701 Pennsylvania Ave, N.W., Suite 800
Washington, D.C. 20004-2654
1. WHAT TYPES OF INFORMATION DOES ADVAMED COLLECT?
We collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
Information you give us. We obtain certain information when you provide it to us (“Contact Information”): for example, if you contact us using the form on our Website, you may provide certain information, including your email, phone, and organization. Some of that information can be used by AdvaMed to identify or contact you directly. You may also choose to provide certain personal information to us, including your zip code and organization information, when you sign up to receive email alerts, when you elect to join our purchasing group and receive discounts from our members, or when you submit an application for membership.
Information we collect about you. AdvaMed also gathers personal information through your use of the Website (“Other Data”). Such information may include: the Internet Protocol (IP) address, unique device identifiers, IDs for advertising, operating system, mobile network information, browser type, existing applications, browsing activity and non-precise device location information (e.g., city or region).
2. HOW DOES ADVAMED USE INFORMATION?
We may use the Contact Information that you provide to respond to your contact inquiries; provide you with services you have requested and/or customer support; register you for membership; communicate with you about news, events, opportunities, products, or services that may be of interest to you; allow you to take part in competitions, campaigns, promotions or surveys; and provide, develop, improve, and personalize the Website.
AdvaMed analyzes the Other Data to help us determine how Users access parts of the Website and who our Users are. By recognizing patterns and trends in usage, AdvaMed is able to better design the Website to improve Users’ experiences, both in terms of content and ease of use.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details provided at the top of this policy.
3. HOW DOES ADVAMED SHARE INFORMATION?
We may share the Other Data with third parties, including but not limited to advisors, advertisers, analytics providers, and investors, for the purpose of conducting our business. AdvaMed uses Google Analytics to track aggregated visitor data, which does not include any personal information. We reserve the right to disclose to third parties anonymised, aggregated Other Data collected for any lawful purpose.
AdvaMed may disclose any personal information which we hold on you to third parties when obligated or permitted to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual unlawful activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.
Finally, AdvaMed may transfer information, including any personal information which we hold on you, to a successor entity (or potential buyer) in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
It is important that the Contact Information we hold about you is accurate and current. Please keep us informed if your Contact Information changes during your relationship with us.
We use reasonable measures to protect information from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee the security of your personal information, and any transmission of your personal information to us is at your own risk. We are not responsible for third party circumvention of any privacy settings or security measures.
We do not knowingly collect or store personal information from anyone under the age of 13 unless or except as permitted by law. ANY PERSON WHO VISITS ANY OF THE WEBSITE REPRESENTS TO US THAT HE OR SHE IS 13 YEARS OF AGE OR OLDER. If we are made aware that we have received Contact Information from someone under 13, AdvaMed will use reasonable efforts to remove that information from our records.
6. COOKIES AND DO NOT TRACK
We do not control the third-party technologies whose services we use to improve the Website, and their use is governed by the privacy policies of third parties using such technologies. For more information about third party advertising networks and similar entities that use these technologies, see http://www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to www.aboutads.info/choices. Once you click the link, you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising companies.
Other than as described herein, AdvaMed does not track your activity over time and across different websites or online services except as among the related sites that constitute AdvaMed’s Website and as otherwise described herein, and we do not currently respond to browsers’ Do Not Track signals with respect to the Website. We do not permit our third-party service providers to collect information from the Website for other sites or for their own purposes other than as described in the preceding paragraph.
7. LINKS TO OTHER SITES
9. USERS IN THE EEA
If you are located within the EEA, you have a number of rights in relation to how we process your personal information. These include:
- The right access the personal information that we may hold about you;
- The right to rectify any inaccurate personal information that we may hold about you;
- The right to have your personal information erased in certain circumstances, for example, where it is no longer necessary for us to process your personal information to fulfil our processing purposes; where you object to your data being processed on certain grounds (for example, for marketing purposes) or where your personal information is being unlawfully processed; and
- The right, in certain limited circumstances, to have your data ported to a new service provider if you no longer wish to use the Website or our services.
You can exercise any of these rights any time by contacting us. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Basis upon which we process your personal information
We will process your personal information where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our organization in conducting and managing our business to enable us to give the best possible service to our members and the best and most secure experience on our Website. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
You have the right to make a complaint at any time to the supervisory authority for data protection issues within your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Transfers outside of the EEA
We, and many of our external third-party partners, are based outside the EEA, so their processing of your personal information will involve a transfer of data outside the EEA.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission (for further details, see European Commission: Adequacy of the protection of personal information in non-EU countries); or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal information the same protection it has in Europe (for further details, see European Commission: Model contracts for the transfer of Personal information to third countries); or
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal information shared between the Europe and the US (for further details, see European Commission: EU-US Privacy Shield).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.