INFORMATION WE COLLECT AND HOW WE USE IT
“Personal Information” means any information or set of information that identifies or could be used to identify you, either directly or indirectly. Personal Information does not include information that is anonymized such that an individual cannot be identified.
Personal Information collected by the Sites may include name, address, contact numbers, and email address, but may also include other information you may choose to provide us with (for example, to provide a requested service, where an employment opportunity is being processed or where a health professional is interested in participating in a clinical trial). You may voluntarily provide us with Personal Information (1) to receive additional information about Precision (ie, newsletters, press releases, marketing materials), (2) if you are interested in pursuing an employment opportunity with Precision, or if you are interested in providing clinical trial investigator services to Precision, (3) to receive access to webcasts, or to receive customized information (usually through the “Contact Us” form).
Precision also collects Personal Information about your computer hardware and software. including, but not limited to, your computer operating system, your Internet Protocol (IP) address, Internet browser, and information regarding your interactions and navigation within the Sites. Our web server automatically collects this category of Personal Information when you make a request to view pages within our Sites.
Use of Personal Information
Such processing of your Personal Information is based:
- On your consent, when you voluntarily subscribe or provide us with Personal Information e.g. to receive information from Precision; or
- On Precision’s legitimate interest to monitor audience and quality of its websites.
Also, any marketing communications sent by Precision have an automatic opt-out link at the bottom of each communication. You may elect to remove yourself from further informational communications at any time by selecting and confirming this link.
INTERNAL AND EXTERNAL DISCLOSURES OF PERSONAL INFORMATION
Personal information will be shared within Precision, companies working as agents of Precision, and third parties only on a “need to know” basis to meet stated legitimate business purposes. Access to databases and folders containing Personal Information is restricted to appropriate staff. Precision does not trade or sell personal information. Under some circumstances, Precision may be required by law enforcement or judicial authorities to disclose certain personal information as part of investigations or for litigation purposes. Precision may disclose Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Precision’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Companies working as agents of Precision are required to sign “processor” and/or confidentiality agreements whereby they will commit to only process Personal Information consistent with contracted purposes and apply appropriate organizational and technical security safeguards.
If disclosure of your Personal Information under the conditions above involves transfer of your Personal Information to countries that were not recognized as providing an adequate level of protection of Personal Information pursuant to the rules applicable in your country, Precision will set up appropriate guarantees to secure your Personal Information in the context of such transfer. In particular, transfers to Precision’s affiliates in the USA are covered by Precision’s Privacy Shield commitments as described in Precision’s Privacy Shield Policy statement below.
COOKIES AND OTHER ANONYMOUS WEB-TRACKING METHODS
In particular, Precision may use session ID cookies and persistent cookies. Session ID cookies may be used to personalize and improve your user experience while viewing our Sites. Session ID cookies are deleted from your hard drive when you terminate your browser session. Persistent cookies may be utilized to collect Non-Personal Information in the form of IP address, Internet Service Provider (ISP), your browser type, platform type, web page navigation, and date/time stamp.
Your IP address is utilized so that we can send you data such as the web pages you have requested, and we may use your browser and platform type to ensure that the data we send to you is properly formatted and displayed. We may aggregate this information with data on the pages visited by other users to track page navigation, site usage, and overall user behaviors associated with our Sites. This data aids in our understanding of how users are using our Sites in terms of page navigation and most frequently requested site pages. Understanding this information enables us to provide you with improved site use and functionality.
Our Sites may contain hyperlinks allowing you to access other websites owned by us and our affiliated companies. Our Sites may also contain hyperlinks to websites owned by our third-party vendors, distributors, and providers (“Linked Sites”). We may provide hyperlinks to the Linked Sites to enable you to conveniently access websites that may be of interest to you. However, once you click on a hyperlink that transfers you from our Sites to a Linked Site, Precision is not responsible for the privacy practices or the content of such Linked Sites.
We are committed to protecting the privacy and security of the Sites. Precision endeavors to protect against the loss, misuse, and alteration of your Personal Information. We have reasonable technical and procedural measures in place to protect any and all information that we receive. Our technical infrastructure that provides the Sites is protected using industry-recognized commercial security products. The maintenance and monitoring of the Sites is aligned with best practices. It should be understood that no methods or procedures for securing Internet-based transmission or storage of data can be claimed to be 100% secure. While we utilize commercially acceptable technology and take reasonable precautions to protect your information, we do not guarantee its absolute security.
EU-US & Swiss-US Privacy Shield
Precision complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union member countries and Switzerland to the United States, respectively. Precision has certified that it adheres to the Privacy Shield Principles. If there is any conflict between this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certifications, please visit www.privacyshield.gov.
Precision’s certification to the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework is on behalf of the following entities:
|· Precision Medicine Group Holdings, Inc.
· Precision Medicine Group, LLC
· Precision Regulatory and Translational Sciences, Inc.
· Precision Bioservices, Inc.
· Precision Oncology, LLC
· Agility Clinical, Inc.
· PMG International Holdings, Inc.
· Ethos Health Communications, Inc.
· Insight Strategy Advisors, LLC
|· Precision Value and Health, Inc.
· Precision for Value, LLC
· Precision for Value (New Jersey), LLC
· Precision for Value (New York), LLC
· Precision for Value (Los Angeles), LLC
· Precision for Value (Chicago), LLC
· Precision Promotional Effectiveness, LLC
· Precision Advisors, LLC
· Precision Health Economics, LLC
· Precision Health Economics (Washington), Inc.
· Precision Effect, Inc.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, Precision is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Precision may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
As per applicable data protection laws and regulations, you rights regarding our processing of your Personal Information are outlined below. You may exercise these rights by contacting Precision at the following contact address: email@example.com. These rights being purely personal, they may only be exercised by the data subject themselves. Please, therefore, attach a copy of a valid ID document to your request; we will only retain that copy for the time necessary to verify your identify.
Right of access
You may request access to your Personal Information that is processed by Precision. In that case, we will provide you with a copy of all of your Personal Information we retain as of the date of your request, together with all mandatory information regarding processing of this data, namely:
- The categories of collected and processed Personal Information;
- The purposes of its processing;
- The categories of data recipients;
- The data retention period;
- Information regarding your rights as data subject.
- Right to data portability
This right differs from the right of access in that (i) it only covers Personal Information Precision collected from you and (ii) it allows you to obtain a copy of your Personal Information in a structured, machine-readable format.
The right to data portability also allows you to request transmission of such Personal Information to another data controller, at your own choice, to the extent that it is technically feasible.
Right of correction
You have a right to request correction of your Personal Information if said Personal Information appears inaccurate, incomplete or outdated.
Right to erasure
You may request erasure of your Personal Information from Precision’s and its processors’ servers and files in the following cases:
- In case your Personal Information is no longer necessary for the purposes for which it has been collected and processed;
- In case you have withdrawn your consent pursuant to the “Right to withdraw consent” section hereunder and there is no other legal basis for the processing;
- In case you have objected to the processing of your Personal Information pursuant to the “Right to object to processing” section hereunder;
- In case the processing of your Personal Information is illicit;
- In case your Personal Information must be erased by Precision in order to comply with its legal obligations;
- In case you were a minor at the time of collection of your Personal Information on the Sites.
If that Personal Information has been shared with third parties, Precision shall inform these third parties of your request for erasure, to the extent that it is feasible.
Right to object to processing
- Precision’s or a third party’s legitimate interest, or
- performance of a task carried out in the public interest or in the exercise of official authority vested in Precision,
you have a right to object to such processing on grounds relating to your particular situation.
Right to limitation of processing
You may request limitation of processing of your Personal Information in the following cases:
- In case you request correction of your Personal Information pursuant to the “Right of Correction” section above, for the duration necessary to check that Personal Information;
- In case processing is illicit and you prefer to limit it rather than erasing the concerned Personal Information;
- In case you want Precision to retain your Personal Information in order for you to use it in the context of a judicial claim; or
- In case you have objected to the processing of your Personal Information by Precision pursuant to the “Right to object to processing” section above, for the period necessary for Precision to assess the grounds relating to your particular situation.
Precision will in such case cease to process the concerned Personal Information and retain them for the appropriate duration.
Right to withdraw consent
Right to lodge a complaint with a supervisory authority
You also have a right to lodge a complaint relating to the processing of your Personal Information by Precision with the competent supervisory authority in your country.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our users who are residents of the State of California to annually request and obtain, at no charge, information about the personal information (if any) we have disclosed to third parties for direct marketing purposes in the preceding calendar year. This information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which information was shared in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to firstname.lastname@example.org or 866-994-0511
Questions or comments regarding this Policy should be submitted to Precision’s Privacy Office by mail to:
Precision Medicine Group, LLC
Attn: Privacy Office
2 Bethesda Metro Center, Suite 850
Bethesda, MD 20814
or by e-mail to Precision’s Privacy Office: email@example.com
Precision has appointed Dr. Karl Kleine as its Data Protection Officer (DPO). You may reach Precision’s DPO at DPO@precisionmedicinegrp.com.
EU-U.S. PRIVACY SHIELD EFFECTIVE DATE: 10/11/2016
SWISS-U.S. PRIVACY SHIELD EFFECTIVE DATE: 12/21/2017