What personal information we collect from you via our Application or our Platform
What non-personal information we collect from you
How we use the information that we collect from you
Information on “cookies” and related technology
Our commitment to secure the personal information we have collected
Notice of changes to the Policy
Our policies concerning children
How we may disclose the information that we collect from you
How long we may retain the information we collect from you
Your rights regarding the information we collect from you
If you have any questions, complaints, or comments regarding this Policy, please contact Pharmosa at [email protected]
1.Collection of Your Information
The Platform or Application is intended to facilitate your storage and transmission of patients’ medical information concerning your patients to physicians and certain others, and this medical information includes personally identifiable information of those patients, including protected health information. Personally identifiable information includes but is not necessarily limited to information that may be used to identify your patients (such as name or address, patient or medical record number, and so on) and that relates to (a) the patient’s past, present or future physical or mental health or condition or (b) the provision of health care to the patient. Pharmosa may receive and create records containing personally identifiable information of your patients. Pharmosa is required by law to take measures to protect the privacy and security of personally identifiable information, and to comply with the terms and conditions of your contract with Pharmosa. The Platform or Application also collects account and other information about you, as a user of the Platform or Application. This information includes personal information about you and your use of the Platform or Application.
2. How We Use The Information We Collect From You
Personal information which we collect via the Platform or Application is for a clinical trial purpose and will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Policy.Generally, we will use the personal information we collect from you to:
provide you with technical support, customer service, and account maintenance;
learn what you like, tailor your experience accordingly, and to improve the platform and the application;
send e-mails to our members who want to receive e-mail from us;
ensure the security of your account;
prevent or detect fraud or abuses of our platform or Application; and
comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
The legal bases for us processing personal information for the purposes described above will typically be because you have provided your consent. However, we may also rely on other legal grounds, for example, where the processing is necessary for our legitimate business interests and for compliance with a legal obligation to which Pharmosa is subject.
3. Use of Technologies by the Platform or Application
The Platform and Application may use various user-tracking mechanisms that describe your use of the Platform and Application, and your responses to communications from Pharmosa and others through the Platform and Application.
4. Information on Cookies and Related Technology
The Pharmosa Platform and Application on such sites, may contain “cookies.” A cookie is a piece of data that is sent to your browser, which will store the cookie on your device if your browser is enabled to accept cookies.
Most internet browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the Site and services may not function properly.
We do collect general, aggregated, demographic, and non-personal information. We will not seek to identify you through cookies or other means, without your consent. This type of anonymous, aggregated profiling and session data may include information that you have provided to us through surveys, polls, etc., but will not be tied to any personal information, without your consent. It may also include aggregated anonymous information about site usage, browser type, device type, and the customer base.
5. Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile device’s [e.g. calendar, contacts, reminders, storage]. If you wish to change our access or permissions, you may do so in your device’s settings.
6. Mobile Device Data
Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.
7. Push Notifications
We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
8. Our Commitment to Secure the Personal Information We Have Collected
While Pharmosa takes precautions against possible breaches in its Platform, Application and customer databases, no web site or Internet transmission is completely secure. Consequently, Pharmosa cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. USE OF THE PHARMOSA SITES AND SERVICES IS AT YOUR OWN RISK.
We urges you to take steps to keep your personal information safe by using a strong password, changing passwords regularly, using different passwords for each account or relationship that you have, logging out of user account after discontinuing use, and closing your web browser.
9. Security of Protected Health Information on Pharmosa Platform and Application
When Pharmosa collects information via the Platform and Application, including personally identifiable information, it follows generally-accepted, industry standards to protect the submitted personally identifiable information and meets HIPAA privacy standards. Pharmosa uses encryption techniques and authentication procedures, among others, to maintain the security of your information and to protect user accounts, devices and systems from unauthorized access. We also protect information by placing it on a secure portion of our servers that is accessible only by certain qualified staffs and other designees of Pharmosa.
You should also remember that regardless of security used, no data transmission over the Internet, and no data storage facility, is 100% secure. While we strive to protect your information, we cannot ensure or warrant the security of such information.
If you have any questions about security, you can contact Pharmosa at [email protected]
11. Applicable Laws
The laws and regulations in different countries impose different (and even conflicting) requirements on the Internet and data protection. The servers that make the Platform and Application available worldwide are located in the United States. All matters relating to the Platform and Application are governed by the laws of the State of California, without reference to its conflicts of law rules that would result in the Platform being subjected to laws of another jurisdiction. Please note that any information you provide may be transferred to the United States, and by using the Platform and/or Application or providing Pharmosa with information, including personally identifiable information, you authorize this transfer.
12. Our Policies Concerning Children
We comply with the Children’s Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. Pharmosa’s website and Pharmosa’s services are not directed toward children under the age of 18.
12.1 Children under the age of 18
If you are under the age of 18, you may not use the Pharmosa website and you may not sign up for any subscription service or buy anything through the Website. Except as may be required by law, Pharmosa will not knowingly collect, maintain, or disclose any personal information from children under the age of 18, without the written consent of their legal guardian.
13. How We Disclose Personal Information That We Collect From you
Pharmosa does not disclose your protected health information, to any third party other than as permitted or required under an applicable Business Associate Agreement, or as you direct through your use of the Platform or Application.
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
13.1 By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
13.2 Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
13.3 Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
13.4 Online Postings
When you post comments, contributions or other content to the Applications, your posts may be viewed by all users and may be publicly distributed outside the Application in perpetuity
13.6 Business Partners
We may share your information with our business partners to offer you certain products, services or promotions.
13.7 Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.
13.8 Sale or Bankruptcy
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
14. Retention of personal information
Personal information will be retained until as long as is reasonably necessary for the purposes listed above or as required by applicable law. Please contact us for further details of applicable retention periods.
15. Your rights
If you don’t want to receive e-mail from us, you can “opt out” of receiving it at the time you register as a member on our web sites or each time we request information from you. If you change your mind and wish to stop receiving e-mails from us, you may also choose to opt out by following the steps described in each such e-mail.
Please follow the directions on the Websites to remove or edit any of your personal information. If you have any questions about your personal information or would like to confirm removal or an opt-out associated with your information please contact us at [email protected]. Please provide your contact information including account credentials, email address, and call back number so that we may potentially contact you with the assistance of this process if necessary.
16. Information for Persons Outside of the United States
Please note that your personal information may be transferred to our outsourced service providers located outside of the United States. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organizational, contractual or other lawful means. Please contact [email protected] for detail on the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
17. California Privacy Right
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us.
According to The California Consumer Privacy Act (“CCPA”), as a California consumer, you have a right to request what personal Information we collect, use, disclose, and sell, if you would like to make such a request please submit your request in writing to us.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months, if you would like to make such a request please submit your request in writing to us.
If you are under 18 years of age, reside in California, and have a registered account with the Application, you have the right to request removal of unwanted data that you publicly post on the Application. To request removal of such data, please contact us, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Application, but please be aware that the data may not be completely or comprehensively removed from our systems.
Pharmosa relies upon the assurances of its vendor, on whose behalf it processes personal information, that they have obtained consents from such End Users. In obtaining such consent, the vendor is responsible for fully informing End Users about the purposes for which their personal information is collected and used, including the types of non-agent third parties to which that information is disclosed, if any, and the choices and means offered individuals for limiting the use and disclosure of their personal information.
If instructed to do so by its vendors, Pharmosa will inform individuals about the purposes for which a vendor collects and uses personal information. Pharmosa will also disclose the types of non-agent third parties, if any, to which Pharmosa discloses any personal information and the choices and means offered individuals for limiting the use and disclosure of their personal information.
Pharmosa requires that any such notice be provided in clear language in a conspicuous manner at the same time individuals are first asked to provide personal information, or as soon as possible thereafter, and in any event before Pharmosa uses or discloses information for a purpose other than that for which it was originally collected.
Pharmosa will work with its vendors to provide End Users with the opportunity to choose (opt out) whether personal information is disclosed to a third-party company that is used by Pharmosa. Pharmosa also works with its vendors in the event that any personal information is to be used for a purpose other than the purpose originally authorized.
For sensitive personal information (e.g., personal information that pertains to racial or ethnic origin, political or religious beliefs, health condition or sexual orientation) or use of personal information for a purpose other than the purpose originally authorized, at the direction of Pharmosa’s vendors, Pharmosa will work with the vendors to ensure that information is disclosed to a third party agent only after the End User explicitly consents (opts in) to the disclosure.
20. Transfers to Third Parties
Pharmosa will only transfer personal information received from the US to a third party consistent with Customer instructions.
Pharmosa will enter into written agreements or contracts with any agents, third-party providers, and independent entities to which Pharmosa transfers personal information to ensure that those organizations adhere to the same level of privacy protection as Pharmosa.
When Pharmosa has knowledge that a third party is using or sharing this personal information in a way contrary to this policy, Pharmosa will take reasonable steps to prevent or stop such processing or use.
21. Access and Security
Upon request and in accordance with Customer instructions, Pharmosa will assist End Users in accessing their personal information that is on the Pharmosa platform.
Pharmosa will coordinate with its Customer and End Users to allow individuals End Users to correct, amend, or delete information that is inaccurate; except in certain cases where providing this access would be disproportionate to the risks to the individual’s privacy or where rights of other individuals would be violated.
Access will not be provided to personal information relating to medical or pharmaceutical clinical trials to the extent that access, disclosure, deletion or alteration of the personal information would jeopardize the integrity of the trial or if contrary to regulatory requirements.
Pharmosa takes precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. These precautions include data redundancy and the implementation of physical and logical security and access controls.
22. Data Integrity
Pharmosa relies upon assurances from its vendor that the personal information Pharmosa possesses is relevant for the purposes for which it is to be used. Pharmosa uses the data in accordance with vendor instruction.
Pharmosa will take reasonable steps to ensure that personal information entered onto its platforms retains its original relevance, accuracy completeness and currency.
Pharmosa’s team ensure Privacy and Data Protection will be periodically reviewed.
23. Additional Notices
Individuals may make requests for access to their personal information, or requests to limit the use and disclosure of their personal information, to Pharmosa Customers who are data controllers of their personal information. In accordance with Customer instructions and applicable law, Pharmosa will assist its clients in responding to such requests.
Please also note that Pharmosa may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
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