Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – www.himsspopulationhealth.org
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to its purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited to a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of the data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right to withdraw any given consent for Processing your Personal Data.
Data we gather
The information you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.
The information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, it could be your shopping cart information, your IP address, your shopping history (if there is any), etc. This information is used to improve the customer experience. When you use our services or look at the contents of our website, your activities may be logged.
The information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds.
Publicly available information
We might gather information about you that is publicly available.
In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
- Technical information, including the Internet Protocol (IP) address, used to connect your device to the Internet;
- Your login information, browser type, and version, time zone setting, browser plug-in types, and versions;
- Operating system and platform;
- Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it.
How we use your Personal Data
We use your Personal Data in order to:
- provide our service to you (for example this could be registering your account, providing you with products and services that you have requested)
- enhance your customer experience;
- improve our website in order to better serve you;
- fulfill an obligation under law or contract;
- provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
- ensure the security and safe operation of our websites and underlying business infrastructure;
- personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested, and
- manage any communication between you and us.
As long as you have not informed us otherwise, we consider offering you products/services that are similar or the same to your purchasing history/browsing behavior to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers (from us and/or our carefully selected partners);
- for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfill obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized.
We might process your Personal Data for additional purposes that are not mentioned here but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context, and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguards for Processing.
We will inform you of any further Processing and purposes.
How we secure your data
We do our best to keep your Personal Data safe. We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. We do not use vulnerability scanning and/or scanning to PCI standards.
We have what we believe are appropriate security controls in place to protect personal data. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.