ExchangeCME Privacy Policy

Last Updated: May 2018

This Privacy Policy describes the privacy practices for exchangeCME.com, which is operated by Integritas Communications ("INTEGRITAS") and Insci Productions ("INSCI" referred to along with INTEGRITAS as “we,” us” and “our”), respectively. We refer to the Site as the "ExchangeCME Network," and along with the information and services made available to users of the ExchangeCME Network, including but not limited to, reference content, clinical tools, applications, sponsored programs, email communications, continuing medical education, market research opportunities, the “Services.”

We provide the Services as a professional resource intended to support healthcare professionals in their efforts to provide high quality medical care to patients. You can choose whether or not you want to register as a ExchangeCME network member and use the Services. If you do choose to use the Services, you must agree to the ExchangeCME Terms of Use which is the contract between us and users of the Services. By accepting the ExchangeCME Terms of Use, you confirm that you have read and understand this Privacy Policy. If you do not want us to collect, use or share information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in the United States where we are located. Except as otherwise noted in this Privacy Policy, ExchangeCME is the data controller responsible for the processing of your personal information as described in this Privacy Policy.

Information Collected

Information about your use of the Services is collected as follows:

  • Registration. When you register as a member of the ExchangeCME, you must provide certain personal information such as your name, email address, zip/postal code, profession, occupation, specialty and depending on your country of practice, your medical license number or equivalent. You may choose to update or supplement the personal information that you provided at registration at any time through your account settings.
  • Services Information. We automatically collect and store information about your use of the Services, such as your engagement with particular content including sponsored informational programs, whether you opened a particular email, clicked on a link, and how often and when you engage with the Services. We also collect information about your device when you access the Services including IP address, browser information (including referring URL), cookie information and, all of which may be associated with information we have about your use of the Services. We use cookies and other tracking technologies, such as pixels, tags, web beacons and software development kits, to collect the information about your use of the Services and your device. If you are a member of the ExchangeCME network, we may elect to associate this information with your registration information. For more information about the use of cookies and other tracking technologies within the ExchangeCME Network, see our Cookie Policy.
  • Market Research: You may participate in market research surveys conducted by us or on our behalf for our own internal business purposes. For some surveys, you may be asked to provide personal information for re-contact or payment fulfillment purposes.
  • Information from Third Party Sources. We may receive additional information about you from third party sources to assist us in providing the Services. For example, we may use third party information to verify and update your registration information, for research purposes or to personalize the Services, including advertising.
  • Non-registered Users. You must register with the ExchangeCME Network to access all of the Services, however, you may be able to access certain limited Services without registering. Even if you have not registered, we collect information about your use of the Services through the use of cookies and other tracking technologies. The information we collect includes the referring website, if applicable, the type of browser you use, the material viewed, and the time and date that you accessed the Services.

How Your Information May be Used

Information about you may be used for the following purposes:

  • Provision of the Services. We may use the information collected about you to provide and improve the Services and to conduct research supporting the development of new Services.
  • Email Communications. By registering as a member of the ExchangeCME Network, you agree to our use of your registration information and other information that we collect about you to send you email communications, including invitations to events and other promotional materials for online activities.
  • Member Profiles. We may associate information that we have collected about your use of the Services with personal information you have provided to us, thereby creating a profile of you that we may update from time to time ("Member Profile"), as further described below.
  • Verification Purposes. We may use your information in conjunction with information from third parties to verify your identity and/or professional credentials. We may require you to provide proof that you are a healthcare professional and if you are unable to do so to our reasonable satisfaction, we reserve the right to deny you participation in the Services or any component thereof. While we take steps to verify that our members who identify as healthcare professionals are actually healthcare professionals, we make no guarantee as to their identity, professional credentials or licensure status.
  • Account Management. We may use your information to administer your account, respond to your inquiries, fulfill your requests and send you administrative communications about the Services.
  • Investigations. We may use your information to detect, investigate and defend against fraudulent or unlawful activity and violations of the ExchangeCME Terms of Use.

Sharing Your Information with Third Parties

Information about your use of the Services may be shared as follows:

  • Contractors Who Work for Us: We work with third party contractors to help us provide the Services and to otherwise assist us in the operation of the ExchangeCME Network, including in the areas of email management and deployment, analytics, marketing, advertising, market research, sweepstakes and contest administration, professional credential validation, customer service and payment fulfillment services. We may provide these contractors with personal information about users of our Services so that they can fulfill their responsibilities to us, however, we do require that they agree to limit their use of this personal information to the fulfillment of these responsibilities.
  • Member Profiles. ExchangeCME may provide Member Profiles, and portions thereof, (excluding contact information and information about your participation in specific named CME and CE activities) to third parties, subject to applicable law, which these third parties may use for their business purposes including marketing.
  • Market Research Surveys: If you receive remuneration for participating in a Sponsored Survey, we may be required to provide the sponsor (or the market research company acting on its behalf) with your personal information for the sponsor's recordkeeping and/or regulatory reporting purposes. If you chose to access a Sponsored Survey that is conducted by a third party market research company, we may identify you to this company through the survey link. Sometimes market research companies send us lists of individuals they wish to reach with particular Sponsored Surveys, and we may inform these companies which of these individuals are members of the ExchangeCME Network so that they can manage their survey recruitment needs accordingly. Also, certain market research survey opportunities made available to you through the Services require the market research company to contact you directly to conduct the Sponsored Survey. We will inform you in the associated survey invitation that we intend to provide your contact information to the market research company that is conducting the Sponsored Survey so that you can decide at such time if you wish to proceed with the opportunity. We do not disclose your Sponsored Survey responses to the associated sponsor in a manner that identifies you.
  • Continuing Medical Education: All activities hosted on Exchange CME are accredited by the Accreditation Council for Continuing Medical Education (ACCME), the American Nurses Credentialing Center and the Accreditation Council for Pharmacy Education to provide continuing education to physicians, nurses and pharmacists, respectively (collectively, "CME/CE"), which CME/CE activities are hosted by ExchangeCME. ExchangeCME is required to periodically submit personal information about CME/CE participants and the CME/CE activities that ExchangeCME hosts, as requested by the applicable accrediting entity. Supporters of ExchangeCME’s CME/CE activities will receive only aggregated data about the CME/CE activities that they support including participation and outcomes measurement reports.
  • Aggregated Information. We may provide aggregated information about users of our Services to third parties as we deem appropriate in our sole discretion. For example, ExchangeCME may tell a customer what percentage of registered users of the ExchangeCME Network reside in a particular geographical area or specialize in a particular clinical area, or what percentage of participants in a market research survey selected a particular response to a survey question.
  • Social Widgets: We may include social widgets within the Sites which enable you to interact with the associated social media services, e.g., to share an article. These widgets may collect browsing data which may be received by the third party that provided the widget, and are controlled by these third parties. You may be able to manage your privacy preferences directly with the applicable social network platform.
  • Business Transfers: If we transfer a business unit (such as a subsidiary) or an asset (such as a website) to another company, that company will be required to treat any personal information collected under this Privacy Policy consistent with the applicable terms of this Privacy Policy.
  • Legal Requirements: We may release personal information when we believe release (i) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order and to meet national security or law enforcement requirements; or (ii) is reasonable in response to a physical threat to you or others, to protect property or defend or assert legal rights of us or others.

Security of Information

We have implemented appropriate technical and organizational security measures to protect the personal information that we have under our control from unauthorized access, use and disclosure and accidental loss. When you enter personal information, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology. You are solely responsible for maintaining the security and confidentiality of your account username and password. Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

Choice and Control

  • Account Information. You may update your registration information at any time through the Account Management feature available on each of the Sites. You may also contact Customer Support at info@exchangecme.com and request that your registration information be updated or deleted. Following your request, we will delete your registration information from our active databases and where feasible from our back-up media. Note that if we delete your account, we may maintain certain de-identified information about you for internal business purposes including research, analytics and reporting.
  • Cookies. Most browser software can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. Refer to our Cookie Policy for additional information about opting out of cookies.
  • Email Communications. If you no longer wish to receive a particular type of email communication from us, you may unsubscribe by clicking the "unsubscribe" link located at the bottom of the email and following the instructions. Also, you may manage your newsletter subscriptions within the newsletter subscriptions area within your account settings. Note that certain email communications that we send to members are service-related and as long as you are a member of the ExchangeCME Network, you may not unsubscribe from such emails. Also, if you have provided us more than one email address, we may continue to contact you using the other email address not associated with the emails from which you have unsubscribed, until you unsubscribe from emails sent to that other address.
  • California Residents. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and have provided your personal information to us, you may request information about our disclosures of certain categories of personal information to third parties for direct marketing purposes in the preceding calendar year. You can submit such request by sending an email to info@exchangecme.com.

Note to Users Outside of the United States

ExchangeCME is located in the United States, as is the ExchangeCME’s technical infrastructure. In order to provide the Services to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

ExchangeCME participates in and has certified compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework with respect to its operation of the ExchangeCME Network. ExchangeCME is committed to subjecting all personal information received from EU member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Frameworks, and to view ExchangeCMe’s certification, visit the U.S. Department of Commerce’s Privacy Shield List.

ExchangeCME is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. ExchangeCME complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, ExchangeCME is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

For more information relevant to ExchangeCME Network users in the EEA, click here.

Children's Privacy

The ExchangeCME Network and the Services are designed and intended for use by adults, and are not intended for nor designed to be used by children under the age of 18. We do not collect personal information from any person we know is under the age of 18.

Privacy Policy Changes

We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address included in your account profile) and/or by means of a notice on the Sites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.

Contacting Us

If you have general questions about your account or the Services, contact Customer Support at info@exchangecme.com. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at info@exchangecme.com or at the following address:

ExchangeCME
Integritas Communications
95 River St, Suite 5C
Hoboken, NJ 07030

ExchangeCME’s users from the EEA may contact our Data Protection Officer at info@exchangecme.com.

Please note that if you contact us to assist you, we may need to authenticate your identity before fulfilling your request.

ExchangeCME Cookie Policy

ExchangeCME and our partners use cookies and other tracking technologies to collect information about your use of the websites and mobile applications that comprise the ExchangeCME Network, and the associated services which include email communications (collectively, the “Services”).

  • “Cookies” are small data files that a website places on your browser when you visit the website. Cookies allow a website or third party to recognize your browser. There are three primary types of cookies:
    • Session cookies are specific to a particular visit and carry information as you view different pages within a website. Session cookies expire and delete themselves automatically in a short period of time, e.g., when you leave the website or when you close your browser.
    • Persistent cookies enable us to recognize you when you visit our website and remember your preferences. Persistent cookies are stored on your browser or mobile device until you choose to delete them, and otherwise typically delete themselves at expiration.
    • Third-party cookies are placed by someone other than us, and may gather browsing activity across multiple websites and sessions. They are usually persistent cookies and are stored until you delete them or they expire based on the time period set in each third-party cookie.
  • “Web beacons” are small graphic files (sometimes called “clear GIFs” or “web pixels”) that are embedded in images on pages of a website or in an email and are typically used to track a user’s activity on the page or whether an email was opened. The beacon sends back to the home server (which can belong to the host site, a network advertiser or some other third party) information from your browser, such as the IP address, the URL of the page on which the beacon is located and the content viewed, the type of browser that is accessing the site and the ID number of any cookies on your computer previously placed by that server.
  • “Application SDKs” are mobile application third-party software development kits that are embedded in mobile applications. These app SDKs permit the collection of information about the app itself, activity in the app, and the device the application is running on.

The cookies used in connection with your use of the Services will generally fall within one of the following categories:

  1. Necessary functionality: These cookies are essential to enable you to navigate the ExchangeCME Network properties and access the Services in a safe and secure manner.
  2. Important functionality: These cookies help us authenticate registered members, remember your profession, specialty, preferences and content interests so that we can provide an enhanced and more personalized user experience.
  3. Performance and Analytics: These cookies provide data on how the Services are functioning to help us improve the performance of the Services and the user experience.
  4. Advertising/Marketing Services: These cookies enable us and our advertising partners to deliver advertisements with the ExchangeCME Network and on third party sites that are more relevant to you and your interests based on your member registration information, content browsing activity, use of the Services and in some cases, other information about you that we or our advertisers have obtained from other sources. Cookies may be used to limit the number of times you see a particular advertisement and to measure of the effectiveness of an advertising campaign.

We may use cookies and other tracking technologies to recognize individual users when they access the Services, remember user preferences, keep track of users’ access to and use of the Services, track whether our emails opened and whether links are clicked, ensure that the Services are functioning properly, analyze trends and to personalize the Services, including advertising within the ExchangeCME Network and on third party websites, so that it is relevant to individual user’s interests which may be inferred based on profession, specialty, location, prior activity within the ExchangeCME Network and also other information that we or our partners may have about our users.

When you use the Services, we may collect information about your device including the IP address (which provides non-precise information, e.g., city or zip code level, about the approximate physical location of the device), unique device identifier (which is different than the device’s serial number), cookie information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device), browser information (including referring URL), operating system, mobile carrier, device settings and App version and usage information, all of which we may associate with information about your use of the Services. When enabled by you, we collect precise location information provided by your mobile device, which you may disable through the device settings. If you are a member of the ExchangeCME Network, we may elect to associate the information collected by cookies and other tracking technologies with your registration information and other information we have about you.

We may personalize the Services, within the ExchangeCME Network, on third party websites and in our email communications, based on your registration information, information collected about your use of the Services and information we receive from third party sources.

Your Choices

Most browser software can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. Typically the cookie settings are within the “options” or “preferences” menu in your browser. The links below provide information about cookie settings for some commonly used browsers:

You can opt-out of interest-based advertising on the Sites by rejecting cookies and through preferences manager or, if you are located in the European Union (EU), you may also opt-out here.

We reserve the right to change this Cookie Policy at any time and any changes will be effective upon posting unless we advise otherwise. We encourage you to periodically review this Cookie Policy for current information about our use of cookies and other tracking technologies.

Effective date: May 24, 2018