Last Updated: December 17, 2019
This Policy applies to individuals who engage in Company Services, including registration, attendance, consumption of and/or creation of medical education content in any format as well as third party service providers that Company relies on to produce Company Services, including vendors, partners and sponsors (collectively, “Customers”).
2. Information Collected – Categories of Information
Information that the Company collects falls in to one of the following categories:
a. Information About You – this includes personally identifiable data (“Personal Data”)
b. Activity Information – this includes information related to things you did (e.g. registration, attendance, purchases, content read/watched, CME credits claimed, etc.) and may or may not be identifiable to your activity. In some cases, Company may receive and store certain non-identifiable information such as information collected passively using various technologies (e.g. visits to a webpage, etc.).
c. Aggregated or De-Identified Data - Company may aggregate and/or de-identify information collected by the Company Services or other means so that the information is not intended to identify you. This Policy does not restrict our use or disclosure of aggregated and/or de-identified information
i. Photography and Video: As part of marketing and fulfilling Company Services, Company may take photos and/or videos of conference attendees, exhibitors and faculty. These photos and videos may be used in marketing materials, including Pri-Med.com. Should you wish for an identifiable photo of you, not to be used for any purpose, you must advise Company in writing as directed below.
Company values the trust that you place in us by letting us act as custodians of your data. We take our responsibility to protect and secure your information seriously and strive for transparency around our information security program, including our practices for protecting and handling that information, further detailed within this Policy.
3. Information Collected – Methods of Collection
How we collect and store information depends on the Company Services in which you participate and use. Information Collected may come from one or more of the following methods:
a. Information You Provide: Company collects information when you voluntarily choose to provide such information, such as when you contact Company with inquiries or utilize Company Services. By voluntarily providing Company with Personal Data, you are consenting to Company’s use of it in accordance with this Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Company and authorized third parties herein for the purposes described in this Policy.
b. Information From Others: We may obtain information about you or activity information from third-parties, such as service providers, marketers, partners, researchers, and other Customers. Information obtained from any third-party source will only be used in accordance with this Policy. If you access the Company Services through a third-party connection or log-in, you authorize Company to collect, store, and use, in accordance with this Policy, any and all information available to Company through the third-party interface.
c. Information We Collect: As you interact with Company Services, Company will collect and derive information about you and/or your activity. Company has multiple ways in which it collects this information:
i. Automatically-Collected Information: Company may automatically collect certain information about the computer or devices that are used to access the Company Services, as well as information about the apps, browsers or mobile devices used, through commonly-used information-gathering tools, such as cookies and web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your browser or device (such as browser/device type and language), your Internet Protocol (“IP”) address, and the actions you take on Company’s websites, such as the pages viewed and the links clicked. We may also collect and analyze information such as: (i) location information, unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Company Services; and (ii) information related to the ways in which you interact with the Company Services, such as referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
4. Information Collected – Purpose
Company uses information collected in a manner that is consistent with this Policy. If you provide Personal Data for a certain reason, Company may use the Personal Data in connection with the reason for which it was obtained. For instance, if you contact Company by email, Company may use the Personal Data you provide to answer your question or resolved your problem. Also, if you provide Personal Data in order to obtain access to Company Services, Company will use your Personal Data to provide access to such services.
If you register for and/or use Company Services, Company will use your Personal Data to provide you with documents and other materials related to such Company Services. Company may also mail you documents and materials related to such Company Services as well as for other products and services that Company believes will be of interest to you.
Company may use your Personal Data, Activity Information and/or Aggregated/De-Identified Data to help Company improve Company Services, including content, user experience and online features/functions.
Company may use information it has collected about your location and/or preferences to customize recommendations of specific Company Services that may be of interest to you. If you access Company Services through a web or mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this.
Company will not use information it has collected about you for any reason other than that specified within this Policy.
5. Information Sharing and Disclosure
Company considers your information to be a vital part of the relationship with you and protects it vigorously. There are, however; certain circumstances in which Company may share information it has collected with certain third-parties without notice to you, as set forth below:
a. Consent: If you consent to the disclosure, we may do so.
b. Event Sponsors: If you sign-up to attend an event or participate in an activity as part of Company Services, Company may share your information with companies involved in supporting the event or activity.
c. Service Providers: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. As such and for business operations purposes only, we may provide access to your information to select third-parties who perform services for us such as registration, mailing, billing, sales, marketing, advertising, market research, fulfillment, data storage, transfer, analysis and processing, analytics, participation in a contest or sweepstakes, and legal services. When Company employs another company to perform a function of this nature, Company endeavors to ensure their security systems are compliant with applicable law and provides them only with the information they need to perform their specific function. Company also requires they limit their use of Personal Data accordingly.
d. Regulatory: Company is an accredited provider of continuing medical education (CME) and as such is required by the Accreditation Council for Continuing Medical Education (ACCME) to ensure that all CME sessions and activities meet certain ethical and business standards and requirements as well as those of other regulatory organizations, including but not limited to the AMA, AANP and the ABIM. In some cases, these requirements call for Company to share Personal Data, Activity Data and Aggregated or De-Identified Data for regulatory reasons related to CME.
e. Business Partners: From time to time, Company may offer you the opportunity to participate in discount plans and similar benefit programs from one or more of Company business partners. If you opt-in to participate in the discount plans or other benefit programs of Company business partners, Company will disclose your Personal Data to such business partners so that they may register you for the applicable discount and/or benefit program.
f. Business Transfers: We reserve the right to disclose and transfer all information collected about you, including, without limitation, your Personal Data, Activity Data, and Aggregated or De-Identified Data, to a successor (or potential successor) company in connection with a merger, acquisition, or sale of all, or components, of our business, or in connection with due diligence associated with any such transaction.
g. Protection of Company and Others: We may disclose any of your information to: (i) comply with legal process; (ii) enforce any agreements that you entered into with us; (iii) respond to claims that any content violates the rights of third parties; (iv) respond to your requests for customer service; and/or (v) the extent necessary for the purposes of the legitimate interests pursued by us or by the third party or parties to whom the data are disclosed, except where such interests are overridden by the interests for fundamental rights and freedoms of the data subjects. We may also disclose information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law.
6. Online Analytics, Advertising and Marketing
Company may use third-party web analytics services such as Google Analytics, Google Adwords and other third-party applications for Display Advertising, in order to advertise online via its “Remarketing” feature. Third-party vendors, including Google, may show our ads on sites across the internet. Company and third-party vendors, including Google, use first-party cookies (such as Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on someone’s past visit to websites. You can opt-out of the Google Analytics Advertiser Feature we use, including through Ads Settings, Ad Settings for mobile apps, or any other available means through this link. To opt-out of Google Adwords advertising features, click here.
Company may also target advertising and/or marketing messages depending on preferences you choose to share with us. Those messages, in any form, may personalize content based on your interests. For example, you may see different content on our website in different areas based on information that you have shared with us or based on observations we have made regarding your previous usage.
We require advertisers and their advertisements to comply with all Federal (United States) and local and provincial (Canada) regulations regarding direct-to-physician advertising, including but not limited to the Federal Food, Drug, and Cosmetic Act as well as relevant FDA guidance documents. We reserve the right to reject any advertisement for any reason.
Company will always offer you a means to choose your preference on how the Company communicates with you, including your ability to “unsubscribe” to future marketing and non-transactional communications by clicking on the “Email Preference Center” link located on the bottom of each of Company’s marketing emails. Additionally, you may send specific requests to firstname.lastname@example.org.
Company takes data privacy seriously and has a strong information security posture including several security safeguards such as physical, administrative (policies & procedures) and technical (access and audit controls) to protect your information and maintain data security. These safeguards vary based on the sensitivity of the information that we collect and store. Although we take appropriate measures to safeguard against loss, misuse and unauthorized access, disclosure, alteration or destruction of information, we cannot assure you that information that we collect will never be disclosed in a manner that is inconsistent with this Policy.
Company may provide bulletin boards, blogs, online comments or chat rooms through Company Services. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Company is not responsible for the personal information you choose to submit in these forums. All such information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, and/or distribute such information to others without limitation or attribution.
Customers, Visitors, and Attendees may elect to use Company’s referral program to inform friends about Company Services. When using the referral program, Company requests the friend’s name and email address. Company will automatically send the friend a one-time email inviting him or her to visit Company’s website, but will not add the friend to ongoing communications streams. In the case where Company posts a list of Customers and testimonials on its websites, Company will first obtain the consent of each customer prior to posting such information or testimonials.
9. Users from Outside the United States
Company Services are governed by the applicable Federal/State/Provincial/Territorial and local laws of the United States and Canada. If you are using Company Services from outside the United States or Canada, your information will still be transferred to, stored, and processed in our facilities, in the United States and Canada.
The data protection and other laws of other countries might be different from the laws of the United States and Canada. When we transfer the information of a resident of the United States or Canada globally we will take all reasonable steps to protect your information and will otherwise store and process your information in compliance with applicable laws.
10. Links to Other Websites
Company Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. Any information you provide via those services is subject to the applicable third-party privacy policies and is not covered by this Policy.
Company Services do not target and are not intended to attract children under the age of 18. Company does not knowingly solicit personal information from children under the age of 18. Should we learn or be notified that we have collected information from users under the age of 18, we will immediately delete such personal information.
12. No Rights of Third-Parties
This Policy does not create rights enforceable by third-parties.
13. How to Contact Pri-Med
If the state or province you reside in has data privacy laws that provide you with rights to request information about the Personal Data that the Company collects about you, or allows you to request Company delete and/or not have the Company sell your Personal Data, please submit a formal Data Subject Access Request (DSAR) by clicking here.
If you have any questions, comments, or concerns regarding this Policy or Company’s privacy practices may be submitted via email to email@example.com, in writing by addressing your inquiries to:
DBC Pri-Med, LLC
c/o Information Security Office
855 Boylston Street
Boston, MA 02116
14. Changes to This Policy
Laws, rules & regulations affecting data privacy change over time. As a result, Company reserves the right to update or modify this Policy at any time without prior notice. Please review this Policy periodically for changes, especially before providing Company with Personal Data. If Company makes material changes to this Policy which could be considered adverse to you, we will provide notification of the material adverse changes in accordance with applicable law.