Effective Date: 25 May, 2018 (last updated 25 May, 2018)
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.
Your California Privacy Rights: If you reside in California, you 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 firstname.lastname@example.org. 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.
Information We Collect
We and third-party service providers may collect information from you including your name, address, phone number and email address 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 also collect information such as:
- 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.
- Geographic location information – identifying only city level, state and country.
- Demographic information and other non-personally identifiable information provided by you.
- Information about how you use the Properties.
- Aggregated information.
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 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).
How We Use Data
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 to 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 learning about trends, sentiment, changes in health practice which are generally used by our clients to assist in their in marketing communications, clinical trial recruitment, risk and reputation management and investor relations
- For other reasons we may describe to you.
How Information may be disclosed
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.
- 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.
Where consultants, 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, typically standard contractual clauses
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.
We keep information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law.
Choices And Access
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 by clicking on the link here. 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 by email at email@example.com.
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. 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.
EU users and our “lawful basis” for using their data
Data protection law in Europe contains a number of “lawful bases” – which are really legal justifications which mean organizations like us are allowed to have personal information in the first place. 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:
We sometimes require 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 interests basis in order to comply with our contractual commitments to our corporate clients.
We analyze how users interact with our website so we can understand better what elements of the design are working well and which are not working so well. This allows to improve and develop the quality of the online experience we offer our users.
Research Service and patients – where EU individuals have posted on social media details of their medical conditions and treatment, this constitutes a “special category” of personal data, in respect of which we rely on the lawful basis that the data has been manifestly made public by the data subject. If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html ).
EU supervisory authorities
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 http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.
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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.
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