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Privacy Policy
Last updated: (25/05/2018)
Cybermed Europe Network Privacy Policy
This Privacy Policy describes the privacy practices for cybermed.eu, cybermed.it, cybermednews.eu, cybermedjunior.eu, cybermedjunior.com, cybermedlife.eu, cybermedlife.com and artforhealingeurope.com (the “Sites”), which are operated by M.A.B. Art Decò – Michael Alexander Barnes ("Cybermed Europe Network" referred to along with M.A.B. Art Decò – Michael Alexander Barne as “we,” us” and “our”), respectively, and our mobile applications. (the "Apps”). We refer to the Sites and Apps collectively as the "Cybermed Europe Network," and along with the information and services made available to users of the Cybermed Europe Network, including but not limited to medical news, reference content, clinical tools, applications, sponsored programs, advertising, email communications, continuing medical education, market research opportunities and discussion forums, the “Services.”
We provide the Services as a professional resource intended to support healthcare professionals in their efforts to provide high quality medical care to patients. You can choose whether or not you want to register as a Cybermed Europe Network member and use the Services. If you do choose to use the Services, you must agree to the Cybermed Europe Network Terms of Use which is the contract between us and users of the Services. By accepting the Cybermed Europe Network Terms of Use, you confirm that you have read and understand this Privacy Policy. If you do not want us to collect, use or share information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in Europe where we are located. Except as otherwise noted in this Privacy Policy, M.A.B. Art Decò – Michael Alexander Barnes is the data controller responsible for the processing of your personal information as described in this Privacy Policy.
Information Collected
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.
- Services Information. We automatically collect and store information about your use of the Services, such as your engagement with particular content including editorial, advertisements, sponsored informational programs from our advertisers, which may include pharmaceutical companies ("Sponsored Programs"), whether you opened a particular email, clicked on a link, your search queries and how often and when you engage with the Services. We also collect information about your device when you access the Services including IP address, browser information (including referring URL), cookie information and advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device), all of which may be associated with information we have about your use of the Services. We use cookies and other tracking technologies, such as pixels, tags, web beacons and software development kits, to collect the information about your use of the Services and your device. If you are a member of the Cybermed Europe Network, we may elect to associate this information with your registration information. For more information about the use of cookies and other tracking technologies within the Cybermed Europe Network, see our Cookie Policy.
- 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.
- Public Forums: When you post a comment on a discussion board or other public forum, by default your username, specialty and degree will be displayed within the forum along with your comment. You may choose to display additional information in your public forum profile, including a photo, by adjusting your discussion profile settings. Information that you post within a public forum is public information and may be used by us and third parties, as further described in the Cybermed Europe Network Terms of Use.
- Information Forms: From time to time we may offer you the opportunity to receive additional information or services from us or from third parties, including our advertisers (e.g., sample request, sales rep visit, direct marketing lists, etc.). If you wish to receive such information or services, you may be asked to provide personal information to fulfill the request. Unless otherwise specified in the request form, we may use such information as described in this Privacy Policy and the third party, if applicable, will use such personal information as described at the point of collection.
- 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.
- Non-registered Users. You must register with the Cybermed Europe Network to access all of the Services, however, you may be able to access certain limited Services without registering. Even if you have not registered, we collect information about your use of the Services through the use of cookies and other tracking technologies. The information we collect includes the referring website, if applicable, the type of browser you use, the material viewed, and the time and date that you accessed the Services.
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.
- Personalize the Services Including Advertising. We may personalize the Services, including the advertising you see within the Cybermed Europe Network, on third party websites and in our email communications, based on your registration information, information collected about your use of the Services and information we receive from third party sources as described above. For example, a user who M.A.B. Art deco – Michael Alexander Barnes believes is a cardiologist or who has browsed cardiology content with the Cybermed Europe Network may be served an advertisement promoting a particular cardiac product within the Cybermed Europe Network, on third party websites and/or within an email that a user who M.A.B. Art deco – Michael Alexander Barnes believes is a neurologist or has not browsed cardiology content will not see. We partner with third parties to manage and conduct our advertising activities including advertising on third party websites. These third parties may use cookies and other tracking technologies to deliver this advertising based on your activities and interests as inferred from your use of the Services and other information they have about you. Also, advertisers may use their own cookies and other tracking technologies in the advertisements served to you through the Services, some of which may enable the advertiser to obtain personal information that can be used to specifically identify you, including the fact that you saw the advertisement, to the extent that you have separately provided consent to the advertiser or to the third party providing the tracking technology. Some advertisers use companies other than M.A.B. Art deco – Michael Alexander Barnes to serve their advertisements on their behalf and to monitor users' responses to these advertisements through the use of cookies and other tracking technologies. While M.A.B. Art deco – Michael Alexander Barnes generally permits the use of third party tracking technologies based on an understanding that they comply with the M.A.B. Art deco – Michael Alexander Barnes Advertising Policy, we do not have control over these third parties' use of cookies and other tracking technologies or how they manage the information they gather through them and M.A.B. Art deco – Michael Alexander Barnes may be unable to verify compliance with the M.A.B. Art deco – Michael Alexander Barnes Advertising Policy.
- 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.
- Investigations. We may use your information to detect, investigate and defend against fraudulent or unlawful activity and violations of the Cybermed Europe Terms of Use.
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.
- Consent: We may disclose your personal information to a third party in a manner not addressed by this Privacy Policy subject to your consent at such time.
- 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.
- Business Transfers: If we transfer a business unit (such as a subsidiary) or an asset (such as a website) to another company, that company will be required to treat any personal information collected under this Privacy Policy consistent with the applicable terms of this Privacy Policy.
- 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 info@cybermed.eu 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.
- Cookies. Most browser software can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. Refer to our Cookie Policy for additional information about opting out of cookies.
- 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
M.A.B. Art deco – Michael Alexander Barnes and Cybermed Europe Network are located in Europe, as is the Cybermed Europe Network’s technical infrastructure. In order to provide the Services to you, we must transfer your personal information to Europe where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside Europe to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in Europe and elsewhere, though European and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to European government or its agencies under legal process made in 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
When you use the Services, we collect, store, use and otherwise process your personal information as described in this Privacy Policy. We rely on a number of legal bases to process your information, including where: necessary for our legitimate interests in providing and improving the Services including offering you content and advertising that may be of interest to you; necessary for our legitimate interest in keeping the Services, Sites and Apps safe and secure; necessary for the legitimate interests of our service providers and partners; necessary to perform our contractual obligations in the Cybermed Europe Network Terms of Use; you have consented to the processing; you have expressly made the information public, e.g., in a discussion forum; necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena or court order or to exercise or defend legal claims; and necessary to protect your vital interests, or those of others.
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 info@cybermed.eu. 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.
We will retain your personal information for as long as necessary to provide the Services to you and fulfill the purposes described in this Privacy Policy. This is also the case for third parties with whom we share your information to perform services on our behalf. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it. If you no longer want us to use your personal information to provide the Services to you, you may close your account.
Children's Privacy
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.
Privacy Policy Changes
We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address included in your account profile) and/or by means of a notice on the Sites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.
Contacting Us
If you have general questions about your account or the Services, contact Customer Support at info@cybermed.eu. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Office by email at info@cybermed.eu or at the following address:
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