Pro-CME Privacy Policy
Updated January 1, 2022
Pro-CME is a service mark of Doctor's Guide Publishing Limited.
In this Privacy Policy, we, Doctor's Guide Publishing Limited, 1, rue Hildegard von Bingen, L-1282 Luxembourg, Luxembourg, provide information about how we collect, use, disclose and otherwise process personal information through websites, mobile applications and newsletters that Pro-CME operates (“Services”) and rights individuals may have under applicable data protection and privacy laws. This Privacy Policy only applies to Services that include a link to this Privacy Policy and may be supplemented by additional notices to you depending on the specific Service you are accessing or using. By “personal information” or “personal data”, we mean information that identifies you or can reasonably be used to identify you. If you are located in the European Economic Area (EEA) or United Kingdom (UK), please also see our Supplemental EEA and UK Privacy Statement here. If you are a resident of California, please also see our Supplemental California Consumer Privacy Act (CCPA) Privacy Policy here.
1. Collection of Personal Information From Users of our Services.
Information You Actively Submit. We collect certain types of personal information when you interact with our Services, such as when you:
- Register for an account on any Service or update your profile information;
- Participate in a medical education activity;
- Respond to an online survey;
- Request information from us about patient assistance resources, medical education activities and other medical communications;
- Submit comments, reviews, or other user-generated content on our Services;
- Request customer or technical support from us; or
- Otherwise submit personal information to us via the Services.
The personal information we collect includes your name, email address, mailing address, telephone number, certain information related to your profession (e.g., specialty, education, hospital affiliation, etc.) and any other personal information that you actively submit to us. In each such instance, you will know what personal information we collect, because you actively submit it. We endeavor to clearly label which information is required and which information is optional in all cases. If you are unable or choose not to provide us with the personal information we reasonably require, we may be unable to provide you with the information or services you have requested.
Information Passively Submitted. When you use our Services, we may also passively track information about your computer, device or Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access our website, the Internet address of websites from which you come to our websites, the type of device you are using to access the Service, the Web browser and operating system you are using, and your movements and interactions on our Services. This data is generated and collected automatically, as part of the standard operation of the Services. Unless you also actively submit personal information to us, any information that is passively submitted typically does not allow us to identify you directly.
Publicly Available Information. Where permitted by applicable law, we may also collect information about your specialty, hospital affiliation and academic or scientific publications from public resources, such as national or local registries of physicians, national or local medical associations, the public websites of hospitals, medical offices, clinics and educational institutions, academic journals, peer-review publications and professional social networking platforms such as LinkedIn.
Cookies and Web Beacons. We may place cookies on users’ computers. Cookies can save data about individual users, such as the user's name, password, username, screen preferences, and the pages of a site viewed by the user. When the user revisits the website, we may recognize the user based on any cookies placed on their computer and customize the user's experience accordingly. For more information about our use of cookies and similar technologies, please see our Cookie Policy.
We may also use web beacons to track who has opened our emails. Web beacons are tiny graphic image files, embedded in a website page that notify the home server (which can belong to the host website, a network advertiser, or some other third party) that some interaction has taken place. This notice may also result in a cookie being set on your device, as described above.
2. Use of Personal Data Collected.
We use personal information that we collect about you through the Services to:
- Upon request, create an account for you for the Services;
- Respond appropriately to your inquiries;
- Update you regarding your account;
- Provide you with, maintain, secure, and improve our Services;
- Provide you with a customized experience in connection with our Services;
- Improve the accuracy and relevance of the results you see when you interact with the search engine and the search engine's integrated chatbot functionality that is part of our Services;
- Discharge our contractual obligations to you; and
- Comply with any legal obligations that apply to us.
To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, we also use your personal information for the following purposes:
- Invite you to participate in online medical education activities, including continuing medical education activities, and send you information about medical activities and promotional communications from pharmaceutical companies by email. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails. We may also invite you via postal mail.
- Invite you to learn more about and request information from us about patient assistance resources, such as sample activities and co-pay incentive activities. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails.
- Send you medical newsletters including the top medical news in your field of interest and medical alerts. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails.
- Send you invitations to complete market research surveys, by email, typically in exchange for honoraria. If you do not wish to receive such emails, you may opt out by following the opt-out instructions included in such emails.
- Review the information provided by you and obtained from public resources to complete your profile and better understand which medical news, education activities and surveys may be of most interest to you.
We also perform statistical analyses of the users of our Services to improve the content, design and navigation of the Services. In these cases, we use aggregate or statistical data that cannot reasonably be used to identify you.
If you respond to a survey, we only use your personal information in connection with your survey responses for the purposes of: (i) verifying your eligibility to participate in a study; (ii) validating your identity and responses for the purposes of preventing duplicate or fraudulent responses; and/or (iii) processing your honoraria payment. Unless we have obtained your explicit consent, we anonymize survey results before sharing them with third parties, although we may be required by applicable law to identify a particular respondent to comply with applicable legal requirements, such as adverse events reporting requirements.
3. Disclosures of Information.
We do not disclose your personal information with others, except in the following circumstances and in accordance with applicable law:
- With your consent;
- To our agents and service providers, who act on our behalf and under confidentiality agreements to deliver services, provide IT support, and help us fulfill the other purposes set forth above;
- If you participate in a medical education activity that we publish and thereby obtain a continuing medical education or similar certificate, we may disclose the fact that you participated in the activity to the medical school or institute that accredited the activity for the purposes of complying with professional accreditation recordkeeping requirements;
- If we publish an activity from another medical education provider, and thereby obtain a continuing medical education or similar certificate, we may disclose the fact that you participated in the activity to the medical education provider for the purposes of complying with professional accreditation recordkeeping requirements;
- As required by applicable law, including, without limitation, in response to any government or regulatory agency request, to cooperate with law enforcement investigations, or upon receipt of any court order; and
- To courts and public authorities to protect you, us, or third parties from harm, such as fraud.
If you respond to a market research survey, we do not disclose your personal information to the third parties on whose behalf we are conducting such research except with your consent or where required by applicable law, such as to comply with applicable adverse incident reporting requirements. We otherwise only disclose market research results to third parties in aggregate (as a collection of total responses), and individual responses of respondents are not disclosed in association with the respondent’s personal information.
4. Security Measures.
We take steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have implemented technical and administrative security features to help prevent the unauthorized release of or access to personal information. Please note, however, that while we have endeavored to create a secure and reliable site for users, the confidentiality or accuracy of any communication or material transmitted to/from us over the Internet cannot be guaranteed. You are responsible for the security of information that you transmit via the Internet. It is your responsibility to safeguard the username and password that you use to access our websites, if any, and to notify us immediately at the contact information below if you ever suspect that your username and/or password has been compromised.
5. Opt-Out Right and Updating Account Information.
If you would like to opt out of receiving invitations to medical education activities, medical surveys or medical newsletters from us, please click the opt-out link at the bottom of our emails. Even after you opt out or update your preferences, however, please allow us sufficient time to process your preferences. It may take up to 10 days to process your email related requests, and up to 30 days for all other requests. Even after you have opted out of receiving invitations to medical education activities, medical surveys and medical newsletters from us, we may still contact you for transactional or informational purposes. These include, for example, customer service issues or any questions regarding a specific inquiry you made to us.
If you believe any information we have about you is no longer accurate or current or would like to access personal information we may have about you, please contact us by emailing Privacy@pro-c.me. Upon authenticating your request, we will update or amend your information, or provide you with access, but we reserve the right to use personal information obtained previously to verify your identity or take other actions that we believe are appropriate.
6. Collection of Personal Data From Children.
We do not knowingly collect personal information from children under the age of 13, and we do not knowingly market the Services or any goods or services to such children.
7. Contacting Us.
If you have any questions regarding this Privacy Policy, you may contact us by emailing Privacy@pro-c.me.
8. Effective Date and Changes to Privacy Policy.
We reserve the right to change this Privacy Policy. If we make a material change to how we collect, use, or disclose Personal Information, we will prominently post an updated Privacy Policy on our Services. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy. If you disagree with our Privacy Policy changes, you may discontinue using the Services.