Updated May 2018.
Symplur is committed to protecting the privacy of our users (“user”, “you” or “your”).
Who does this policy apply to?
This policy applies to:
- visitors to our Websites (“Website Visitors”);
- individuals who register to use the products and services which we market for subscription (the “Service(s)”);
- individuals who sign up to receive newsletters and other updates about Symplur products and services;
- individuals who are third-party content authors of social media content (“Social Media Authors”),
For the purposes of this Policy, the term, “Site(s)”, shall refer collectively to www.symplur.com as well as the other websites that we operate and that link to this Policy.
- your use of our Site and/or Services;
- your interactions with us or our business partners, contractors and suppliers;
- the information we receive regarding Social Media Authors,
as well as to set out the rights you have to control the use of your information, and thereby assist you in making informed decisions when using our Site and Services.
This Policy (and where it relates to our Services; together with our Terms and Conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Important Note for European Users
Information submitted by you will be stored, processed, and used by us and our third party service providers who help us to deliver our services and operate our business.
Who We Are
Symplur is a healthcare social media analytics company that promotes deeper understanding of healthcare by strengthening the voices of those who need to be heard with insights from the Healthcare Social Graph®.
We have offices in the greater Los Angeles region in California, USA. Our headquarters information is listed below in the Contact Us section.
Information We May Collect about You
We may collect and process the following information about you:
Information we collect about you
- Website Visitors and Attendees –
- If you express interest in obtaining additional information about our services or if you sign up with a Symplur Account, we may also collect contact information (such as your name, job title, email address, work mailing address and business telephone number) as well as company information (such as company name, industry, location, annual revenue) that you provide “by completing forms on the Site, including if you download content, register for an event or webinar, upload or submit any material via the Site, submit a request for a demo or ask us for more information;
- We may also collect data about how you interact with messages we send to you, for example; whether you opened an email and how you respond to periodic email and website campaigns;
- We collect information you provide to us through communications you send to us, for example; to report a problem or to submit queries, concerns or comments regarding the Site or its content;
- We may also collect other data directly from you, from time to time.
- Website Visitors and Attendees –
- Customer – In order to provide the Services, we require our customers to provide us with certain contact information (such as company name, contact names, email addresses, mailing address, phone numbers, job titles and Authorized Users of the Services). We may also require financial/billing information (billing name, email address, mailing address, and credit card numbers) from our customers.
- Authorized Users –
- Additionally, we collect user and contact information (such as your name, email address, job profile, title, user permissions and password) about the individuals who are authorized to use our Services on behalf of our Customers (“Authorized Users”). If you are not an administrative user for your account, the same data about you may be provided by a colleague or other third party;
- We collect data about you when you use any part of our Services. For example, if you are logged in to your account, we will collect data as to how often you use the Services, which Services you use, what queries you created or amended, user permission settings and activities, API usage, and other data about how you interact with the Services;
- We may also collect data about how you interact with messages we send to you, for example; whether you opened an email or read an in-app message and how you respond to periodic surveys;
- We collect information you provide to us through communications you send to us, for example; to report a problem or to submit queries, concerns or comments regarding the Services; if you contact our support services, we will collect the data we need to categorize your question and respond to it. We also use this data to track potential issues with our Services and customize our support responses to better serve you;
- We may also require financial/billing information (billing name, email address, mailing address, and credit card numbers) from our customers, which may include Authorized Users’ information;
- We may also collect other data directly from you, from time to time.
- Social Media Authors – Finally, our Services themselves collect, process and store information, that may include personal information, from a variety of publicly available online sources, such as social networking sites, blogs, forums and news websites. This information is sourced only from content that has been made publicly available on the Internet and is used solely to provide our Services. The only parts of this Policy that are applicable to Third Party Content are contained in the Third Party Content and Social Media Authors section below.
It is always your choice whether or not to provide personal information. However, if you should choose to withhold requested information, you may not be able to use certain features of the Site or we may not be able to provide you with certain services.
Information we receive from other sources
Our Lawful Basis
We will only process personal data in a way that is compatible with and relevant to the purpose for which it has been collected. To the extent necessary for those purposes, we will take reasonable steps to ensure that the Information is accurate, complete, current and reliable for its intended use.
EU Users & Data Subjects: Our Lawful Basis for Using Personal Data
The data protection law in Europe only permits processing under certain prescribed lawful bases. For our EU users and data subjects we have been careful to ensure we have a lawful basis for all the personal data we process. Our lawful bases include:
- Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver our products or services to you. For example, if you want to use our products or subscribe to our Service, we need your name and contact details so we can communicate with you.
- Legitimate interests: This is a technical term in data protection law for our commercial interests where these have been weighed against the interests or rights and freedoms of the individual and it has been decided that our interests are not outweighed by those rights and freedoms. We sometimes require your personal data to pursue our legitimate interests in a way which might be reasonably expected as part of running our business and which does not materially impact your interests, rights. For example, we analyze how users interact with our Site and Services so we can better understand which elements are working well and which are not working well.
- Consent: The legal basis for our processing of data may also be where we have your consent (for example where consent is required to send certain marketing communications).
- Compliance with a legal obligation: Sometimes the law says we need to collect and use your data. For example, we may pass on details of individuals involved in fraud or other criminal activity to law enforcement authorities and tax laws require us to retain records of orders and payments for our Services, which can include contact details of individuals within our corporate customers.
We may communicate with you by phone, in writing, via email, or other means available on or through the Site and Services (for example, via pop-up messaging or push notifications). We may communicate transactional or service messages to you, such as welcoming you to our Services or informing you of scheduled downtime. We may also send you marketing communications, as described below.
How Your Information May be Used
We use information held about you for a wide range of purposes, including:
- to provide, operate, maintain, improve, and promote the Site and Services; including any obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to process and complete transactions, and send you related information, including purchase confirmations and invoices; as well as verify and carry out financial transactions in relation to payments you make to us;
- to 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;
- to provide you with information about services, products or programs we feel may interest you, such as new products and services, features, a/b testing opportunities, surveys, newsletters, offers, promotions; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us through the Contact Us options provided below or following the unsubscribe instructions included in our marketing communications. In order to provide our Services to you, you cannot opt out of receiving transaction or service messages from us;
- to administer our Site and Services under our terms and for internal operations, including troubleshooting, account management, and, in our legitimate interests, data analysis, work prioritization, testing, research, tracking users’ movements, and gathering broad demographic information for aggregate use for the improvement of our Site and Services so that we can provide all of our users with a better experience;
- to ensure in our legitimate interests that content from our Site and Services are presented in the most effective manner for you and for your computer;
- as part of our legitimate efforts to keep our Site and Services safe and secure, including to investigate and prevent fraudulent transactions, unauthorized access to the Site and Services, and other illegal activities;
- for our legitimate interest of measuring or understanding the effectiveness of advertising we serve to you and others, and to personalize the Site and Services, including by providing features or advertisements that match your interests and preferences;
- to notify you about changes to our services or policies; and
- for other purposes for which we obtain your consent.
We may combine the information you give to us with the information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive). We may also use data to conduct research and development.
We do not sell or trade personally identifiable information about our Site visitors or our Customers or their Authorized Users.
We may share your personal data with:
- Trusted third parties, including our business partners, sub-contractors, and suppliers who provide services to us (including handling and delivering email communications, newsletters, and website hosting services). These third parties assist us in operating our Site and Services, conducting our business, or servicing you and have agreed to keep this information confidential and use such information only for purposes relating to their services for us;
- Other Users on the Site: From time to time, we may post testimonials on the Site that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us through the Contact Us options noted below;
- Social networking and other websites: the Site or Service may allow you to post information on social networking sites. We do not share your personal data to such websites unless you direct the Site or Service to share it. The use of the information by such social networking sites will be governed by their privacy policies and we do not control their use of shared data;
- Our prospects or customers: If you choose to be a reference to our prospects and customers regarding our products and services, we will obtain your consent to provide your contact information to them. If you wish to update or remove your reference information, you can contact us through the Contact Us options noted below.
We may also share your personal data under the following circumstances:
- Merger, sale, or other asset transfers: As a result of the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, reorganization or liquidation of Symplur. Your personal data may be transferred as part of such a transaction (as one of the transferred assets) as permitted by law and/or contract;
- As required by law: If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements with you; or to protect the rights, property, or safety of Symplur, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and law enforcement purposes;
- With your consent: We may also disclose your information, including your personal information, where you have specifically provided your consent for the disclosure. You may withdraw consent at any time by clicking the unsubscribe link at the bottom of any communication we send to you, or by using one of the Contact Us options noted below.
Marketing Choices (Opt-Out/Discontinue)
Please keep in mind however, that regardless of these preferences regarding promotional contacts,, we may contact you for other reasons connected to the service you request or receive, such as those related to:
- an order for a product or a service you placed;
- an inquiry you made;
- a newsletter you may have subscribed to;
- a legally required notice; and
- any other necessary administrative, service or maintenance notices relating to your subscription or account.
We may also retain a record of any stated objection by you to receiving Symplur updates for the purpose of ensuring we can continue to respect your wishes and not contact you further.
This Site may contain links to third-party websites. These links are provided solely as a convenience to you and not as an endorsement by Symplur of the contents on such third-party websites. Symplur is not responsible for the privacy practices or content of linked third-party sites and does not make any warranty or representation regarding the content or accuracy of materials on such sites. If you decide to access linked third-party websites, you do so at your own risk. Please review the privacy policies of these websites before submitting any personal data to these sites.
If you comment on a blog post on our Sites (“Interactive Area”), you should be aware that any personal data you submit there can be read, collected, or used by other readers of these blogs, and could be used to send you unsolicited messages. We are not responsible for the personal data you choose to submit in these blogs. To request removal of your personal information from an Interactive Area, you may contact us through the Contact Us options noted below. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We place great importance on the security of all personal data associated with our users. We have security measures in place to attempt to protect against the loss, misuse, unauthorized access, disclosure, alteration, or destruction 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. While we cannot ensure or guarantee that loss, misuse, unauthorized access, disclosure, alteration, or destruction 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 the Site, or Services, while it is in transit over the Internet and any such submission is at your own risk.
You are responsible for maintaining the confidentiality of any user name or password that you use. It is advisable to logoff the Site or Service and close your browser when you have finished your user session to help ensure others do not access your personal data.
Storage and Transfers of Your Information
Your personal data which we collect is sent to and stored on secure servers located in the United States. Such storage is necessary in order to process the information. Personal data submitted may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information Sharing), which may be situated outside the European Union (EU) and may be processed by staff operating outside the EU. Where we transfer your personal data, we will take all reasonable steps to ensure that your privacy rights continue to be protected.
Retention and Deletion of Personal Data
We will only keep your personal data as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements. We may need to retain certain personal data even once the purpose of using data under this Policy has been completed to enforce our terms, for fraud prevention, to identify, issue, or resolve legal claims, for proper record keeping purposes and/or as required for our business operations, or by applicable laws. We may retain certain information beyond this time for historical or statistical research purposes. We may also retain a record of any stated objection by you to receiving our updates for the purpose of ensuring we can continue to respect your wishes and not contact you further.
Your Rights (EU Users)
Under the General Data Protection Regulation (GDPR), individuals located in the EU have the right under certain circumstances:
- to be provided with a copy of their personal data held by us;
- to request the update, correction, or erasure of any of their personal data held by us;
- to object to any further processing of their personal data, including the right to object to marketing communications;
- to request that we restrict the processing of their personal data;
- to request that the data they have provided be transferred to a third party; and
- to withdraw consent: where the basis of processing their personal information is based on consent, they have the right to withdraw that consent at any time.
You can exercise the rights listed above at any time by contacting us at email@example.com or through the Contact Us options noted below.
You will not have to pay a fee to access your data or to exercise any other rights. We may, however, charge a fee if we believe your request is unfounded or excessive.
We may need to request specific information from you to enable us to confirm your identity and to ensure that you have the right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request, in order to process your request.
We aim to respond to all legitimate requests within 30 days. Occasionally, it may take us longer than 30 days to process your request pending the extent and complexity of your request. In this case, we will notify you and keep you updated.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (see http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html) that can provide further information about your rights and our obligations in relation to your personal data. In the UK, this is the Information Commissioner (https://ico.org.uk/).
Third Party Content and Social Media Authors
Symplur receives personal data from third parties, such as Twitter, and other online public blogs and forums. We are required to comply with our contract with them or their public terms and conditions.
- Our Services collect, use, process and store information that has been made publicly available on the Internet (“Third Party Content”). In general, the Third Party Content can be found using a standard Internet search engine or by visiting the applicable websites directly. We do not have any ownership interest or control over the Third Party Content or any direct relationship with those persons who post such Third Party Content. We obtain Third Party Content through agreements with certain data providers, who either have a direct relationship with Social Media Authors or who search and index publicly available information (including data) from the Internet. We do not attempt to gain unauthorized access to any information and do not circumvent any passwords or other technology protections. We only gather Third Party Content that is made available to the public by the site or by the individual Social Media Author.
- Our Services provide analytics that allow our customers to aggregate and analyze the Third Party Content. Our Services may also be used by our customers to collect certain personal information about individual Social Media Authors and their online activities, such as interactions with a customer’s website and/or in relation to a customer’s products and services. We require our customers to comply with all applicable legal requirements in using the Third Party Content, including any applicable privacy laws.
Information we collect about you
The data we collect varies depending on the source of the data, what the source or platform chooses to make available to us, and what you choose to make publicly available. It could include the following:
- your name, username, handle, or other identifier;
- the content of the information you have published via that name, username, handle, or other identifier, including comments, expressions, opinions, posts, etc.;
- your profile picture or other images or videos that you post or interact with;
- your job title or profession (including category of profession, for example “journalist”);
- your interests;
- your location;
- any other information you publish on an Internet website we search or on a third party platform that provides us with data.
In addition to the data you make available about yourself, we may also use that information to infer other data about you in the context of a wider conversation. For example, based on your name, we may infer your gender and use it in an aggregated display as part of our Services. Equally, based on the content of one of your posts, we may infer some of your interests, your profession, your location, etc.
We may also analyze the content of the data you publish and provide our analysis to our customers. For example, if you publish a Tweet stating that you like a certain conference, we may mark that Tweet as having a positive sentiment toward that conference.
Uses of the Information We Collect about You
The legal basis for the data that we process is pursuant to our legitimate interests. Our legitimate interests are in providing our Services to our customers, which includes providing technology that empowers our customers to act with more certainty in a way that is easy-to-access and use.
Additionally, your information is used in the following ways:
- Allow our customers to learn more about their brand, their customers, their competitors, and other information available on the social web that is relevant to our customers;
- In ways related to, but ancillary, to the Services that we offer. For example, we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties;
- We may also use the data to improve our Services.
Although it is the responsibility of our customers to use our Services properly, we do put in place safeguards to protect your data. We require our customers to comply with applicable law, including data privacy law, when using our Services. We also prohibit our customers from using our Services, including your data, in a way that is outside of your reasonable expectations.
When we infer data about you, we do so automatically. The inferences are based on algorithms that analyze the data that you have posted. We do not make any decisions about you based on the data that we process about you (inferred or not). In other words, we only make the data available to our customers. It is up to our customers what (if anything) to do with the data and any inferences about the data.
We will only process data about you which may be deemed sensitive or part of a special category under data protection law which has been made public and available to us by virtue of it being public.
Sharing your data
In addition to sharing your data with our Customers, we may share your data as described in the Information Sharing section (with the exclusion of Site testimonials and prospect or customer references) of this Policy.
We will store and transfer your data as described in Storage and Transfers of Your Information.
Retention of your data
In relation to our legitimate interests as it relates to historical and statistical research, we retain your data for as long as it is made publicly available.
Privacy practices of third parties
This Policy only addresses our collection, processing, and use (including disclosure) of your data. Our customers and other third parties that may have access to your data can use it in other ways in accordance with their own privacy practices and applicable law. We encourage you to familiarize yourself with the privacy statements provided by any platform you use to publish any information.
As a Social Media Author, you are the source of the data. You have control over that data within the platform or forums that you choose to publish it on (e.g. Twitter, and other blogs, forums, etc.), including through using the privacy settings made available to you by that platform or forum. In addition to whatever rights you have via your relationship with any publishing platform, you also have certain rights relating to your data that we process, as set out in this Policy.
If you believe we have information from you that you do not want us to have, please Contact Us as described below and contact the social media provider to whom you initially gave that information. We will delete your content upon your request, if we are able to do so.
If you reside in the European Union (EU) or other jurisdictions that provide access rights under law, you may access your information or have it corrected or updated in accordance with applicable law by contacting us through the Contact Us options described in this Policy (See Your Rights (EU Users) above).
We are committed to protecting the online privacy of children. In accordance with the Children’s Online Privacy Protection Act in the United States and the GDPR in the EU, we will not knowingly collect or solicit any personally identifiable information from or provide any services to children under the age of 16. Our Site and its content are not directed at children under the age of 16. If we learn that we have collected personal data from a child under the age of 16 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
Email questions about our privacy and security practices to: email@example.com
Online request through: Contact Us