1. The Basics
A. About Us
We are a pharmaceutical marketing services company headquartered in Parsippany, New Jersey. Our services include providing registration and logistics services for client-sponsored meetings. We collect or receive Personal Information on behalf of our clients for their business purposes.
B. Key Terms
“Affiliate” means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.
“Control” means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term “Controlled” shall be construed accordingly.
“Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, address, email address, employer name, or other demographic information.
“you” and “your” means any person who visits our Web site.
This section applies to the Personal Information we receive, collect and process from you through our Web site or from our clients.
A. Information We Collect
The Personal Information that we collect may include:
- Email address
- Educational degree(s)
- Practice name
- Phone number
- Areas of specialization
- National Provider Identifier Number
- State license number
- State of licensure
- Information about therapies used in treating patients
- How you heard about our events or activities (email, colleague, mailed invite, other)
- Which event or activity, date/title you preregistered for
- Activity acceptance/decline (speaker confirmation) and activity management
- Invitations to speakers and attendees for our events and activities
- Travel management
- Content access, posting and management (content library)
- Expense submissions, management and payment details
- Travel Information
- Biographical Information and Curriculum Vitae (CV)
- Feedback about event or activity, including content, materials, location and facilities
- Feedback about event or activity speakers
- Information provided in surveys about our services generally
- Training management
B. How We Use Your Personal Information
We may process any category of your Personal Information we collect. “Process”, “Processing”, or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, using, disclosing by transmission, disseminating or otherwise making available, combining, restricting, erasing, or destroying. We are a “processor” of Personal Information on behalf of our clients.
We may use your Personal Information for the following purposes:
- To provide you with the general use of our Web site in connection with your use of our products or services, such as registering you for a client-sponsored event or activity.
- To manage business communications with you and respond to your communications with us.
- To provide you with information about the products and services that you request from us, such as registration and participation in a client-sponsored events and activities.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, or any contracts entered into between us and our clients.
- To notify you about changes to the Web site or any services we offer or provide through it.
- To report completed events or activities to clients.
- To administer and protect our business and our Web site.
C. Change Of Purpose
We will only use your Personal Information for the purposes for which we received or collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
D. Disclosure Of Your Personal Information
We may disclose aggregated information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect or you provide as described in this Policy.
We may disclose your Personal Information in accordance with our business administrative practices.
We may disclose your Personal Information to our clients for whose event or activity you are registering.
We may disclose your Personal Information as necessary to comply with any court order, law, or legal process, including to respond to any government or regulatory request or to enforce or apply our Web site’s Terms and Conditions and other agreement between us and you, including for billing and collection purposes, if applicable.
We may disclose your 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 Guidemark Health, Inc.’s, assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Web site’s users is among the assets transferred.
We may disclose your Personal Information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Guidemark Health, Inc., our clients, or others. This includes, without limitation, exchanging information with other companies and organizations for the purposes of fraud protection.
E. Choices About How We Use And Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. Various mechanisms are available to provide you with the following control over your information:
Disclosure of Your Personal Information for Third-Party Advertising. We do not share Personal Information with third parties other than as set out in this Policy.
Sale of Your Personal Information. We do not sell any Personal Information that we receive or collect.
F. International Transfers
We are located in the United States. Accordingly, if you are an EU national and reside in the EU or are a non-EU national residing in the EU, please note that processing of your Personal Information is governed by The General Data Protection Regulation 2016/679 (“GDPR”) and will involve a transfer of your Personal Information outside the European Economic Area.
The transfer of your Personal Information to us and by us to third parties as permitted in this Policy is based on the following GDPR exceptions from the GDPR prohibition on transferring Personal Information outside the EU without adequate protections:
- You have explicitly consented to the proposed transfer after having been informed of the possible risks of such transfers of your Personal Information due to the absence of an adequacy decision under GDPR and appropriate safeguards.
- The transfer is necessary for the performance of a contract between you and us or the implementation of pre-contractual measures taken at your request.
- The transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person.
G. Data Retention And Security
By submitting your Personal Information to us, you agree to this transfer, storing, or processing described in this Policy. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. You should not disclose your password to anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Generally, we will retain your Personal Information as necessary to provide any of our products or services to you. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Information to those employees, agents, and service providers who need to know that information in order to provide services to us and yourself. We maintain physical, electronic, and procedural safeguards to protect your Personal Information.
We will notify you and any applicable regulator of a breach where we are legally required to do so.
H. Your Legal Rights
You have the following rights in relation to your Personal Information:
Request access to your Personal Information. You are entitled to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of your Personal Information. You are entitled to have any incomplete or inaccurate Personal Information we hold about you corrected, although we may need to verify the accuracy of the new Personal Information you provide to us.
Request erasure of your Personal Information. You are entitled to ask us to delete or remove Personal Information when there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information when you have successfully exercised your right to object to processing (see below), when we may have processed your Personal Information unlawfully, or when we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information. When we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground because you feel it impacts your fundamental rights and freedoms.
Request restriction of processing your Personal Information. You are entitled to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the accuracy of your Personal Information; (b) when our use of your Personal Information is unlawful but you do not want us to erase it; (c) when you need us to hold your Personal Information, even if we no longer require it, because you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your Personal Information but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your Personal Information. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format.
Right to withdraw consent. If we rely on this as the legal basis of lawful processing, you may withdraw your consent at any time.
Right to lodge a complaint with the supervisor authority. You have the right to make a complaint at any time to Consumer Financial Protection Bureau, Attention: Chief Privacy Officer, Re: Privacy Complaint, 1700 G Street, NW, Washington, DC 20552 email: [email protected] or if you are subject to the GDPR, to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach any government office, so please contact us in the first instance.
If you wish to exercise any of the rights set out above, please Contact Us at [email protected]
I. Do Not Track
J. Changes to this Policy
K. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please send an email to [email protected] You may also contact us by postal mail at Guidemark Health, Inc. 6 Campus Drive, Parsippany, NJ 07054 Attn: James W. Hoblitzell.
Dated: August 10, 2021