Privacy Policy | HCP Space


<div> <div class="body container"> <p> At IQVIA, we are strongly committed to protecting your privacy. To protect your privacy, we provide this notice explaining our online information practices via HCP Space and the choices you can make about the way your information is collected and used.</p><div> <h5>Scope</h5> <div> <p> This Policy applies to HCP Space, an HCP Community and Learning Platform, encompassing a Global Site and Microsites, for registered health care professionals (“HCP”, “HCPs” or “you”). As such, this Policy applies to Personal Information – any information relating to an identified or identifiable natural person – that is Processed by <strong>IQVIA Operations France SAS, with registered address in 17bis, place des Reflets – Tour D2 TSA 64567 92099 La Défense cedex</strong> (“IQVIA”, “us”, “we”) on IQVIA HCP Space platform website and mobile applications (Android or iOS mobile and iPad) operated by or on behalf of IQVIA (the “Platform”).</p><p> Through the Platform, HCPs share their professional identities, engage with their network, exchange knowledge and professional insights – upload, access, share, publish and use information as it pertains to medical information, diagnosis, prognosis, innovative methods in treatment and learning recommendations about the treatment of patients –, as well as to learn and develop skills.</p><b>No Personal Information of patients or that may constitute a breach of patient confidentiality may be shared via Platform.</b> <p> This Policy is intended to meet requirements globally, including those in North America, Europe, Africa, Middle East, South Asia, and other jurisdictions. However, HCPs residing in Iran, Syria, Cuba, Crimea and North Korea are not eligible/permitted to use / be a member of HCP Space.</p><p>You may only use HCP Space, after reading and accepting the <a href="https://hcpspace.app/tnc" target="_blank">Terms and Conditions of Use of HCP Space</a>.</p></div></div><div> <h5>Data Controller(s)</h5> <div> <p> <strong>IQVIA will be the data controller</strong> of your Personal Information provided to, or collected by or for, or processed in connection with the Platform.</p><p> You may also be invited to or apply to sign up to a sponsored microsite (“Microsite”). A Microsite is a closed space within HCP Space which aims to engage a specialized group of HCPs and can be accessed by invitation only. IQVIA may set up Microsites on behalf of healthcare industry stakeholders who may sponsor content or events in order to facilitate HCP engagement. <strong>The relevant sponsor of the Microsite will be the data controller</strong> of your Personal Information provided to, or collected by or for, or processed in connection with sponsored microsites (“Microsite(s)”), created by said Microsite sponsor, and in accordance with its privacy statement. Please consult the Microsite sponsor’s privacy terms before using the respective Microsite.</p><p>IQVIA may also process your Personal Information provided via Microsite(s) for its own purposes.</p><p> In general, IQVIA does not act as a data processor regarding the data processing activities occurring via the Platform. However, if Microsite´s sponsor requests IQVIA to process your Personal Information on its behalf, IQVIA will act as said sponsor´s data processor in accordance with the applicable legal requisites and with sponsor´s privacy terms, as described in their Privacy Policy.</p></div></div><div> <h5>Lawful bases for processing</h5> <div> <p> We will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to make the Platform available) and IQVIA´s legitimate interests (i.e., to protect you, us, or others from threats (such as security threats or fraud), enable or administer our business, such as for quality control, to manage corporate transactions, such as mergers or acquisitions). Where we rely on your consent to process Personal Information, you have the right to withdraw your consent at any time. Where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact us at PrivacyOfficer@IQVIA.com.</p></div></div><div> <h5>What Personal Information do we collect about you and why do we collect it?</h5> <div> <ul> <li> <p> To create an account, you need to provide Personal Information, including your name, profession, speciality, professional license (professional certificates or accreditation certificates), email address and/or mobile number, and password. Note that until professional identity verification is complete you will have read-only access to the Platform;</p></li><li> <p> To develop your profile, you may add information, such as information regarding your education, work experience, place of work, skills, photo, city or area. Do not add Personal Information to your profile that you would not want to be publicly available as we cannot guarantee that other users may not share this information with outside parties;</p></li><li> <p> To post, upload information, and foment useful connections, we collect Personal Information from you when you provide, post or upload it onto our Platform, such as when you fill out a form, participate in a survey or in webinars and 3D virtual events;</p></li><li> <p> To learn from your actions on HCP Space, to derive insights and determine your engagement levels, which will help to identify you as a Key Opinion Leader and reach out to you for collaboration on activities such as hosting webinars for the HCP community, leading case study creation, conducting or participating in surveys or research studies, as per your interactions on the Platform;</p></li><li> <p> To provide information feeds and industry updates regarding topics you may care about, or suggest eLearning experiences and send invitations promoting network growth, we may use information you and others post that includes information about you (as part of articles or posts) on our Platform.;</p></li><li> <p> To analyse Platform use, we analyse log usage data when you visit or otherwise use our Platform, such as when you view or click on content, fill a survey, join a webinar, attend an e-learning course, perform a search or share articles;</p></li><li> <p> To provide you access to a Microsite, we may process Personal Information the Microsite sponsor responsible for said Microsite provides us about you / your eligibility to use the Platform;</p></li><li> <p>To provide you with support, we use your Personal Information to analyse, respond to and resolve complaints.</p></li></ul> <p>Please take notice: you have <strong>choices</strong> about how we use your Personal Information.</p></div></div><div> <h5>General Insights and Analytics</h5> <div> <p> We may use your Personal Information to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, or create demographic insights.</p><p> We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content to provide the Services to you and perform our contact with you. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.</p></div></div><div> <h5>Do we share your Personal Information?</h5> <div> <p> Your profile is fully visible to all other HCP Space users, IQVIA and to Microsite sponsors. However, subject to your <a href="https://hcpspace.app/privacy-policy" target="__blank">choices</a>, you may restrict other HCPs from viewing your online activity, as there are three levels of settings: Only Me, My Connections, and Everyone. Please note that the default is set to “My Connections” and can be modified at any given time.</p><p> We may also share your Personal Information as described in this Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.</p><ul> <li> <p> Vendors and Service Providers: We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (ii) in connection with the provision of the Platform. IQVIA has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements;</p></li><li> <p> Business Partners: IQVIA may share Personal Information with IQVIA affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you, subject where required by law, to your consent. These business partners are Zoom Video Communications, Inc., StreamOn Technologies Pte Ltd., FocusVision Worldwide, Inc., MDBriefCase Group Inc., Medical Practice Consulting (Pty) Ltd., Medvarsity Online Ltd., Salesforce.com, inc., IQVIA Operations France SAS, and Twilio Inc.</p><p> In such cases, our business partner’s name will appear, along with IQVIA’s. IQVIA requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it by any mean or for any purpose other than the means and purpose for which we provided it to them;</p></li><li> <p> Microsites: IQVIA will share your Personal Information with [Clients / Companies] which create a Microsite – If you register for a Microsite, your Personal Information will be shared with the sponsor administrator, which will process the information for its own purposes and in accordance with its own privacy statement;</p></li><li> <p> Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures): We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to:</p><ol type="i"> <li> <p>comply with law enforcement or national security requests and legal process, such as a court order or subpoena;</p></li><li> <p>respond to your requests;</p></li><li> <p>protect yours’, ours’ or others’ rights, property, or safety;</p></li><li> <p>to enforce IQVIA policies or contracts;</p></li><li> <p>to collect amounts owed to us (if applicable);</p></li><li> <p> when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or</p></li><li> <p>if we, in good faith, believe that disclosure is otherwise necessary or advisable.</p></li></ol> <p> In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Platform. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities;</p></li><li> <p> Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, IQVIA will endeavour to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected and will comply with any legal or regulatory additional requirements applicable to those transfers.</p></li></ul> <p> We do not share Personal Information with unrelated third parties who are not covered by this Privacy Policy without your prior permission, except to the extent reasonably necessary to:</p><ol type="i"> <li> <p>correct technical problems and malfunctions;</p></li><li> <p>protect the security and integrity of our Platform;</p></li><li> <p>protect our rights, interests and property and the rights, interests and property of others;</p></li><li> <p>comply with laws or to respond to judicial process;</p></li><li> <p>provide information to law enforcement agencies or for an investigation of a matter as applicable, or otherwise as required or permitted by law.</p></li></ol> </div></div><div> <h5>Data Retention</h5> <div> <p> We generally retain your Personal Information as long as you keep your account open or as long as is required for the purposes for which it was collected, to resolve disputes, establish legal defences and comply with applicable laws.</p><p> If data retention is not required for one of the purposes indicated above, we generally delete closed account information within 15 days of account closure.</p></div></div><div> <h5>Your rights</h5> <div> <p> We provide many choices about the collection, use and sharing of your Personal Information. Please consult your <a href="https://hcpspace.app/privacy-policy" target="__blank">profile and privacy management</a>.</p><p>For Personal Information that we have about you, you may have the right to:</p><ul> <li> <p>inquire as to whether IQVIA is processing Personal Information about you;</p></li><li> <p>to request IQVIA correct, amend, block or delete Personal Information;</p></li><li> <p>opt out of certain uses and disclosures of your Personal Information;</p></li><li> <p> withdraw consent, at any time (and opt out of further processing, in which case we may still collect and use non-Personal Information regarding your activities on our Platform);</p></li></ul> <p> If you are an EU or Russia resident, you may have additional rights available to you, including the right to file a complaint with your local data protection authority, the right to object to your data being processed, and certain rights related to our use of any automated-decision making processes (to the extent applicable).</p><p> Some of these rights are directly exercisable by you, through your <a href="https://hcpspace.app/privacy-policy" target="__blank">profile and privacy management</a>. When they are not, please send an e-mail with your request to PrivacyOfficer@IQVIA.com. Such requests will be processed in line with local laws.</p><p> If you receive any unwanted notifications from us (In-app, emails, push notifications), you can manage them <a href="https://hcpspace.app/privacy-policy" target="__blank">here</a>. Note that you will continue to receive certain communications regarding IQVIA and our Platform and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms and Conditions of Use or this Policy).</p><p> The Privacy and management settings you have chosen within the Global Site will be applicable on any Microsite. However, Microsites have their own Privacy Policies, which should be consulted, as well as their own contact details for privacy related questions / requests.</p></div></div><div> <h5>Do Not Track</h5> <div> <p> Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.</p></div></div><div> <h5>Our commitment to data security</h5> <div> <p> We will implement the requisite legal, organisational and technical measures or procure their implementing for the protection of your Personal Information from illegal or accidental access, destruction, change, blocking, copying, providing , disseminating and from other illegal actions in relation to your Personal Information. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.</p><p> By using the Platform or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Platform. If we learn of a security system’s breach, we may attempt to notify you electronically. You may have a legal right to receive this notice in writing.</p></div></div><div> <h5>California Users</h5> <div> <p> California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. IQVIA does not share Personal Information with Third Parties for their own marketing purposes. If you are a California user, you may also have certain rights available to you under the California Consumer Privacy Act. Please review our <a href="https://www.iqvia.com/about-us/privacy/ccpa" target="__blank">California Consumer Privacy Act Notice</a> for additional details.</p></div></div><div><h5>International transfers</h5><div><p>As the database is operated on a worldwide basis, the database may be stored or accessed outside the EEA and the UK by IQVIA affiliates, our customers and third-party providers located in other jurisdictions where our affiliates operate (listed on the office locations page of (<a href="https://www.iqvia.com/about-us/privacy/ccpa" target="__blank">www.iqvia.com</a>).</p><p>Information is transferred outside the EEA and the UK:<ol type="i"><li><p>To the following countries that the EEA and the UK have determined offer adequate protection for personal data under Art.45 of the EU and UK GDPR: Argentina – <a href="https://eur-lex.europa.eu legal-content/EN/TXT/?uri=CELEX%3A32003D0490" target="_BLANK">EU Adequacy Decision</a>; Canada – <a href="https://eur-lex.europa.eu legal-content/en/TXT/?uri=CELEX%3A32002D0002" target="_BLANK">EU Adequacy Decision (Commercial Organisations)</a>; Japan – <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2019.076.01.0001.01.ENG&toc=OJ:L:2019:076:TOC" target="_BLANK">EU Adequacy Decision</a>; New Zealand – <a href="https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32013D0065" target="_BLANK">EU Adequacy Decision</a>; Israel – <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061" target="_BLANK">EU Adequacy Decision</a>; Republic of Korea – <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022D0254" target="_BLANK">EU Adequacy Decision</a>; Switzerland – <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32000D0518" target="_BLANK">EU Adequacy Decision</a>; United States – <a href="https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en" target="_BLANK">EU Adequacy Decision (commercial organisations participating in the EU-US Data Privacy Framework)</a>; United Kingdom – <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D1772" target="_BLANK">EU Adequacy Decision under the GPDR</a>; Uruguay - <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32012D0484" target="_BLANK">EU Adequacy Decision</a>; These countries are also covered by the UK’s adequacy regulations and are listed on the <a href="https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-transfers-a-guide/#Q1" target="_BLANK">Information Commissioner’s Office’s</a> website.</p></li><li>Where we have put in place standard contractual clauses for the transfer of personal data to third countries (controller to controller (for transfers to customers and IQVIA affiliates) and controller to processor (for transfers to third party providers) adopted by the European Commission under Commission Implementing Decision (EU) 2021/914 in accordance with Art.46(2) GDPR and, in the case of transfers from the UK, as amended by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses issued by the Information Commissioner.</li></ol></p><p>A copy of the relevant mechanism can be provided by us for your review on request.</p></div></div><div> <h5>Notification of changes</h5> <div> <p> We keep our privacy statement under regular review, and we will place any updates on this Platform. If you continue to use it and use the services made available to you after such changes have been made, you hereby provide your consent to the changes. If there are any material changes to this Policy, notably if we use Personal Information for any new purpose not originally authorized by you, we will endeavour to provide information regarding the new purpose and give you the opportunity to exercise your rights, contacting you through the Platform or by email. If you continue to use the Platform after we publish or send a notice about the changes to the Policy, this means that you are agreeing to the updated Policy as per the communicated effective date. We agree that no changes shall take effect retrospectively.</p></div></div><div> <h5>How to contact us</h5> <div> <p> If you wish to exercise your rights in relation to any of your information you provided to us or if you have any questions regarding this statement or would like more information on our privacy practices, please contact us at: PrivacyOfficer@IQVIA.com.</p><p> If you are an EU or Swiss citizen and feel that IQVIA is not abiding by the terms of this Policy, please contact IQVIA at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.</p></div></div></div></div>