Privacy Notice - Springer Healthcare Limited
This is the privacy notice (“notice”, “policy”) for the website which is run and provided by Springer Healthcare Ltd, The Campus, 4 Crinan Street, London N1 9XW; email [email protected] (we, us and our).
We will only use the personal data gathered over this website as set out in this policy. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.
I. Summary of our processing activities
The following summary provides you with a quick overview of the processing activities that are undertaken on our website. You will find more detailed information under the indicated sections below.
- When you visit our website for informational reasons without setting up an account, only limited personal data will be processed to provide you with access to the website itself (see section III).
- In case you register for one of our services or subscribe to receive communications, further personal data will be processed in the scope of such services (see section IV).
- Furthermore, your personal data may be used to provide you with relevant advertising for related medical education (see section IV) and for statistical analysis that helps us to improve our website (see section V). Additionally, we improve your website experience with third party content (see section VI).
- Your personal data may be disclosed to third parties (see section VII) that might be located outside your country of residence; potentially, different data protection standards may apply (see section VIII).
- We have implemented appropriate safeguards to secure your personal data (see section IX) and retain your personal data only as long as necessary (see section X).
- Under the legislation applicable to you, you may be entitled to exercise certain rights with regard to the processing of your personal data (see section XI).
- Personal data: means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
- Processing: means any operation which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or any kind of disclosure or other use.
III. Informational use of the website
When you visit our website for informational reasons, i.e. without registering for any of our provided services listed under IV and without providing us with personal data in any other form, we may automatically collect additional information about you which will contain personal data only in limited cases and which is automatically recognized by our server, such as:
- the website from which you have been directed to our site from;
- the date and time of your requests;
- your device type, screen resolution and browser version;
- your internet service provider; or
- information on your operating system, including language settings.
We use such information only to assist us in providing an effective service (e.g. to adapt our website to the needs of your device or to allow you to log in to our website), and to collect broad demographic information for anonymized, aggregated use.
The personal data automatically collected is necessary for us to provide the website, Article 6 sec. 1 sent. 1 lit. b GDPR, and for our legitimate interest to guarantee the website’s stability and security, Article 6 sec. 1 sent. 1 lit. f GDPR.
IV. Registration for our services
1. Communicating with us
Our websites offer medical news and educational content. In order to access the aforementioned content, you may have to submit your contact information. With regard to the submission of your contact details and its subsequent use, we may process:
- your email address;
- your specialty and main area of work;
- your National Provider Identifier (NPI) number or other relevant prescribing numbers;
- Information (such as your name) that is provided through contact forms and email to us; or
- Communications sent by you (e.g. via e-mail or website communication forms).
We will process the personal data you provide to:
- provide you with the services and information offered through the website or which you request; or
- communicate with you regarding your request.
For this, the legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR
The use of your personal data for behavioral advertising and profiling is done for the legitimate interest to improve your experience while using the website, Article 6 sec. 1 sent. 1 lit. f GDPR.
We use the personal data and contact data you provide by sign-up or registration to inform you directly about medical education programs and websites.
The use of your personal data for directly advertising related products and services is a legitimate interest for us as a provider of this website, Article 6 sec. 1 sent. 1 lit. f GDPR.
Affiliated companies of Springer Healthcare Ltd are based in countries outside of the EU which may not provide the same level of data protection as countries in the EU.
You can object to the use of your personal data for direct marketing at any time. We will then refrain from any processing to the extent it is related to such purposes. You can inform us about your objection by contacting us at Springer Healthcare Ltd, The Campus, 4 Crinan Street, London N1 9XW email [email protected]
2. Access to sponsored content
Our website offers microsites providing access to sponsored content, e.g. to congress videos. To be able to access the videos you need to register providing the data:
- your name;
- your address;
- your degree and a speciality description; and
- your National Provider Identifier (NPI) number or other relevant prescribing numbers.
We will process the personal data you provide to:
- check your eligibility for access to the content; where content is restricted to specific professional groups this is clearly stated in the registration form;
- provide you with the services and information offered on the microsite;
- communicate with you regarding your request; or
- fulfil our legal obligations regarding any mandatory reporting e.g. if access to the content is subject to ToV reporting under the US Sunshine Act of 2021.
For this, the legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR
1. General information about the analysis
For our statistical analyses, we use web analysis services that collect data on the use of this site and our apps.
The analysis services collect information such as:
- Information on the device and browser (device type, operating system, browser version);
- IP address;
- Websites viewed, URL click stream (order in which the pages were viewed);
- Geographical location;
- Date and time of the website visit; and
- Reference page, application, or service;
We only use the information provided by the providers to determine the most useful information for you and to improve and optimize our website and apps. The information collected with the help of the analysis services is not linked to personal data.
Depending on the provider, the data generated about your use of our website and apps may be stored in a country outside the European Economic Area (EEA) and processed there, e.g. B. the United States. Further information on the potential risks of cross-border data transfers can be found under XII. The analysis services only collect the IP address that is assigned to you when you visit this website, but not your name or other identifiers. The provider uses this information to evaluate your use of the website and apps, to compile reports on website usage and to offer us other services relating to the use of the website and apps and the internet.
The legal basis for this processing is Art. 6 Paragraph 1 Clause 1 lit. f GDPR. The processing is based on our legitimate interest in evaluating the data traffic on our website and in our apps to increase your user experience and to generally optimize the website and apps.
2. Google Analytics / Google Tag Manager
We use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). On our behalf Google will use the information generated by a cookie for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet activity in connection with the use of the website.
We have activated the IP-anonymization within the Google Analytics service, and your IP address will be truncated within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The IP-address your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google.
VI. Third party content and social media plug-ins
You can view a full list of third party content and social media plug-ins in use on this/these website(s) by selecting “Manage cookies/Do not sell my data” in the website footer.
Links to third party websites
VII. Information sharing
Your personal data will only be disclosed to a third party to the extent necessary to fulfill our contractual relationship. Legal basis for the transfer of your personal data is Article 6 sec. 1 sent. 1 lit. b and f GDPR and represents our legitimate interest to implement our general terms and conditions of business or any other agreements concluded with you.
Some of the recipients mentioned above reside outside the EEA. For further information about cross border transfer in general and transfers outside of the EEA see VIII.
We may disclose anonymous aggregate statistics about users of the website in order to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personal data.
In the event that we undergo re-organisation or are sold to a third party, any personal data we hold about you may be transferred to that re-organized entity or third party in compliance with applicable law.
We may disclose your personal data if legally entitled or required to do so (for example if required by law or by a court order).
VIII. Cross border data transfers
Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards from your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to maintain an adequate level of data protection when sharing your personal data with such countries.
In the case of a transfer to a country outside of the EEA, this transfer is safeguarded by EU Standard Contractual Clauses. You can find further information about the aforementioned safeguards under:
https://ec.europa.eu/info/law/law-topic/data-protection_en or by contacting the Data Protection Team at [email protected].
We have reasonable state of the art security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our website whilst it is in transit over the internet and any such submission is at your own risk.
X. Data retention
We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfill the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.
XI. Your rights
Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:
- require (i) information as to whether your personal data is retained and (ii) access to and/or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods;
- request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
- refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;
- object, on grounds relating to your particular situation, that your personal data shall be subject to a processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing;
- take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators;
- require (i) to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller; and/or
- not to be subject to any automated decision making, including profiling (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or affects you with similar significance.
You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us using the contact details set out below.
XII. Contacting us
XIII. Amendments to this policy