idos App Network Privacy Policy

This Privacy Policy describes the privacy practices of idōs and its affiliates (referred to collectively as “idōs,” “us,” “we” and “our”) in relation to your use of our websites, mobile applications and other resources intended for use by healthcare professionals and which we refer to as the “idōs App Network,” including the information and services made available to users of the idōs App Network, such as medical news, reference content, clinical tools, applications, sponsored programs, advertising, email communications, continuing medical education, market research opportunities and discussion forums (collectively, the “Services”).

This Privacy Policy does not apply to our properties and services that display a link to a different privacy policy. In the event that we expand the idōs App Network through our acquisition of another company and/or its properties, that company may operate under its own privacy policy accessible via a link on its properties until we integrate its privacy practices with ours, at which point a link to this Privacy Policy will be displayed on its properties.

We provide the Services as a professional resource intended to support people, healthcare professionals in their efforts to provide high quality medical care to patients. You can choose whether or not you want to use the Services. If you do choose to use the Services, you must agree to the idōs App Network Terms of Use which is a contract between us and users of the Services. By agreeing to the idōs App Network Terms of Use, you confirm that you have read and understand this Privacy Policy which explains how we collect, disclose, transfer, secure and use information about you in connection with your use of the Services and the rights and choices you have regarding these activities. If you do not want us to collect and use information about you as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in the United States and any other country from where the applicable idōs App Network property is operated. Please be aware that the privacy laws and standards in certain countries may differ from those that apply in the country in which you reside. Unless otherwise specified herein or on the property from which you have accessed this Privacy Policy, idōs is the controller of the personal information that we collect about you as described in this Privacy Policy.

Information Collected

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

• Registration. In order to use the Services, you may be required to register an account and provide certain personal information such as your name, email address, zip/postal code, profession, occupation, specialty and depending on your country of practice, your medical license number or equivalent. You may choose to update or supplement the personal information that you provided at registration at any time through your account settings or by contacting idōs App Customer Service.

• Services Information. We automatically collect and store information about your use of the Services, such as your engagement with particular content including editorial, advertisements, sponsored informational programs from our advertisers, which may include pharmaceutical companies ("Sponsored Programs"), 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), cookie information and advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device). We use cookies and other tracking technologies, such as pixels, tags, web beacons and software development kits, 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 idōs App Network, see our Cookie Policy.

• Cross-Device Tracking. We and our service providers collect and store information about users' interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices. We do so in order to:

· provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices;

· detect and prevent fraud;

· allow users to use our service on one device and pick up seamlessly where they left off on another device;

· limiting the number of times a user is shown the same advertisement, across known or inferred devices

For information on your advertising choices and opt-out, please see the “Choices and Control” section of this Privacy Notice.

• 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) or payment fulfillment purposes.

• Public Forums. When you post a comment on a discussion board or other public forum, by default your username, specialty and degree will be displayed within the forum along with your comment. You may choose to display additional information in your public forum profile, including a photo, by adjusting your discussion profile settings. Information that you post within a public forum is public information and may be used by us and third parties, as further described in the idōs App Network Terms of Use.

• Information and Registration Forms. From time to time we may offer you the opportunity to receive additional information or services from us or from third parties, including our advertisers (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.

• 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.

• Non-registered Users. You must register with the idōs App 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.

Information about you may be used for the following purposes:

• Provision of the Services. We may use the information      collected about you to provide and improve the Services, and to develop      new Services.
• Member      Profiles. We may associate information      that we have collected about your use of the Services with your      registration information and any other information we have about you, as      described in this Privacy Policy, thereby creating a profile of you that      we may update from time to time ("Member Profile").
• Communications. By registering as a member of the idōs App Network,      you agree to the use of your registration 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.
• Personalize      the Services Including Advertising.      We may personalize the Services, including the advertising you see within      the idōs App Network, on third party websites and in our email      communications, based on information included in your Member Profile. For      example, a user who idōs App believes is a cardiologist or who has browsed      cardiology content with the idōs App Network may be served an      advertisement promoting a particular cardiac product within the idōs App      Network, on third party websites and/or within an email that a user who idōs      App believes is a neurologist or has not browsed cardiology content will      not see. We partner with third parties to manage and conduct our      advertising activities including advertising on our websites and on third      party websites. These third parties may use cookies and other tracking      technologies to deliver this advertising based on your activities and      interests as inferred from your use of the Services and other information      they have about you. Also, advertisers may use their own cookies and other      tracking technologies in the advertisements served to you through the      Services, some of which may enable the advertiser to obtain personal      information that can be used to specifically identify you, including the fact      that you saw the advertisement, to the extent that you have separately      provided consent to the advertiser or to the third party providing the      tracking technology. Some advertisers use companies other than idōs App to      serve their advertisements on their behalf and to monitor users' responses      to these advertisements through the use of cookies and other tracking      technologies. While idōs App generally permits the use of third party      tracking technologies based on an understanding that they comply with the idōs      App Advertising Policy, we do not have control over these third parties'      use of cookies and other tracking technologies or how they manage the      information they gather through them and idōs App may be unable to verify      compliance with the idōs App Advertising Policy.
• Verification      Purposes. We may use your information      in conjunction with information from third parties to recognize you as a      registered member when you visit one of our properties and to verify your      identity and/or professional credentials. We may require you to provide      proof of your identity, including that you are a healthcare professional,      and if you are unable to do so to our reasonable satisfaction, we reserve      the right to deny you access to the Services. While we take steps to      verify that our members who identify as healthcare professionals are      actually healthcare professionals, we make no guarantee as to their      identity, professional credentials or licensure status.
• Account      Management. We may use your information      to administer your account, respond to your inquiries, fulfill your      requests and send you administrative communications about the Services.
• Investigations. We may use your information to detect, investigate      and defend against fraudulent or unlawful activity, violations of the idōs      App Terms of Use and to otherwise establish, exercise and defend our legal      rights.

Sharing Your Information with Third Parties

Information about your use of the Services may be shared as follows:

• Service      Providers. We work with third party      service providers to help us provide the Services and to otherwise assist      us in the operation of the idōs App Network, including in the areas of      email management and deployment, analytics, marketing, advertising, market      research, sweepstakes and contest administration, identity and      professional credential validation, content distribution, customer      service, payment fulfillment, event logistics, website maintenance and      data storage and security. We may provide these service providers with      personal information about users of our Services so that they can fulfill      their responsibilities to us, however, we do require that they agree to      limit their use of this personal information to the fulfillment of these      responsibilities.
• Advertising      and Sponsored Programs. We      may provide your personal information to third party sponsors of      advertisements and Sponsored Programs, subject to applicable law.      Specifically, when you are exposed to an advertisement through the      Services, whether on one of our websites or apps, in an email or through some      other means, or when you engage in a Sponsored Program, e.g., access a      sponsored information resource, open one of our sponsored emails, idōs App      may provide your personal information, such as your name and specialty      (but not your email or postal address) to the applicable sponsor and/or      its agents on the sponsor's behalf. We may also provide such third parties      with details about your engagement with the advertisement or Sponsored      Program (e.g., whether you viewed or otherwise interacted with certain content),      your answers to any questions contained in the Sponsored Program and      information about you that we have received from third parties.      Additionally, when you register as a member of the idōs App Network, we      may provide your personal information (but not your email or postal      address) to potential sponsors of advertisements and Sponsored Programs      that may be offered or provided to you through the Services, subject to      applicable law. Please review the Privacy Policies of these third parties      to familiarize yourself with their practices. All advertisements and      Sponsored Programs (including any links to Sponsored Programs) made      available within the idōs App Network, including through emails, will be      identified to you by the label Advertisement, Information from Industry,      Sponsored, idōs App Professional or some similar designation indicating      that the content, which may pertain to a particular medical condition,      therapy, product or service, has been selected by a third-party sponsor.
• Member      Profiles. Subject to applicable law, idōs      App may provide Member Profiles, and portions thereof, (excluding contact      information and information about your participation in specific named CME      and CE activities) to third parties, including our advertising customers,      which these third parties may use for their business purposes including      marketing.
• Market      Research. If you receive remuneration      for participating in a market research program offered through our      Services, we may provide your personal information to our payment fulfillment      vendor so that it can process and deliver your payment to you and for its      recordkeeping and regulatory compliance purposes, and also to the program      sponsor (or the market research company acting on its behalf) for its      recordkeeping and regulatory compliance purposes. If you choose to access      a survey that is conducted by a third party market research company, we      may identify you to this company. Sometimes market research companies send      us lists of individuals they wish to reach with particular market research      opportunities and we may inform these companies which of these individuals      are members of the idōs App Network so that they can manage their      recruitment needs accordingly. Also, certain market research opportunities      require us or the market research company to contact you directly to      conduct the survey, including by telephone. We will inform you in the      research invitation if you will be required to provide additional contact      information, e.g., phone number, to participate so that you can decide at      that time if you wish to proceed with the opportunity. We do not disclose      your survey responses to the sponsor in a manner that identifies you.
• Logging      in to Another Website Using Your idōs App Credentials. Certain third party websites permit you to log in using      your idōs App Network username and password. If you choose to log in to      one of these websites using your idōs App Network access credentials, we      may give this website information included in your registration profile      including personal information such as your name, specialty, occupation      and email address, (but not your idōs App username and password), which      the operator of the website has agreed to use in accordance with its      website's privacy policy. You should review the third party website's      privacy policy before logging in. If the privacy policy of the third party      site permits, we may receive information about your use of this third      party site, which we may use in accordance with this Privacy Policy.
• Adverse      Event Reporting. If you provide us information      about an adverse event regarding a pharmaceutical product or medical      device, we may be required to report such information along with your      contact information to the manufacturer as required for it to fulfill its      reporting obligations to the applicable regulatory authority. If you do      not want this information reported to the applicable manufacturer and      regulatory authority, then do not provide us with adverse event      information. 
• Consent. We may disclose your personal information to a third      party in a manner not addressed by this Privacy Policy subject to your      consent at such time.
• Aggregated      Information. We may provide aggregated      information about users of our Services to third parties as we deem      appropriate in our sole discretion. For example, idōs App may tell a      customer what percentage of registered users of the idōs App Network      reside in a particular geographical area or specialize in a particular      clinical area, or what percentage of participants in a market research      survey selected a particular response to a survey question. 
• Social      Widgets. We may include social widgets      within our websites and apps which enable you to interact with the      associated social media services, e.g., to share an article. These widgets      may collect browsing data which may be received by the third party that      provided the widget, and are controlled by these third parties. You may be      able to manage your privacy preferences directly with the applicable      social network platform.
• Business      Transfers and Affiliates.      We may share your information with any member of our group of companies      (meaning our subsidiaries, our ultimate holding company and its      subsidiaries) for their use for the purposes set forth in this Privacy      Policy, including to market to you through a variety of channels as      described herein, subject to applicable law. In connection with a      corporate change in control resulting from, for example, a sale to, or      merger with, another entity, or in the event of a sale of assets or a      bankruptcy, we reserve the right to transfer your personal information to      the new party in control or the party acquiring assets. In the event of      such a change, your personal information will continue to be treated in      accordance with this Privacy Policy, as may be modified as described      below.
• Legal      Requirements. We may release personal      information when we believe release (i) is required to comply with valid      legal requirements such as a law, regulation, search warrant, subpoena or      court order and to meet national security or law enforcement requirements;      or (ii) is reasonable in response to a physical threat to you or others,      to protect property or defend or assert legal rights of us or others.

We have implemented appropriate technical and organizational security measures to protect the personal information that we have under our control from unauthorized access, use, disclosure and accidental loss. When you enter personal information, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology. You are solely responsible for maintaining the security and confidentiality of your account username and password. Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

 
Choice and Control

• Account      Information. You may update your      registration information at any time through the Account Management      feature available on each of our properties. You may also contact Customer      Support at support@idōs.app     and request that your registration information be updated or deleted. Note      that if we delete your account, we may maintain certain de-identified      information about you for internal business purposes including research,      analytics and reporting.
• Cookies. Most browser software can be set to reject all      cookies, including third party cookies, however, if you choose to reject      our cookies, your ability to access and use the Services will be limited.      Refer to our Cookie Policy for additional information      about opting out of cookies.
• Mobile      Opt-out. You may control      interest-based advertising on your mobile device by enabling the “Limit Ad      Tracking” setting in your iOS device’s settings or “Opt out of Ads      Personalization” in your Android device’s settings. This will not prevent      you from seeing advertisements, but will limit the use of device      advertising identifiers to personalize ads based on your interests.
• Precise      Location Information. You      may disable the transmission of precise location information through your      device settings. To change location settings on your device, please refer      to your device’s official knowledge base.
• Email      Communications. If you no longer wish to      receive a particular type of email communication from us, you may      unsubscribe by clicking the "unsubscribe" link located at the      bottom of the email and following the instructions. Also, you may manage      your newsletter subscriptions within the newsletter subscriptions area      within your account settings. Note that certain email communications that      we send to members are service-related and as long as you are a member of      the idōs App Network, you may not unsubscribe from such emails. Also, if      you have provided us more than one email address, we may continue to      contact you using the other email address not associated with the emails      from which you have unsubscribed, until you unsubscribe from emails sent      to that other address.
• Push      Notifications. We may send you push      notifications from time-to-time to notify you of upcoming events or      promotions we think may be relevant to you. If you no longer wish to      receive these types of notifications, you may turn them off at the device      level. 
• California      Residents. If you are a California      resident, California law may provide you with additional rights regarding      our use of your personal information. For more information relevant to our      users who are California residents, please read below.

 
We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in our Privacy Policy or in the CCPA have the same meaning when used in this notice. 

We have collected the following categories of information from consumers within the last twelve (12) months: 

A.  Identifiers. 

A real name, alias, postal   address, unique personal identifier, online identifier, Internet Protocol   address, email address, account name, Social Security number, driver's   license number, passport number, or other similar identifiers. 

B. Personal information listed   under Cal. Civ. Code § 1798.80(e). 

A name, signature, Social Security   number, physical characteristics or description, address, telephone number,   passport number, driver's license or state identification card number,   insurance policy number, education, employment, employment history, bank   account number, credit card number, debit card number, or any other financial   information, medical information, or health insurance information. Some   personal information included in this category may overlap with other   categories. 

C.  Protected classification   characteristics under California or federal law. 

Age (40 years or older), race,   color, ancestry, national origin, citizenship, religion or creed, marital   status, medical condition, physical or mental disability, sex (including   gender, gender identity, gender expression, pregnancy or childbirth and   related medical conditions), sexual orientation, veteran or military status,   genetic information (including familial genetic information). 

D.  Commercial Information. 

Records of personal property,   products or services purchased, obtained, or considered, or other purchasing   or consuming histories or tendencies. 

E.  Biometric Information. 

Genetic, physiological,   behavioral, and biological characteristics, or activity patterns used to   extract a template or other identifier or identifying information, such as,   fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,   gait, or other physical patterns, and sleep, health, or exercise data. 

F.  Internet or other similar   network activity. 

Browsing history, search history,   information on a consumer's interaction with a website, application, or   advertisement. 

G.  Geolocation data. 

Physical location or movements. 

H.  Sensory data. 

Audio, electronic, visual,   thermal, olfactory, or similar information. 

I.  Professional or   employment-related information. 

Current or past job history or   performance evaluations. 

J.  Non-public education   information. 

Education records directly related   to a student maintained by an educational institution or party acting on its   behalf, such as grades, transcripts, class lists, student schedules, student   identification codes, student financial information, or student disciplinary   records. 

K.  Inferences drawn from   other personal information. 

Profile reflecting a person's   preferences, characteristics, psychological trends, predispositions,   behavior, attitudes, intelligence, abilities, and aptitudes. 

Certain information that we collect identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).

Personal information does not include: 

• Publicly available information from government records.
• De-identified or aggregated consumer information.
  • Information included in categories D and G is       collected and used in a de-identified and/or aggregated manner.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health       Insurance Portability and Accountability Act of 1996 (HIPAA) and the       California Confidentiality of Medical Information Act (CMIA) or clinical       trial data; or 
  • personal information covered by certain       sector-specific privacy laws, including the Fair Credit Reporting Act       (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial       Information Privacy Act (FIPA), and the Driver's Privacy Protection Act       of 1994.  

As described in our Privacy Policy, we may obtain the categories of personal information listed above from the following categories of sources: 

• Directly      from you, such as when you register with us.
• Indirectly      from you, such as information we may collect in the course of providing      the Services.
• Directly      and indirectly from your activity on our Sites and Apps, as described      below under Personalize the Services. 
• From      third parties that interact with us in connection with the Services, such      as from governmental entities or from other third party sources to verify      and update your registration information, for research purposes or to      personalize the Services, including advertising.

Use of personal information.

Each of categories A, B, F, I and K described above may be used for the following business purposes: 

• Provision      of the Services. We may use your personal      information to provide and improve the Services, and to develop new      Services.
• Member      Profiles. We may associate your      personal information with respect to your use of the Services with your      registration information and any other information we have about you, as      described in this privacy notice, thereby creating a profile of you that      we may update from time to time ("Member Profile").
• Communications. By registering as a member of the Idōs Network, we      may use of your registration information and other information collected      about you as described in this privacy notice 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.
• Personalize      the Services. We may personalize the      Services, including the advertising you see within the Idōs Network, on      third party websites and in our email communications, based on information      included in your Member Profile. For example, a user who idōs App believes      is a cardiologist or who has browsed cardiology content with the Idōs      Network may be served an advertisement promoting a particular cardiac      product within the Idōs Network, on third party websites and/or within an      email that a user who idōs App believes is a neurologist or has not      browsed cardiology content will not see. We partner with third parties to      manage and conduct our advertising activities including advertising on our      websites and on third party websites. These third parties may use cookies      and other tracking technologies to deliver this advertising based on your      activities and interests as inferred from your use of the Services and      other information they have about you. Also, advertisers may use their own      cookies and other tracking technologies in the advertisements served to      you through the Services, some of which may enable the advertiser to      obtain personal information that can be used to specifically identify you,      including the fact that you saw the advertisement, to the extent that you      have separately provided consent to the advertiser or to the third party      providing the tracking technology. Some advertisers use companies other      than idōs App to serve their advertisements on their behalf and to monitor      users' responses to these advertisements through the use of cookies and      other tracking technologies. While idōs App generally permits the use of      third party tracking technologies based on an understanding that they      comply with the idōs App Advertising Policy, we do not have control over      these third parties' use of cookies and other tracking technologies or how      they manage the information they gather through them and idōs App may be      unable to verify compliance with the idōs App Advertising Policy.
• Verification      Purposes. We may use your information      in conjunction with information from third parties to recognize you as a      registered member when you visit one of our properties and to verify your      identity and/or professional credentials. We may require you to provide      proof of your identity, including that you are a healthcare professional,      and if you are unable to do so to our reasonable satisfaction, we reserve      the right to deny you access to the Services. While we take steps to verify      that our members who identify as healthcare professionals are actually      healthcare professionals, we make no guarantee as to their identity,      professional credentials or licensure status.
• Account      Management. We may use your information      to administer your account, respond to your inquiries, fulfill your      requests and send you administrative communications about the Services.
• Investigations. We may use your information to detect, investigate      and defend against fraudulent or unlawful activity, violations of the Idōs      Terms of Use and to otherwise establish, exercise and defend our legal rights.
   

Sharing your personal information

Personal information disclosed for a business purpose

• Service      Providers. We work with third party      service providers to help us provide the Services and to otherwise assist      us in the operation of the Idōs Network, including in the areas of email      management and deployment, analytics, marketing, advertising, market      research, sweepstakes and contest administration, identity and professional      credential validation, content distribution, customer service, payment      fulfillment, event logistics, website maintenance and data storage and      security. We may provide these service providers with personal information      about users of our Services so that they can fulfill their      responsibilities to us, and we require that they agree to limit their use      of this personal information to the fulfillment of these responsibilities.
• Advertising      and Sponsored Programs. We      may provide your personal information to third party sponsors of      advertisements and Sponsored Programs, subject to applicable law.      Specifically, when you are exposed to an advertisement through the      Services, whether on one of our websites or apps, in an email or through      some other means, or when you engage in a Sponsored Program, e.g., access      a sponsored information resource, open one of our sponsored emails, idōs      App may provide your personal information, such as your name and specialty      (but not your email or postal address) to the applicable sponsor and/or      its agents on the sponsor's behalf. We may also provide such third parties      with details about your engagement with the advertisement or Sponsored      Program (e.g., whether you viewed or otherwise interacted with certain      content), your answers to any questions contained in the Sponsored Program      and information about you that we have received from third parties.      Additionally, when you register as a member of the Idōs Network, we may      provide your personal information (but not your email or postal address)      to potential sponsors of advertisements and Sponsored Programs that may be      offered or provided to you through the Services, subject to applicable      law. Except as otherwise provided by applicable law, we are not      responsible for how these third parties use your information. All      advertisements and Sponsored Programs (including any links to Sponsored      Programs) made available within the Idōs Network, including through      emails, will be identified to you by the label Advertisement, Information      from Industry, Sponsored, idōs App Professional or some similar      designation indicating that the content, which may pertain to a particular      medical condition, therapy, product or service, has been selected by a      third-party sponsor.
• Member      Profiles. Subject to applicable law, idōs      App may provide Member Profiles, and portions thereof, (excluding contact      information and information about your participation in specific named CME      and CE activities) to third parties, including our advertising customers,      which these third parties may use for their business purposes including      marketing.
• Market      Research. If you receive remuneration      for participating in a market research program offered through our      Services, we may provide your personal information to our payment      fulfillment vendor so that it can process and deliver your payment to you      and for its recordkeeping and regulatory compliance purposes, and also to      the program sponsor (or the market research company acting on its behalf)      for its recordkeeping and regulatory compliance purposes. If you choose to      access a survey that is conducted by a third party market research      company, we may identify you to this company. Sometimes market research      companies send us lists of individuals they wish to reach with particular      market research opportunities and we may inform these companies which of      these individuals are members of the Idōs Network so that they can manage      their recruitment needs accordingly. Also, certain market research      opportunities require us or the market research company to contact you      directly to conduct the survey, including by telephone. We will inform you      in the research invitation if you will be required to provide additional      contact information, e.g., phone number, to participate so that you can      decide at that time if you wish to proceed with the opportunity. We do not      disclose your survey responses to the sponsor in a manner that identifies      you.
• Continuing      Medical Education. Idōs,      LLC (“Idōs”) is jointly accredited by the Accreditation Council for      Continuing Medical Education, the American Nurses Credentialing Center and      the Accreditation Council for Pharmacy Education to deliver continuing      education for the healthcare team (collectively, "CME/CE"),      which CME/CE activities are hosted by Idōs on Idōs Education (idōs.org),      which is part of the Idōs Network. As an accredited entity, Idōs is      required to periodically submit personal information about CME/CE      participation to the relevant accrediting entities. Idōs and its      affiliates that develop independent medical education content (“IME”),      including idōs App Global LLC ("idōs App Global"), may provide      your personal information to accredited providers that certify CME/CE and      IME offered through the Services as required to process your credits,      fulfill their reporting obligations to the relevant accreditation bodies,      and for their internal recordkeeping and regulatory purposes. Commercial      supporters of CME/CE and IME activities receive only aggregated data about      the activities that they support including participation and outcomes      measurement reports. We may share your personal information among our      affiliates for the purpose of sending you a survey with respect to a      CME/CE or IME activity.
• Logging      in to Another Website Using Your Idōs Credentials. Certain third party websites permit you to log in      using your Idōs Network username and password. If you choose to log in to      one of these websites using your Idōs Network access credentials, we may      give this website information included in your registration profile      including personal information such as your name, specialty, occupation      and email address, (but not your Idōs username and password), which the      operator of the website has agreed to use in accordance with its website's      privacy policy. You should review the third party website's privacy policy      before logging in. If the privacy policy of the third party site permits,      we may receive information about your use of this third party site, which      we may use in accordance with this privacy notice.
• Adverse      Event Reporting. If you provide us information      about an adverse event regarding a pharmaceutical product or medical      device, we may be required to report such information along with your      contact information to the manufacturer as required for it to fulfill its      reporting obligations to the applicable regulatory authority. If you do      not want this information reported to the applicable manufacturer and      regulatory authority, then do not provide us with adverse event      information. 
• Consent. We may disclose your personal information to a third      party in a manner not addressed by this privacy notice subject to your      consent at such time.
• Aggregated      Information. We may provide aggregated      information about users of our Services to third parties as we deem      appropriate in our sole discretion. For example, we may tell a customer      what percentage of registered users of the Idōs Network reside in a      particular geographical area or specialize in a particular clinical area,      or what percentage of participants in a market research survey selected a      particular response to a survey question.
• Social      Widgets. We may include social widgets      within our websites and apps which enable you to interact with the      associated social media services, e.g., to share an article. These widgets      may collect browsing data which may be received by the third party that      provided the widget, and are controlled by these third parties. You may be      able to manage your privacy preferences directly with the applicable      social network platform.
• Business      Transfers and Affiliates.      We may share your information with any member of our group of companies      (meaning our subsidiaries, our ultimate holding company and its      subsidiaries) for their use for the purposes set forth in this privacy      notice, including to market to you through a variety of channels as      described herein, subject to applicable law.
• Legal      Requirements. We may release personal      information when we believe release (i) is required to comply with valid      legal requirements such as a law, regulation, search warrant, subpoena or      court order and to meet national security or law enforcement requirements;      or (ii) is reasonable in response to a physical threat to you or others,      to protect property or defend or assert legal rights of us or others.
   

In the preceding twelve (12) months, we may have disclosed your personal information included in each of categories A, B, F, I and K for each business purpose described above depending on your use of the Services described herein.
 

We disclose your personal information for a business purpose to the following categories of third parties: (i) service providers, and (ii) third parties to whom you or your agents authorize us to disclose your personal information in connection with the Services.  
 

Personal information “sold” to third parties

In the preceding twelve (12) months, we may have “sold“ the personal information included in each of categories A, B, F, I and K described above to our commercial clients in connection with our advertising and sponsored programs described under Advertising and Sponsored Programs above.

We do not sell the personal information of consumers that we know are minors under 16 years of age without affirmative authorization as required under the CCPA.  
 

Your rights

The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

Access to specific information and data portability rights

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. Once we receive and confirm your verifiable consumer request, we will disclose to you: 

• the      categories of personal information we collected about you.
• the      categories of sources for the personal information we collected about you.
• our      business or commercial purpose for collecting or selling that personal      information.
• the      categories of third parties with whom we share that personal information.
• the      specific pieces of personal information we collected about you (also      called a data portability request).
• if      we sold or disclosed your personal information for a business purpose, two      separate lists disclosing:
• sales,      identifying the personal information categories that each category of      recipient purchased; and
• disclosures      for a business purpose, identifying the personal information categories      that each category of recipient obtained.

 
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 

 
Deletion rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

• complete      the transaction for which we collected the personal information, provide a      good or service that you requested, take actions reasonably anticipated      within the context of our ongoing business relationship with you, or      otherwise perform our contract with you.
• detect      security incidents, protect against malicious, deceptive, fraudulent, or      illegal activity, or prosecute those responsible for such activities.
• debug      products to identify and repair errors that impair existing intended      functionality.
• exercise      free speech, ensure the right of another consumer to exercise their free      speech rights, or exercise another right provided for by law.
• comply      with the California Electronic Communications Privacy Act (Cal. Penal Code      § 1546 seq.).
• engage      in public or peer-reviewed scientific, historical, or statistical research      in the public interest that adheres to all other applicable ethics and      privacy laws, when the information's deletion may likely render impossible      or seriously impair the research's achievement, if you previously provided      informed consent.
• enable      solely internal uses that are reasonably aligned with consumer      expectations based on your relationship with us.
• comply      with a legal obligation.
• make      other internal and lawful uses of that information that are compatible      with the context in which you provided it.
   

Right to opt out of the sale of your personal information

You have the right to opt out of the sale of your personal information subject to certain exclusions as described below. Once we receive your request, we will not sell your personal information, unless an exclusion applies. We may request that you authorize the sale of your personal information after 12 months following your opt-out.  
 

The CCPA excludes certain transfers of your personal information from what constitutes a sale thereof: 

• As      directed by you:
• When      you direct us to intentionally disclose your personal information or use      the Services to intentionally interact with us or a third party (provided      that third party does not sell your personal information, unless that      disclosure would be consistent with the CCPA).
• Opt-out      signal:
• We      may share an identifier for you if you have opted out of the sale of your      personal information for the purposes of alerting third parties of your      election.
• Service      provider:
• We      may share your personal information with a service provider that is      necessary to perform a business purpose as described above if both of the      following conditions are met:
• we      provide notice of the sharing and your opt-out right as described herein.
• the      service provider does not further collect, sell, or use the personal      information of the consumer except as necessary to perform the business      purpose.
• Change      of control:
• We      may transfer to a third party your personal information as an asset that      is part of a merger, acquisition, bankruptcy, or other transaction subject      to certain requirements described in the CCPA. 

We are unable to process opt-out requests across devices or the Apps for advertising services described herein. For example, if you opt out on your browser, we are not able to honor that request if you are using one of our Apps due to our practices and the limitations described above. Please see below on how to opt out across devices.

Exercising access, data portability and deletion rights

To exercise the access, data portability and deletion rights described above, please submit a request to us by either: 

• Calling      us at (888) 405-3132 x170.
• Sending      a message to our Chief Privacy Officer Send email to our CPO.
   

By calling the toll-free number or using the above form, you will be asked to provide certain identifying information, such as name, email, residency and date of birth, which we will only use to process or verify your request. You will be asked to validate your request by clicking a validation link in an email that will be sent to the email address provided.  
 

The verifiable consumer request must: 

• Provide      sufficient information that allows us to reasonably verify you are the      person about whom we collected personal information or an authorized      representative.
• Describe      your request with sufficient detail that allows us to properly understand,      evaluate, and respond to it.
   

If you are exercising your right to access, portability or deletion, you may be asked to provide further verifying documentation, such as proof of residency and identity.  
 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465. 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.  
 

Exercising opt-out right

You may exercise your opt-out right by visiting our website and clicking the “Do Not Sell My Personal Information“ link in the footer.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will cover a period of no less than 12 months preceding the receipt of a verifiable consumer request. The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  
 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: 

• Deny      you goods or services.
• Charge      you different prices or rates for goods or services, including through      granting discounts or other benefits, or imposing penalties.
• Provide      you a different level or quality of goods or services.
• Suggest      that you may receive a different price or rate for goods or services or a      different level or quality of goods or services.
   

We may provide a different level of Services if the difference is reasonably related to value provided by your data.  
 

We reserve the right to change or modify this privacy notice and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. By continuing to use the Services after changes are made to this privacy notice, you agree to such changes. We encourage you to periodically review this privacy notice for the latest information on our privacy practices.  
 

Note to Users Outside of the United States

idōs App and most of our group companies are located in the United States, as is a majority of the idōs App Network’s technical infrastructure including its data hosting facilities. In order to provide the Services to you, we likely will transfer your personal information outside of your country of residence including to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.
 

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

idōs App participates in and has certified compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework with respect to its operation of the idōs App Network. idōs App is committed to subjecting all personal information received from EU member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Frameworks, and to view idōs App’s certification, visit the U.S. Department of Commerce’s Privacy Shield List.  
 

idōs App is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. idōs App complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, idōs App is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  
 

Children's Privacy

The idōs App Network and the Services are designed and intended for use by adults, and are not intended for nor designed to be used by children under the age of 18. We do not collect personal information from any person we know is under the age of 18.
 

Privacy Policy Changes

We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address included in your account profile) and/or by means of a notice on our websites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.
 

Contacting Us

If you have general questions about your account or the Services, contact Customer Support at info@idos.app.  
 

Effective date: August 1, 2021