REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Last updated: (25/05/2018)
Information about your use of the Services is collected as follows:
- Registration. When you register as a member of the Cybermed Europe Network, you must 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.
- Market Research: You may 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 ("Sponsored Surveys"), where in this context "sponsor" means the third party that commissioned the survey. For some surveys, you may be asked to provide personal information for re-contact or payment fulfillment purposes.
- Information from Third Party Sources. We may receive 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 update your registration information, for research purposes or to personalize the Services, including advertising.
How Your Information May be Used
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 conduct research supporting the development of new Services.
- Email Communications. By registering as a member of the Cybermed Europe Network, you agree to our use of your registration information and other information that we collect about you to send you email communications, including advertisements and other promotional materials from third party sponsors, including pharmaceutical companies.
- Member Profiles. We may associate information that we have collected about your use of the Services with personal information you have provided to us, thereby creating a profile of you that we may update from time to time ("Member Profile"), as further described below.
- Verification Purposes. We may use your information in conjunction with information from third parties to verify your identity and/or professional credentials. We may require you to provide proof 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 participation in the Services or any component thereof. 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.
Sharing Your Information with Third Parties
Information about your use of the Services may be shared as follows:
- Contractors Who Work for Us: We work with third party contractors to help us provide the Services and to otherwise assist us in the operation of the Cybermed Europe Network, including in the areas of email management and deployment, analytics, marketing, advertising, market research, sweepstakes and contest administration, professional credential validation, customer service and payment fulfillment services. We may provide these contractors 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 a Site, in an App, in an email or through some other means, or when you engage in a Sponsored Program, e.g., access a sponsored information resource or open a sponsored email from M.A.B. Art deco – Michael Alexander Barnes, M.A.B. Art deco – Michael Alexander Barnes may provide your personal information, such as your name and specialty, but not your contact information such as email address and 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 Cybermed Europe Network, we may provide your personal information, excluding contact information, 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 Cybermed Europe Network, including through emails, will be identified to you by the label Advertisement, Information from Industry, Sponsored, M.A.B. Art deco – Michael Alexander Barnes or some similar designation indicating that the content, which may pertaining to a particular medical condition, therapy, product or service, has been selected by a third-party sponsor.
- Member Profiles. M.A.B. Art deco – Michael Alexander Barnes 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, subject to applicable law, which these third parties may use for their business purposes including marketing.
- Market Research Surveys: If you receive remuneration for participating in a Sponsored Survey, we may be required to provide the sponsor (or the market research company acting on its behalf) with your personal information for the sponsor's recordkeeping and/or regulatory reporting purposes. If you chose to access a Sponsored Survey that is conducted by a third party market research company, we may identify you to this company through the survey link. Sometimes market research companies send us lists of individuals they wish to reach with particular Sponsored Surveys, and we may inform these companies which of these individuals are members of the Cybermed Europe Network so that they can manage their survey recruitment needs accordingly. Also, certain market research survey opportunities made available to you through the Services require the market research company to contact you directly to conduct the Sponsored Survey. We will inform you in the associated survey invitation that we intend to provide your contact information to the market research company that is conducting the Sponsored Survey so that you can decide at such time if you wish to proceed with the opportunity. We do not disclose your Sponsored Survey responses to the associated sponsor in a manner that identifies you.
- Adverse Event Reporting. If you provide us information about an adverse event regarding a pharmaceutical product, we may be required to report such information along with your contact information to the manufacturer as required for the manufacturer 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.
- 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, M.A.B. Art deco – Michael Alexander Barnes may tell a customer what percentage of registered users of the Cybermed Europe 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 the Sites 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.
- Legal Requirements: We may release personal information when we believe release 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 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.
Security of Information
We have implemented appropriate technical and organizational security measures to protect the personal information that we have under our control from unauthorized access, use and 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 the Sites and Apps. You may also contact Customer Support at [email protected] and request that your registration information be updated or deleted. Following your request, we will delete your registration information from our active databases and where feasible from our back-up media. 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.
- Interest-Based Ads. You can opt-out of interest-based advertising on the Sites by rejecting cookies as described above and through preferences manager or, if you are located in the European Economic Area (EEA), you may also opt-out here. Please note that even if you reject cookies and opt-out of interest-based advertising, you will continue to receive generic advertisements through the Services. Note that the Sites do not respond to web browser “do not track” signals. You can learn more about managing your preferences for ads online, particularly for many third-party advertising networks, through resources made available by the Digital Advertising Alliance at https://www.aboutads.info or the Network Advertising Initiative at https://optout.networkadvertising.org. Note that if you delete cookies, use a different device, or change web browsers, you may need to opt out again.
- 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. You also may disable the transmission of precise location information through your device settings.
- 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 Cybermed Europe 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.
Note to Users Outside of Europe
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
M.A.B. Art deco – Michael Alexander Barnes 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
M.A.B. Art deco – Michael Alexander Barnes 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. M.A.B. Art deco – Michael Alexander Barnes complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
Additional Information for Cybermed Europe Network’s Visitors from the EEA
If you are a Cybermed Europe Network user in the EEA, then in accordance with applicable law, you can: access personal information we have about you in a machine readable format (we will try to provide information within 30 days of your request); have your personal information corrected or deleted (in most cases you can correct personal information you have submitted to us through your account settings); in certain circumstances, object to our processing of your personal information and we will discontinue such processing unless we have compelling legitimate grounds to continue; withdraw consent previously provided (however a withdrawal does not affect the lawfulness of processing of your personal data that occurred prior to the date of withdrawal); in certain circumstances, request that your personal information be transferred to another service provider, where feasible; or if you believe that we have not complied with applicable data protection laws, lodge a complaint with your local supervisory authority. If you wish to inquire as to whether we maintain any of your personal information and if so, whether you wish to exercise any of those rights that are available to you with respect to such personal information, you may contact Cybermed Europe Network Customer Support at [email protected]. We will respond to your request within a reasonable timeframe.
We may process your personal information to contact you by email to provide you with information that may be of interest to you. You may opt-out of this direct marketing through the unsubscribe link in the email communications we send to you or by changing your subscription preferences in your account settings.
The Cybermed Europe 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.
M.A.B. Art Decò – Michael Alexander Barnes
01030 Monterosi (VT) Piazzale A. La Marmora, 13
Phone: +39 3381508675
Please note that if you contact us to assist you, we may need to authenticate your identity before fulfilling your request.
Effective date: May 25, 2018