This Policy describes the information that we gather from you on the Service, how we use and disclose such information, and the steps we take to protect such information. By using the Service, you consent to the privacy practices described in this Policy.
Crossmarket Digital certifies that it adheres to the Privacy Shield Framework established by the United States Department of Commerce and the European Union.
Questions or Complaints about Crossmarket Digital, its use, retention and disclosure of Personal Data;
or Requests to disclose, withdraw consent to use for any or all purposes, or to receive copies of or remove Personal Data from Crossmarket Digital; should be directed to: Info@weareclinics.com
Crossmarket Digital collects several categories of Personal Information as defined by the European Union General Data Privacy Regulation (GDPR), which and Personal Health Information (PHI) as defined by the US Health Insurance Portability and Accountability Act (HIPAA).
Personal Data. Personal Data is the term used by the European Union General Data Protection Regulation (“GDPR”) and is defined as “any information relating to an identified or identifiable natural person (known as a “Data Subject”); any identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an on-line identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Crossmarket Digital may use your PHI and Personal Data to provide its services, as follows:
- Identifiers, such as name, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, address, telephone number, fax number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, bank account number, credit card number, debit card number, or any other financial information, physical illness, mental illness or disabilities.
- Protected classification characteristics under California or US federal law, such as age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.
- Engagement with Crossmarket Digital website.
- Professional or employment-related information
- Education information, such as degrees, education level and school attended.
We obtain the personal information listed above from the following sources:
• User-provided Information. When you use the Service, you may provide and we may collect what is generally called “Personal Information,” or “Personal Data,” which is information that specifically identifies an individual. Directly and indirectly from you when using our Services or visiting our website.● “Cookies” Information. When you visit the Service, we may send one or more cookies (a small text file containing a string of alphanumeric characters) or similar code to your Devices. Some of this code may remain on your Devices and may be used by your browser or Devices on subsequent visits to the Service. This allows us to “remember” what you have done on the Service before and personalize the Service for you. Please look through your browser’s or device’s technical support resources to learn the correct way to remove or disable this code. Please note that disabling this code may prevent you from accessing some of the functionality and offerings available via the Service.
● “Automatically Collected” Information. When you use the Service, we may automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include your IP address or other device address or ID, web browser and/or device type, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users.
● Third Party Web Beacons and Third Party Buttons. We may also implement third- party content or advertising on the Service that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third party content on the Service. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about you through such third parties’ browser cookies, even when you do not interact with the button. Information collected through web beacons and buttons is collected directly by these third parties, and Crossmarket Digital does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
● Analytics. We may work with different companies who offer services that can assist us in better understanding how users of our Services interact with and use our Services.
● Information from Other Sources. We may obtain information, including Personal Data, from your employer, third parties and sources other than the Service, such as our partners, advertisers, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
How we use the information we collect.
We use the information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:
- ● We use the information that we collect on the Service to provide Crossmarket Digital Services and to operate, maintain, enhance and provide all features of the Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Service.
- ● We use the information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, feature, and functionality.
- ● Crossmarket Digital will not contact you to ask unnecessary or irrelevant questions or to provide irrelevant information. Crossmarket Digital may use your email address or other information we collect on the Service (i) to contact you for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to your User Content posted on the Service; and (ii) to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with.
- ● Generally, after you have consented to the used of your Personal Data as provided herein, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices” at any time. Crossmarket Digital will only retain your Personal Data during the term of your Agreement to use the Service and as required by law.
When we disclose information. Except as described in this Policy, we will not disclose your information that we collect on the Service to third parties without your consent. When we disclose your Personal Data, we will disclose the amount necessary for the purpose of the disclosure. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
- ● Any information that you voluntarily choose to include in a publicly accessible area of the Service, such as a public profile page, will be available to anyone who has access to that content, including other users.
- ● We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
- ● We may make certain automatically-collected, aggregated, or otherwise non- personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.
- ● We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
- ● We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
- ● Information about our users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
- Crossmarket Digital will not sell Personal Data or otherwise disclose it to third parties for profit.
Your Rights as a Data Subject
At any point while Crossmarket Digital is in possession of or processing your Personal Data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be deleted from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organization.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to opt out of automated processing or profiling.
- Right to judicial review: in the event that Crossmarket Digital refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
Note that Crossmarket Digital may deny a deletion request if retention is necessary to:
- Fulfill Crossmarket Digital’s obligations to provide the Services;
- Detect security incidents, and avoid malicious, deceptive, fraudulent or illegal activity
- Respond to intrusions, excise malware and repair errors
- Protect Crossmarket Digital’s rights or the rights of other users
- Comply with the California Electronic Communications Privacy Act
- Engage in public or peer reviewed scientific, historical or statistical research in the public interest that adheres to applicable ethics and privacy rules, if the deletion may render impossible or seriously impair the research’s achievement
- Internal Uses
- Comply with legal obligations
The Contact Information for Crossmarket Digital’s Privacy/ Data Protection: Info@weareclinics.com
Recourse and Binding Arbitration
In the event you are not satisfied with the resolution of your complaint by the Crossmarket Digital Privacy Officer, at Crossmarket Digital’s expense you may bring the matter to an independent recourse mechanism through the International Centre for Dispute Resolution-American Arbitration Association (ICDR-AAA) using the Notice of Arbitration Forms at http://go.adr.org/privacyshield.html.
Disputes may be sent to the following address as well: International Centre for Dispute Resolution Case Filing Services 1101 Laurel Oak Road, Suite 100
Voorhees, NJ 08043
Email box: firstname.lastname@example.org
Crossmarket Digital, at your request, can confirm and provide machine readable copies of any Personal Data it retains and describe how it has been used and to whom it has been disclosed. Under the GDPR, you may request the following:
- Identity and the contact details of the person or organization that has determined how and why to process your Personal Data.
- Contact details of the data protection officer known as the Crossmarket Digital Privacy Officer.
- The purpose of any use of your Personal Data and the legal basis if other than your consent.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients to whom your Personal Data is/will be disclosed.
- A description of methods by which Crossmarket Digital, a European based company, may securely transfer Personal Data to a third country or international organization for processing or retention consistent with the GDPR and US law.
- Retention period for your Personal Data.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- Information about withdrawing your Personal Data from Crossmarket Digital permanently.
- How to lodge a complaint with the EU supervisory authority.
- Whether the use, disclosure or retention of your Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us contacting the privacy officer identified above, in writing. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Service. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
The Service may contain features or links to Web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 13, and we do not knowingly collect Personal Data from children under the age of 13. Children age 13 to 16 may use Crossmarket Digital only with the consent of a legally responsible parent or guardian. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that personally identifiable information has been collected on the Service from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Service, then you may alert the Privacy Officer in writing and request that we delete that child’s personally identifiable information from our systems.
We use certain physical, managerial, and technical safeguards consistent with the HIPAA, GDPR and CCPA requirements, which are designed to improve the integrity and security of your personally identifiable information. We cannot, however, ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify the Privacy Officer in writing.
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.