Legal

Privacy Policy

Last updated · April 2022

Introduction

Your privacy is important to us. At GNM, we work to protect the privacy of our members and to help to ensure the proper use and disclosure of such information, as well as foster a culture that value privacy through awareness.

This Privacy Policy explains how we handle and treat your data when you visit our site, www.gnmhealthcare.com.

1. Purpose of this Policy

This Privacy Policy (“Privacy Policy“) explains our approach to any personal information that we collect from you and the purposes for which we process your personal information. It also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of your personal information that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services and/or to understand how your personal information may be processed by us. Please take a moment to read and understand it.

2. Who are we and what do we do

GNMHealthcare Inc., with its parents, affiliates and subsidiaries (collectively, “GNMHealthcare”, “us”, “our” or “we”), owns, operates, or provides access to, several interactive websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, communities, for professionals in the healthcare industry (collectively “Services”). This Privacy Policy applies to all information collected about you by GNMHealthcare’s Professional division, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Except as otherwise noted in this Privacy Policy, GNMHealthcare is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR“)), which means that we decide how and why the information you provide to us is processed. Contact details are provided in Section 3 below. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

This Privacy Policy covers information collected through the websites www.gnmhealthcare.com and the application GNM Healthcare.

3. How to contact us

If you have general questions about your account or the Services, contact Customer Support at info@gnmhealthcare.com. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at infoprivacypolicy@gnmhealthcare.com or at the following address:

GNM Healthcare Group Companies, Inc

112 West 34th Street, Floor 18.

New York, NY 10120

GNM Healthcare’s users from the EEE may contact our Data Protection Officer at dpo@gnmhealthcare.com

Please note that if you contact us to assist you, we may need to verify your identity if there is a reasonable doubt before fulfilling your request.

4. What personal information do we collect

We may collect personal data from you in the course of our activities, including when you use our site, when you contact or request information or because of the relationships you may have with one or more members of our team and our customers.

Our primary goal in collecting personal information from you is to help us:

  • verify your identity
  • deliver our Services
  • improve, develop, and market new Services
  • carry out requests made by you on the Site or in relation to our Services
  • comply with any applicable law, court order, other judicial process, or the requirements of a regulator
  • enforce our agreements with you
  • protect the rights, property, or safety of us or third parties, including our other clients and users of the Site or our Services
  • use as otherwise required or permitted by law.

To undertake these goals, we may process the following personal information:

Information about your use of the Services is collected as follows:

  • Services Information. We automatically collect and store information about your use of the Services, such as your engagement with particular content including editorial, whether you opened a particular email, clicked on a link, your search queries and how often and when you engage with the Services. We also collect information about your device when you access the Services including IP address, precise location information, browser information (including referring URL) andcookie information. We use cookies to collect the information about your use of the Services and your device. For more information about our use of cookies and other tracking technologies in relation to your use of the GNM Healthcare, see our Cookie Policy
  • Market Research. You may be invited to participate in market research surveys conducted by us or on our behalf for our own internal business purposes and also market research surveys conducted by or on behalf of third-party sponsors that commissioned the survey. For some surveys, you may be asked to provide personal information for re-contact (e.g., by e-mail or phone).
  • Information and Registration Forms. From time to time, we may offer you the opportunity to receive additional information or services from us (e.g., sample request, sales rep visit, direct marketing, etc.), or to register to attend live events, either in-person or via livestream. If you wish to participate in such opportunities, you may be asked to provide personal information to fulfill the request. Unless otherwise specified in the request form, we may use such information as described in this Privacy Policy and the third party, if applicable, will be required to use such personal information as described at the point of collection.
  • Non-registered Users. You must contact GNM Healthcare Network to gain full access to Services; however, you may be able to access certain limited Services without registering. Even if you have not registered, we collect information about your use of the Services through the use of cookies and other tracking technologies. The information we collect includes the referring website, if applicable, the type of browser you use, the material viewed, and the time and date that you accessed the Services.
  • Non-registered Userswho fill out the contact form on the website : You are required to provide contact information to enable us to communicate with you about services and other information that may be of interest to you.


5. How do we use your personal information

We may use your information for the following purposes:

  1. Provision of the Services. We may use the information collected about you to provide and improve the Services, and to develop new Services.
  2. Communications. By contacting GNM Healthcare, you agree to the use of your contact information and other information collected about you as described in this Privacy Policy to communicate with you about the Services and other information that may be of interest to you. These communications may be conveyed through a variety of channels, subject to applicable law, including emails and may contain advertisements and other promotional materials from third party sponsors, including pharmaceutical companies.
  3. Personalize the Services Including Advertising. Personalization is necessary for the performance of the contract between you and us according to which we deliver the Services. We analyze or deduct your preferences and interests based on a number of factors including:
    • your interactions with our Services and the GNM Healthcare, such as:
      • your viewing and search history,
      • the time and location of Your access to our Services,
      • the devise you use,
      • answers you give to surveys and quiz,
      • our content you post, like, share or recommend, including through social media. Other users with similar tastes and preferences on our Service.
      • your interactions with other websites including with the GNM Healthcare Network, subject to our Cookies Policy.
    • This information is used to classify users into different groups or segments, using algorithms and machine-learning. This analysis helps identify links and patterns between different behaviors and characteristics to recommend relevant Services for you. This will never prevent you from accessing and browsing the Services available to you within the GNM Healthcare.
  4. Account Management. We may use your contact information to respond to your inquiries, fulfill your requests, and send you administrative communications about the Services.
  5. Investigations. We may use your information to detect, investigate and defend against fraudulent or unlawful activity, violations of the GNM Healthcare Terms of Use and to otherwise establish, exercise and defend our legal rights.
  6. Marketing/communications
    We carry out Email marketing activities using your personal information. We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section below for more details of the information collected and how it is collected) to send you marketing communications.

It is necessary for us to use your personal information.

  • It is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
  • It is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

What is our legal basis for marketing purposes?

We will only send you marketing communications where youhave consented to receive such marketing communications, or where we have a lawful right to do so.

  • Client insight and analysis
    We analyze your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed.

    Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

    • an IP address to monitor Site traffic and volume;
    • a session ID to track usage statistics on our Site;
    • information regarding your personal or professional interests, demographics, experiences with our products and contact preferences.

However, some cookies are strictly necessary for the proper functioning of the site and do not require your consent. By using this information, we can measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see.

For further information, please see our cookie privacy.

7. Marketing direct

We may Process your User Information to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.

We may Process your User Information to contact you via email. We may send information to you regarding the Services – information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

8. Use of the GNM Healthcare Website

As with most other websites, the GNM Healthcare website automatically collects certain information and stores it in log files. This information may include Internet Protocol (IP) addresses, the general region or location where your computer or device accesses the Internet, browser type, operating system, and other information about your use of the GNM Healthcare website, including a history of the pages you view. We use this information to help us design our site to better meet the needs of our users. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitors’ movements, and gather broad demographic information that helps us identify visitor preferences.

GNM Healthcare has a legitimate interest in understanding how customers and potential customers use our website. This allows GNM Healthcare to provide more relevant services.

Cookies and Web Beacons

GNM Healthcare provides a comprehensive cookie notice that describes the cookies used on the GNM Healthcare website and provides information on how users can accept or decline them. To view the notice, simply click here.

9. What Information We Disclose to Third Parties

We may disclose your User Information to:

  • legal and regulatory authorities;
  • our external advisors;
  • parties who Process User Information on our behalf (“Processors”).
  • any party as necessary in connection with legal proceedings;
  • any party as necessary for investigating, detecting or preventing criminal offences;
  • any purchaser of our business;

We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to :

  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
  • outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
  • third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section;
  • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
  • any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
  • any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

10. International Transfers of Information

To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

11. Data Security

To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

12. Data Accuracy

We take every reasonable step to ensure that your User Information is kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

13. Data Minimization

We take every reasonable step to limit the volume of your User Information that we Process to what is necessary.

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

14. Data Retention

Your personal data is stored by GNM Healthcare on its servers, and on the servers of the cloud-based database management services GNM Healthcare engages, located in the United States. GNM retains data for the duration of the customer’s business relationship with GNM Healthcare and for a period of time thereafter to allow members to recover accounts if they decide to renew, to analyze the data for GNM Healthcare’s own operations. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at dpo@gnmhealthcare.com

15. Data subjects rights

The European Union’s General Data Protection Regulation and the privacy laws of other countries provide certain rights to data subjects. A good explanation of these (in English) is available on the UK Information Commissioner’s Office website.

This privacy notice is intended to provide you with information about the personal data GNM Healthcare collects about you and how it is used. If you have any questions, please contact us at dpo@gnmhealthcare.com

If you would like to confirm that GNM Healthcare processes your personal data, or to have access to the personal data that GNM Healthcare may hold about you, please contact us at dpo@gnmhealthcare.com

You may also request information about the purpose of the processing; the categories of personal data involved; who else besides us may have received the data from GNM Healthcare; what was the source of the information (if you did not provide it directly to GNM Healthcare); and how long it will be kept. You have the right to correct (rectify) the record of your personal data kept by GNM Healthcare if it is inaccurate. You may request GNM Healthcare to delete or cease processing this data, subject to certain exceptions. You may also ask GNM Healthcare to stop using your data for direct marketing purposes. In many countries, you have the right to lodge a complaint with the relevant data protection authority if you have concerns about the way GNM Healthcare handles your personal data. Where technically possible, GNM Healthcare will – at your request – provide you with your personal data or transfer it directly to another data controller.

Reasonable access to your personal data will be provided to GNM Healthcare free of charge upon request to GNM Healthcare at dpo@gnmhealthcare.com. If access cannot be provided within a reasonable period of time, GNM Healthcare will notify you of a date when the information will be provided. If access is denied for any reason, GNM Healthcare will provide an explanation for the denial.

If you have any questions or complaints about the processing of your personal data, you can send an email to GNM Healthcare’s Data Protection Officer at dpo@gnmhealthcare.com. If you are located in the European Union, you may also contact the European Data Protection Supervisor or the data protection authority in your country.

16. California Consumers

The California Consumer Privacy Act (“CCPA”) provides certain rights for California consumers. If you are a consumer residing in California, the following additional terms apply to you.

You can request the following information about how we have collected and used your Personal Information during the past 12 months:

  • The categories of Personal Information we have collected.
  • The categories of sources from which we collected the Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share the Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
  • Access: You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • You can ask us to delete the Personal Information that we have collected from you.
  • You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

How to Exercise Your Rights

You may submit requests to exercise your California privacy rights described above as follows:

Right to information, access, and deletion. If you are a California resident, you may submit a request to exercise your information, access, and deletion rights by emailing infoprivacypolicy@gnmhealthcare.com

  • Right to opt-out of the “sale” of your Personal Information. We do not sell your personal information.

These rights are not absolute, and in some instances, we may decline your request as permitted by law. We will need to verify your identity to process your information, access, and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to log into your GNM Healthcare’s account (if applicable), provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of the valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.

Our Personal Information Collection and Use Practices

The categories of Personal Information we collect are described below by reference to the statutory categories of Personal Information specified in the CCPA (California Civil Code section 1798.140):

  • Identifiers, such as name, email address, postal address, username, password, IP address,
  • Internet or network activity information, such as information generated from interactions with our online services, such as data collected through server logs and cookies and similar technologies.
  • Geolocation, such as your city or other general location.
  • Information from Third Party Sources. We may obtain additional information about you from third party sources to assist us in providing the Services. For example, we may use third party information to verify and augment your registration information, for research purposes or to personalize the Services, including advertising
  • Inferences that we derive from the preceding or other information we collect.

Sources. Internet/network activity information, geolocation, IP address, and other online identifiers are collected automatically through your use of our online services. We may collect some professional information, and California customer records information from our affiliates, third party data providers, or publicly available sources. Otherwise, we collect the information above from you.

Disclosures to third parties for business purposes. We describe the categories of third parties to whom we disclose Personal Information described above for business purposes in the section of our Privacy Policy entitled “Who do we share your information with.”

Business/commercial purposes for use. We describe the business and commercial purposes for which we use the Personal Information described above in the section of our Privacy Policy entitled “Hox do we use your personal information”.

This section describes our practices currently and during the 12 months preceding the ‘Last Updated’ date of this Statement.

California Shine the Light Law

Under California’s Shine the Light law, you may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to dpo@gnmhealthcare.com . In your request, you must include the statement “Shine the Light Request” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

17. How this Privacy Policy May Change

We may change this Privacy Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we will indicate on our websites that our Privacy Policy has changed prior to the change becoming effective. The then-posted version of the Privacy Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Privacy Policy.

We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.