Pro-ficiency Privacy Policy

Pro-ficiency Hub Privacy Policy

This Privacy Policy describes how Pro-ficiency, LLC (“Pro-ficiency,” “we”, “us”, or “our”) handles personal information that we collect through our website and mobile applications (together with the website, the “Services”). The Services are designed to help our customers manage their businesses (“Businesses”).

Personal Information We Collect

Information you provide to us. Personal information you may provide to us through the Services includes:

Identification information: including your name, address, email address, phone number, company name, signature, title and/or role.

Communications: when you contact us with questions, feedback, respond to one of our surveys, or otherwise communicate with us we may collect the information in such communications.

Marketing information: such as your preferences for receiving our marketing communications, and details about your engagement with them.

Third party account information: if you choose to connect third party accounts to the Services, we may collect information associated with your third party account such as the name, email address, and profile information you provided to the relevant third party. In particular you are a Business and you opt to import or sync your Google account, contacts, iCal or similar accounts or services with our Services, we will collect and store information such as your contacts’ (including contacts your services provider(s) or application automatically added to your address book when you communicated with addresses or numbers not already on your list) email address, name, address, website URL, phone number and other metadata assigned to a contact (collectively, “Contacts’ Information”). We obtain this data in order to create profiles, suggest existing profiles for you to connect with and invite new persons to use the Services.

     Location information, that may be collected by our Services and third parties integrated into our Services (ex. a rough estimate of location from your IP address).

Derived Information: we may infer your preferences for certain products based on the personal information we collect about you.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Data providers, such as information services and data licensors.
• Public sources, such as social media platforms.

Automatic data collection. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with Pro-ficiency, our communications and other online services, such as:

• Device information, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G).
• Online activity information, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing Pro-ficiency’s Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them. We also use Google Analytics to monitor activity on the Site and to assist with advertising. Click here to learn how Google Analytics collects and processes data. Online activity information, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing Pro-ficiency’s Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them. We also use Google Analytics to monitor activity on the Site and to assist with advertising. Click here to learn how Google Analytics collects and processes data.

Technologies we use for automated data collection include:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. For example, we use cookies to keep track of your shopping cart and to provide other personalized experiences.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Your Personal Information

We use your personal information for:

Service delivery: including to:

• Provide, operate and improve the Services and our business of providing an all in one platform to manage Businesses;
• To create, maintain, and authenticate your account;
• Conduct research and analysis relating to Pro-ficiency, our Services, and our business;
•      Communicate with you about Pro-ficiency, including by sending surveys, offers, announcements, updates, security alerts, and support and administrative messages;
• Understand your needs and interests, and personalize your experience with Pro-ficiency and our communications; and
• Provide support for Pro-ficiency and respond to your requests, questions and feedback.

Research and development: We may de-identify personal information, as well as information available in Vendor contracts and related proposals that you may upload, and use the de-identified information for research and development, including to analyze and improve the Services and promote our business. Pro-ficiency does not use or aggregate gmail information for these purposes.

Marketing and advertising: We and our advertising partners may use your personal information for marketing and advertising purposes, including:

• Direct marketing. We or our advertising partners may send Businesses and clients of Businesses who use our Services direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via postal mail, email, telephone, text message, and other means. We do not use Contacts’ Information for direct marketing.
• Interest-based advertising. We engage advertising partners, including third party advertising companies and social media companies, to display ads on the Services and other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the “Automatic data collection” section above) over time across the Services, our communications, and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Online tracking opt out” section below.

Public profiles: We may use Contacts’ Information (excluding Gmail Information and other information collected from Google services such as Gmail, Contacts, and Calendar), together with other publicly available information, to create public profiles for individuals who we think may be interested in our Services. Once we have created a profile, we may suggest that other users of the Services connect with the created profile. If any users take an action on the created profile, we will notify the profile owner so they may claim their page. If we have created a public profile for you, we will provide an “opt-out” link at the bottom of the profile if you wish to have your profile deleted.

Connections and Invitations: We may also use Contacts’ Information to suggest connections and to enable you to invite others to use our Services and connect with you. It is your choice whether to invite someone to our Services. For clarity, if an invitee accepts the invitation, then the invitee shall be subject to the terms and conditions of this Privacy Policy and our Terms of Service. We may also receive personal information about you when others import or sync their Contacts’ Information.

Compliance and protection: We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Enforce the terms and conditions that govern Pro-ficiency and our Services; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Related Companies: We may also share your personal information (excluding Gmail Information) with our subsidiaries and affiliates for purposes consistent with this Privacy Policy.

Service providers: Companies and individuals that provide services on our behalf or help us operate Pro-ficiency, the Services, or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Advertising partners: Third party advertising companies and other third parties, including Pro-ficiency’s parent, affiliates, other brands and business partners for commercial purposes like the interest-based advertising purposes described above.

Professional advisors: Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others: Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees: Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate financing, divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Pro-ficiency (including, in connection with a bankruptcy or similar proceedings).

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through the Services or posting, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

Your Choices

Update or correct your information. To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct information in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions.

Opt out of marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you.

Online tracking opt out. There are a number of ways to opt out of having your online activity and device information collected through the Services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Click here for more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in.
• Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:
  • Google
  • Facebook
  • Twitter
• Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites
  • Digital Advertising Alliance for Mobile Apps
  • Network Advertising Initiative

Note that you will need to opt out on every browser and device that you use because these opt out mechanisms are specific to the device or browser on which they are exercised.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. Learn more about “Do Not Track” here.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other Sites and Services
Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information. You use the Services at your own risk.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We periodically review our policies and procedures to evaluate their effectiveness and ensure that they remain up to date. We cannot, however, ensure or warrant the security of any information you transmit to Pro-ficiency or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.

We have put in place procedures to respond to any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, Pro-ficiency may promptly notify those persons whose personal information has been compromised by posting a notice on the Site, via the functionality of the Services, or by sending an e-mail to you. You may have a legal right to receive this notice in writing.

Pro-ficiency cannot ensure that your Personal Data will be protected, controlled or otherwise managed pursuant to this Privacy Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.

Processing of Data in the U.S.

We are headquartered in the United States and may use services providers that operate in other countries. Your personal information may therefore be processed in the United States or transferred to other locations where privacy laws may not be as protective as those in your state, province, or country.  We do have Data Processing Agreements in place with processors outside the United States.

How long we store your Personal Data

We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How We Use Your Personal Data and Why unless you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data. We will only retain your Personal Data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your Personal Data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Children

Pro-ficiency does not sell products for purchase by children under the age of 18. If you are under 18 years of age you should not utilized this site. If we learn that we have collected personal information through the services from a child under 18 without the consent of the child’s parent or guardian, we will delete it.

Notice to California Users

We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).

Subject to certain exceptions, including those applicable to individuals acting as business representatives, the CCPA grants California residents the following rights.

Information: You can request information about how we used and shared your personal information through the Services during the past 12 months. Our Privacy Policy provides this information. We describe the sources through which we collect personal information and the types of personal information collected in the “Personal Information We Collect” section above. We describe the purposes for which we use and share this information in the “How We Use Your Personal Information” section above and the “How We Share Your Personal Information” section above.

Access: You can request a copy of the personal information that we maintain about you.

Deletion: You can ask to delete the personal information that we maintain about you.

Opt Out Of Sale Of Your Personal Information: You can instruct businesses that sell your personal information to stop doing so – Pro-ficiency however, does not sell your personal information.

To exercise these rights, or request an alternative form of this Privacy Policy, please contact us. We will not treat you differently if you exercise these rights.

To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

Authorized agents: California residents can empower an “authorized agent” to submit requests on their behalf.

Data Integrity and Purpose Limitation. We take reasonable steps to ensure that personal information is reliable for its intended use, and that it is accurate, complete and current for as long as we retain it. We will retain the data as long as necessary for the following purposes: delivering the Services, engaging in customer service, complying with legal obligations, auditing, performing security and fraud prevention, responding to legal and regulatory inquiries, and preserving or defending our legal rights or those of other users or third parties.

Notice to Other State Privacy Policy Users

The above rights identified for State of California residents apply to any user in a State with similar privacy policies (e.g. Nevada, Utah, etc.).

GDPR Notice

Those individuals outside the United States may contact us to exercise their data protection rights in accordance with applicable data protection laws.  We may ask to verify your identity to ensure that we only disclose personal data to authorized individuals and to help us respond efficiently to the request. If you would like to make a data subject request, you may open a request with us directly by contacting us at privacy@pro-ficiency.com or you may contact us using the contact information provided at the end of this Privacy Notice. 

Access: the right to know what personal data we store about you and to request that we send you a copy of that personal data.

Data portability: the right to request that we transfer the personal data we have collected about you to another organization.

Correction: the right to request that we correct or update any inaccurate or incomplete personal data we hold about you. 

Deletion: the right to request that we delete your personal data. This right is sometimes also referred to as the “right to erasure” or the “right to be forgotten.”  This right may be limited depending on the source of the personal data.

Restriction: the right to request that we restrict or suspend processing of your personal data, and the right to object to further processing of your personal data that is inconsistent with the purpose for which it was collected.

Objection: the right to object to our use of your personal data to send you newsletters or other email marketing notifications, including through automated decision making. 

Complaints: We are committed to resolving any inquiries or concerns about our collection or use of your personal data and we hope to resolve any concern brought to our attention. However, if you feel that your concern has not been adequately resolved, you may have the right to contact your local data protection authority.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website and/or other Services.

How to Contact Us

Pro-ficiency Privacy Notices:
Email:	privacy@pro-ficiency.com
Mail:	Pro-ficiency, LLC 4242 Six Forks Road Suite 1550 Raleigh, NC 27609

Panorama and MedComms

This Privacy Notice relates to personal data collected by Pro-ficiency, LLC and its affiliates (collectively, “Pro-ficiency” “we” or “us” or “our”) about healthcare professionals and other medical, scientific, healthcare, and academic experts (referred to hereinafter as “KOLs” or also “you” or “your” if we have collected personal data about you subject to this Privacy Notice) which we curate and publish for use by our customers and their users in our relevant products and services and their associated databases (our “Products”). 

It is our hope and belief that our Products benefit KOLs by providing opportunities for them to connect and engage with life sciences companies and develop meaningful collaborations across therapeutic areas in the pursuit of improving patient outcomes and reducing the burden of disease. 

Please carefully read this Privacy Notice and contact us with any questions.

Personal Data Collected

We collect and process personal data about KOLs from publicly accessible sources such as websites and databases and from other third-party sources such as data and content providers. In some limited cases we may receive KOL personal data from our customers, and in those cases our customer may be the data controller. We may also need to collect and process information a KOL shares with us when they contact us or interact with      us      directly. The personal data in our Products generally includes professional details about KOLs such as: 

• Name, affiliated institution, institution address, e-mail address 
• Areas of specialization Professional association and industry affiliation details 
• Publication details, including authorship and peer review information 
• Clinical trial investigator details 
• Media and editorial records and details 
• Event and speaking engagement details 
• Award and recognition details
• Education
• Photograph
• Diversity, equity and inclusion information
• Inferences may be drawn from the above information

We do not request or knowingly collect personal data about children.

How the Personal Data is Used

We use the KOL data we collect to curate and publish content in our Products to our customers and end users, which includes a searchable directory of KOLs containing the professional details described above. 

Our customers generally process the personal data in our Products for the purposes of (i) identifying clinical, healthcare and scientific experts, (ii) engaging and communicating with those experts and (iii) conducting business planning and market intelligence. 

Pro-ficiency or our customers and end users may also process personal data for: 

• Scientific, historical, and statistical research purposes 
• Detecting, preventing, or investigating fraud, contract or policy violations, or criminal acts 
• Legal, compliance, and audit related purposes (including for the purposes of enforcing legal rights or defending legal proceedings) 
• General business administration, and data management and analytics purposes 
• Corporate restructuring, including a reorganization or sale of business or assets 
• Marketing and sales purposes, to the extent permitted by applicable law

The processing of the KOL data is based on our own legitimate interests and those of our customers for the purposes described above, and we have carried out a legitimate interest assessment to support this determination. In cases where legitimate interests are not a suitable basis to process KOL data, we may process the personal data pursuant to a legal obligation or based on the KOL’s consent or consent granted via a customer.

How Personal Data is Shared

We may share personal data we process about KOLs with the following types of recipients or as otherwise described in this Privacy Notice.

Pro-ficiency Customers

We may share KOL personal data with our customers and end users, which are generally companies in the life sciences industry, through our Products. Once our customers have accessed the KOL personal data through our Products, they become an independent data controller and are responsible for meeting their own obligations under applicable data protection laws arising out of their processing of the personal data.  The KOL personal data remains the property of Pro-ficiency.

Service Providers and Business Partners

We may share KOL personal data with third party service providers, contractors or business partners to support our business. These third parties may perform services for us such as cloud hosting, meeting planning services, payment services, product engineering or quality assurance services or we may work with a business partner to provide services to common customers.  

Pro-ficiency Family of Companies 

We may share KOL personal data within Pro-ficiency’s family of companies (e.g., our corporate affiliates). 

Government and Law Enforcement Agencies

We may share KOL personal data with government bodies or law enforcement agencies if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personal data in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, Pro-ficiency’s products or services, or the general public.

Buyers and Investors

In the event of a sale, merger or other transfer of all or part of Pro-ficiency’s assets, or in connection with a bankruptcy (or similar) proceeding or an investment in Pro-ficiency by a third party, we may share KOLO personal data with third parties as part of these events or proceedings as necessary or required. 

Data Subject Rights

KOLs may contact us to exercise their data protection rights in accordance with applicable data protection laws.  We may ask the KOL to verify their identity to ensure that we only disclose personal data to authorized individuals and to help us respond efficiently to the request. If you would like to make a data subject request, you may open a request with us directly by contacting us at privacy@pro-ficiency.com or you may contact us using the contact information provided at the end of this Privacy Notice. 

Access: the right to know what personal data we store about you and to request that we send you a copy of that personal data.

Data portability: the right to request that we transfer the personal data we have collected about you to another organization.

Correction: the right to request that we correct or update any inaccurate or incomplete personal data we hold about you. 

Deletion: the right to request that we delete your personal data. This right is sometimes also referred to as the “right to erasure” or the “right to be forgotten.”  This right may be limited depending on the source of the personal data.

Restriction: the right to request that we restrict or suspend processing of your personal data, and the right to object to further processing of your personal data that is inconsistent with the purpose for which it was collected.

Objection: the right to object to our use of your personal data to send you newsletters or other email marketing notifications, including through automated decision making. 

Complaints: We are committed to resolving any inquiries or concerns about our collection or use of your personal data and we hope to resolve any concern brought to our attention. However, if you feel that your concern has not been adequately resolved, you may have the right to contact your local data protection authority.

Security

We work hard to protect the information we handle from loss, misuse and unauthorized access or disclosure by maintaining appropriate organizational, technical and physical security measures. These measures may include encryption, firewalls, role-based data access, intrusion-detection tools and physical access controls to data centers. However, given the nature of communications and information processing technology, we cannot guarantee absolute security.

International Data Transfers

Pro-ficiency is a global company and we may transfer, store, or process KOL personal data in a country outside your jurisdiction, including countries outside the European Economic Area (“EEA”), that have a lower or different level of data protection law than your own country. However, we have taken appropriate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights. For example, if we transfer personal data from the EEA to a country outside it, such as the United States, we will implement an appropriate data transfer solution such as entering into EU standard contractual clauses with the data importer or taking other measures to provide an adequate level of data protection under EU law.

Retention of Information

We will retain your personal data for as long as necessary to support our Products, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.

Changes to this Privacy Notice

We encourage you to check this page periodically for any changes. We may revise this Privacy Notice from time to time. Any changes to this Privacy Notice take effect immediately after being posted or otherwise provided by us.

Contact Information and Inquiries

If you have any questions or comments about this Privacy Notice or how we handle your information, please contact our Data Protection Officer in any of the following ways.

Pro-ficiency Privacy Notices:
Email:	privacy@pro-ficiency.com
Mail:	Pro-ficiency, LLC 4242 Six Forks Road Suite 1550 Raleigh, NC 27609