold within the last 12 months. You may request the categories of information, or the specific pieces of information using this form.
- Right to Delete: California residents have the right to request the deletion of their personal information. You may submit a deletion request using this form.
- Right to Opt Out: California residents have the right to opt out of the sale of their personal information. You may submit an opt out request using this form.
- Right to Non-Discrimination: California residents have the right not to receive discriminatory treatment for the exercise of these rights. W2O does not discriminate or change service levels in any way for anyone exercising their privacy rights.
- Authorized Agent: California residents have the right to designate an authorized agent in order to make requests under CCPA on their behalf. When using an authorized agent, a notarized statement signed by both you and your designated agent must be provided. Please use firstname.lastname@example.org to submit any requests using an authorized agent.
Employees of W2O Group, job applicants, and contractors are currently exempt from CCPA under Assembly Bill 25, except for information category requests.
California residents also have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at email@example.com. or write to us at the address listed below. Indicate in your letter or email that you are a California resident making a “Shine the Light” inquiry.
Lawful Basis: Data protection law in Europe contains a number of “lawful bases” – which are legal justifications which mean organizations like us are allowed to have and use personal information. For our EU users and other EU individuals whose personal data we process, we have been careful to ensure we have a lawful basis for all data we have. Our lawful bases include:
- Legitimate Interest: We sometimes use your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will send promotional communications about our service, subject to EU users’ legal rights to control whether we do so. We also collect and use information as part of our Research Services on a legitimate interest basis in order to comply with our contractual commitments to our corporate clients. We also collect information as part of employment application processes.
- Research Service – where EU individuals have posted on social media publicly available details of their medical conditions, treatment, and other health information, this constitutes a “special category” of personal data in respect of which we rely on the lawful basis of legitimate interest for research purposes, and that the data has been manifestly made public by the data subject (Article 9, 2(e)). W2O uses appropriate safeguards including encryption and pseudonymization to protect the data we collect and the rights of data subjects.
- Consent: In certain circumstances such as when you sign up for a newsletter or event through our website, when submitting your contact and other information you’ll be asked for your consent for us to process your data for that specific purpose.
The categories of data we collect are available on this page in the Information We Collect section.
The GDPR provides several rights to users located in the European Union, including:
- Right to Access: You have the right to access the data about you that we hold.
- Right to Rectification: If you believe the data we hold on you is incorrect, you can tell us and we’ll correct it.
- Right to Object and Withdraw Consent: You have the right to object to the use of your data for direct marketing – in which case you may withdraw your consent by opt out or unsubscribe in the marketing itself. You may also object to our processing in instances where our lawful basis is legitimate interest.
- Right to Restrict Processing: There are certain circumstances in which you can request we suspend the processing of your personal data.
- Right to Erasure (Right to be forgotten): You have the right to request that we delete your data, and we will do so provided we do not have a legal obligation to keep it.
- Right to Data Portability: In cases where we process your information under the legal basis of consent, you can obtain a copy of your data in a commonly used and machine-readable format
- Rights Related to Automated Decision Making: W2O does not use automated decision making that has legal or similarly significant effects on you.
To exercise these rights, you may submit an access request via these forms:
Where W2O or our service providers and consultants process the personal data of EU or UK users outside the European Economic Area, and in particular in the United States our policy is to have an appropriate legal mechanism in place to ensure that transfer of personal data is in compliance with European data protection law, including the use of standard contractual data protection clauses, or in some cases approved certification mechanisms.
For our EU users, the Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data. For EU users outside the UK, you may approach your local data protection authority – see https://edpb.europa.eu/about-edpb/board/members_en
In circumstances where W2O acts as a controller:W2O Group
199 Water Street
New York, NY 10038
Data Protection Officer
Dan Linton – Global Data Privacy OfficerW2O Group
30 S 15th St, 11th Floor
Philadelphia, PA 19102
You may also contact us by email at firstname.lastname@example.org or write to the following address:W2O Group
199 Water Street
New York, NY 10038
You may also call us toll free: 1-800-485-5071
Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.
A printable version of this policy is available here.
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