I: Introduction

This privacy policy (this “Privacy Policy”) describes how Precina, Inc. (“Precina,” “we,” “us,” or “our”) collects, uses, shares and otherwise handles personal information about individuals (“you,” and/or “your”) who visit and use our website and mobile applications, and any related products, features, and services (collectively, the “Service” or “Services”).

Any patient information that you provide to us in connection with your use of the Services (“Patient Information”), will be used solely to provide the Services to you and your patient. We do not monitor communication content and we do not record audio or video calls. We do not sell Patient Information.

By using the Service, whether as a registered member or an unregistered visitor, you acknowledge that you have read this Privacy Policy, and consent to the handling of your personal information as described in this policy, which we may update from time to time as described in the “Changes to this Privacy Policy” section, below.

Precina is a United States company. The Services are not intended for users outside of the United States and non-US healthcare professionals are not eligible for Precina membership. By using the Services, you consent to your personal information being stored and otherwise processed in the United States as described in this Privacy Policy.

NO PORTION OF THE SERVICES (INCLUDING, WITHOUT LIMITATION, ANY PRECINA MOBILE APPLICATION) MEETS THE DEFINITION OF A “DEVICE” UNDER SECTION 201(H) OF THE FEDERAL FOOD, DRUG, AND COSMETIC ACT (“FD&C ACT”), AND AS SUCH THE SERVICES ARE NOT SUBJECT TO FEDERAL DRUG ADMINISTRATION (“FDA”) OVERSIGHT OR COMPLIANCE. THE SERVICES ARE EXPRESSLY INTENTED TO BE A MEDIUM OF COMMUNICATION BETWEEN HEALTHCARE PROVIDERS AND PATIENTS, AND THE SERVICES ARE EXPRESSLY NOT INTENDED TO BE USED IN THE DIAGNOSIS OF DISEASE OR OTHER CONDITIONS, OR IN THE CURE, MITIGATION, TREATMENT, OR PREVENTION OF DISEASE IN MAN, OR ARE INTENDED TO AFFECT THE STRUCTURE OR ANY FUNCTION OF THE BODY OF MAN OR OTHER ANIMALS.

II: Collection of Information

We collect personal information that you provide us directly, from third party sources, and automatically when you use the Services as follows:

Information that you Provide to Us Directly:

Precina Member Accounts:

When you register a Precina account and become a Precina member, we require you to provide certain personal information. Precina members must provide their email address, and certain information about their education, such as school attended, year of graduation, and specialty. To enhance accuracy and integrity, and to confirm your status as a healthcare professional, we require registering members to verify their identity and credentials, which verification may require them to answer identity verification questions and/or provide us a professional email address, a copy of their professional license, medical ID or other relevant documentation. While we take steps to verify that Precina Members are actually the healthcare providers they claim to be, we make no guarantee as to any member’s identity, professional credentials or licensure status.  

You may choose to update or supplement the information you have provided to us at any time as described in the “Updating Your Account Information” section below.

Submissions:

We collect content and information that you submit to the Services, including comments, searches, contacts, schedule details, your resume, survey responses, creative submissions, and member support requests.

Communications Tools:

The Services include secure communication tools that enable our members to communicate with each other and their patients. You may also choose to share information with your patients with our communication tools such as your image, your chosen display of a virtual background, or the phone number you choose to display. We collect information about usage of these tools, such as when a member uses the tool and the duration of a call. As described above, any Patient Information that you provide us in connection with your use of the Services will be used solely to provide the associated services to you and your patient. We do not monitor communication content and we do not record audio or video calls.

If you act as or on behalf of a “covered entity” under the Health Insurance Portability and Accountability Act (HIPAA) and choose to transmit protected health information subject to HIPAA in connection with your use of a Precina secure communication tool, this information will be handled in accordance with the Precina Business Associate Agreement incorporated by reference into the Precina Terms of Service or our Business Associate Agreement with the relevant covered entity, as applicable.

Information Collected Automatically When You Use The Services:

In addition to your personal information that you provide to us directly, we collect a variety of personal information automatically when you use the Services through the use of cookies and similar technologies (e.g., pixels, web beacons and device identifiers), which we refer to as “Log Data” as further described in the “Cookies and Similar Technologies” section below. Log Data includes activity information such as the date and time that you access one of our sites or apps, and whether you view, click or otherwise interact with content, including articles, links, advertisements promoting the products and services of Precina or our customers, open or click a link in one of our emails, conduct a search on one of our websites, share an article displayed in your newsfeed, or send, receive, or engage with a message sent through the Service. We collect device information including your IP address (which is a unique numerical address that identifies your device when you access the Internet), your browser and device type and model, operating system, your ISP and mobile carrier, your advertising ID (which is a unique, user-resettable identification number associated with a mobile device), other unique identifiers associated with your computer or mobile device, and the URL of the site from which you access our site.

The use of these technologies helps us serve you better by understanding what you’re interested in, tracking trends, measuring the effectiveness of our content, including ads, and saving your preferences. For information about how you can manage your cookie preferences, refer to the “Choices Regarding Personal Information” section, below.

If you make a video call through the Services, you may have the option to display a virtual background. Depending on your device, this feature uses Apple’s TrueDepth API or Android’s Selfie Segmentation API to track your face, figure and movement based on information collected through your device while this feature is enabled. This information does not leave your device, is not stored or shared with third parties, and is used solely to provide this optional feature.

We do not collect precise location information unless you elect to enable location services on your device, but we do receive information about your general location at a city or zip code level through your computer’s IP address and your mobile device.

III: Uses of Information

Except as otherwise provided herein, we may use the personal information we collect about you for the following business and commercial purposes:

Provision of the Service:

We use your information to provide, operate, support, and improve the Services, including through the development of new tools and features.

Communications:

We use your information to communicate with you about the Services. These communications may contain information about your professional connections, professional opportunities, conferences and other events (including whether your colleagues plan to attend, as informed by the event sponsor), relevant editorial content, and marketing about products and services of Precina and our customers. These communications may be sent through a variety of channels, including on-site or in-app notifications and email. If you use the Services to communicate with a patient, we may send you text messages relating to these communications, e.g., your patient is waiting to join a video call. Refer to the Precina Terms of Service for more information about text messaging. We also use your information to process, store, and transmit your communications through the Services.

Personalizing Your Experience:

We use your information to personalize the Services including content, employment opportunities, marketing messages, and advertising served to you on our sites and third-party sites, and to generally enhance your Precina experience. We use your information to target (and measure the performance of) advertising and other content sponsored by third parties, including pharmaceutical companies promoting their products and therapies, and hospitals promoting their services. For example, if you are an oncologist or have demonstrated an interest in oncology content, you may see advertisements targeted to oncologists or oncology-interested members. Advertising will be identified as an “Advertisement,” “Sponsored,” “Promoted” or some similar designation indicating that the content is promotional and has been selected by the third-party sponsor.

Other Uses of Your Information:

We also use your information to detect, investigate, and prevent fraudulent, harmful, unauthorized, unethical or illegal activities to protect the rights, safety and property of Precina, our users and others, including through the enforcement of the Precina Terms of Service, in connection with legal proceedings, including arbitration, and to comply with our legal obligations. Also, we may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

IV: Sharing of Information

In connection with the activities described above, we may share your personal information with third parties as follows:

Business Partners:

We may share your profile information with trusted business partners that we work with to provide the Services to you and others.

Research Institutions:

As part of our mission to understand and support the medical profession, we may share your information with research institutions that perform research related to their respective missions. We require these institutions to agree that they will only use and share the data as needed for the approved research purpose and that any resulting research output be aggregated and anonymized so that it cannot be linked back to any individual. We may publish or allow others to publish insights learned from such research activities.

Service Providers:

We may share your information with third parties that help us provide the Services and operate our business, including in the areas of website and database hosting and maintenance, telecommunications, information security, fraud detection and prevention, email management, data analytics, marketing, advertising, member support, and identity and professional credential verification.

Commercial Clients:

We provide our commercial clients, including hospitals, recruiters, and life science companies, with profile search and messaging tools as part of our talent and marketing services businesses. They use these tools to select members that may be interested in their information and opportunities, including in the areas of employment and other professional opportunities, events, clinical trials, innovative therapies, and other clinical solutions, and we communicate their messages to the selected Precina members on their behalf. If your employer or another third party purchases a paid Service from Precina for your use and you elect to use that Service, this third party will have the right to control access to and obtain information about your use of the paid Service. We may also provide our commercial clients with limited member information in connection with our audience development and performance reporting for their advertising and other sponsored content programs delivered through the Service. When you engage with sponsored content, we may share with the sponsor and its agency limited information from your Precina profile such as your name, specialty, and zip code, along with details about the engagement such as whether you viewed and or interacted with an advertisement. Prior to sharing this information, we require the recipients to agree to limit their use to the authorized purpose. We do not share your profile information or any personal contact information with our commercial clients without your consent.

Advertising Partners:

We work with third party partners to serve advertising for us on third party sites and to evaluate the effectiveness of our advertising. These third parties use cookies and similar technologies to collect information about your use of our sites, other sites and online services over time, including certain Log Data described above, so they can display our ads to you on other sites and apps. For example, if you visit Precina and also use a social media platform, you may see a Precina ad in your social media newsfeed. These activities, known as interest-based advertising, are intended to make the ads you see online more relevant to your interests. Please see the “Choices Regarding Personal Information” section below for information about opting out of interest-based based advertising.

Business Transferees:

We may share your personal information in connection with a business transaction (or potential transaction) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Precina or our corporate affiliates (including, in connection with a bankruptcy or similar proceedings).

Affiliated Companies:

We may share personal information with our corporate affiliates for use consistent with this Privacy Policy.

Authorities:

We may access, preserve, and share your information with third parties, as required or permitted by applicable law, if we believe it is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us, which may involve disclosure to law enforcement, courts, or governmental authorities. Also, if you provide us information about an adverse event relating to a pharmaceutical product or medical device, we may be required to report this information along with your contact information to the manufacturer so it can comply with legally required reporting obligations.

Other Third Parties:

We may access, preserve, and share your information if we determine it is reasonably necessary or appropriate to investigate, prevent or take action regarding suspected fraudulent, harmful, unethical or illegal activities, or any violation of the Precina Terms and Conditions or to protect and defend the legal rights, safety, and property of Precina, our employees, agents and contractors (including to enforce our agreements) or in connection with any safety or security concerns, including the personal safety of our users and the public.

With Your Consent:

We also may share your personal information with a third party in a manner not addressed by this policy with your consent.

V: Cookies and Similar Technology

We and our service providers and partners, as described above, use various tools to collect data when you visit our sites and apps, including cookies, pixel tags, and other similar technologies. These technologies enable us to track usage of the Services and to enhance the user experience by providing a more relevant and personalized online experience. A cookie is a small data file that is sent to a user’s browser when visiting a website. It is stored, accessed and maintained on the computer’s hard drive or on a tablet or mobile device. A cookie contains a unique number that allows a website to recognize a particular user’s device each time that user visits the website so they don’t need to log in each time they visit and their preferences can be stored. Cookies enable us to measure the use and effectiveness of our content, track user trends, monitor and stabilize our websites, and improve the quality of the Services and content personalization (including ads) both on Precina and third-party sites.

Most browsers can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. We and our partners also use pixel tags, often in conjunction with cookies. Pixel tags are small pieces of code that are embedded on web pages and apps in order to provide us with information about how our sites and apps are used. We also include pixel tags in our emails to inform us whether the recipient has opened those emails and/or clicked on links in those emails.

VI: Third-Party Links

Our Services may contain links to third-party sites. Any access to and use of such linked sites is not governed by this policy, but instead is governed by the privacy policies of those third-party sites, which we encourage you to read. We are not responsible for the information practices of such third-party sites.

VII: Data Retention

We will retain your personal information for at least the period reasonably necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. If we delete some or all of your personal information, we may continue to retain and use aggregate or anonymous data previously collected and/or aggregate or anonymize your personal information.

VIII: Choices Regarding Personal Information

Your Account and Profile Information:

If you have registered a Precina Account, you may review and update certain personal information through your account settings. If you prefer to submit an update request to us directly, or if you wish to close your account, please contact us at support@precina.com.

Opting Out of Marketing Emails:

You may opt-out of receiving marketing emails from Precina at any time by opting out via the link the email footer, adjusting your account settings or sending an opt-out request to support@precina.com. Please be aware that you cannot opt-out of receiving services messages from us including security and legal notices.

Controlling Cookies and Interest-Based Advertising:

If you would prefer not to accept cookies, visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Note that rejecting cookies will not prevent device identification and related data collection from occurring. Also, if you choose to reject cookies, your access to some functionality and areas of the Service may be restricted. For additional information about cookies visit www.allaboutcookies.org.

As described above, we allow certain third-party partners to place tracking technologies on the Service for the purpose of delivering interest-based advertising to you on third party sites. You can opt-out of certain third party interest-based advertising services we may use by visiting the following links: for Google: Google Marketing Platform opt-out page; For Twitter: Twitter’s Privacy Controls for Personalized Ads; For Facebook: Facebook Ad Preferences; and for LinkedIn: LinkedIn General Advertising Preferences.

We may use Google Analytics to recognize you and link the devices you use when you visit the Service on your browser or mobile device. Google Analytics allows us to better understand how our users interact with the Service and to tailor our content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses information from sites or apps that use our services” currently located at www.google.com/policies/privacy/partners.You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout.

You can learn more about managing your preferences for interest-based ads online, particularly for many third-party advertising networks, by visiting the Network Advertising Initiative and the Digital Advertising Alliance. Note that even if you opt-out from interest-based advertising through these organizations’ tools, cookies may still be used to collect data for purposes other than interest-based advertising, including analytics. Also, you will still see ads, but they will not be targeted based upon the information collected through these tracking technologies. When using the preferences and opt-out settings described above, you will need to apply them on every device and on every browser from which you wish to opt-out. Because some of these settings rely on a cookie that stores your preferences, if you delete or clear your browser’s cookies, you may need to opt-out again. You can also control interest-based advertising on your mobile device by enabling the “Limit Ad Tracking” setting on your iOS device or “Opt out of Ads Personalization” on your Android devices.

Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. We do not respond to “Do Not Track” signals at this time.

Push Notifications:

If you consent to receive push notifications, you may withdraw your consent at any time by adjusting the appropriate operating system settings on your mobile device.

IX: Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time and in our sole discretion. When we make a change, we will update the “Effective Date” and post the updated policy on or through the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as by e-mail (if you have an account where we have your contact information) or another manner through the Service. Any modifications to this privacy policy will be effective upon posting or as otherwise indicated at the time of posting. In all cases, by continuing to use the Service after posting of the updated policy, you are consenting to the changes. If you object to any changes, you may close your account by contacting support@precina.com.

X: Contact Us

If you have any questions about this policy or Precina’s privacy practices, you may reach us at any time by emailing support@precina.com or by contacting us at:

Precina
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