Privacy Policy

    M3 USA Corporation, doing business as M3 Global Research ("M3", "we", "us" or "our") grant you permission as a user ("User", "you" or "your") to access and use our sites, software, applications, content, products and services ("Services"), which are owned or licensed by us on the sites www.research.m3.com and www.m3globalresearch.com (collectively, the "Sites"). This Privacy Policy governs your use of the Sites and our provision of the Services on which this policy is posted. PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING ANY M3 SERVICES.

    The privacy of our users on the Internet is of the utmost importance to us. Since M3 and its related network of Sites and Services gather certain types of information about our users, we feel that you should completely understand the conditions and terms surrounding the gathering and use of information about those using our Sites and services. This Privacy Policy Statement divulges what information we gather, how we use it, and how to correct, change, or remove it. The Services made available through M3 may be provided in a variety of media and devices now known or hereinafter developed including mobile applications, and include without limitation news, reference tools, and applications, sponsored programming, personalized content, continuing medical education, communication tools and discussion boards.

    I. YOUR ACCEPTANCE OF THESE TERMS OF USE

    This Privacy Policy and our Terms of Use apply each time you access the Sites or use the Services. When you access the Sites or use the Services, you accept this Privacy Policy and the Terms of Use as if you had signed them, and you consent to our collecting and using your information as described in this Privacy Policy and our Terms of Use. If you do not agree to this Privacy Policy or our Terms of Use, you may not access the Sites or use the Services.

    We may revise or terminate these Terms of Use or our Privacy Policy at any time, without notice to you. You are responsible for reviewing these Terms of Use and our Privacy Policy regularly. Your access of the Sites or use of any of the Services following the posting of changes to these Terms of Use or our Privacy Policy means you agree to abide by those changes. Any questions regarding our Privacy Policy or Terms of Use should be directed to M3 at privacy@usa.m3.com.

    This Privacy Policy was last revised on March 21st, 2017.

    II. INFORMATION WE COLLECT VIA OUR SITES

    Information We Collect from Unregistered Visitors

    You must register to access our full Services; however, you may be able to access certain limited areas of the Sites without disclosing any personally identifiable information. We will collect non-personally identifiable information, i.e. information that is not traced back to any individual and is not used on its own to identify an individual.

    Even if you have not registered, M3 will collect such data including: the referring website, if applicable, the type of browser you use, the time and date that you accessed the Services, the pages you visited and viewed throughout our Sites, and what computers responded to a market research survey.

    Taken in aggregate, this information enables us to better develop and fund the Services, provide content, and respond to our users’ needs. We will explain how this is done in the "Information Collected through Tracking Technology" section of this Privacy Policy.

    Information We Collect from Registered Users

    Account Registration: You must register to access our full Services. When you register for the Services, you are asked to provide identifying information such as your name, email address, zip code and other professional information, e.g. specialty and profession. Additional information may be requested, which may be required to access some Services. We may collect additional information about registered users from third party sources to assist us in providing the Services. For example, we may use such third party sources to verify and update registration information and confirm licensure status.

    Information We Collect through Services We Offer

    Market Research: Registered users of the Services may opt-in to receive offers to participate in market research studies offered by M3. From time to time, registered users may also be invited to participate in a sponsored or unsponsored market research study through an email invitation, on-site popup or some other means. In order to participate in any such survey, you will be required to agree to additional terms and conditions as part of the opt-in process.

    Furthermore, in addition to providing your responses to the survey questions you may be asked to provide personally identifiable information that may be combined with information that you have already provided at registration or that we have received from a third party source. These studies are intended to give specific anonymous feedback to third parties as described in the "IMPORTANT INFORMATION ABOUT CONSENT" section of this Privacy Policy.

    Reporting Compensation and Tax Information: If you participate in a survey that pays compensation, M3 may have an obligation to report such payments. By participating in a market research survey, you are permitting us to disclose your earned compensation as appropriate to comply with all laws and other reporting requirements. In addition, IRS regulations prevent us from paying individuals in excess of $600 in any given tax year without valid tax information. If tax information is not provided within 12 months after completing a survey, compensation above $600 in any tax year is forfeited.

    Additional Forms and Emails: We may also ask you to provide additional information after you register if you want to obtain additional services or information, or to resolve complaints or concerns.

    III. INFORMATION COLLECTED THROUGH TRACKING TECHNOLOGY

    M3 collects information about your activity on the Sites using technologies such as cookies, including third-party cookies, web beacons and server log files.

    Usage Tracking
    M3 uses traffic analysis software on our servers to track user traffic patterns throughout the Services. M3 uses this data to break down overall usage statistics according to IP address, domain name, browser type, and MIME type by reading this information from the data automatically sent by the browser whenever a web page is requested. Additionally, solely in connection with your voluntary participation in a market research study or screening, your computer may (i) be tracked by digital fingerprinting or watermarking to help ensure unique responders to a survey, and (ii) accessed to assess browser compatibility and/or video cam usability.

    Cookies
    A cookie is a small text file placed in your computer’s browser to store your preferences. A cookie can be accessed only by the server that originally created the cookie. A cookie cannot store or send back any information to us that you have not specifically and voluntarily provided while on a Site, or that is not among the information mentioned above that is contained in every user’s browser (e.g., domain name, browser type). Cookies do not contain personally identifiable information; however, once you choose to furnish a Site with personally identifiable information, this information may be linked to the data stored in the cookie.

    M3 uses cookies to monitor and manage Service development and delivery, and potentially to permit greater personalization of the Service based on your preferences and specifications. We may assign cookies to devices that access our Services to help us dynamically generate content to users of the Services.

    Web Beacons
    M3 and our third party business partners may also use "web beacons" or clear .gifs, or similar technologies, which are small pieces of code placed on a web page, to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

    We and our third-party business partners use the information automatically generated by cookies and web beacons, as well as other information that we or they have, to provide you with an optimal website experience.

    At this time, the Sites do not recognize automated browser signals regarding tracking mechanisms, which may include "do not track" instructions. However, you can change your privacy preferences regarding the use of cookies and similar technologies through your browser. You may set your browser to accept all cookies, block certain cookies, require your consent before a cookie is placed in your browser, or block all cookies. If your browser is set to block cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser will tell you about your options for managing your cookies.

    IV. HOW WE USE INFORMATION WE COLLECT

    We retain and use the information we collect about you as follows:

    • To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, and for other customer services purposes.
    • To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Site or Services.
    • To understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and the Services and respond to desires and preferences.
    • To personalize content.
    • As necessary to comply with our legal obligations, resolve disputes, enforce our agreements (including this Privacy Policy and the Terms of Use), to protect or defend our rights, to investigate, prevent, or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the safety of any person.
    • We may also use aggregate or de-identified information about users for other marketing, research and other purposes as further described in the "INFORMATION SHARING AND DISCLOSURES" section of this Privacy Policy.

    V. INFORMATION SHARING AND DISCLOSURES

    Except as described in this Privacy Policy or as specifically agreed to by you, we will not disclose to any third party personally identifiable information we gather from you through the Sites.

    "No-Spam" Policy
    Your email address will not be sold to a third party if you sign up to be included on our email distribution list. You may opt out or unsubscribe at any time.

    Aggregate Data
    We aggregate data from registered and unregistered users for use in Service funding, analysis, development and delivery. Aggregate usage information provided to third parties or used to deliver services to third parties allows us to keep our services free to users. Aggregated information is pooled from many individual records and stripped of any data that could be used to identify an individual. Information collected in the registration process is never shared with third parties in a personally identifiable way, except as identified in this Privacy Policy.

    Third Parties
    In addition to aggregate information, we may share some kinds of personally identifiable information with third parties as described below.

    Market Research Studies: From time to time, we may invite you via e-mail to participate in sponsored or unsponsored market research studies. When you agree to participate in a study, you agree to share with M3 personally identifiable information, such as your name, email address, zip code and professional information. Generally, these studies provide specific feedback using aggregated, de-identified data to third parties used to analyze trends and statistics for medical marketing, research, and development purposes, and neither your identity nor your specific feedback is shared with third parties. However, under the following circumstances, your identity may be shared with third parties and/or associated with specific feedback: (i) when we have your consent, (ii) when we match user information with such third party’s data, and (iii) when we believe in good faith that the law requires it. In all circumstances, the privacy of our panel members is protected, and if such sharing is permitted or required, your answers and identity will remain confidential. Please review the "IMPORTANT INFORMATION ABOUT CONSENT" section of this Privacy Policy for additional information.

    In participating with our studies, you have the option to provide us with information that you report about yourself through our surveys ("Self-Reported Information"). For example, you may provide us with information about your ethnicity, disease conditions (e.g. Type 2 Diabetes), other health-related information related to the objective of the study.

    Affiliated Companies: M3 and its affiliates are part of the M3, Inc. group of companies that provide Internet services for physicians and other healthcare professionals around the world (collectively, "Affiliates"). M3 may share your personal information with Affiliates, which may use your personal information to send you emails about services they provide, new programs and selected information from their sponsors as it relates to your specialty or area of clinical practice.

    Companies Who Work with Us: From time to time, we contract with third parties to help us provide or improve our services. For example, we may hire consultants who help us prevent fraud and violation of our terms of service, analyze data, provide marketing assistance, or provide customer service or fulfillment services. In order to provide these services, these third parties may have limited access to some of the personally identifiable information we maintain about users of our Services. We require all such parties to comply with the terms of this Privacy Policy, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us.

    VI. IMPORTANT INFORMATION ON CONSENT

    Consent to the Use of Sensitive Information
    Certain Services may request personal and sensitive information, such as information about your health and self-reported information such as racial, ethnic origin, sexual orientation, and current medical conditions. If you elect to provide such information, you consent to it being used by us to:

    1. Analyze and provide you with our Services;
    2. Determine whether you would be suitable to take part in surveys, polls or questionnaires that we are conducting;
    3. Perform research activities for the surveys in which you participate in;
    4. Monitor and improve existing products or services that we offer or to develop new products and services.

    We will not use your sensitive information without your consent unless: (i) the information has been anonymized or aggregated so that you cannot reasonably be identified as an individual; or (ii) a legal obligation requires us to use it in some way (e.g. a court order requires us to disclose the information).

    Consent to the Transfer of your Personal Information

    1. By using the Sites, you consent to the storing and processing of your personal information, including sensitive information (if applicable), in the USA and countries outside of the country you live in. We use a range of measures to safeguard information but these countries may have laws that are different from those of your country of residence. You also consent to your personal information, including sensitive information (if applicable), being transferred in the event of a business transition such as a merger, acquisition by another company, or other transaction or proceeding. In such a case, your information would be used as set out in any pre-existing Privacy Statement.
    2. We will not disclose or sell your individual-level information (i.e., information about a single individual's diseases or other medical information) to any third-party or to a third-party for research purposes without your explicit consent.
    3. We may share anonymized and aggregate information with third-parties; anonymized and aggregate information is any information that has been stripped of your name and contact information and aggregated with information of others or anonymized so that you cannot reasonably be identified as an individual.
    4. We will use your information and share it with third-parties for scientific research purposes only if you indicate your consent on the "Consent Checkbox" on your account setup page. Note that we will disclose your individual-level information only if we obtain additional explicit consent from you.
    5. If you have any questions about our privacy practices, please email us at privacy@usa.m3.com or send a letter to the address provided in the "Contact Information" section located at the bottom of this Privacy Policy.

    Using information with your consent
    You have the choice to participate in M3 market research by providing your consent. M3 market research may be sponsored by, conducted on behalf of, or in collaboration with third-parties, such as non-profit foundations, academic institutions or pharmaceutical companies. M3 market research may study a specific group or population, identify potential areas or targets to conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care. M3 uses your aggregate Self-Reported Information as specified in this Privacy Policy.

    Consent process for research
    Your Self-Reported Information may be used for market research only if you have consented by checking the consent checkbox during your registration. If you’ve signified consent by checking this checkbox on the application page, M3 USA may use all Self-Reported Information for research purposes. When your Self-Reported Information is being used for market research purposes, it will not be linked to your personal identifiable information (Account Registration Information).

    Withdrawing your Consent
    You may withdraw your consent to participate in market research at any time by changing your consent status on your Account Settings page, or by sending a request to the Privacy Administrator at privacy@usa.m3.com. M3 will not include your Self-Reported Information in new market research occurring after 30 days from the receipt of your request. Any market research involving your data that has already been performed prior to our receipt of your request will not be reversed, undone, or withdrawn. You may also discontinue your participation in market research by closing your account. If you withdraw your consent for market research your Self-Reported Information may still be used by us and shared with our third-party service providers to provide and improve our Services and shared as Aggregate Information that does not identify you as an individual.

    VII. ACCOUNT MANAGEMENT

    Accessing and Modifying your Account Information
    If your Registration Information changes, you may access, correct or update most of it from your Account Settings page. You may also modify and delete certain of your information, or update your consent status. You may be able to view your self-reported information entered into a survey, form, or feature from your account on the surveys page. Please note that you may not be able to delete certain user content that has been shared with others through the Service and that you may not be able to delete information that has been shared with third-parties, though we can work with you to prohibit your data from being shared with third-parties in the future. We will respond to your request to access within 30 days.

    Upon request M3 will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information; or, for assistance on correcting or updating or receiving a copy of your data please send a request this information please contact us at privacy@usa.m3.com.

    Account Closure and Erasure
    If you no longer wish to participate in our Services or no longer wish to have your personal information be used, you may close your account by sending a request to the Privacy Team at privacy@usa.m3.com. When closing an account, we remove all Personal Information within your account (or profile) within thirty (30) days of our receipt of your request. Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in M3 USA Research cannot be removed from ongoing or completed studies that use the information. In addition, we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) as long as your account is active or as needed to provide you services, as well as for accounting, audit and compliance purposes.

    Information Processing Preferences
    If, at any point, you decide to change or limit the extent of processing of your personal information, you can contact our Privacy team; refer to Contact Information below for contact details. We will respond to your request to access within thirty (30) days.

    Notification of Preference Changes
    Upon modification or erasure of your personal data, we will communicate the changes with each recipient to whom your personal data have been disclosed. We will inform you about those recipients if requested.

    Data Portability
    You always have the option to review your personal information you’ve shared with us on your account profile page including past surveys, survey statuses, and compensation information. In addition, you may ask to receive a copy of this personal information; you may also request to have this data transmitted to another company. Please note, to protect the confidentiality of our users, we may verify your identify prior to transmitting this data.

    Right to Object
    As a user of our Services, you have the right to object at any time to the processing of your personal information and any direct marketing that you receive based on your personal data.

    Opt Out
    M3 engages with users who register on our Sites and elect for e-mail communication. For example, we may use your email address to send newsletters or discussion group updates, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law.

    We provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from us, such as emails or updates from us regarding new services and products offered on the Sites or if you do not want us to share your personally identifiable information with third parties.

    Users always have the opportunity to "opt–out" or change preferences via a link in the footer of all non–transactional email messages or by accessing the "My Account" page on the registered site. These options are made available in email messages delivered from our company. Alternatively, you may request to have your personal information modified or removed from our databases by sending a request via email at privacy@usa.m3.com or by fax to 202-293-1690, including your first and last names and email address with which you originally registered.

    Please note that you may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.

    VIII. IMPORTANT SECURITY INFORMATION

    Legal Requirements
    We may release account and other personally identifiable information when we believe release (1) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) is reasonably necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Privacy Policy, or as evidence in litigation in which we are involved. In the event that we are legally compelled to disclose your personally identifiable information to a third party, we will attempt to notify you unless doing so would violate the law, court order or government instruction.

    Joint Data Controller
    For the purposes of this Privacy Policy, M3 USA Corporation is considered a joint data controller with M3 (EU) Ltd. Contact information can be found below.

    Business Transactions
    In the event of a change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale or assets or a bankruptcy, M3 shall have the right to transfer all personal information collected through the Services to the acquiring party. In the event of such change, your personal information will continue to be treated in accordance with this Privacy Polity until such time as any changes to the Privacy Policy are set forth herein.

    Security of Information
    M3 USA takes information security seriously. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, M3 uses a range of physical, technical, and administrative measures to safeguard your Personal Information. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.

    Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password authentication information you use to access our Services. You should not disclose your authentication information to any third-party and should immediately notify M3 of any unauthorized use of your password. M3 cannot secure Personal Information that you release on your own or that you request us to release.

    Your information collected through the Service may be stored and processed in the United States or any other country in which M3 or its subsidiaries, affiliates or service providers maintain facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.

    Children's privacy
    M3 USA is committed to protecting the privacy of children as well as adults. Neither M3 nor any of its Services are designed for, intended to attract, or directed toward children under the age of 18.

    Data Retention
    We will retain your information for as long as your account is active or as needed to provide you with our services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at privacy@usa.m3.com. In addition, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

    IX. PRIVACY SHIELD COMPLIANCE

    M3 Global Research complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. M3 Global Research has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

    M3 Global Research is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. M3 Global Research complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

    M3 Global Research submits to being subject to the investigatory and enforcement powers of the FTC, the Department of Transportation, or any other U.S. authorized statutory body with regards to our self-certification and implementation of the Principles, and acknowledges the right of the EU or Swiss individual, under certain conditions, to invoke binding arbitration, at no cost to the individual, in filing a complaint disputing M3's adherence to these practices.

    Independent Dispute Resolution Mechanism
    In compliance with the Privacy Shield Principles, M3 Global Research commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union and Switzerland with inquiries or complaints regarding our Private Shield policy should first contact M3 Global Research, refer to our Contact Information section below.

    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.

    In addition, you may lodge a complaint to a supervisory authority if you consider that your personal data has been processed in breach of applicable legislation or this privacy policy; refer to the following link for a complete list of Data Protection Authorities (http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm)

    X. CONTACT INFORMATION

    If you have questions about this Privacy Statement, please email M3’s Privacy Administrator at privacy@usa.m3.com, or send a letter to:

    Privacy Administrator
    M3 USA Corporation
    501 W. Office Center Drive; Suite 410
    Fort Washington, PA 19034
    (202) 293-2288

    M3 EU Contact information can be located here (https://eu.m3.com/Contact)

    Please refer to our Privacy Shield profile on the Privacy Shield Website for specific details regarding our direct contact details at M3 USA’s Privacy Shield profile

    For all other questions regarding your account, preference changes, or our services, please e-mail support@m3globalresearch.com