Last Modified: 5/22/2018
Modifications to the Terms of Service
Focus Insite LLC, in its sole and absolute discretion, may make changes or modifications to the Site or to this Agreement (including any policies or agreements which are incorporated by reference herein) at any time and without prior notice to you, and such changes or modifications shall be effective immediately upon posting to this Site. You acknowledge and agree that (i) Focus Insite LLC may notify you of such changes or modifications by posting them to this Site and (ii) your use of this Site or the Services after such changes or modifications have been made (as indicated by the “Last Revised” date at the top of this page) shall constitute your acceptance of this Agreement as last revised. In addition, Focus Insite LLC may occasionally notify you of upcoming changes or modifications to this Agreement by email. We therefore recommend that you keep your account information including, but not limited to, your email address, current.
DATA PROTECTION OFFICER
Focus Insite LLC is headquartered in West Chester, Pennsylvania in the USA. Focus Insite LLC has appointed an internal data protection officer for you to contact if you have any questions, requests on your personal data, concerns or complaints please send an email to email@example.com
HOW WE COLLECT AND USE (PROCESS) YOUR PERSONAL DATA
Focus Insite LLC collects personal data about its members and those that participate in our activities. We use this personal data to provide you with services as described below. We do not sell personal data to anyone and only share it with third parties who are facilitating the delivery of our services or when you give us explicit additional permission.
PERSONAL DATA YOU GIVE US ABOUT YOURSELF WHEN YOU REGISTER
Personal data we collect and process: We collect the personal data you provide on the registration form; your name, address, telephone number, email address, and if you are a healthcare professional information about your occupation so that we can target and tailor invitations to participate in Activities.
PERSONAL DATA YOU GIVE US WITHIN YOUR MEMBERSHIP PROFILE
Personal data we collect and process: Focus Insite LLC collects from you additional personal data either before Activities or within the member website. This is used to allow us to invite you to participate in Activities that you are more likely to be interested in and qualify for. For example; for physicians, this may include information about your medical experience and the types of patient you treat; and for patients, it may include information about your condition(s) which can including sensitive (special category) personal data.
PERSONAL DATA YOU GIVE US WITHIN AND IMMEDIATELY BEFORE OR AFTER ONLINE ACTIVITIES
Personal data we collect and process: Activities should not contain requests for you to provide personal data. However, Focus Insite LLC maintains systems that control access to and measure outcomes (for example; if you completed the Activity or failed to qualify) so we may need to collect personal data before and/or after the Activity. This data is not linked directly to the Activity data and is only passed to third parties with your explicit consent and/or as laid out in this policy.
PERSONAL DATA RELATED TO YOUR PREVIOUS PARTICIPATION IN ACTIVITIES
Personal data we collect and process: We collect and store records of the Activities you have been invited to participate in, whether you responded to them, qualified for them, completed or partially completed them. We keep this data so that we make it available via the Sites and can respond to member enquiries. On occasions we may also send you invitations to new activities based upon your participation in previous Activities.
We use this data in aggregate to understand how many individuals of any type may participate in any future Activity and to understand trends in and patterns of participation.
We also maintain records of any data quality issues that may have been identified in the data you provided within an Activity so we can manage the quality of the data we provide to clients – this may affect your invitation to future Activities.
PAYMENT DETAILS YOU GIVE US FOR COMPENSATION PAYMENTS
Personal data we collect and process: We collect and use specific personal data so that we can process payment of your Activity compensation. The personal data we need to use varies depending on the form of payment but can include name, mailing address and email address. This is used only to process these payments but may be shared with payment processing partners to process the payment. This personal data is also retained for financial reporting, audit and tax purposes.
PERSONAL DATA WE GET FROM THIRD PARTIES
Personal data we get: Clients sometimes send us lists of healthcare professionals who they would like us to include or exclude in specific Activities. We also subscribe to various lists of healthcare professionals that we use to validate registrations and to append a variety of unique identification numbers to assist with deduplicating registrations and matching client lists. Lists of healthcare professionals are also for direct marketing purposes outside the EU.
PERSONAL DATA WE RETAIN FOR AN EXTENDED PERIOD
Personal data we collect and process: In order to manage its business, Focus Insite LLC needs to retain limited personal data about previous members for longer periods of time. We have carefully limited the personal data retained and the circumstances in which it is needed to the following:
- Requests by individuals to not email them
- Requests by individuals not to be contacted by Focus Insite LLC
- Individuals who have objected to Focus Insite LLC processing their personal data (where there is not an overwhelming interest in us continuing to do so)
This personal data is not shared with anyone and is only used to honour your requests or to prevent subsequent Activity participation.
PERSONAL DATA WE MAY COLLECT ABOUT YOU
Personal data we collect and process: We use a variety of public sources to collate information about professionals we believe may be suitable to complete specific Activities or may wish to become members of Focus Insite LLC. We may also receive a referral from one of your colleagues and process that information in a similar way. The information would include your name, contact information (address, phone number(s) and possibly email address) and your healthcare specialty.
PERSONAL DATA CREATED BY YOUR USE OF THIRD PARTY PLATFORMS
Your use of third party websites and services associated with Focus Insite LLC may expose your personal data. These sites are beyond our control and you should see their respective privacy policies: LinkedIn, Twitter, Facebook, Focus Insite LLC Blog (WordPress)
LINKS TO OTHER WEBSITES
Within Focus Insite LLC
Focus Insite LLC has its headquarters in the USA. Personal data we collect from you will be processed in the USA. The USA has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Focus Insite LLC relies on Model Clauses (Article 46), and EU-U.S.Privacy Shield (to which we self-certify) and derogations for specific situations as set forth in Article 49 of the GDPR.
Privacy Shield Compliance
Focus Insite LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Focus Insite LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
Focus Insite LLC submits to being subject to the investigatory and enforcement powers of the FTC, the Department of Transportation, or any other U.S. authorized statutory body with regards to our self-certification and implementation of the Principles, and acknowledges the right of the EU individual, under certain conditions, to invoke binding arbitration, at no cost to the individual, in filing a complaint disputing Focus Insite LLC’s adherence to these practices.
To suppliers and contractors
SECURITY OF YOUR PERSONAL DATA
To protect the privacy of personal data you provide us with, 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 this 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 personal data. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
The European Union’s General Data Protection Regulation and some other countries’ privacy laws provide certain rights for EU data subjects. A good explanation of them (in English) is available on the website of the United Kingdom’s Information Commissioner’s Office.
If you wish to confirm that Focus Insite LLC is processing your personal data, or to have access to the personal data Focus Insite LLC may have about you, please contact our Data Protection Officer by emailing firstname.lastname@example.org
You may also request information about:
- the purpose of the processing;
- the legal basis for that processing;
- the categories of personal data and the data subject concerned;
- who else outside Focus Insite LLC might receive your data from Focus Insite LLC and the protection provided
- what the source of the information was (if you didn’t provide it directly to Focus Insite LLC);
- how long it will be stored.
You have a right of:
- access, rectification, erasure, restriction, objection and data portability on your personal data. To exercise your rights, you can write the Data Protection Officer at email@example.com. You can also lodge a complaint with the Data protection authority (www.ico.org.uk)
Reasonable access to your personal data will be provided at no cost to Focus Insite LLC members, and Activity participants and others upon request made to Focus Insite LLC via our Data Protection Officer. Focus Insite LLC will provide you the information within the legal time frame. If for some reason access is denied, Focus Insite LLC will provide an explanation as to why access has been denied.
Independent Dispute Resolution Mechanism
Focus Insite LLC commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Private Shield policy should first contact Focus Insite LLC, refer to our Contact Information section below.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request .
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
For all other questions regarding your account, preference changes, compensation for surveys or our services, please e-mail firstname.lastname@example.org.
We know how important data protection is these days and will do everything we can to protect your privacy and preserve your trust. Feel free to reach out at any time if you have questions and, if we make additional changes to our policies, you’ll be the first to know
INFORMATION COLLECTION AND USE
Focus Insite may disclose Personal Information as described above and where it is required to do so by law or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on Focus Insite or this Site; (2) protect and defend the rights or property of Focus Insite; or (3) act in urgent circumstances to protect the personal safety of users of Focus Insite, its web sites or the public. If Focus Insite should ever file for bankruptcy or merge with another entity, we may sell the information you provide to us to a third party or share your Personal Information with any company with whom we merge.
Focus Insite provides you the opportunity to participate in multiple surveys on this Site. We may from time to time use a trusted service provider to conduct these surveys; however, we will not share the Personal Information you provide through a survey with other third parties unless we give you prior notice and the opportunity to opt-out of such disclosure.
As part of our business, we collect certain non-personally identifiable information about our members and use such anonymous or aggregate data to come to certain conclusions for our clients. “Aggregate Information” is information in summary form which does not contain any information or data that is identifiable to a specific person. We share the Aggregated Information we obtain from surveys with our partners and clients. We will only link aggregate user data to the specific individual who provided it to us in order to provide such individual with a reward for their participation.
3. CORRECTION OF PERSONAL INFORMATION SUBMITTED
We believe you should be in control of your Personal Information so if at any time you want to change the information you have provided to us, you may do so by logging in to your account and deleting or changing certain information in the “My Profile” section of the Site.
If at anytime you wish to discontinue your membership with Focus Insite and no longer wish to receive survey invitations, you may opt-out of receiving them by following the instructions included in any e-mail communication you receive from Focus Insite or by emailing us at email@example.com
5. SITE SECURITY
Focus Insite operates secure data networks protected by industry standard firewall and password protection systems. We review our security and privacy policies and enhance them as necessary. Focus Insite only allows authorized personnel at the company to have access to the information provided by you and does its best to ensure that your Personal Information is secure and protected.
6. CONTACT US
If you have any concerns or questions regarding the privacy of the information you provide to Focus Insite, please contact Focus Insite at firstname.lastname@example.org