Last updated: July 2023
It also includes information about individuals whose personal information we may process when they apply to work at ContenteGeneMD.
GNM Healthcare Group Companies USA, Inc.
112 West 34 th St, 18 th floor
New York, NY 10120
GNM Healthcare's users from the EEA may contact our Data Protection Officer at email@example.com
Please note that if you contact us to assist you, we may need to verify your identity if there is a reasonable doubt before fulfilling your request.
Effective date: August 15th , 2021
We may collect personal data from you in the course of our activities, including when you use our site, when you contact or request information, when you choose to subscribe to our services or because of the relationships you may have with one or more members of our team and our customers.
Our primary goal in collecting personal information from you is to help us:
Information about your use of the Services is collected as follows:
We may use your information for the following purposes:
We carry out the following marketing activities using your personal information:
We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section below for more details of the information collected and how it is collected) to send you marketing communications.
What is our legal basis?
It is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications where you have consented to receive such marketing communications, or where we have a lawful right to do so.
Client insight and analysis
We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed.
By using this information, we can measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see.
We also use this information for marketing purposes (see the marketing section above for further details).
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available.
It is necessary for us to use your personal information.
Service Providers. We work with third party service providers to help us provide the Services and to otherwise assist us in the operation of the GNM Healthcare sites. We may provide these service providers with personal information about users of our Services so that they can fulfill their responsibilities to us, however, we do require that they limit their use of this personal information to the fulfillment of these responsibilities.
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, GNM Healthcare may tell a customer what percentage of registered users of the GNM Healthcare 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 our websites 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 (i) 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 (ii) 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.
As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers, who will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.
Further, we may appoint external data controllers where necessary to deliver the Services for example, but without limitation, accountants, barristers or other third party. When doing so we will comply with our legal and regulatory obligations in relation to the personal information, including but without limitation, putting appropriate safeguards in place.
What is our legal basis?
It is necessary for us to perform our obligations in accordance with any contract that we may have with you.
It is in our legitimate interest or a third party's legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. For more information relevant to our users who are California residents, please click here.
GNM Healthcare 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.
For visitors to the Site, we will retain relevant personal information for at least three years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation or similar legislation around the world, or for longer if we are required to do so according to our regulatory obligations or professional indemnity obligations.
For Service provision to any client, we will retain relevant personal information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation or similar legislation around the world, or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.
If personal information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
When you unsubscribe, your contact data (email address) will be kept for 3 years from the exercise of that right. This data, will in no case, be used for purposes other than the management of "right of opposition". Only the data necessary to take into account the right of opposition, will be stored. (e-mail address).
We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, rules, and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.
You have the following rights in relation to the personal information we hold about you:
Your right of access. If you ask us, we'll confirm whether we're processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we've shared your personal information with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to erasure. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we've shared your personal information with others, we'll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to restrict processing. You can ask us to 'block' or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we've shared your personal information with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to data portability. You have the right, in certain circumstances, to obtain personal information you've provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere for their own purposes across different services.
Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or to ask us to transfer this to a third party of your choice ;
- processing your personal information for direct marketing purposes.
Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time in Subscriptions & Preferences.
Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we've handled your personal information, you can report it to the relevant Supervisory Authority.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
The Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as GNM Healthcare has no control over information that is submitted to, or collected by, these third parties.
Please note that as U.S. residents your personal information may be made available to the U.S. government or its agencies in connection with legal proceedings in the United States.