Effective as of May 4, 2021, PromptusMed, Ltd. (“PromptusMed”), and its subsidiaries (collectively, the “PromptusMed Group” or “we” or “us” or “our”), Privacy Policy (“Policy”).
This Policy details our commitment to protecting the privacy of individuals who:
For the purposes of this Policy, the term “Websites” shall refer collectively to www.promptusmed.com as well as the other websites that the PromptusMed Group operates and that link to this Policy. This Policy describes how the PromptusMed Group collects, uses, shares and secures the personal information that you provide. It also describes your choices regarding use, access and correction of your personal information.
For the purposes of this Policy, the term “Subscriber” means an individual or an entity that has entered into a Service Agreement (defined below) for use of our Services.
In addition to the Websites that link to this Policy, this Policy applies to the following:
Our Websites may contain links to other websites. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.
With the exception of Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with electronic data, text, messages, communications or other materials submitted to and stored within the Services by you (“Service Data”). Service Data security and privacy practices are detailed in and governed by the respective Subscription Agreement, or such other applicable agreement between you and any member of the PromptusMed Group relating to your access to and your use of such Services (collectively referred to as the “Service Agreement”).
Subscribers to our Services are solely responsible for establishing policies for, and ensuring compliance with, all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as “data subjects”) with whom our Subscribers interact.
We collect information under the direction of our Subscribers, and have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. The use of information collected through our Services shall be limited to the purpose of providing the service for which Subscribers have engaged a member of the PromptusMed Group. If you are an individual who interacts with a Subscriber using our Services (such as a customer or user of one of our Subscribers) and require assistance or would either like to amend your contact information or no longer wish to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.
We ask for and may collect personal information about you such as your name, address, phone number, email address, and instant messaging ID, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account (an “Agent” or “End-User” as defined in the Service Agreement). We base the processing of your personal information on our legitimate interest, to provide you with the necessary functionality during your use of our Service(s).
We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.
We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including: participation in webinars, surveys, contests, promotions, requesting customer support, or otherwise communicating with us. We process your personal information to perform our contract with you for the use of our websites and the Service(s) and to fulfill our obligations under the Service Agreement to you; where we have not entered into the Service Agreement with you, we base the processing of your personal information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request.
We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of the PromptusMed Group participates, in order to facilitate your registration or attendance at an event, including sending related communications to you.
When you or your Agents download and use our Services, we automatically collect information such as the type of device you use, the operating system version of the device, the cellular carrier facilitating connection to the mobile application, and the country the connection is arising from, to perform our obligations under the Subscription Agreements with our Subscribers.
We and our authorized partners may use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites. For detailed information about the use of cookies on our Websites and how to manage your cookie settings, please read and review our Cookie Policy found here.
We may use web beacons, tags and scripts on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.
We collect analytics information when you use the Websites to help us improve them, including through the use of cookies. We may also share aggregated and/or anonymized data about your actions on our Websites with third-party service providers of analytics services. We also use mobile analytics software to allow us to better understand the functionality of our mobile versions of our Services on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
We may use the information we collect about you (including personal information, to the extent applicable) in order to perform our obligations under our Service Agreement with you and on the basis of our legitimate interest including to (a) provide, operate, maintain, improve, and promote the Websites and the Services; (b) enable you to access and use the Websites and the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners (you can opt-out of receiving marketing communications from us
by, sending an unsubscribe request email to marketing@promptusmed.com, providing
the names/email address(es) that you would like removed from our marketing databases and added to our ‘Do Not Contact’ list” or following the unsubscribe instructions included in our marketing communications); (f) process and deliver contest entries; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for research, marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features that match your interests and preferences; and (j) for other purposes for which we obtain your consent.
If you are a visitor from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.
However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your personal information. If we process personal information in reliance on your consent, you may withdraw your consent at any time.
If you have questions about, or need further information concerning, the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.
We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
We may also share aggregated and/or anonymized information regarding your use of the Services with third parties, for marketing or research purposes, based on our legitimate interest to develop and promote Service(s). However, we would never identify you, your Agents or End-Users as the source of the information.
We may collect, and we may engage third-party analytics providers to collect, metrics and information regarding your use of the Service, including evaluating how Agents and End-Users use the Service (“Usage Data”), to develop new features, improve existing features or inform sales and marketing strategies, based on our legitimate interest to improve the Services. When we process Usage Data, any personal information shall be anonymized.
Any such third-party analytics providers will not share or otherwise disclose Usage Data, although we may make Usage Data publicly available from time to time.
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.
We may share information, including personal information, with any member of the PromptusMed Group, and they will use that information only for the purposes already described in this Policy.
We may share information, including personal information, with our channel partners, solely for the purpose of enabling our channel partners to notify you about our Services. PromptusMed requires its channel partners to provide an opt-out option within its communications to you. By opting out, you are opting out of receiving future communication from our channel partner.
We may also share personal information with third parties when we have your consent to do so.
If you are a Subscriber to our Services, you agree that you are responsible for notifying your customers using our Services about how the PromptusMed Group may use your customers’ personal information as described in this Policy and for obtaining prior consent from your customers to disclose their personal information to us.
PromptusMed is both a “business” and a “service provider” under the GDPR and LGPD. The following supplemental privacy policy applies to information we collect in our role as a business—this is when we interact directly with you.
When we act as a service provider (for example, by providing our services to another company or orgnisation that you interact with), we follow the instructions of the business that engaged us with respect to how we process your personal information. If you would like more information about how your personal information is processed by other companies, including companies or organisations that engage us as a service provider, please contact those companies or organisations directly.
We may collect the following categories of information:
For each category of information, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, and/or from third party providers. We collect the information to provide you with services, protect our customers and ourselves (including the services), and to improve the services. We do not share personal information with Third Parties as the term is defined under the GDPR or LGPD.
Our Services are intended for use by public or private organisations. Where our Services are made available to you through a Subscriber of ours, that entity is the data controller of your personal information. Your data privacy questions and requests should initially be submitted to the PrmptusMed Subscriber in its capacity as your data controller. PromptusMed is not responsible for our Subscribers’ privacy or security practices which may be different than this Policy.
Where PromptusMed is the data controller of personal information (for example, personal information relating to Website Visitors, Attendees and individuals who register to use our Services), then we retain the personal information we collect where we have an ongoing legitimate business need to do so (for example, to provide you with our Services, to enable your participation in an event, and to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or aggregate it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If your personal information is processed within a Subscriber’s Service Data, we will process the personal information for as long as we are instructed to do so by the relevant Subscriber that is the data controller of the Subscriber Service Data.
An individual who seeks to exercise their data protection rights in respect of personal information stored or processed on behalf of a Subscriber of ours within the Subscriber’s Service Data (including to seek access to, or to correct, amend, delete, port or restrict processing of such personal information) should direct his/her query to our Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the personal information, we will respond to their request within thirty (30) days. We will retain personal information that we process and store on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers.
Our Services give Agents and End-Users the ability to access, update and delete certain personal information from within the Service. For example, you can access your Agent or End-User profile and make updates to your personal information. In cases where we act as the data controller of your personal information, we will provide you with information about whether we hold any of your personal information upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
If you no longer wish to use our Services, PromptusMed’s Subscriber may be able to deactivate your End-User account. First, please contact PromptusMed’s Subscriber with your request. If you are a PromptusMed Subscriber and are unable to deactivate an End-User account through your administrator settings, please email support@promptusmed.com.
Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Services. Some Service Data is anonymized and used by PromptusMed Group members or their partners.
This anoymized data is used for research purpose and service improvement and development. For more information on how we use anonymized Service Data, please refer to the Service Agreement.
You may request that your personal information no longer be accessed, stored, used and otherwise processed where you believe that a PromptusMed Subscriber or PromptusMed do not have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this Policy. Where you gave us consent to use your personal information for a limited purpose, you can contact us to withdraw that consent. You can also opt-out of our use of your personal information for marketing purposes by contacting us, make a withdraw consent request to privacy@promptusmed.com. When you make such requests, we may need time to investigate and facilitate your request.
Please note that an End-User of a PromptusMed Subscriber should first contact PromptusMed’s Subscriber with a request to stop access, storage, use of personal information. If there is delay or dispute as to whether we have the right to continue using your personal information, we will restrict any further use of your personal information until the request is honored or the dispute is resolved, provided the PromptusMed Subscriber does not object (where applicable).
You may have certain rights with respect to your personal information, including:
If you wish to exercise any data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to privacy@promptusmed.com and we will respond to your request in accordance with applicable data protection laws.
Please be as specific as possible in relation to the personal information you wish to access. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We will respond to your request within 45 days of receipt, or notify you if we require additional time.
If you would prefer, you may designate an authorized agent to make a request on your behalf.
You have the right to complain to your local data protection authority if you are unhappy with our data protection practices. Contact details for data protection authorities in the European Economic Area are available here.
We do not knowingly collect any personal information from children under the age of 16. If you are under the age of 16, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Websites or Services, please contact us at privacy@promptusmed.com, and we will use commercially reasonable efforts to delete that information.
We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to handle your personal information in accordance with this Policy.
Personal information collected, stored, used and/or processed by the PromptusMed Group, as described in this Policy, is collected, stored, used and/or processed in accordance with Brazilian Law No. 13,709/2018, as amended (LGPD). Those individuals who use or access our Website or Services expressly consent to the collection, use, storage and processing of their personal information by us for the purposes described in this Policy.
We do not sell personal information of any individual, including personal information of minors under 16 years of age.
This Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.
If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective.
If you do not accept any changes made to this Policy, please discontinue use of the Websites and the Services.
If you have questions or complaints regarding this Policy or about the PromptusMed Group’s privacy practices, please contact us by email at privacy@promptusmed.com.
Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
A Portuguese version of this policy can be found here.
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