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PV BRIEFING PRIVACY POLICY

Updated January 1, 2020

PV Briefing is a service mark of PeerDirect Publishing.

In this Privacy Policy, we, PeerDirect Publishing, 1, rue Hildegard von Bingen,
L-1282 Luxembourg, Luxembourg (“we”) provide information about how we collect,
process and share personal information through websites, mobile applications and
newsletters that PV Briefing operates (“Services”). This Privacy Policy only
applies to Services that include a link to this Privacy Policy and may be
supplemented by additional notices to you depending on the specific Service you
are accessing or using. By “personal information” or “personal data”, we mean
information that identifies you or can reasonably be used to identify you. If
you are located in the European Economic Area, please also see the Supplemental
European Online Privacy Statement here. If you are a resident of California,
please also see our Supplemental California Consumer Privacy Act (CCPA) Privacy
Policy here. Individuals who have a visual disability may be able to use a
screen reader or other text-to-speech or text-to-Braille tool to review the
contents of this document.

1. Collection of Personal Information From Users of our Services

Information You Actively Submit. We collect certain types of personal
information when you interact with our Services, such as when you:

 * Register for an account on any Service or update your profile information;
 * Participate in a medical education activity;
 * Respond to an online survey;
 * Request information from us about patient assistance resources, medical
   education activities and other medical communications;
 * Submit comments, reviews, or other user-generated content on our Services;
 * Request customer or technical support from us; or
 * Otherwise submit personal information to us via the Services.

The personal information we collect includes your name, email address, mailing
address, telephone number, certain information related to your profession (e.g.,
specialty, education, hospital affiliation, etc.) and any other personal
information that you actively submit to us. In each such instance, you will know
what personal information we collect, because you actively submit it. We
endeavor to clearly label which information is required and which information is
optional in all cases. If you are unable or choose not to provide us with the
personal information we reasonably require, we may be unable to provide you with
the information or services you have requested.

Information Passively Submitted. When you use our Services, we may also
passively track information about your computer, device or Internet connection,
such as the IP address of your computer and/or Internet service provider, the
date and time you access our website, the Internet address of websites from
which you come to our websites, the type of device you are using to access the
Service, the Web browser and operating system you are using, and your movements
and interactions on our Services. This data is generated and collected
automatically, as part of the standard operation of the Services. Unless you
also actively submit personal information to us, any information that is
passively submitted typically does not allow us to identify you personally.

Publicly Available Information. Where permitted by applicable law, we may also
collect information about your specialty, hospital affiliation and academic or
scientific publications from public resources.

Cookies and Web Beacons. We may place cookies on users’ computers. Cookies can
save data about individual users, such as the user's name, password, username,
screen preferences, and the pages of a site viewed by the user. When the user
revisits the website, we may recognize the user based on any cookies placed on
their computer and customize the user's experience accordingly. For more
information about our use of cookies, please see our Cookie Policy.

We may also use web beacons to track who has opened our emails. Web beacons are
tiny graphic image files, embedded in a website page that notify the home server
(which can belong to the host website, a network advertiser, or some other third
party) on a non-personally identifiable basis that some interaction has taken
place. This notice may also result in a cookie being set on your device, as
described above.

Use of Personal Data Collected

We use personal information that we collect about you through the Services to:

 * Upon request, create an account for you for the Services;
 * Respond appropriately to your inquiries;
 * Update you regarding your account;
 * Provide you with, maintain, secure, and improve our Services;
 * Provide you with a customized experience in connection with our Services;
 * Improve the accuracy and relevance of the results you see when you interact
   with the search engine and the search engine's integrated chatbot
   functionality that is part of our Services;
 * Discharge our contractual obligations to you; and
 * Comply with any legal obligations that apply to us.

To the extent permitted by applicable law, including in accordance with your
consent where required by applicable law, we also use your personal information
for the following purposes:

 * Invite you to participate in online medical education activities, including
   accredited continuing medical education activities, and send you information
   about medical activities and promotional communications from pharmaceutical
   companies by email. If you do not wish to receive such emails, you may opt
   out by following the opt-out instructions included in such emails. We may
   also invite you via postal mail.
 * Invite you to learn more about and request information from us about patient
   assistance resources, such as sample activities and co-pay incentive
   activities. If you do not wish to receive such emails, you may opt out by
   following the opt-out instructions included in such emails.
 * Send you medical newsletters including the top medical news in your field of
   interest and medical alerts. If you do not wish to receive such emails, you
   may opt out by following the opt-out instructions included in such emails.
 * Send you invitations to complete market research surveys, by email, typically
   in exchange for honoraria. If you do not wish to receive such emails, you may
   opt out by following the opt-out instructions included in such emails.
 * Review the information provided by you and obtained from public resources to
   complete your profile and better understand which medical news, education
   activities and surveys may be of most interest to you.

We also perform statistical analyses of the users of our Services to improve the
content, design and navigation of the Services. In these cases, we use aggregate
or statistical data that cannot reasonably be used to identify you.

If you respond to a survey, we only use your personal information in connection
with your survey responses for the purposes of: (i) verifying your eligibility
to participate in a study; (ii) validating your identity and responses for the
purposes of preventing duplicate or fraudulent responses; and/or (iii)
processing your honoraria payment. Unless we have obtained your explicit
consent, we anonymize survey results before sharing them with third parties,
although we may be required by applicable law to identify a particular
respondent to comply with applicable legal requirements, such as adverse events
reporting requirements.

2. Sharing of Information

We do not share your personal information with others, except in the following
circumstances and in accordance with applicable law:

 * With your consent;
 * To our agents and service providers, who act on our behalf and under
   confidentiality agreements to deliver services, provide IT support, and help
   us fulfill the other purposes set forth above;
 * To our affiliates and partners under confidentiality agreements who work with
   us to improve our and their services and business practices;
 * If you participate in a medical education activity that we publish and
   thereby obtain a continuing medical education or similar certificate, we may
   disclose the fact that you participated in the activity to the medical school
   or institute that accredited the activity for the purposes of complying with
   professional accreditation recordkeeping requirements;
 * If we publish an activity from another medical education provider, and
   thereby obtain a continuing medical education or similar certificate, we may
   disclose the fact that you participated in the activity to the medical
   education provider for the purposes of complying with professional
   accreditation recordkeeping requirements;
 * As required by applicable law, including, without limitation, in response to
   any government or regulatory agency request, to cooperate with law
   enforcement investigations, or upon receipt of any court order; and
 * To courts and public authorities to protect you, us, or third parties from
   harm, such as fraud.

If you respond to a market research survey, we do not share your personal
information with the third parties on whose behalf we are conducting such
research except with your consent or where required by applicable law, such as
to comply with applicable adverse incident reporting requirements. We otherwise
only share market research results with third parties in aggregate (as a
collection of total responses), and individual responses of respondents are not
shared in association with the respondent’s personal information.

Typically, PeerDirect Publishing only provides aggregated data to commercial
supporters of PeerDirect Publishing, and only such data that is relevant to
their interests and/or the programs that they support. However, if a commercial
supporter of a program that was published for the U.S. already has personally
identifiable information about a user, PeerDirect Publishing may provide that
commercial supporter with information about whether that user participated in
any of its sponsored programs, and information collected as a result of that
user’s participation in such sponsored programs. This information will only be
shared where and as permitted by applicable law, and may include the user’s time
and date of access, the content viewed or otherwise accessed on the site, the
website the user came from, the type of browser used, and other information
related to and provided by the user when participating in such sponsored
programs.

3. Security Measures

We take steps to protect your personal information from loss, misuse, and
unauthorized access, disclosure, alteration, and destruction. We have
implemented technical and administrative security features to help prevent the
unauthorized release of or access to personal information. Please note, however,
that while we have endeavored to create a secure and reliable site for users,
the confidentiality or accuracy of any communication or material transmitted
to/from us over the Internet cannot be guaranteed. You are responsible for the
security of information that you transmit via the Internet. It is your
responsibility to safeguard the username and password that you use to access our
websites, if any, and to notify us immediately at the contact information below
if you ever suspect that your username and/or password has been compromised.

4. Opt-Out Right and Updating Account Information

If you would like to opt out of receiving invitations to medical education
activities, medical surveys or medical newsletters from us, please click the
opt-out link at the bottom of our emails. Even after you opt out or update your
preferences, however, please allow us sufficient time to process your
preferences. It may take up to 10 days to process your email related requests,
and up to 30 days for all other requests. Even after you have opted out of
receiving invitations to medical education activities, medical surveys and
medical newsletters from us, we may still contact you for transactional or
informational purposes. These include, for example, customer service issues or
any questions regarding a specific inquiry you made to us.

If you believe any information we have about you is no longer accurate or
current or would like to access personal information we may have about you,
please contact us by emailing privacy@peerdirect.com. Upon authenticating your
request, we will update or amend your information, or provide you with access,
but we reserve the right to use personal information obtained previously to
verify your identity or take other actions that we believe are appropriate.

5. Collection of Personal Data From Children

We do not knowingly collect personal information from children under the age of
13, and we do not knowingly market the Services or any goods or services to such
children.

6. Contacting Us

If you have any questions regarding this Privacy Policy, you may contact us by
emailing privacy@peerdirect.com.

7. Effective Date and Changes to Privacy Policy

We reserve the right to change this Privacy Policy. If we make a material change
to how we collect, use, or disclose Personal Information, we will prominently
post an updated Privacy Policy on our Services. Where required to do so by law,
we may seek your prior consent to any material changes we make to this Privacy
Policy. If you disagree with our Privacy Policy changes, you may discontinue
using the Services.


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