Privacy Policy (General)

Updated: April 2020

We at HCG (“we”, “us” or “our”) respect your privacy.

HCG is a company located in the United States. Synergy Medical Communications Ltd, Synergy Medical Communications Inc, Chameleon Communications International Ltd, Chameleon Communications International Inc, ProEd Communications Inc, Health Science Communications (HSC) Inc, The Scienomics Group (TSG) Inc are affiliates of HCG.

This privacy policy applies to the processing of personal data by HCG in the United States.

Please see our GDPR Privacy Policy for how we (to the extent we are subject to the General Data Protection Regulation) and our European affiliates process your personal data.

If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”

PURPOSE OF THIS POLICY

This privacy policy (“Policy”) explains our approach to any personal information that we might collect from you using this website (the “Site”) and in other situations or interactions with us, as well as the purposes for which we process your personal information. This Policy also sets out your rights in respect of our processing of your personal information.

This Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it or otherwise cease processing it for a specific purpose. This Policy is intended to assist you in making informed decisions when using this Site or otherwise providing personal information to us or in other situations where we may process your personal information.

This privacy notice is not intended to apply to the processing of personal information of HCG employees which is dealt with under our separate workplace privacy policy.

We respect your concerns about privacy. We participate in the EU-U.S. Privacy Shield framework (“Privacy Shield”) issued by the U.S. Department of Commerce. We commit to comply with the Privacy Shield Principles with respect to any personal information that we receive from the European Union.

TYPE OF PERSONAL INFORMATION COLLECTED

Personal information is information that identifies you as an individual. Categories of personal information we collect include:

  • contact information (e.g. name, physical address, telephone number, email address),
  • information about your interests or affiliations,
  • information for hiring and human resources (e.g. employment and education history, work eligibility status, date of birth, financial account information, government-issued identification information), and
  • additional information you submit to us.

Additional information about the personal information we collect is described in the section HOW WE USE PERSONAL INFORMATION below.

WAYS OF OBTAINING PERSONAL INFORMATION

We may collect and receive your personal information using different methods:

Personal information you provide to us. You may give us your personal information directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site or in hard copy or participate in a survey, subscribe to receive our marketing communications or provide feedback to us otherwise through your interactions with us.

Personal information received from third parties. From time to time, we will receive personal information about you from third parties. Such third parties may include analytics providers, payment providers, hotel and transport providers and third parties that provide technical services to us so that we can operate our Site and provide our services.

Publicly available Personal information. From time to time we may collect personal information about you from publicly available sources or personal information about you that you or a third party may make publicly available to us (for example through speaking at events or publishing articles or other news stories).

HOW WE USE PERSONAL INFORMATION

Our primary goal in collecting personal information from you is to:

  • verify your identity,
  • provide our services to clients;
  • help us improve our products and services and develop and market new products and services,
  • carry out requests made by you to us,
  • investigate or settle inquiries or disputes,
  • comply with any applicable law, court order, other judicial process, or the requirements of a regulator,
  • enforce our agreements with you,
  • protect the rights, property or safety of us or third parties, including our other clients and users of the Site,
  • provide support for the provision of our Services, and
  • use as otherwise required or permitted by law.

We set out in more detail the specific ways in which we may use your personal information below. Please note that these examples are non-exhaustive and may be subject to local rules and restrictions – we will only carry out these activities to the extent permitted by local law. If local law requires us to obtain consent in order to process the personal information as described then we will do so.

Client administration

Information we collect with respect to our clients and potential clients is used to enable us to respond to client requests, to administer client accounts with us, to conduct credit checks, and to verify and carry out financial transactions for payments made to us.

Who do we share personal data with for this purpose?

We may share such personal data with our third party vendors (such as our payment service providers or IT providers), financial institutions, group companies, affiliates, professional advisors, regulatory bodies or other law enforcers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Informational enquiries

We may collect information for requests for information about our company. We may also provide you with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Contact information may be requested in each case, together with details of other personal information that is relevant to these inquiries. This information is used in order to enable us to respond to your requests.

Who do we share personal data with for this purpose?

We may share such personal data with our clients, group companies, affiliates, or agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Surveys and voting

We may collect personal information from you via surveys or voting polls. Participation is voluntary and you will have the opportunity to decide whether or not to disclose information. At times, you may have to register to vote or to take part in a survey. We would use that information to report the results of the survey or vote.

Who do we share personal information with for this purpose?

We may share such personal information with our clients, group companies, affiliates, survey partners or agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Industry information

We may collect, and maintain databases containing, information about Healthcare Professionals, allied Healthcare Professionals, subject matter experts and other professionals in the medical communications, pharmaceutical, healthcare, or media industry collected by us or by our trusted third party service providers. Such information may include an individual’s name, business contact details, professional interests and affiliations. This information may be information that is voluntarily supplied to us by those individuals through our Site or in other situations (such as public speaking events), or information that is public or available in third party databases or via third party content platforms (including social media platforms). Further we may collect and/or review other publicly available media and other content including content made available through scientific literature, public news sites and social media sites to understand what people are saying about a particular therapeutic area, us and our clients. We use this information to inform the provision of our services to our clients. We may also use this information for our own internal administrative and promotional purposes. We make efforts to minimize the use of this information to that which is strictly necessary for our legitimate business interests.

Who do we share personal information with for this purpose?

We may share such personal data with our clients, group companies, affiliates, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Social media

We may collect or process individuals’ personal data who engage with us through our social media channels (including by visiting our social media pages or otherwise communicating with us via social media).  We may also operate our client’s social media pages, accounts or channels acting on their behalf.

Who do we share personal information with for this purpose?

We may share such personal information with our clients, group companies, affiliates, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Events

From time to time, we may organize and host road shows and other industry events to promote our services or on behalf of clients. For this purpose we may process individuals’ names and contact information (including email address, postal address and telephone number) to communicate with them about such events where they have specifically requested information about such events or where we have another lawful basis for sending that information to them.

If you attend one of our events, we may use your personal information to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary or other requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications we send to our clients and/or publish on our Site, in print or other media.

Who do we share personal information with for this purpose?

We may share such personal information with our clients, group companies, affiliates, event and ticketing partners or agents, third party vendors (such as our IT providers) or professional advisers or event organizers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Insight and analysis.

We may analyse individuals’ contact details with other personal information that we observe about them from their interactions with our Site, our email communications and/or with our services.

We may use log files and other tracking technologies to collect personal information from the computer hardware and software used to access the Sites, or from mobile devices. This may include an IP address to monitor Site traffic and volume.

This information is used to create insights about our visitors’ browsing habits on our Site.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see.

We also use this information for marketing purposes (see the MARKETING COMMUNICATIONS section below for further details).

Who do we share personal information with for this purpose?

We may share such personal information with our group companies, affiliates, third party vendors (such as our analytics providers or other IT providers) or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Marketing communications.

We may carry out marketing activities using your personal information. In particular, we may use personal information to form a view on what we think the individual may want or need, or what may be of interest to the individual.  We may use that information to provide individuals with marketing information about our events and services we feel may be of interest.

Who do we share personal information with for this purpose?

We may share your information with our group companies, affiliates, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Receipt of services.

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.

Who do we share personal information with for this purpose?

We may share such personal information with our clients, group companies, affiliates, partners, agents, third party vendors or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Recruitment

If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual.  We use such personal information for the following purposes: a) to assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelancer positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application; b) to take any steps necessary to enter into any contract of employment (or otherwise) with the individual; c) to comply with any regulatory or legal obligations in relation to any such application; and d) to review our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation.

Who do we share your personal information with for this purpose?

We may share such personal information with our group companies, affiliates, third party vendors or professional advisers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

Visiting our premises.

If an individual visits any of our premises we may collect contact information as part of our sign in process.  We may also capture their image on our surveillance camera or CCTV.

Who do we share personal information with for this purpose?

We may share such personal information with our clients, group companies, affiliates, recruitment partners or agents, third party vendors (such as our IT providers) or advisers or law enforcers or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

  • Business administration and legal compliance.

We may use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • to protect the rights of third parties; and
  • in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets

 

Who do we share personal information with for this purpose?

We may share personal information with our clients, group companies, affiliates, agents, partners, third party vendors or professional advisers, emergency service providers or law enforcers or other regulatory bodies (including tax and social security authorities) or such other third parties as indicated in the SHARING YOUR INFORMATION section below in connection with this purpose.

 

PERSONAL INFORMATION OF CHILDREN

We do not intend to or knowingly collect personal information from children.

 

SHARING YOUR INFORMATION

We may share your personal information with any of our group affiliates, or with our agents, partners, clients or contractors or professional advisers or government or regulatory bodies for the following purposes: (a) provide our services to clients or otherwise receive assistance in processing transactions; (b) fulfillment of requests for information, receiving and sending communications, updating marketing lists, analyzing data; (c) provision of IT and other support or internal administrative business services; or (d) assistance in other ancillary to the operation of tasks, from time to time. Our agents, partners and contractors will only use your information to the extent necessary to perform their functions.

We will not sell your personal information to other companies and we will not share it with other companies for them to use without your consent, except in in the circumstances listed above or in connection with the sale or merger of HCG or the division or office responsible for the services.

 

OBTAINING YOUR CONSENT

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail, post or phone using the contact details set out in this Policy.

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

 

ACCESS

We provide you with reasonable access to the personal information maintained about you. We also provide you with a reasonable opportunity to correct, amend or delete the information where it is inaccurate. We may limit or deny access to personal information where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of third persons would be violated.

 

CHOICE AND MEANS

We generally offer you the opportunity to choose whether your personal information may be (a) disclosed to third-party controllers or (b) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by you. To the extent required by the Privacy Shield Principles, we obtain opt-in consent for certain uses and disclosures of sensitive data. Unless we offer you an appropriate choice, we use personal information only for purposes that are materially the same as those indicated in this Policy. To exercise your choices you may contact us as indicated in this Policy.

We may share personal information with our affiliates as described above under SHARING YOUR INFORMATION. We may disclose personal information without offering an opportunity to opt out, and we may be required to disclose such information (a) to third-party processors we have retained to perform services on our behalf and pursuant to our instructions, (b) if we are required to do so by law or legal process, or (c) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. We also reserve the right to transfer personal information in the event of an audit or if we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

 

SECURITY

HCG takes reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data. Also see CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION below.

 

THIRD PARTY LINKS AND SERVICES

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

This Policy does not apply to these third-party websites and third party service providers.

 

COOKIES

We use cookies and similar technologies to collect personal information from the computer or other device you use to access the Site. “Cookies” are pieces of information that may be placed on your device for the purpose of collecting data to facilitate and enhance your communication and interaction with our Site. We may also allow certain third parties to place cookies as described below.

We use cookies and other technologies on all our sites to ensure the best possible experience on our Site. These uses include:

  • analytical cookies to recognize and count users of our Site, measure the effectiveness of our content, and understand how visitors use our Site. We currently use Google Analytics for this purpose; or
  • placing, or allowing a third party to place, functional cookies to make a website easier to use, such as cookies that maintain a user’s session.

 

You can review your Internet browser settings to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.

For more information about how we use cookies please see our COOKIE POLICY available on the Site.

 

OPT OUT AND UNWANTED COMMUNICATIONS

To opt-out of any future promotional or marketing communications or any other communications from us, you should send a request to us at the contact information in the section entitled CONTACT DETAILS. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of this Site may no longer be available to you.

 

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure. We take reasonable and appropriate measures to protect your personal information, including but not limited to sophisticated software and hardware that prevent personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

Information regarding job applications is encrypted and transmitted in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the URL. Only employees or third parties who need the information to process a specific request are granted access to personally identifiable information.

 

ONWARD TRANSFERS

We might receive personal information under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf. In such case, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we are able to prove that we are not responsible for the event giving rise to the damage.

 

COMPLIANCE WITH THE PRIVACY SHIELD

HCG complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. HCG has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

 

CHANGES TO THIS PRIVACY POLICY

We may make changes to this Policy from time to time. This Site includes a date on which it was last updated.

To ensure that you are always aware of how we use your personal information, we will update this Policy from time to time to reflect any changes to our use of your personal information. We encourage you to review this Policy periodically to be informed of how we use your personal information.

 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Where applicable law imposes restrictions on the length of time for which personal information can be retained, we will generally comply with this by retaining personal information only for as long as is necessary for the purposes described in this Policy, after which it will be deleted from our systems. The principle may be departed from where required by law.

If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

 

RECOURSE ENFORCEMENT AND LIABILITY

We are subject to the investigatory and enforcement powers of the Federal Trade Commission. We have mechanisms in place designed to effect compliance with the Privacy Shield Principles. We conduct an annual self-assessment of personal information handling practices to verify that the attestations and assertions we make about our Privacy Shield privacy practices are true and that such privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumer Recourse: You may file a complaint concerning our processing of your personal information. We will take steps to remedy issues arising out of any alleged failure to comply with the Privacy Shield Principles. You may contact us as specified below about complaints regarding our personal information handling practices.

 

CONTACT DETAILS

For questions or concerns about this Policy, or to ask questions or express concerns about our collection, management and processing of personal information, Consumers may by contact us by:

Attn: Compliance Team
Healthcare Consultancy Group
488 Madison Avenue, 5th Floor
New York, NY, 10022

 

ALTERNATIVE DISPUTE RESOLUTION

If a Consumer’s complaint cannot be resolved through our internal processes, we will cooperate with the alternative dispute resolution provider JAMS (Judicial Arbitration and Mediation Services) pursuant to the JAMS International Mediation Rules, available on the JAMS website at: https://www.jamsadr.com/eu-us-privacy-shield.

JAMS mediation may be commenced as provided for in the relevant JAMS rules. The mediator may propose any appropriate remedy, such as deletion of the relevant personal information, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the personal information of the Consumer who brought the complaint. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over us. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about our compliance with the Privacy Shield Principles.

In addition to the above and under certain conditions, the individual may invoke binding arbitration for complaints that have not been resolved by any of the other Privacy Shield mechanisms. See Annex 1 of the Privacy Shield framework for further information: https://www.privacyshield.gov/servlet/servlet.FileDownload?file=015t00000004qAg.

 

California Consumer Privacy Statement

Effective: March 2020

This California Consumer Privacy Statement supplements the HCG Privacy Policy (General) and applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to our personnel.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information
  • Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our Privacy Policy (General). In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes

Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, and auditing compliance

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Short-term, transient use

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Debugging to identify and repair errors that impair existing intended functionality

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Undertaking internal research for technological development and demonstration

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

2. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

  • Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection

Categories of Personal Information

Directly from you, such as when you contact us with a question or comment

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

From your devices, such as when you visit our Site

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Your family or friends, such as when they provide us with your contact information so we can send information that may interest you

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Our affiliates and subsidiaries

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Vendors who provide services on our behalf

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Social networks

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Government entities

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Consumer data resellers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

  • Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties

Categories of Personal Information

Our affiliates and subsidiaries

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Vendors who provide services on our behalf

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Professional services organizations, such as auditors and law firms

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Our business partners

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Internet service providers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Data analytics providers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Government entities

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Operating systems and platforms

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Social networks

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Consumer data resellers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information

 

  • Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose:

  • Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
  • Signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Audio, electronic, visual, and similar information
  • Professional or employment-related information
  • Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
3. California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

We do not sell, and have not sold in the previous 12 months, consumers’ personal information.

How to Submit a Request: To submit an access or deletion request, contact Privacy@hcg-int.com or call us at 1-833-520-0506.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide us with information about you to verify your identity. The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact Privacy@hcg-int.com to request this Statement in an alternative format.