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PRIVACY POLICY

 * 1. Information collection and use
 * 2. How and why we share your information
 * 3. How we secure your information
 * 4. Your rights
 * 5. Contact us

Update: January 1st, 2020


GENERAL STATEMENT

Sermo® is the world’s most trusted and preferred social platform for doctors
with over 800,000 verified and credentialed members across 150+ countries. Our
community of doctors come to Sermo to anonymously seek real life, peer-to-peer
medical expertise and share their honest experiences about their profession.

Sermo’s mission is to revolutionize real-world medicine by democratizing medical
knowledge and insights to improve clinical outcomes. Our unique and
collaborative network benefits each stakeholder in the healthcare ecosystem from
our members and clients to the real-world medical community at large.

This Privacy Policy applies to all Services and websites that are offered and
provided by Sermo, its divisions and its affiliates.

If you are located in the European Union, the data controller responsible for
your information is WorldOne Research Limited, a company incorporated in England
and Wales with its registered office at 3 Murphy Street, Third Floor, London SE1
7FP, United Kingdom.

If you are a California resident, the collection, use and disclosure of your
personal information, as well as your individual rights, are subject to our
Privacy Statement – California.

This Privacy Policy (“Privacy Policy”) discloses the privacy practices for Sermo
(sometimes referred to as “Sermo”, “we”, “our” or “us”) with regard to your
(“You” or “Your”) use of the website (app.sermo.com or www.Sermo.com) (the
“Site” or “Sites”). This Privacy Policy has been updated for the European
General Data Protection Regulation in force as of May 25, 2018 (“GDPR”)

Please read this Privacy Policy carefully so You understand how Sermo processes
and protects Your information and also in order to ensure that the benefits and
obligations of membership are understood. We also encourage members talk to us
with any questions, comments or suggestions having read this Privacy Policy.


OUR PRIVACY POLICY

In the course of providing You a high quality Sermo experience and through Your
interactions with us, Sermo collects information about You and about Your use of
our Site.

Sermo takes your privacy and its obligations under data protection laws very
seriously, and we strive to be transparent at all times about our treatment of
your information.


1. INFORMATION COLLECTION AND USE

REGISTRATION INFORMATION

Before You can register for Sermo, You will need to provide Your name, address,
phone number, email address and a copy of your physician license or professional
credentials. We will use this information to set-up, validate and administer
your account. You must also consent to the privacy practices set out in this
Privacy Policy, as well as agree to our Terms of Use and Code of Conduct in
order to register.

We may use your information to send you information about our services, and
provide you with information about other goods and services we offer that are
similar to those that you have already used or enquired about to market to you.
We may also use this information to provide you, or (based on your explicit
consent, if and when required under applicable law) permit selected third
parties to provide you, with information about goods or services we feel may
interest you. If you are an existing customer, we will primarily contact you by
electronic means (email or SMS) with information about goods and services
similar to those which you have expressed interest in.

Your information may also be used to help prevent spam, fraud, or abuse. You may
use your settings for email and mobile notifications to control notifications
you receive from our Services. You may also unsubscribe from a notification by
following the instructions provided with the notification or instructions
available via the Site.

PERSONAL ACCOUNT INFORMATION

Once a registered member of Sermo, You may provide additional information in
Your personal account profile which describes You, including Your birth date,
social network username, medical school, institutional affiliations,
credentials, professional experiences, memberships, evidence of Your
specialism(s), academic background and biography. Providing additional
information in Your personal profile is not required and entirely optional, but
it may allow You to derive greater benefits from using Sermo, such as receiving
profile-targeted invitations to participate in surveys, if you choose to provide
it. This information can be updated or removed by You at any time, and You may
choose whether to make some of this information publicly visible to other social
network participants

INFORMATION WE RECEIVE FROM YOU

A key part of Sermo involves encouraging the free flow of ideas, opinions and
content between medical professionals, and most of this information provided by
users is available to be viewed by other Sermo users and third parties with whom
we are conducting business. However, regardless of the nature of your posts, we
ensure your opinion will remain anonymous if you wish it to be.

When You post content such as articles, comments and photos on Sermo, we may
also receive additional data (or metadata) related to the content, for example,
the time, date, and place You took a photo.

We also collect information when you navigate the Sermo site, for example, when
You visit a Sermo page, send or receive a message, click on or otherwise
interact with content, post content, view or click on ads we display, perform a
search, or participate in polls. We may use this information to make inferences,
such as about the content, subjects and ads You may be interested in. If You
have agreed to our use of cookies (see our Cookie section and policy below) and
one of our cookies on your device identifies You, Your usage information and the
log data described below, such as your IP address, will be associated by us with
Your account.

We also receive and use Your information when You decide to contact us. If You
email us, we may keep Your message, email address and contact information. We
need this to categorise Your enquiry, respond to it and, if applicable,
investigate any breach of our Terms of Service, Code of Conduct or this Privacy
Policy. We may also use this information to customise and improve our services
over time. We do not use this information for external advertising.

To set-up and run Your Sermo account, we may ask you to provide some financial
information in order to allow You to be compensated for participating in
Opportunities (see our Terms of Service). If You choose to withdraw these
amounts through gift cards or charitable donations, we will need to collect
information from You in order to process these transactions. Where such
Opportunities are offered by third parties, we will also need to collect
information about Your participation in such Opportunities from those third
parties, in order to validate payments. We may also need to send the information
set out in this section to trusted third parties that we appoint to process and
administer such payments.

Sermo does not collect personal health information about individuals. Sermo does
not collect or maintain information that would associate a submission with a
specific patient. So please ensure that You do not disclose anything that would
allow a patient to be identified. Note also that Sermo does not possess a data
based key to re-identify patient data.

INFORMATION TO/FROM THIRD PARTIES

We reserve the right to instruct trusted third parties to process Your
information in order to verify Sermo user identities and ensure that members are
medical professionals and to protect the integrity of Sermo by preventing fraud.

We may obtain data from our affiliates or our advertising partners, customers
and other third parties, such as Woopra, which help us (or them) deliver
sponsored content onto Sermo, understand online activity, and generally improve
Your Sermo experience. Such third parties may share information about You which
includes a browser cookie ID, website URL visited, mobile device ID, or
cryptographic hash of a common account identifier (e.g. usernames or email
address), which enables Sermo to provide ads on the Site and monitor Your
preferences and Your interest in them. However, You can choose to block certain
ads by enabling an ad blocker to Your web browser so that Your information will
not be matched to information shared by ad partners for this purpose. Sermo also
makes use of Google Analytics, a web analytics service provided by Google, Inc.
(“Google”), which uses cookies to analyse how users use the website. The
information generated by the cookie about Your use of the website will generally
be transmitted to and stored by Google on servers in the United States. At the
request of Sermo, Google will use this information for the purpose of measuring
Your activity on Sermo’s website, compiling statistical reports on overall
website activity for Sermo on an anonymous basis and providing other services
relating to website activity and internet usage. Google will not associate your
IP address with any other information held by Google. In addition, you can
prevent the collection of the information generated by the Google cookie, as
well as the processing of this data by Google, by downloading and installing a
browser plug-in available here.

DMD Healthcare Communications Network℠ Privacy Statement

Sermo and its related digital services participate in the DMD Healthcare
Communication Network℠ (the “Network”) and as such has implemented various
technologies for universal registration/login among all Network member websites.
These technologies are managed by DMD Marketing Corp. (“DMD”), and may involve
the collection, receipt, and sharing of information with DMD, its clients and
other Network members. If you would like to understand how this digital
service’s participation in the Network affects your privacy, please click here.

Please note that the Network registration/login system may be different from the
registration/login used by this digital service for other products and services.
To the extent that anything in this privacy policy conflicts with the policy for
the Network technologies, the conflict will be resolved in favor of the policy
applicable to the Network technologies.

This site or product includes IP2Location LITE data available from
https://lite.ip2location.com.

COOKIE INFORMATION

A cookie is a small piece of data that is sent to Your browser from a Web server
and stored on Your computer’s hard drive. A cookie cannot be used to read data
off Your hard disk, nor can it read cookie files created by other sites. We use
cookies to improve Your experience on the site; for example, by setting a cookie
on Your browser, You would not have to log in a password more than once, thereby
saving time. You can choose whether to accept cookies or not by changing the
settings of Your browser. You can reset Your browser to refuse all cookies or
allow Your browser to show You when a cookie is being set. If You reject the
cookies on the Site, You may still be able to use the Site, but Your use may be
limited in some areas or limited to certain functions of the Site.

The Sermo Site uses session cookies and persistent cookies to better understand
how you interact with the Site, to monitor aggregate usage by and web traffic,
to enable You to access surveys and to make improvements the Site. You can learn
more about the use of cookies in our Cookie Policy.

LOG INFORMATION

When you use our Site, Sermo may use information such as Your IP address,
browser type, operating system, referring web page, pages previously visited,
location (see below), mobile carrier, device and/or application identifiers,
search terms, and cookie information to align our services with changes in Your
device usage patterns, to administer the Site and to gather certain demographic
information for aggregate use. We may also receive log information when You view
or interact with links on the Sermo site, including sites operated by third
parties.

LOCATION INFORMATION

We may receive information concerning your location if, for example, You choose
to post content which reveals this information. We may also determine Your
location using information from Your device, such as GPS data, information about
wireless networks or cell towers near Your device, or IP address. Subject to
your explicit consent, we may use this to improve and customise our service to
You, for example by making you aware of content, people and ads more relevant to
Your location. You can choose to turn off location services on Your device if
you prefer, however if You do so You will not benefit from such tailored
content.


2. HOW AND WHY WE SHARE YOUR INFORMATION

We will only process the information we collect about You in accordance with
this Privacy Policy or where You have otherwise authorised us to do so by
granting us your explicit consent.

Sermo is free and we want to make sure it remains this way for a long time.
Organizations seeking physician expertise, such as pharmaceutical companies,
medical device firms, and biotech firms underwrite the market research and
sponsorship opportunities within our site and help us fund the delivery of Sermo
to You. We may direct You to pages which contain commercial content or You may
be presented with the opportunity to engage with sponsored content, such as at
the conclusion of a RealTime survey or  via Sermo Conversations, Sermo Promo and
Sermo Ratings, which are further described in the Terms of Service. We may then
provide our partners with engagement effectiveness metrics that include the
sharing of some minimal personal data for performance assessment purposes. To
the extent required by law, we will collect your explicit consent prior to
providing such identifiable information.

To protect the anonymous nature of our physician conversations, we will clearly
identify commercial content with logos or with words such as “Sermo Client”,
”Client Page”, “From Industry”, “sponsored polls” or “sponsored page” or other
clear identifiers instead of using Your information, prior to Your engagement.
As a Panel member, Sermo (or its service providers or affiliates on Sermo’s
behalf) may contact you multiple times via any and all contact information that
you provide to Sermo.

We engage service providers to perform certain functions on our behalf and help
us provide our services. We may share Your information with such service
providers, who are carefully selected by us, where we impose legal obligations
on them which are consistent with this Privacy Policy, and on the condition that
they act only on our instructions and keep Your information secure. We may also
share Your information with other entities within the Sermo group and we have
implemented technical and contractual measures to help ensure that Your
information is secure through-out the Sermo group.

Subject to implementing relevant safeguards under Art. 46 GDPR, the data that we
collect from you will be transferred to, and stored at, a destination outside
the European Economic Area (“EEA”). It will also be processed by staff operating
outside the EEA who work for us or for one of our service providers. We will
take all steps necessary to ensure that Your information is subject to the
required technical and organisational measures as required under law and are
treated in accordance with this Privacy Policy.

Users of the Site are prohibited from revealing any information that might
identify another user; and doing so will constitute grounds for immediate
termination of that members’ account. However, if You have chosen to reveal
personal data on the Site it is possible that other users may make reference to
it. As such, please consider carefully what information You choose to make
public on the Site.

SALE OF ASSETS, MERGER, ACQUISITION, BANKRUPTCY

Information collected from You, or received by us from others about you may be
transferred to a third party to the extent permitted by law, as a result of a
sale or acquisition, merger or bankruptcy involving Sermo. This Privacy Policy
will apply to Your information as transferred to the new entity. We will still
inform You beforehand and provide you with a possibility to object within a
reasonable timeframe.

LEGAL REQUESTS

Sermo takes Your right to privacy very seriously and has taken measures to
safeguard Your personal data. Sermo will only disclose Your personal data other
than as set out above in the event we are required to do so by law, rule,
regulation, law enforcement, governmental official, legal authority or similar
requirements.


3. HOW WE SECURE YOUR INFORMATION

We are committed to protecting the security of Your information. We use a
variety of industry-standard security technologies and procedures designed to
help protect Your information from unauthorized access, use, or disclosure.
Despite these measures, You should know that we cannot fully eliminate security
risks associated with information and transmission of data over the internet, it
can never be completely secure. In the event of a data security breach, we will
take all essential actions as required under applicable laws.

The Site may contain links to other sites. The linked sites are not necessarily
under the control of Sermo. Please be aware that Sermo is not responsible for
the privacy practices of such other sites. Sermo encourages You to be aware when
You leave this Site and to read the privacy policies of each and every web site
that collects personal information. If You decide to access any of the
third-party sites linked to this Site, You do this entirely at Your own risk.
Any links to any partner of the Site is responsibility of that partner and Sermo
shall not be responsible for notification of any change in name, or location of
any information on the Site.


4. YOUR RIGHTS

You also have a legal right under the GDPR and other relevant data protection
laws to: (i) access the information we hold about you and (ii) to a copy of any
information about You held by us. Upon request, we will provide You with access
to and a copy of this information. You also have a right to (iii) correct any
errors in this information, (iv) request its deletion or (v) to object to any
processing operations (provided we are not under legal obligations to retain
certain information) and (vi) to revoke any given consent at any time.

We reserve the right to decline requests that are (i) unreasonably repetitive,
(ii) that jeopardise the privacy of others, (iii) the validation facility, (iv)
the interests of justice, (v) or where we are otherwise required to retain Your
personal data by law.

You can exercise Your rights to access, edit and delete your information in
accordance with the GDPR, CCPA (see here our CCPA Privacy Statement), Nevada
Privacy Law SB-220 or other relevant local privacy laws at your location – at
any time by Contacting Us or emailing us at support@sermo.com. Lastly, if you
are a European Union resident, you also have the right to submit a complaint to
the relevant data protection authority in your European Union member state.

UPDATE AND DELETION OF PERSONAL INFORMATION

If Your personal information changes (such as Your address), You can update Your
profile on the Profile page of the Site. Sermo will correct, update or remove
Your personal data as directed or You can do so Yourself via the self-service
Profile page mentioned above.

If You no longer desire to use the Site, you may permanently delete your Sermo
account. The time to deactivate Your account will vary according to your prior
history with Sermo. In the simplest cases, deactivation will be prompt following
the receipt of a “cooling off” communication reminding you of the results of
deactivation. For some accounts the process will be longer as we complete
certain administrative task relating to Your past activity and any incentives
You may have earned. However, Sermo will aim to complete account deactivations
within 28 days from the original request. This does not affect any information
use choices You make, which will be honoured promptly.

If You no longer wish to be a member of the Sermo Panel, You may request to be
removed from the Panel at any time. If You choose to opt-out of the Panel, You
do not automatically terminate Your Sermo membership.

You can request Your personal details to be removed from the Panel active
database and to have your participation in the Panel terminated by:

 * Contacting Us, choosing “I want to delete my information” as the inquiry
   subject; or
 * sending Us an e-mail at support@sermo.com from the e-mail address you
   registered with and with the words “” in the subject line.

Failure to follow the stated procedure correctly may result in delay in the
removal of Your information from the Panel databases. Your removal request will
be dealt with promptly. If You choose to remain a Sermo member, we will retain
Your personal information for as long as necessary for the purpose for which it
was collected and processed, such as with respect to Your Sermo membership.

LAWFUL BASES TO PROCESS YOUR INFORMATION UNDER THE GDPR

Sermo is the data controller of Your information and when we collect and process
Your information, we rely on Your consent or our legitimate business interests
as the legal basis to do so. The GDPR provides for six legal bases that permit
an organisation like Sermo to lawfully process Your information. The six are:

 1. You have given consent to the processing of Your information for one or more
    specific purposes. For example: clicking “I agree” to a cookie alert while
    browsing a page on the internet or consenting to a specific information
    processing request contained within an online survey.
 2. Processing is necessary for the performance of a contract to which You are a
    party or in order to take steps at the request of You prior to entering into
    a contract. For example: when You agree to be a Sermo panel member Sermo
    will then process your information to: verify Your identity, location and
    professional specialisms, determine the market research opportunities
    [whether via email or telephone surveys] You are eligible for, match You
    with third party market research targeting lists [e.g. the U.K.’s GMC list],
    project related pre and post market research analytics provided that Your
    personal data will not remain with a third party or be used for any other
    purpose; use Your data to respond to regulatory requests, create and
    administer an incentives account for the incentives You earn as a Sermo
    panel member and respond to Your queries via our Member Care team.
 3. Processing is necessary for compliance with a legal obligation to which
    Sermo is subject. For example: accurately reporting taxes, complying with
    financial transparency laws [e.g. Loi Bertrand and Loi Anti-Cadeaux in
    France] or reporting pharmacovigilance adverse events information.
 4. Processing is necessary in order to protect the vital interests of You or of
    another natural person. For example: reporting Your information as part of a
    potentially life-saving or life-threatening event, via Sermo’s obligation to
    report adverse events.
 5. Processing is necessary for the performance of a task carried out in the
    public interest or in the exercise of official authority vested in Sermo.
    This legal base will probably not be used by Sermo.
 6. Processing is necessary for the purposes of the legitimate business
    interests pursued by Sermo or by a related third party, except where such
    interests are overridden by Your interests or fundamental rights and
    freedoms. For example: Your information is an important element in Sermo’s
    provision of a global social network, free at the point of access. As a
    result Sermo is able to provide its social platform based tools and
    products, such as Sermo Drug Ratings™ tool that is based upon the drug
    ratings You provide and then You have the right to use the Sermo Ratings
    results via the Site. The Sermo Community team also uses Your information to
    help administer this Site and Sermo’s market research and social network
    activity that are in part generated form this Site.

NOTIFICATION OF CHANGES

We may update this Privacy Policy at any time, with or without advance notice.
In the event of any change in the way we treat Your personal data, or in the
Privacy Policy document itself, we will display a notice on the Sermo website
(app.Sermo.com) or send You an email, so that You may review the changed terms
prior to continuing to use the Site. As always, if You object to any of the
changes to our terms, and You no longer wish to use the Site, You may contact
Sermo Support to deactivate Your account. Unless stated otherwise, our current
Privacy Policy applies to all information that Sermo has about You and Your
account.

SITE AND SERVICE UPDATES

As necessary, Sermo may send You Site and service announcement updates. You are
not able to unsubscribe from service announcements, which contain important
information about the Site, unless you delete your account. Sermo primarily
communicates via e-mail with You to provide requested services and to resolve
issues relating to Your accounts.


5. CONTACT US

Should You have questions about this policy or Sermo’s information collection,
use and disclosure practices, feel free to Contact Us. You may also contact our
interim Data Protection Officer and General Counsel by a written request at

Sermo,
Attn: Data Protection Officer and General Counsel
3 Murphy Street, Third Floor,
London SE1 7FP, United Kingdom.

We will use all reasonable efforts to respond promptly to requests, questions or
concerns You may have regarding our use of personal information about You.
Except where required by law, Sermo cannot ensure a response to questions or
comments regarding topics unrelated to this policy or Sermo’s privacy practices.

Sermo


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