Precision Medicine Group, LLC and its affiliates (together, “Precision”, “we”, “our,” or “us”) is committed to protecting the privacy of your Personal Information (as defined below). We respect individual privacy and value the trust of our customers and employees, consumers, patients, healthcare providers, business partners, and others who provide their Personal Information to us. This privacy policy explains what Personal Information we collect from you and how we use it, and is intended to give you confidence in the privacy and security of your Personal Information when accessing the available pages on any of the following Precision websites (collectively, the “Sites”):
newsletter.precisionhealtheconomics.com
The Sites provide you with information about Precision and our services and products. This Privacy Policy applies to the Sites and other websites or online services, including our portals, that are operated by or on behalf of Precision and that link or refer to this Privacy Policy. Precision collects data to operate effectively and provide you the best experiences with our services and products.
INFORMATION WE COLLECT AND HOW WE USE IT
Information Collection
“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
We will not use or disclose your Personal Information in a manner inconsistent with applicable law or this Privacy Policy. We may use your Personal Information to: (i) respond to inquiries, (ii) supply requested information on Precision’s services and products, (iii) allow you to participate in registration-only features of the Sites when you choose to do so, (iv) ensure that content from the Sites is presented in the most effective manner for you and for your computer, and (v) maintain and monitor quality of the Sites and provide general statistics regarding use of the Sites.
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, including but not limited to Standard Contractual Clauses. 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.
DATA RETENTION
Your Personal Information is retained by Precision for no longer than is needed for performance of the respective purpose of its processing as described under this Privacy Policy. It may however be retained for a longer duration, as archive, for the purpose of proof management in prevention of any claim.
COOKIES AND OTHER ANONYMOUS WEB-TRACKING METHODS
There are various methods that can be used to provide tailored information to you from a website, including one called “cookies.” A cookie is a small data file that a website you visit may save on your computer or handheld device that usually includes an anonymous unique identifier. Precision uses cookies and web server logs to assist in the collection of site usage statistics. This information may include Personal Information including the date/time of visits, specific pages viewed, time spent browsing our Sites, and the websites visited immediately prior to and after visiting our Sites. Our Sites will ask for your permission through a “cookie banner” to store cookie files on your computer/handheld device. Note also that most Internet browsers allow you to erase cookies from your hard drive, block all cookies, or receive a warning before a cookie is stored. Refer to your browser’s help files to learn more about these functions.
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.
LINKING
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.
SECURITY
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.
CHANGES TO THIS PRIVACY POLICY
As privacy laws and regulations change, and as Precision and the Sites evolve, it may be necessary to revise or update our Privacy Policy without advance notice to you. Changes to this Privacy Policy will be reflected when we revise the “Last Updated” date at the end of this Privacy Policy. If we make changes that are material to the protection of your data, we will provide you with appropriate notice before such changes take effect.
YOUR RIGHTS
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: privacy@precisionmedicinegrp.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
For those of the processing activities described under this Privacy Policy which are based on your consent or on their necessity for our performance of a contract to which you are a party, you also have a 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
For those of the processing activities described under this Privacy Policy which are based either on:
- 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
For those processing activities described under this Privacy Policy that are based on your consent, you have a right to withdraw that consent at any time, without justification.
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 privacy@precisionmedicinegrp.com or 866-994-0511
CONTACT INFORMATION
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: privacy@precisionmedicinegrp.com
Precision has appointed Amy Ford as its Data Protection Officer (DPO). You may reach Precision’s DPO at DPO@precisionmedicinegrp.com.
PRECISION PRIVACY POLICY LAST UPDATED: January 2021