Collection of Your Personal Data
We collect your information to give you convenient access to our Websites’ features, to verify your identity in our interactions with you, to personalize your experience on the Websites, and for customer service purposes. Your information also helps us keep you posted on status updates and service reminders. If you contacted us through https://clinithink.com or registered for access https://clixnotes.clinithink.com we may also contact you about offers that may interest you.
Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by sending a detailed email to firstname.lastname@example.org. Under certain circumstances we may not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe.
Please note that for personal data about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity–which determined the means and purposes of processing, all such requests should be made to that entity directly. We will honor and support any instructions they provide us with respect to your personal data.
If you use the Websites to transform clinical narrative (“NL Medical Data” see definition here) then we may use, copy and/or modify any NL Medical Data to support product improvement and utilization analysis.
The use of information collected through our service shall be limited to the purpose of providing the service for which the customer or partner has engaged Clinithink.
Clinithink predominantly collects information under the direction of its customers and partners and therefore has limited direct relationship with the individuals whose personal data it processes. If you are a customer of one of our customers or partners, and Clinithink is acting as a data processor for said customer or partner, and you would no longer like to be contacted by that customers or partners that use our service, please contact that customer or partner that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers and partners.
Clinithink acknowledges that you have the right to access your personal information. An individual who seeks access to correct, amend, or delete inaccurate data should initially direct their query to Clinithink’s customer or partner (the data controller). If you have engaged Clinithink personally through our Websites then we will support your access to correct, amend, or delete inaccurate data. Please contact us using the details at the end of this policy. If requested to remove data we will respond within a reasonable timeframe.
We will retain your personal data for as long as needed to provide you services. Clinithink will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, web browser type, internet service provider (ISP), referring or exit pages, the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system, and date and time stamps, and/or clickstream data to analyse trends in the aggregate and administer the site.
We automatically and store it in our logs. We will hold this data in line with our data retention policy for 7 years. After this time we will use reasonable efforts to delete this data.
Our Use, Disclosure and Retention of Your Information
We may combine information we collect about you from our Websites with information we obtain about you from other sources such as social media sites for example LinkedIn where information has been publicly shared. This may include combining the data we hold such as name and business email with information about the company you work for and/or company location or comments about our products or similar products you have posted on social media for the purpose of creating more tailored advertising of our services and products and better engaging with customers for example by a geographic advertising campaign. We use HubSpot to manage this process, their privacy notice can be found here https://legal.hubspot.com/product-privacy-policy We may also aggregate personal and other information about you or NL Medical Data that you submit to our Websites with information about and NL Medical Data from our other customers or partners.
Sometimes we hire other companies to provide products and services to you on our behalf, such as processing transactions, hosting websites, conducting customer surveys, and providing customer service. We may share some of your Personal Data with companies we hire to provide products and services to you on our behalf in order to enable them to perform such work. These companies are prohibited from using your Personal Data for any other purpose and are required to maintain its confidentiality.
We will retain Personal Data for the duration of a contract and for up to 7 years from the date you last used our Websites in line with our data retention policy. Following this time reasonable efforts will be employed to delete this Personal Data.
Opting out of Relevant Advertising
Accessing and Updating Your Information
We may send you e-mails with promotional offers only if you opt-in to receiving such e-mails. If you would no longer like to receive e-mailed special event information, sales notifications or other messages from us, please provide us with your contact information or follow the “Unsubscribe” instructions on such e-mails. Your e-mail address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in progress.
You may have additional rights depending on the territory in which you are a resident. These rights under applicable law, may include the following:
Please use the contact link at the end of this policy to contact us to exercise these rights. Please include your full name, email address, country of residence and company information as part of a detailed email so that we can verify your identity prior to considering your request and undertaking any relevant further action. We will respond to your request within a reasonable timeframe and in line with the timescales as determined by the applicable data protection legislation.
We employ and maintain technology and security measures designed to protect your information. When you submit sensitive information on our Websites, that information is subject to a variety of protections, including firewalls and password-protected features for certain website options. However, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us or receive from us.
Third Party Websites
You may have the option to enter third party websites through our Websites, or you may have the option to enter our Websites from another third party website. Since we cannot be assured that such third party websites follow our privacy policies, we encourage you to ask questions and review the privacy policies of these third parties. We have no responsibility or liability for the actions or policies of these independent sites, do not endorse any product or service that may be mentioned or offered in such websites, and are not responsible for the content or privacy practices of such websites.
Visiting our Websites from Outside of the United States
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
The Company’s US subsidiary, Clinithink LLC, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from the European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield list https://www.privacyshield.gov/.
Clinithink LLC is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Clinithink LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Clinithink LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). 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.
If you have unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolutions provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolutions procedures have been exhausted.
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