Digital Therapeutics Alliance ™
This Policy applies to Personal Information that is Processed by DTA in the course of our business, including on DTA websites (each a “Site”), mobile applications, forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of DTA, the “Services”). This Policy does not apply to companies that DTA does not own or control. All individuals whose responsibilities include the Processing of Personal Information on behalf of DTA are expected to protect that data by adherence to this Policy.
3. TRANSPARENCY/NOTICE—TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with DTA and the requirements of applicable law. Some of the ways that DTA may collect Personal Information include:
- You may provide Personal Information directly to DTA through interacting with the Services, participating in surveys, and requesting Services or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
DTA collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with DTA, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address, or other information when you choose to request information about our Services, register for DTA’s newsletter that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Site and/or Services and in any manner consistent with the policies provided herein.
- Posting on the Site. DTA may offer publicly accessible pages, blogs, or community forums. You should be aware that, when you disclose information about yourself in on DTA’s public pages, blogs, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
- Information Submitted Via Services. You agree that DTA is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. DTA will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
- Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to DTA and to enhance our ability to provide you with information about our business, products, and Services.
3.2 How DTA Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Products, Services, or Information Requested. DTA may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of DTA’s Services;
- Contact you to answer requests for customer support or technical support;
- Allow you to register for events.
- Administrative Purposes. DTA may use Personal Information about you for its administrative purposes, including to:
- Measure interest in DTA’s Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about Individual accounts and activities on DTA’s Services and systems, and, in DTA’s discretion, changes to any DTA policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities.
- Marketing DTA Products and Services. DTA may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. DTA may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as described in Section 6.
- Research and Development. DTA may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, DTA may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Direct Mail, Email and Telephone. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on DTA’s products and services or events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
- Anonymous and Aggregated Information Use. DTA may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access DTA’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and DTA may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within DTA and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Other Uses. DTA may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are electronic identifiers that are transferred automatically to your computer through your browser that allow our computers to save certain information you provide us and store information about you so we can recognize you when you visit our Site in the future. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
3.4 Third-Party Websites AND Social Media Platforms
Although this Policy applies to the all information obtained by you for the purpose of accessing or using content controlled and owned by DTA, it does not apply to businesses or entities that are not owned or controlled by us.
The Site contains links to other Third-Party websites. Please be aware that DTA does not claim any responsibility for the privacy practices of these Third-Party sites. We encourage you to be aware when you leave our Site and to take reasonable precautions, including reading the privacy policies of Third-Party websites when sharing your personal Information on Third-Party websites.
DTA’s Services may include publicly accessible blogs. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
4. HUMAN RESOURCES DATA
DTA collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
- Workflow management, including assigning, managing and administering projects;
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- Job grading activities;
- Performance and employee development management;
- Organizational development and succession planning;
- Benefits and personnel administration;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Diversity and inclusion initiatives;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
- Compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- Acquisitions, divestitures, and integrations.
5 ONWARD TRANSFER—DTA MAY DISCLOSE YOUR INFORMATION
5.1 Information We Share
It is DTA’s policy not to disclose, sell, or rent your Personal Information to any individual, business, government entity, or outside parties except as needed to provide the Services you’ve requested through us or as outlined below.
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. DTA has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners. DTA may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Service that you have requested. DTA may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with DTA’s. DTA requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which DTA provided them.
- Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you post something to the public areas of the Site. We are not responsible for privacy practices of the other users who will view and use the posted information.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce DTA policies or contracts; (v) to collect amounts owed to DTA; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
5.2 Data Transfers
All Personal Information collected via or by DTA may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to DTA, you consent to the storage of your Personal Information in these locations.
6. OPT-OUT (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to DTA’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites.
6.2 Email and Telephone Communications
6.3 Human Resources Data
With regard to Personal Information that DTA receives in connection with the employment relationship, DTA will use such Personal Information only for employment-related purposes as more fully described above. If DTA intends to use this Personal Information for any other purpose, DTA will notify the Individual and provide an opportunity to opt out of such uses.
6.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
7. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
Although DTA makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which DTA is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If DTA determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, DTA will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. DATA RETENTION
9. SECURITY OF YOUR INFORMATION
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
10. INTERNATIONAL USERS
11. REDRESS/COMPLIANCE AND ACCOUNTABILITY
12. OTHER RIGHTS AND IMPORTANT INFORMATION
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, DTA will endeavor to comply with the law or contract.
12.2 California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. DTA does not share Personal Information with Third Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, DTA or to which DTA discloses Personal Information for use on its behalf.
- “Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of DTA or its subsidiaries worldwide.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, DTA or DTA’s Agents.
14. REVISION HISTORY