H1.CO CALIFORNIA PRIVACY STATEMENT
Last revised May 8, 2020
2. What is Personal Information
We may collect, use, sell, or share your personal information. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). “Personal information” does not include:(1) publicly available information, such as information that is lawfully made available from federal, state, or local records, and (2) de-identified or aggregate consumer information.
- Personal information that we collect about you when you are acting as our job applicant, employee, owner, director, officer, medical staff member, or contractor to the extent that we collect and use your personal information solely within the context of that role. This also includes your emergency contact information and personal information that is necessary for us to retain to administer benefits for you. However, you will still receive a notice at the time of collection, which outlines the categories of personal information we collect and the purposes for which we collect the categories of personal information
- Personal information we receive from you reflecting a communication or transaction between us and another business when you are acting as an employee, owner, director, officer, or contractor of such company, partnership, sole proprietorship, nonprofit, or government agency and you are seeking a product or service from us for the company, partnership, sole proprietorship, nonprofit, or government agency (Business Consumer). We have outlined the limited rights afforded to Business Consumers below.
3. Personal Information We Collect, Use, Sell, or Share
The CCPA requires us to disclose certain information regarding our collection, use, sale, and sharing of personal information.
Collecting Your Personal Information
In the past 12 months, we have collected the following categories of personal information:
- Identifiers. This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
- Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). This may include a name, address, telephone number, education, employment, employment history.
- Characteristics of Protected Classification under California or Federal Law. This may include age and gender).
- Internet or other similar network activity. This may include browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.
- Sensory data. This may include audio, electronic, visual or similar information.
- Professional or employment-related information. This may include current or past job history.
- Inferences drawn from other personal information. This may include information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your abilities or aptitudes.
In the past 12 months, we have collected personal information from the following categories of sources:
- Public sources (including content made public on NGO websites, open access websites, university and conference websites, scholarly publication websites, government public databases, professional network websites, corporate websites, open payments and clinical trials, and public regulatory filings and public news sources)
- Direct enquiries from consumers and other individuals
- Information provided to us by customers, where we are acting as their agent.
We may collect your personal information for the following business or commercial purposes:
- Commercial/Economic Interests: We use personal information to build our database of professionals operating in our chosen areas, together with information of those professionals’ publicly disclosed activities (e.g., their publication activity, engagement in clinical trials etc). We perform aggregations and analytics on that data in order to provide our customers (professional subscribers to our services who work primarily in the life sciences and capital markets industries) with a summarized view of healthcare professionals related to their particular area of interest.
- Account Services: If you are a customer subscribed to our services, we use personal information to offer our account services, including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on the service provider’s behalf.
- Security and Fraud Detection: We use personal information for our security and fraud detection services including: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
- Debugging: We use personal information to engage in debugging to identify and repair errors that impair existing intended functionality.
- Improvement of Products and Services: We use personal information to verify, maintain, and improve our products and services.
- Internal Research: We use personal information for our internal research related to technological development and demonstration.
- Advertising and Marketing Services: We use personal information to provide advertising or marketing services on our own behalf.
- Legal Obligations: We use personal information to comply with legal obligations.
- Audits: We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
- Merger/Acquisition/Bankruptcy, etc.: We may use your personal information as part of a merger, acquisition, bankruptcy, or other transaction where a third party assumes control of us.
Disclosing Your Personal Information for a Business or Commercial Purpose
We may disclose your personal information to service providers and third parties in order to carry out specific business or commercial purposes. In the preceding 12 months, we have disclosed the following categories of consumer personal information for business or commercial purposes to service providers and the following categories of third parties:
- Personal information described in the California Customer Records Statute to prospective investors in the company, and to service providers who support our sales and account administration activities
- Internet or other similar network activity to service providers whom we engage to assist us with marketing analytics
- All categories of personal information may be stored and processed on database services provided by our technology service providers.
Selling Your Personal Information for a Business or Commercial Purpose
We may sell your personal information to a third party for a business or commercial purpose. As explained further below, you have the right to opt out of the sale of your personal information at any time by submitting a verifiable request to us.
In the past 12 months, we have sold the following categories of consumer personal information to the following categories of third parties:
- Personal information described in the California Customer Records Statute, and inferences drawn from that personal information to companies operating in the Pharmaceutical and Financial Services sectors.
In the past 12 months, we have sold personal information for the following business or commercial purposes:
- Commercial/Economic Interests: We use personal information to build our database of professionals operating in our chosen areas, together with information of those professionals’ publicly disclosed activities (e.g., their publication activity, engagement in clinical trials etc). We perform aggregations and analytics on that data in order to provide our customers with a summarized view of healthcare professionals related to their particular area of interest.
It is our business practice not to sell the personal information of minors under 16 years of age and we have no actual knowledge of doing so.
4. Your Rights under the CCPA
As described in more detail below, the CCPA provides you with certain rights regarding the collection, use, sale, and disclosure of your personal information.
The Right to Know About Personal Information Collected, Used, Sold, or Disclosed
You have the right to request that we provide you with certain information about the personal information we collect, use, sell, or disclose about you as well as the categories and specific pieces of information that we have collected about you in the 12 months before your submission of a verifiable consumer request. Specifically, you have the right to request the following information:
- The specific pieces of personal information we have about you.
- The categories of personal information we have collected about you, including:
a) The categories of personal information we have collected about you in the past 12 months.
b) The categories of sources from which the personal information about you was collected.
c) Our business or commercial purpose for collecting your personal information.
d) If we shared your personal information:
– The categories of personal information that we disclosed about you for a business purpose in the past 12 months and, for each category identified, the categories of third parties to which it disclosed that particular category of personal information; and
– The categories of third parties that we share personal information.
e) If we sold your personal information:
– Our business or commercial purpose for selling your personal information.
– The categories of your personal information that we have sold about you in the past 12 months and, for each category identified, the categories of third parties to which it sold that particular category of personal information.
A household may request to know aggregate household personal information by submitting a verifiable consumer request. Also, unless the household has a password-protected account, if all consumers in a household jointly request access to specific pieces of information for the household, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.
However, there is certain information that we will not disclose to you. This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answer, or unique biometric data generated from measurements or technical analysis of human characteristics.
This right does not apply to Business Consumers.
The Right to Request Deletion of Personal Information
You have the right to request that we delete any personal information that we have collected from you and maintained about you. Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a deletion request and delete your personal information from our records, we will also direct any service providers we work with to also delete your personal information from their records. If we store any of your personal information in our archived or back-up systems, we will delete your information once the systems are accessed, restored, and/or used.
A household may request the deletion of aggregate household personal information by submitting a verifiable consumer request. In addition, unless the household has a password-protected account, if all consumers in a household jointly request deletion of household personal information, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.
Please note that we may deny your deletion request for a number of different reasons, which are identified in the CCPA.
This right does not apply to Business Consumers.
The Right to Opt Out of or Opt In to the Sale of Your Information
At times, we may sell your personal information to another party. If we sell your personal information, you will have the right to, at any time, direct us to not sell your personal information (Right to Opt-Out). However, we will not sell the personal information of consumers that, to our actual knowledge, are less than 16 years of age (Minor Consumer). Once you opt-out, we will not sell your personal information unless you subsequently provide us with affirmative authorization to sell your personal information. We will wait at least 12 months after you have opted out of the sale of your personal information to third parties to request that you authorize the sale of your personal information.
If you have opted-out of the sale of personal information but we need to sell the information as a condition to completing a transaction, we will inform you that your transaction requires a sale of your personal information and provide you with instructions on how you can opt-in.
5. Exercising Your Rights under the CCPA
Submitting a Verifiable Request to Know or Request to Delete
To exercise your Right to Know or your Right to Delete, please submit a verifiable consumer request to us by either:
- Calling us at 1-844-915-2272
- Visiting https://www.h1.co/legal/privacy-preferences
- Sending an e-mail to [email protected]
To submit a verifiable consumer request, you (or your authorized agent) will be asked to:
- Provide your full name, title and designations, phone number, employing institution, business email address
- Provide a link to an existing public profile in your employing institution where that exists
- Provide evidence of authorization / copy of power of attorney where you are an authorized agent of the consumer
- Where a request is made by email, to submit the above information from the consumer’s business email account above, or where you are an agent, copy the consumer on the email sent from your business email account.
Only you (or an authorized agent) may make a verifiable consumer request.
Verifying Your Identity
Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems. If you submit a request to know specific pieces of personal information or a request to delete certain information, in addition to verifying your identity with information we have on file, you also may be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose personal information is the subject of the request. If we are unable to respond to your request for specific pieces of information, we will evaluate your request as if it is a request to know the categories of personal information that we have collected about you.
If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account and we will also require you to re-authenticate yourself before we disclose your personal information. If we suspect fraudulent or malicious activity on or from your account, we will not comply with your request until we perform further verification to determine whether your request is authentic and you are the person about whom we have collected the personal information.
We will generally avoid requesting additional information from you to verify you. However, if we cannot verify your identity based on the information we currently maintain, we may request additional information from you, which will only be used to verify your identity and for security or fraud-prevention purposes. We will delete any new personal information we collect to verify your identity as soon as practical after processing your request unless otherwise required by the CCPA.
Generally, if we are unable to verify your identity, we will deny your request and inform you of our inability to verify your identity and explain why we were unable to do so. If you submitted a request to delete and we are unable to verify your identity, we will ask you if you would like to opt-out of the sale of personal information (see next section for additional information).
Please note that we are only required to respond to your request for access to your personal information twice within a 12-month period.
Responding to Your Request to Know or Delete
Once we receive your verifiable consumer request, we will confirm our receipt of your request within 10 business days and provide you with additional information about how we will process the request. Our goal is to respond to your request within 45 calendar days of receiving the request, beginning on the day we receive the request. However, in the event that we need more time (up to 90 calendar days) to respond to your request, we will provide you with notice and an explanation of the reasons that we will take more than 45 calendar days to respond. Any disclosures we provide will cover the 12-month period preceding the verifiable consumer request’s receipt. If we are unable to comply with a given request, we will provide you with a response explaining why we have not taken action on your request and identifying any rights you may have to appeal the decision.
We will not charge you to verify your identity. In addition, we will not charge you to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Submitting a Request to Opt Out of or Opt In to the Sale of Your Information
At any time, you (or your authorized agent) have the right to opt out of the sale of your personal information to third parties (Right to Opt-Out). Please see our Notice of Right to Opt-Out for additional information.
To exercise your Right to Opt-Out, please submit a request to us as follows:
- Submit a request on our privacy preferences page
- Send an email to [email protected]
We will not charge you to verify your identity. In addition, we will not charge you to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Responding to a Request to Opt-Out or Opt-In the Sale of Your Information
We will act upon your request as soon as feasibly possible, but no later than 15 business days from receipt of your request. We will also instruct any third parties to whom we have sold your information after you submitted your request, if any, to not further sell the information and we will immediately notify you when we have done so.
If we have a good-faith, reasonable, and documented belief that a request to opt-out is fraudulent, then we may deny the request, and we will inform you of the denial and provide you with an explanation regarding why we believe the request is fraudulent.
Authorized Agent for Requests
You may designate an authorized agent to make a request on your behalf. Unless you have a power of attorney, if you would like to use an authorized agent, which is an individual or business registered with the Secretary of State that you have authorized to act on your behalf, to submit a request, you must provide the authorized agent with written and signed permission to do so, verify your own identity directly with us, and directly confirm that you provided the authorized agent with permission to submit the request. We may deny a request from an authorized agent that does not submit proof that they are authorized to act on your behalf.
We will not discriminate against you for exercising any of your CCPA rights. For example, unless otherwise permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
7. Changes to our California Privacy Statement
We are required by law to update this California Privacy Statement at least once each year. This California Privacy Statement was last updated on the date shown at the start of this statement.
8. Contact Information
If you have any questions regarding our privacy policies, our California Privacy Statement, the ways in which we collect, use, disclose, and sell your personal information, or how to exercise your rights under the CCPA, please do not hesitate to contact us at:
Email: [email protected]
Postal Address: 386 Park Ave S, New York, NY 10016