Effective on: January 1, 2019
Introduction and Scope
This Policy does not apply to Personal Data we collect by other means, such as Personal Data of clinical trials participants we process in the course of providing life sciences services (the “Services”) to our customers, or the Personal Data of our employees.
Within the scope of this Policy, EVERSANA acts as a data controller for the Personal Data we process.
Basis of Processing
We may process your Personal Data on the basis of:
- the need to perform a contract with you or to take steps at your request prior to entering into a contract;
- our legitimate interests, such as our interest in marketing and selling our Services;
- the need to comply with the law; or
- any other ground, as required or permitted by law.
Where we receive your Personal Data as part of providing our Services to you based on a contract, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide the Services to you.
How We Receive Personal Data
We may receive your Personal Data when:
- you provide it directly to us through our Website;
- you provide it directly to us at an event or conference;
- you provide it to us while participating in a webinar we host or sponsor;
- we collect your information from publicly available platforms such as LinkedIn;
- our customers (including their employees, contractors, and other representatives of the company) provide it to us;
- we receive it from other companies within our corporate group;
- our service providers provide it to us;
- we purchase lists of individuals who might be interested in becoming customers of ours; or
- when a friend of yours or one of our partners or customers refers you to our Services by providing your Personal Data to us.
Categories of Personal Data
We may process the following types of Personal Data:
- biographical information, such as first and last name;
- employment information, such as the name, address, and contact information of your employer; and
- contact information, such as email address and postal address.
Purposes of Processing
We may process your Personal Data for the purposes of:
- marketing and selling our Services to you;
- enabling the use of our Services;
- responding to your requests or questions; and
- sending you email marketing communications about our business which we think may interest you.
When the purposes of processing are satisfied and no lawful basis of processing remains, we will delete your Personal Data.
Sharing Personal Data with Third Parties
We may share Personal Data with our subsidiaries and affiliates, as well as with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing support and infrastructure for our Sales & Marketing Systems, providing our Services, or as required by law. Our service providers may provide:
- application hosting services;
- cloud storage services;
- email software;
- content management system (CMS) software;
- customer resource management (CRM) software;
- marketing automation software;
- webinar software;
- data analytics software; and
- email marketing software.
Some of these third parties may be located outside of the European Union or the European Economic Area. In some cases, the European Commission may not have determined that the countries’ data protection laws provide a level of protection equivalent to European Union law. We will only transfer your Personal Data to third parties in these countries when there are appropriate safeguards in place. These may include the European-Commission-approved standard contractual data protection clauses.
Other Disclosure of Your Personal Data
We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.
If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.
We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Services are first-party cookies, since they are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our Services. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.
If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Services’ features. For more information, please visit https://www.aboutcookies.org/.
You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Services do not have the capability to respond to “Do Not Track” signals received from web browsers.
Data Integrity & Security
We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction.
Access & Review
If we process your Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data. You may also have the right to ask that we limit our processing of such Personal Data, as well as the right to object to our processing of such Personal Data. You may also have the right to data portability.
To submit these requests or raise any other questions, please contact us by using the information in the “Contact Us” section below.
Privacy of Children
We do not knowingly collect the Personal Data of children under the age of 18 in the context of our Sales & Marketing Systems.
European Union Supervisory Authority Oversight
If you are a data subject whose Personal Data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.
Changes to this Policy
If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Effective” date. By continuing to use our Services after we post any of these changes, you accept the modified Policy.
If you have any questions about this Policy or our processing of your Personal Data, please write to our Associate Counsel by email at firstname.lastname@example.org or by postal mail at:
Attn: Associate Counsel
190 North Milwaukee Street
Milwaukee, WI 53202
Please allow up to four weeks for us to reply.
European Union Representative
We have appointed VeraSafe as our representative in the EU for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative/ or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
|VeraSafe Ireland Ltd|
Unit 3D North Point House
North Point Business Park
New Mallow Road
|VeraSafe Czech Republic s.r.o.|