PRIVACY
NOTICE
Last
updated August 27, 2020
Thank
you for choosing to be part of our community at Physician Software Systems, LLC
("Company," "we," "us," or
"our"). We are committed to protecting your personal
information and your right to privacy. If you have any questions or concerns
about this privacy notice or our practices with regard to your personal
information, please contact us at info@physoft.com.
This
privacy notice describes how we might use your information if you:
- Visit our website at www.physoft.com
- Engage with us in other
related ways including any sales, marketing, or events
In
this privacy notice, if we refer to:
- "Website,"
we are referring to any website of ours that links to this policy
- "Services,"
we are referring to our website, and other related services, including any
sales, marketing, or events
The
purpose of this privacy notice is to explain to you in the clearest way
possible what information we collect, how we use it, and what rights you have
in relation to it. If there are any terms in this privacy notice that you do
not agree with, please discontinue use of our services immediately.
Please
read this privacy notice carefully, as it will help you understand what we do
with the information that we collect.
TABLE
OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
2. HOW DO WE USE YOUR
INFORMATION?
3. WILL YOUR INFORMATION BE
SHARED WITH ANYONE?
4. HOW LONG DO WE KEEP YOUR
INFORMATION?
5. HOW DO WE KEEP YOUR
INFORMATION SAFE?
6. DO WE COLLECT INFORMATION
FROM MINORS?
7. WHAT ARE YOUR PRIVACY
RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK
FEATURES
9. DO CALIFORNIA RESIDENTS
HAVE SPECIFIC PRIVACY RIGHTS?
10. DO WE MAKE UPDATES TO
THIS NOTICE?
11. HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
12. HOW CAN YOU REVIEW,
UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1.
WHAT INFORMATION DO WE COLLECT?
Personal
information you disclose to us
In
Short: We
collect personal information that you provide to us.
We
collect personal information that you voluntarily provide to us when you
express an interest in obtaining information about us or our products and
services, when you participate in activities on the Website or otherwise when
you contact us.
The
personal information that we collect depends on the context of your
interactions with us and the website, the choices you make and the products and
features you use. The personal information we collect may include the
following:
Personal
Information Provided by You. We collect names; phone numbers; email addresses; mailing
addresses; job titles; and other similar information.
All
personal information that you provide to us must be true, complete and
accurate, and you must notify us of any changes to such personal information.
2.
HOW DO WE USE YOUR INFORMATION?
In
Short: We
process your information for purposes based on legitimate business interests,
the fulfillment of our contract with you, compliance with our legal
obligations, and/or your consent.
We
use personal information collected via our website for a variety of business
purposes described below. We process your personal information for these purposes
in reliance on our legitimate business interests, in order to enter into or
perform a contract with you, with your consent, and/or for compliance with our
legal obligations. We indicate the specific processing grounds we rely on next
to each purpose listed below.
We
use the information we collect or receive:
- To send you marketing
and promotional communications. We and/or our third-party marketing partners may use
the personal information you send to us for our marketing purposes, if
this is in accordance with your marketing preferences. For example, when
expressing an interest in obtaining information about us or our website,
subscribing to marketing or otherwise contacting us, we will collect
personal information from you. You can opt-out of our marketing emails at
any time (see the "WHAT ARE YOUR PRIVACY
RIGHTS?"
below).
- Deliver targeted
advertising to you.
We may use your information to develop and display personalized content
and advertising (and work with third parties who do so) tailored to your
interests and/or location and to measure its effectiveness.
3.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In
Short:
We only share information with your consent, to comply with laws, to provide you
with services, to protect your rights, or to fulfill business obligations.
We
may process or share your data that we hold based on the following legal basis:
- Consent: We may process your
data if you have given us specific consent to use your personal information
for a specific purpose.
- Legitimate Interests: We may process your
data when it is reasonably necessary to achieve our legitimate business
interests.
- Performance of a
Contract:
Where we have entered into a contract with you, we may process your personal
information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your
information where we are legally required to do so in order to comply with
applicable law, governmental requests, a judicial proceeding, court order,
or legal process, such as in response to a court order or a subpoena
(including in response to public authorities to meet national security or
law enforcement requirements).
- Vital Interests: We may disclose your
information where we believe it is necessary to investigate, prevent, or
take action regarding potential violations of our policies, suspected
fraud, situations involving potential threats to the safety of any person
and illegal activities, or as evidence in litigation in which we are
involved.
More
specifically, we may need to process your data or share your personal
information in the following situations:
- Business Transfers. We may share or
transfer your information in connection with, or during negotiations of,
any merger, sale of company assets, financing, or acquisition of all or a
portion of our business to another company.
4.
HOW LONG DO WE KEEP YOUR INFORMATION?
In
Short:
We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We
will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is
required or permitted by law (such as tax, accounting or other legal
requirements). No purpose in this notice will require us keeping your personal
information for longer than 90 days.
When
we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, 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.
5.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In
Short:
We aim to protect your personal information through a system of organizational
and technical security measures.
We
have implemented appropriate technical and organizational security measures
designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able
to defeat our security, and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information,
transmission of personal information to and from our website is at your own
risk. You should only access the Website within a secure environment.
6.
DO WE COLLECT INFORMATION FROM MINORS?
In
Short:
We do not knowingly collect data from or market to children under 18 years of
age.
We
do not knowingly solicit data from or market to children under 18 years of age.
By using the Website, you represent that you are at least 18 or that you are
the parent or guardian of such a minor and consent to such minor dependent's
use of the Website. If we learn that personal information from users less than
18 years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you
become aware of any data, we may have collected from children under age 18,
please contact us at roelof.boonstra@physoft.com.
7.
WHAT ARE YOUR PRIVACY RIGHTS?
In
Short:
In some regions, such as the European Economic Area (EEA) and United Kingdom
(UK), you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any
time.
In
some regions (like the EEA and UK), you have certain rights under applicable
data protection laws. These may include the right (i)
to request access and obtain a copy of your personal information, (ii) to
request rectification or erasure; (iii) to restrict the processing of your
personal information; and (iv) if applicable, to data portability. In certain
circumstances, you may also have the right to object to the processing of your
personal information. To make such a request, please use the contact details provided below. We will
consider and act upon any request in accordance with applicable data protection
laws.
If
we are relying on your consent to process your personal information, you have
the right to withdraw your consent at any time. Please note however that this
will not affect the lawfulness of the processing before its withdrawal, nor
will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
If
you are a resident in the EEA or UK and you believe we are unlawfully
processing your personal information, you also have the right to complain to
your local data protection supervisory authority. You can find their contact
details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If
you are a resident in Switzerland, the contact details for the data protection
authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
8.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most
web browsers and some mobile operating systems and mobile applications include
a Do-Not-Track ("DNT") feature or setting you can activate to signal
your privacy preference not to have data about your online browsing activities
monitored and collected. At this stage no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this privacy notice.
9.
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In
Short:
Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California
Civil Code Section 1798.83, also known as the "Shine The
Light" law, permits our users who are California residents to request and
obtain from us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with which
we shared personal information in the immediately preceding calendar year. If
you are a California resident and would like to make such a request, please
submit your request in writing to us using the contact information provided
below.
If
you are under 18 years of age, reside in California, and have a registered
account with the Website, you have the right to request removal of unwanted
data that you publicly post on the Website. To request removal of such data,
please contact us using the contact information provided below, and include the
email address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the
Website, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g.
backups, etc.).
CCPA
Privacy Notice
The
California Code of Regulations defines a "resident" as:
(1) every
individual who is in the State of California for other than a temporary or
transitory purpose and
(2)
every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All
other individuals are defined as "non-residents."
If
this definition of "resident" applies to you, we must adhere to
certain rights and obligations regarding your personal information.
What
categories of personal information do we collect?
We
have collected the following categories of personal information in the past
twelve (12) months:
|
|
|
|
|
A. Identifiers |
Contact details, such as real name, alias,
postal address, telephone or mobile contact number, unique personal
identifier, online identifier, Internet Protocol address, email address and
account name |
YES |
|
B. Personal information categories listed in
the California Customer Records statute |
Name, contact information, education,
employment, employment history and financial information |
YES |
|
C. Protected classification characteristics
under California or federal law |
Gender and date of birth |
NO |
|
D. Commercial information |
Transaction information, purchase history,
financial details and payment information |
NO |
|
E. Biometric information |
Fingerprints and voiceprints |
NO |
|
F. Internet or other
similar network activity |
Browsing history, search history, online
behavior, interest data, and interactions with our and other websites,
applications, systems and advertisements |
NO
|
|
G. Geolocation data |
Device location |
NO |
|
H. Audio, electronic, visual, thermal,
olfactory, or similar information |
Images and audio, video or call recordings
created in connection with our business activities |
NO |
|
I. Professional or employment-related
information |
Business contact details in order to provide
you our services at a business level, job title as well as work history and
professional qualifications if you apply for a job with us |
YES |
|
J. Education Information |
Student records and directory information |
NO |
|
K. Inferences drawn from other personal
information |
Inferences drawn from any of the collected
personal information listed above to create a profile or summary about, for
example, an individual's preferences and characteristics |
NO |
We may
also collect other personal information outside of these categories instances
where you interact with us in-person, online, or by phone or mail in the
context of:
- Receiving help through
our customer support channels;
- Participation in
customer surveys or contests; and
- Facilitation in the
delivery of our Services and to respond to your inquiries.
How
do we use and share your personal information?
More
information about our data collection and sharing practices can be found in
this privacy notice.
You
may contact us by email at info@physoft.com, or by referring to the contact
details at the bottom of this document.
If
you are using an authorized agent to exercise your right to opt-out we may deny
a request if the authorized agent does not submit proof that they have been
validly authorized to act on your behalf.
Will
your information be shared with anyone else?
We
may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Each service provider is
a for-profit entity that processes the information on our behalf.
We
may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration.
This is not considered to be "selling" of your personal data.
Physician
Software Systems, LLC has not disclosed or sold any personal information to third
parties for a business or commercial purpose in the preceding 12 months.
Physician Software Systems, LLC will not sell personal information in the
future belonging to website visitors, users and other consumers.
Your
rights with respect to your personal data
Right
to request deletion of the data - Request to delete
You
can ask for the deletion of your personal information. If you ask us to delete
your personal information, we will respect your request and delete your
personal information, subject to certain exceptions provided by law, such as
(but not limited to) the exercise by another consumer of his or her right to
free speech, our compliance requirements resulting from a legal obligation or
any processing that may be required to protect against illegal activities.
Right
to be informed - Request to know
Depending
on the circumstances, you have a right to know:
- whether we collect and
use your personal information;
- the categories of
personal information that we collect;
- the purposes for which
the collected personal information is used;
- whether we sell your
personal information to third parties;
- the categories of
personal information that we sold or disclosed for a business purpose;
- the categories of third
parties to whom the personal information was sold or disclosed for a
business purpose; and
- the business or
commercial purpose for collecting or selling personal information.
In
accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or
to re-identify individual data to verify a consumer request.
Right
to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We
will not discriminate against you if you exercise your privacy rights.
Verification
process
Upon
receiving your request, we will need to verify your identity to determine you
are the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we
can match it with information you have previously provided us. For instance,
depending on the type of request you submit, we may ask you to provide certain
information so that we can match the information you provide with the
information we already have on file, or we may contact you through a
communication method (e.g. phone or email) that you
have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We
will only use personal information provided in your request to verify your
identity or authority to make the request. To the extent possible, we will
avoid requesting additional information from you for the purposes of
verification. If, however, we cannot verify your identity from the information
already maintained by us, we may request that you provide additional
information for the purposes of verifying your identity, and for security or
fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other
privacy rights
- you may object to the
processing of your personal data
- you may request
correction of your personal data if it is incorrect or no longer relevant,
or ask to restrict the processing of the data
- you can designate an
authorized agent to make a request under the CCPA on your behalf. We may
deny a request from an authorized agent that does not submit proof that
they have been validly authorized to act on your behalf in accordance with
the CCPA.
- you may request to
opt-out from future selling of your personal information to third parties.
Upon receiving a request to opt-out, we will act upon the request as soon
as feasibly possible, but no later than 15 days from the date of the
request submission.
To
exercise these rights, you can contact us by email at info@physoft.com, or by
referring to the contact details at the bottom of this document. If you have a
complaint about how we handle your data, we would like to hear from you.
10.
DO WE MAKE UPDATES TO THIS NOTICE?
In
Short: Yes,
we will update this notice as necessary to stay compliant with relevant laws.
We
may update this privacy notice from time to time. The updated version will be
indicated by an updated "Revised" date and the updated version will
be effective as soon as it is accessible. If we make material changes to this
privacy notice, we may notify you either by prominently posting a notice of
such changes or by directly sending you a notification. We encourage you to
review this privacy notice frequently to be informed of how we are protecting
your information.
11.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If
you have questions or comments about this notice, you may contact our Data
Protection Officer (DPO) by email at dpo@physoft.com, by phone at
(331) 212-9000, or by post to:
Data
Protection Officer
Physician
Software Systems, LLC
3333
Warrenville Rd, Ste 200
Lisle,
IL 60532
United
States
12.
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based
on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that
information, or delete it in some circumstances. To request to review, update,
or delete your personal information, please visit www.physoft.com.