Last Updated: January 18, 2023
Collection of Information
- Identity Data: Your name, contact information, including e-mail address, and certain user information deemed necessary for you to use the Website and interact with other users and any other information that you may share with us or post for viewing via the Website. This information also permits the Website to communicate separately with you and provide you with information concerning the lead management global community.
- Technical Data: Your computer’s Internet protocol (IP) address, device identifiers, browser type, operating system, Internet service provider, the date and time of your visit, information about the links you click and pages you view within the Website, and other standard server log information. We may also collect certain location information when you use the Website, such as your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers.
- Patient Information: The Website will not process protected health information of any patients. You are prohibited from posting or sharing via the Website any medical information unless that information has been de-identified and anonymized.
Use of Information
We may use the information we collect online to:
- Provide the Website, as it is necessary for the performance of the contract for us to use your Identity Data to enable access to the Website;
- Contact you, as it is in our legitimate interest to be able to contact you with matters related to the Website or the subject matter of the Website;
- Analyze and improve the use of the Website, as it is in our legitimate interest to be able to manage and improve the Website;
- For any other purposes disclosed to you at the time we collect you information or pursuant to your consent.
Sharing of Information
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. We may share your information in the following circumstances.
- We may share your information with third-party vendors and service providers that help us with specialized services, including performance monitoring, hosting, and data processing. These third-party vendors and service providers may not use your information for purposes other than those related to the services they are providing to us
- We may share your information with other members accessing the Website who will see any information that you publicly post to the Website.
- We may share your information with our affiliates.
- We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, health, safety, and security of Cleveland Clinic, our affiliates, patients, users, or the public.
- We can transfer your information in the event of a transfer of the assets of the organization, merger, or consolidation or in the unlikely event of bankruptcy.
- We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.
Update Information. We encourage you to update, edit, and keep current your information. You can easily correct or update your personal information at any time by sending us an email.
Security Measures. We use measures designed to protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure.
Authentication Security. In the event you access any part of the Website requiring a username and password, you are solely responsible for keeping such username and password strictly confidential.
Users 18 Years and Older. We do not knowingly allow individuals under the age of 18 to create accounts that allow access to the Website. By using the Website, you confirm that you are 18 years of age or older.
Automated Processing. There is no automated decision-making that is made in connection with any of the Website users or their personal data.
Record Retention. For users located in the United Kingdom or European Economic Area, we will retain their Identity Data for the period that the individual is using the Website. If an individual does not use the Website for a period of 3 years, we will either delete your credentials to use the Website or will ask you whether you wish to continue to remain a user for the Website.
For United Kingdom and European Economic Area Users. The following rights apply to any users located in the United Kingdom or the European Economic Area Users:
- Access: Subject to certain exceptions, you have the right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Correcting: You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Deletion: You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object: You have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Restrict: You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Portability: You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent: You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
What we may need from you
Should you wish to exercise the rights accorded to you by data protection laws as described out above, please contact us. 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.
Time limit to respond
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.
Additional Contact Details
For any user located in the United Kingdom, we have appointed the following as the data representative for you to contact with any data request:
Article 27 Representative (UK GDPR): Cleveland Clinic London Ltd
Contact information: firstname.lastname@example.org (put LEADConnection in the subject line)
European Economic Area
For any user located in the European Economic Area, we have appointed the following as the data representative for you to contact with any data request:
Article 27 Representative (GDPR): DataRep is the Data Protection Representative so that you can contact them directly in your home country. DataRep has locations in each of the 27 European Union countries and Norway & Iceland in the European Economic Area (EEA).
Contact Information: Email address: email@example.com quoting
in the subject line. Contacting the DataRep on the online form at www.datarep.com/data-request.
All United Kingdom and European Economic Area users have the right to make a data protection complaint to the applicable supervisory authority.