SERMO Master Privacy Policy

Effective Date: October 11, 2012

This Privacy Policy provides you with information regarding SERMO's policies and procedures regarding the collection, use and disclosure of personal information and other data that we receive via our various websites and Services from our users and health care panel members and participants. Unless otherwise defined, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

1. ​Application of this Privacy Policy

This Privacy Policy applies to all Services and websites that are offered and provided by SERMO, its divisions, and its affiliates.

2. ​Safe Harbor Compliance

SERMO complies with the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks developed by the United States Department of Commerce in consultation with the European Commission and the Federal Data Protection and Information Commissioner of Switzerland. You may view our certification on the United States Department of Commerce website: https://safeharbor.export.gov/list.aspx. SERMO is also registered with ICO (United Kingdom Information Commissioner’s Office), The State Data Protection Inspectorate of the Republic of Lithuania, and P-Mark (Japan). In countries where SERMO is not registered, we strive to follow local data protection legislation, including with respect to CNIL (France), and BDSG (Germany).

3. ​Changes to this Privacy Policy

This Privacy Policy may be updated from time to time. Material changes will be posted conspicuously on the website and will be otherwise communicated to you online, if you have chosen to provide us with your email address. All changes will be effective immediately upon their posting. Depending on your geographic location, and the nature of the changes you may be required to agree to any such modifications before access to the website or Services following the implementation of such modifications. Otherwise, by accessing the website or Services following posting of changes to the Privacy Policy, you agree to all such changes and your use of the Website following any such notice will signify and constitute your assent to and acceptance of such revised Privacy Policy. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE EXIT THE WEBSITE AND CEASE ALL USE OF ANY SERVICES.

4. Market Research Guidelines

SERMO is a professional online market research and interactive media company. In the conduct of our market research activities, we adhere to CASRO (Council of Survey Research Organizations) guidelines in protecting survey respondent confidentiality along with ESOMAR (European Society for Opinion and Marketing Research),the MRS (Market Research Society), EphMRA (European Pharmaceutical Research Association) and BHBIA (British Healthcare Business Intelligence Association) codes of conduct. We also strive to comply with individual country's local market research codes of conduct, even if we are not a member.

SERMO maintains high standards of professional conduct in the collection and reporting of any survey information you may provide. All personal information remains strictly confidential and all survey responses are pooled together. All answers provided will remain anonymous unless explicitly stated in the details for a particular survey or unless SERMO otherwise obtains a survey respondent's consent to disclose the information to the survey sponsor. We may however disclose your medical education number as set forth below.

In the event that you choose to participate in our interactive or other data collection services, or otherwise participate in any response that is not traditional market research, such as our MNOW Prognosis Service, we may disclose your Personal Information (defined below) and specific responses to the SERMO customer that is the Service recipient. We may also post your name in connection with your predictions and responses as contemplated for the specific Service as further set forth in the Terms of Use.

In addition, if you choose to participate in our interactive or other data collection services, or otherwise participate in any response that is not traditional market research, such as our MNOW Prognosis Service, we will forward to you communications, which may include banner advertising or other advertisements that we believe may be of interest to you based on your Services participation and other online activity, which we may track and collect.

5. Where is my information located?

All data collected from the SERMO websites and your participation in any panel for the Services that we provide is primarily stored on our servers in the United Kingdom at our data center in London. We also maintain a secondary server in the United States in the State of North Carolina to facilitate Service speed and provide a redundant backup of all data such that all data will reside in both the United Kingdom and the United States. However, we may also utilize data centers in or near our Asia facilities as well.

You expressly acknowledge and consent that your data may be transferred to SERMO's various facilities and third party providers in the European Union, in the United States and in Asia and may be maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you choose to provide information to us, you understand that it may be used, maintained and processed in of the above locations. Your consent to this Privacy Policy as evidenced by your submission of your information represents your agreement to that transfer.

6. How long do you keep my information?

We will store your information and data collected from you indefinitely unless you expressly request to be removed from our databases and Services by contacting us as set forth below. Because we recruit and market our Services and survey panels on a continuous basis, it is likely you will be approached from our marketing or recruitment teams, even if you have your information removed from our databases.

7. What information do you collect and how do you use it?

​a.​ Active Collection

Our primary goals in actively collecting information are to provide and improve our Services, to administer your subscription to our Services, and to enable you to enjoy and easily navigate the website and Services offerings.

Personal Information

When you contact us, apply to become a registered Services user or participant in one of our Services (such as participating in a survey or becoming a member of our MNOW panel – formerly known as our LeadPhysician panel), or when you join our mailing lists or use our Services to submit an electronic communication or post content, we will ask you for your personally identifiable information. This refers to information about you that can be used to contact or otherwise identify you ("Personal Information"). Personal Information may consist of your name, e-mail address, medical education number and mobile telephone number. If you are signing up to participate in panels or to participate in a Service that may entitle you to receive an honoraria or incentive, we may also request financial information and bank details to facilitate the payment of honoraria or incentives.

We may also request additional information from you through a number of profiling questions, that request information on details such as your personal and professional profile describing your credentials, professional experiences, academic background, and field of medical specialty. Providing additional information beyond what is required to participate in the our panels and Services is entirely optional. However, providing this additional profiling information can help us facilitate your use of and access to our Services, especially if you are registering to become a survey panel member, as we can direct to you more specific opportunities and marketing information that may be of interest to you.

We use your Personal Information to provide the Services or communications that you request, authenticate your Services and/or panel account registration, and to administer your inquiries and communicate with you. We may also use your Personal Information in other ways naturally associated with the circumstances in which you provided the information.

We may combine your Personal Information and aggregate it with information collected from other visitors or sources to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Service is used. We may also use the combined information without aggregating it to serve you specifically.

We also use your Personal Information to send you advertisements, marketing and other promotional materials and information that we believe may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions, provided in our communications to you, or contact us via e-mail at the address specified at the end of this Privacy Policy (See " Changing or Deleting Information," below). We will implement your request within 14 days of receiving the requested changes.

Please note that we will use your Personal Information to contact you with notifications related to your use of the Services and/or website; you may not opt out of these notifications for so long as you are receiving Services.

Medical Education Number

We may use and disclose your medical education number in the event that a SERMO client and survey sponsor has questions on any adverse event reported in or related to a survey. In addition, we may also use and disclose your medical education number if the survey sponsor requests that information pursuant to your consent.

We may also use your medical education number to associate your survey data with data we have obtained and collected from third parties based on your use of our Services and other internet data we have collected.

Finally, certain states and other jurisdictions require us to report honoraria and incentive payments to medical professionals such that we are required by certain government regulations to report honoraria or incentive payments to your medical education number.

IP Addresses

Some jurisdictions consider IP addresses to be personally identifiable and some do not. SERMO collects IP addresses as you register and use our website as described below in "Log Data."

Digital Fingerprinting

SERMO uses IP addresses, in part, with certain technological measures to engage in digital fingerprinting. We use digital fingerprinting to confirm identities of survey respondents, to attempt to reduce any fraud in our Services and surveys, and to enhance your user experience, for example, by delivering website and Services content specific to you.

Public Forums

We may offer message boards, bulletin boards or similar public forums where you and other users of our Service can communicate. We may use your Personal Information to identify you with a posting in a public forum. In addition, we may collect and maintain, in the aggregate and otherwise, the information that you provide in such public forums for data aggregation and analysis.

The protections described in this Privacy Policy do not apply to third party use of information that you publicly post (including personally identifiable information about yourself or any person) in connection with your use of these public forums. Any information you share in a public forum is public information and may be seen or collected by other persons, including third parties that do not adhere to our Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Services.

You must not engage in any conductor disclosure any information in violation of hippa, hitech or other applicable laws or regulations protecting medical privacy and/or patient information.

​b. ​Passive Collection

Log Data

When you visit our website, our servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your computer's Internet Protocol address (addressed above), browser type or the webpage you were visiting before you came to our website, pages of our website that you visit, the time spent on those pages, information you search for on our website, access times and dates, and other statistics.

We use this information to monitor and analyze use of the website and for the website's technical administration, to assist in monitoring and preventing fraud and response duplication, to increase our website's functionality and user-friendliness, and to better tailor the Service to our visitors' needs. Except as may be set forth above, we do not treat Log Data as Personal Information, but may combine Log Data with your Personal Information to provide you with targeted advertising or targeted offers that we think may be of interest to you. We may also aggregate, analyze and evaluate Log Data for the same purposes as stated above regarding Personal Information.

Web Beacons and Widgets

We may use web beacons, which are small pieces of computer code embedded in websites and emails, and other widget code to track if and when you open email communications from use and when you visit our websites to transmit information about web activity from the website, which may include your visits to third party sites and your visits to us from third party websites.

Cookies

If you sign up to participate in our panels or otherwise receive or participate in Services, you are agreeing that we may place and use cookies.

Like many websites, we use "cookies" to collect information. We may place a text file called a "cookie" in the browser files of your computer. The cookie itself does not contain Personal Information although it will enable us to relate your use of the SERMO website to the Personal Information that you have chosen to provide us. Third party advertisers on the website may also place or read cookies on your browser. We may also use information collected from such third party cookies in partnership with our service providers to provide you with targeted advertising and other marketing materials and otherwise to serve up content that we believe may be of interest to you.

We may use cookies to store visitors preferences, record session information, record user-specific information on what pages users access or visit, alert visitors to new areas that we think might be of interest to them when they return to our site, customize web page content based on visitors' browser type or other information that the visitor sends and to monitor our websites and Services for fraudulent activity.

We may also use cookies to track your website activity to provide you with targeted advertising or targeted offers that we think may be of interest to you only when you participate in those activities that are not traditional market research or identified as such.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the website or all functionality of the website or Services.

Please note that we also use flash cookies as part of our digital fingerprinting process and may also use flash cookies for other fraud detection and fraud prevention activities. You may disable flash cookies by setting your computer system to disallow or disable third party flash content. However, if you disable flash cookies, we cannot confirm or verify any response from you and we may not accept your survey response or other response or posting.

Phishing

Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or social security number or national identification numbers in an unsolicited e-mail or telephone communication. We will only collect bank account and payment information from you within our online portal. For more information about phishing, visit the Federal Trade Commission's website at http://www.ftc.gov.

8. How Do We Share and Disclose Your Information?

Except as otherwise noted in this Privacy Policy, we do not sell or share your Personal Information without your consent. Deidentified and other aggregated information may be provided to third parties for marketing, advertising, or other uses.

Affiliates

We may share and disclose any information or data that we have or collect from your use of the website or receipt of any Services with any SERMO divisions or affiliates, who are also bound by this Privacy Policy.

Aggregated Data

SERMO expressly reserves the right to aggregate all information and data (including de-identified Personal Information) disclosed to SERMO in connection with the Services and access to its websites. All such aggregated information is the sole and exclusive property of SERMO and SERMO may use, transfer, license and sell such aggregated information internally or to any third party in its discretion.

Third Party Service Providers

We or our divisions or affiliates may engage third party companies and individuals to facilitate the provision of our Services, such as to provide recruitment, moderation, sample de-duplication, payment processing and other related services and to otherwise provide the Services on our behalf, and to perform website-related services (e.g., without limitation, hosting, maintenance services, database management, web analytics and improvement of the website’s features) and to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information. If they do, this access is only so that they may perform these tasks on our behalf and they will be obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of SERMO, its divisions, affiliates or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

Business Transfers

SERMO may sell, transfer or otherwise disclose some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets in any context.

9. General.

Accessing your Information

When you sign up to join our panels or otherwise receive or participate in any of our Services, you may access your information at any time by logging into the SERMO website portal with your unique user ID and password generated during registration for the Services.

Changing or Deleting Your Information

Access to your Personal Information is restricted only to you. You may edit your Personal Information at any time by logging in to your account using your user name and password.

If you would like us to change or delete your Personal Information in our system, or make changes to your privacy settings, please contact us as set forth below. We will implement your changes within 14 days of receiving your request.

Please note we may retain server/backup copies of all such data as we may be legally required to do so or as may exist in our backup services and archives, which will be deleted in the ordinary course of our business as such backups and archives are replaced.

Security

We strive to operate secure data networks protected by industry standard firewall and password protection systems. We employ administrative, physical and electronic measures designed to help protect your Personal Information from unauthorized access. However, the internet is inherently insecure and we cannot guarantee the security of data sent over the internet. While no online computer system can be completely security, the measures taken by SERMO are reasonably designed to reduce the likelihood of a security breach.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on our Website in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Links to Other Websites

Our website contains links to other websites. The fact that we link to a website or display a third party banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Toward Children

This website is not directed to persons under 18. As a result, we do not knowingly collect personally identifiable information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us as set forth below. If we become aware that a child under 18 has provided us with Personal Information, we will delete such information from our files.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at support@mnow.com.

North and South America
200 Park Avenue South, Ste 1301
New York
NY 10003
United States

Europe and Africa
WorldOne Research dba SERMO
3 Murphy St
Floor 3
London SE1 7FP
United Kingdom

Australia and Asia
Unit 504, No. 3 Building
5 Software Park Road
Dalian, P.R. China, 116023