Privacy Policy

Last updated: July 2023

Your privacy is important to us. At GNM Healthcare, we work to protect the privacy of our members and to help to ensure the proper use and disclosure of such information, as well as foster a culture that value privacy through awareness. This Privacy Policy explains how we handle and treat your data when you (i) register or visit our site, www.contentgenemd.com or associated sites of GNM Healthcare Group Companies USA, Inc. or pages (the "Site") or (ii) engage with us to use the products or services that ContentGeneMD provides (our "Services") when you subscribe.

It also includes information about individuals whose personal information we may process when they apply to work at ContenteGeneMD.

1- PURPOSE OF THIS POLICY

This Privacy Policy ("Privacy Policy") explains our approach to any personal information that we collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. It also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of your personal information that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services and/or to understand how your personal information may be processed by us as a result of providing the Services to third parties or when you apply to work at ContentGeneMD. Please take a moment to read and understand it.

2- WHO ARE WE AND WHAT DO WE DO?

We provide the Services as a professional resource intended to support healthcare professionals in their efforts to provide high quality medical information to patients. You can choose whether or not you want to use the Services. If you do choose to use the Services, you must agree to the GNM Healthcare Terms of Use which is a contract between us and users of the Services. By agreeing to the GNM Healthcare Terms of Use, you confirm that you have read and understand this Privacy Policy which explains how we collect, disclose, transfer, secure and use information about you in connection with your use of the Services and the rights and choices you have regarding these activities. If you do not want us to collect and use information about you 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 the United States and any other country from where the applicable GNM Healthcare property is operated. Please be aware that the privacy laws and standards in certain countries may differ from those that apply in the country in which you reside. Unless otherwise specified herein or on the property from which you have accessed this Privacy Policy, GNM Healthcare Group Companies USA, Inc. is the data controller of the personal information that we collect about you as described in this Privacy Policy.

3- HOW TO CONTACT US?

If you have general questions about your account or the Services, contact Customer Support at info@gnmhealthcare.com. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at infoprivacypolicy@gnmhealthcare.com or at the following address:

GNM Healthcare Group Companies USA, Inc.
112 West 34 th St, 18 th floor
New York, NY 10120
United States

GNM Healthcare's users from the EEA may contact our Data Protection Officer at dpo@gnmhealthcare.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

4- WHAT PERSONAL INFORMATION DO WE COLLECT?

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:

• - verify your identity ;
• - deliver our Services ;
• - improve, develop, and market new Services ;
• - carry out requests made by you on the Site or in relation to our Services ;
• - comply with any applicable law, court order, other judicial process, or the requirements of a regulator ;
• - enforce our agreements with you ;
• - protect the rights, property, or safety of us or third parties, including our other clients and users of the Site or our Services ;
• - use as otherwise required or permitted by law.

Information about your use of the Services is collected as follows:

• Registration. To use the Services, you may be required to register an account and 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 or by contacting GNM Healthcare Customer Service at info@gnmhealthcare.com.
• 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, precise location information, 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). We use cookies to collect the information about your use of the Services and your device. For more information about our use of cookies and other tracking technologies in relation to your use of the GNM Healthcare Network, see our Cookie Policy.
• Market Research. You may be invited to 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 that commissioned the survey. For some surveys, you may be asked to provide personal information for re-contact (e.g., by e-mail or phone).
• Information and Registration 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, etc.), or to register to attend live events, either in-person or via livestream. If you wish to participate in such opportunities, 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 be required to use such personal information as described at the point of collection.
• Information from Third Party Sources. We may obtain 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 augment your registration information, for research purposes or to personalize the Services, including advertising.
• Non-registered Users. You must register with the GNM Healthcare Network to gain full access to 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.

5- HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use your information for the following purposes:

• Provision of the Services. We may use the information collected about you to provide and improve the Services, and to develop new Services.
• Member Profiles. We may associate information that we have collected about your use of the Services with your registration information and any other information we have about you, as described in this Privacy Policy, thereby creating a profile of you that we may update from time to time ("Member Profile"). This processing of your Member Profile is necessary to deliver the Services tailored according to your specialty and interests (known or inferred), as further described below in Personalize the Services Including Advertising.
• Communications. By registering as a member of the GNM Healthcare, you agree to the use of your registration information and other information collected about you as described in this Privacy Policy to communicate with you about the Services and other information that may be of interest to you. These communications may be conveyed through a variety of channels, subject to applicable law, including emails and may contain 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 GNM Healthcare Network, on third party websites and in our email communications, based on information included in your Member Profile. For example, a user who GNM Healthcare believes is a cardiologist or who has browsed cardiology content with the GNM Healthcare may be served an advertisement promoting a particular cardiac product within the GNM Healthcare, on third party websites and/or within an email that a user who GNM Healthcare believes is a neurologist or has not browsed cardiology content will not see.
   Personalization is necessary for the performance of the contract between you and us according to which we deliver the Services. We analyze or deduct your preferences and interests based on a number of factors including:
   your profile (information provided at the registration time), enriched with other information obtained from third-party sources to ensure accuracy of our data and comply with our legal obligations;
   your interactions with our Services and the GNM Healthcare Network, such as:
  - your viewing and search history,
  - the time and location of your access to our Services,
  - the device you use,
  - answers you give to surveys and quiz,
  - our content you post, like, share or recommend, including through social media. Other users with similar tastes and preferences on our Service;
  - your interactions with other websites including with the GNM Healthcare Network, subject to our Cookies Policy.
   This information is used to classify users into different groups or segments. This analysis helps identify links and patterns between different behaviors and characteristics to recommend relevant Services for you. This will never prevent you from accessing and browsing the Services available to you within the GNM Healthcare Network.
• Verification Purposes. We may use your information to recognize you as a registered member when you visit one of our properties and to verify your identity and/or professional credentials. We may require you to provide proof of your identity, including 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 access to the Services. 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, violations of the GNM Healthcare Terms of Use and to otherwise establish, exercise and defend our legal rights.
• Marketing/communications.

  We carry out the following marketing activities using your personal information:

   Email marketing

  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.

  Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

  - an IP address to monitor Site traffic and volume ;
  - a session ID to track usage statistics on our Site ;
  - information regarding your personal or professional interests, demographics, experiences with our products and contact preferences.

  Please see our Cookie Policy for further information.

  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.

6- WHAT IS OUR LEGAL BASIS TO USE OR PROCESS YOUR PERSONAL INFORMATION?

It is necessary for us to use your personal information.

• - 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.
• - It is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

7- WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

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.

Business Transfers and Affiliates. We may share your information with any member of our group of companies (meaning our subsidiaries, our ultimate holding company and its subsidiaries) for their use for the purposes set forth in this Privacy Policy, including to market to you through a variety of channels as described herein, subject to applicable law. In connection with a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, we reserve the right to transfer your personal information to the new party in control or the party acquiring assets. In the event of such a change, your personal information will continue to be treated in accordance with this Privacy Policy, as may be modified as described below.

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.

8- OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Site use certain Tags, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

9- THIRD PARTY CONTRACTORS AND OTHER CONTROLLERS

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.

10- PRIVACY FOR CALIFORNIA RESIDENTS

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.

11- CHILDREN'S PRIVACY

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.

12- HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

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).

13- CONFIDENTIALITY AND THE SECURITY OF YOUR PERSONAL INFORMATION

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.

14- HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

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.

15- COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS

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.

16- NOTE TO USERS OUTSIDE OF THE UNITED STATES

GNM Healthcare is located in United States, as is a majority of the GNM Healthcare technical infrastructure including its data hosting facilities. In order to provide the Services to you, we likely will transfer your personal information outside of your country of residence to EU where it will be stored and processed in accordance with this Privacy Policy. In order to protect your personal information and to ensure we will comply with our legal and regulatory obligations in relation to personal information, including having a lawful basis for transferring personal information, we will put appropriate safeguards to ensure an adequate level of protection for the personal information.

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.

Users of www.contentgenemd.com website who are located within the territory of the European Union are subject to the provisions of the RGPD regarding the collection and processing of their personal data. You can consult our Privacy Policy which will inform you of how we process your personal data.

17- CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.