Updated January 1, 2022
2. How Do We Collect Personal Information From Users of Our Services?
(i) When You Actively Submit Personal Information. We collect certain types of personal information when you interact with our Services, such as when you:
- Register for an account on any Service or update your profile information;
- Participate in a medical education activity;
- Participate in or respond to an online survey;
- Request the following from us:
- information about patient assistance resources, medical education activities, and other medical communications;
- customer or technical support;
- Submit comments, reviews, or other user-generated content on our Services; or
- Otherwise submit personal information to us via the Services.
The personal information We collect through active submission includes your name, email address, mailing address, telephone number, certain information related to your profession (e.g., specialty, education, hospital affiliation, etc.), and any other personal information that you actively submit to us. In each such instance, you will know what personal information We collect, because you actively submit it. We endeavor to clearly label which information is required and which information is optional in all cases. If you are unable or choose not to provide us with the personal information We reasonably require, We may be unable to provide you with the information or services you have requested.
(ii) When You Passively Submit Personal Information. When you use our Services, We may also passively track information about your computer, device or Internet connection.
The information We collect through passive tracking includes the IP address of your computer and/or Internet service provider, the date and time you access our website, the Internet address of websites from which you come to our websites, the type of device you are using to access the Service, the Web browser and operating system you are using, and your movements and interactions on our Services. This data is generated and collected automatically, as part of the standard operation of the Services. Unless you also actively submit personal information to us, any information that is passively submitted typically does not allow us to identify you personally.
(iii) Publicly Available Information. Where permitted by applicable law, We may also collect information about your specialty, hospital affiliation, and academic or scientific publications from public resources.
(iv) Cookies. We may place cookies on Users’ computers. Cookies can save data about individual Users, such as the User's name, password, username, screen preferences, and the pages of a site viewed by the User.
(v) Web Beacons. Web beacons are tiny graphic image files embedded in a website page that notify the home server (which can belong to the host website, a network advertiser, or some other third party) on a non-personally identifiable basis that some interaction has taken place. This notice to the home server may also result in a cookie being set on your device, as described above. We may use web beacons to track who has opened our emails.
3. How Do We Use the Personal Data Collected Through the Above Sources?
(i) We use personal information that We collect about you through the Services to:
- Upon request, create an account for you for the Services;
- Respond appropriately to your inquiries, and to provide updates to you regarding your account;
- Provide you with a customized experience in connection with our Services;
- Discharge our contractual obligations to you; and
- Comply with any legal obligations that apply to us.
(ii) To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, We also use your personal information for the following purposes:
- To invite you to participate in continuing medical education (“CME”) activities and other medical communications activities by email. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails. We may also invite you via postal mail;
- To send you medical newsletters including relevant information about symposia, medical news, and online CME activities. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails;
- To send you invitations to complete educational needs assessment surveys, by email, typically in exchange for honoraria. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails.
If you respond to a survey, We only use your personal information in connection with your survey responses for the purposes of: (i) verifying your eligibility to participate in a study; (ii) validating your identity and responses for the purposes of preventing duplicate or fraudulent responses; and/or (iii) processing your honoraria payment. Unless We have obtained your explicit consent, We anonymize survey results before sharing them with third parties, although We may be required by applicable law to identify a particular respondent to comply with applicable legal requirements.
(iii) We also perform statistical analyses of the Users of our Services to improve the content, design and navigation of the Services. In these cases, We use aggregate or statistical data that cannot reasonably be used to identify you.
4. Do We Disclose Your Personal Information With Others?
We do not disclose your personal information with others, except in the following circumstances and in accordance with applicable law:
- With your consent;
- To our agents and service providers, who act on our behalf and under confidentiality agreements to deliver services, provide IT support, and help us fulfill the other purposes set forth above;
- To our affiliates and partners under confidentiality agreements who work with us to improve our and their services and business practices;
- If you participate in a medical education activity that We sponsor and thereby obtain a CME or similar certificate, We may disclose the fact that you participated in the activity to the institute or university that accredited the activity for the purposes of complying with professional accreditation recordkeeping requirements;
- As required by applicable law, including, without limitation, in response to any government or regulatory agency request, to cooperate with law enforcement investigations, or upon receipt of any court order; and
- To courts and public authorities to protect you, us, or third parties from harm, such as fraud.
If you respond to an educational needs assessment survey, We do not disclose your personal information with any third party except with your consent or where required by applicable law. However, We may disclose educational needs assessment results with third parties in aggregate (as a collection of total responses), but individual responses of respondents are not disclosed in association with the respondent’s personal information.
5. What Security Measures Do We Take With Respect to Your Personal Information?
We take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have implemented technical and administrative security features to help prevent the unauthorized release of or access to personal information. Please note, however, that while We have endeavored to create a secure and reliable site for Users, the confidentiality or accuracy of any communication or material transmitted to/from us over the Internet cannot be guaranteed. You are responsible for, among other things:
- The security of information that you transmit via the Internet; and
- For safeguarding the username and password that you use to access our websites, if any, and to notify us immediately at the contact information below if you ever suspect that your username and/or password has been compromised.
6. You Have Opt-Out Rights
If you would like to opt out of receiving invitations to CME activities, educational needs assessment surveys or medical newsletters from us, please click the opt-out link at the bottom of our emails. Even after you opt out or update your preferences, please allow us sufficient time to process your preferences. It may take up to 10 days to process your email related requests, and up to 30 days for all other requests. Even after you have opted out of receiving invitations to CME activities, educational needs assessment surveys, and medical newsletters from us, We may still contact you for transactional or informational purposes. These include, for example, customer service issues or any questions regarding a specific inquiry you made to us.
7. How to Update Account Information
If you believe any information We have about you is no longer accurate or current or would like to access personal information We may have about you, please contact us by emailing email@example.com. Upon authenticating your request, We will update or amend your information, or provide you with access, but We reserve the right to use personal information obtained previously to verify your identity or take other actions that We believe are appropriate.
8. Collection of Personal Data From Children
We do not knowingly collect personal information from children under the age of 13, and We do not knowingly market the Services or any goods or services to such children.
9. How You Can Contact Us