Privacy Policy

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We Take Data Protection Seriously.

Alira Health cares about your privacy. For this reason, we collect and use personal information only as needed, protect your information, and put you in control. This privacy policy explains how we collect and use information, and your rights and choices regarding your personal information. We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page.

Alira Health Corporate Headquarters and its affiliated companies (together, “Alira Health” or “we”) recognize the importance of protecting the privacy of your personal information, and have prepared this Privacy Notice to provide you with important information about our privacy practices. This Privacy Notice applies when you use the Alira Health website, applications, or other online services that link to or refer to this Privacy Notice and that is owned and operated by Alira Health (the “Services”).  This Privacy Notice does not apply to information collected through other websites or online services.

By using the Services, you consent to the practices described in this Privacy Notice. Please take a moment to review the terms of our Privacy Notice. If you have any questions about this Privacy Notice, please contact us at [email protected]

This Privacy Notice is only valid for all pages hosted on our Website. It is not valid for the pages hosted by third parties to which Alira may refer and whose privacy notices may differ. We cannot therefore be held responsible for any data processed on these websites or by them. This Notice also applies to any other website that Alira Health may operate, including our Company pages on Facebook, Instagram, LinkedIn and Twitter.

The protection of your privacy in the processing of personal information is an important concern to us. When you visit our website, our web servers will regularly store the IP address of your Internet service provider, the website you came from, the pages of our website that you browse, and the date and duration of your visit. This information is a prerequisite for the technical transfer of the website and securing server operations. This data will not be analyzed for personal information.

If you disclose data to us via our contact form, this information will be stored on our servers for the purpose of data backup. Your information will be used exclusively for processing your request. Your personal information will be treated in strict confidence and will not be disclosed to third parties.

Data Controller

Alira Health Corporate Headquarters
1 Grant Street, Suite 400
Framingham, Massachusetts 01702
United States
[email protected]
+1 (774) 777 5255

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

We may collect personal information about our users in various ways. For example, we may collect information that you provide to us or information that we collect through your use of the Services.

Personal Data You Provide to Us

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• First name and last name
• Business email address
• Company
• Job title
• Postal address
• Phone number

Personal Data We Collect from Your Computer and Other Devices Used to Access the Services.

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

For example, we may collect information about how many visitors visit a specific page on the Services, how long they stay on that page, and which hyperlinks, if any, they click on. We collect this information, in part, through the use of technologies such as cookies and web beacons, which are discussed in greater detail in our Cookies section of the Privacy Policy. We may also group this information into aggregate visitor data.

As we also collect aggregate statistical data through our page hosted on LinkedIn, Facebook, Instagram and Twitter, Alira Health will be joint controller with the above-mentioned social media in that regard. For any other processing performed on the platforms, LinkedIn, Facebook, Instagram and Twitter will be the sole data controller.

Facebook (including Instagram) and LinkedIn have created an “addendum” to their user agreements for company pages for the processing for which they are joint controllers with us. Twitter does not provide yet such agreements.

When you use location-enabled services, we also may collect specific location information drawn from your device’s GPS, Bluetooth, or WiFi signals.

Information from Third-Party Sources

We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you.

In addition to the services, Alira Health collects information about healthcare professionals when they interact with us or our representatives. Alira Health also collects personal data from a number of third-party data sources, in particular from publicly available sources such as public registers of healthcare professionals, published journals and event materials and from websites of healthcare professionals or their employers. Alira Health also makes use of third-party data providers to enhance its own knowledge of the healthcare sector. This data will include information about health care providers’ role(s), qualifications, specialty, employer, experience, publications and other information related to their professions.

We Use the Collected Data for Various Purposes

• To provide and maintain the Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer care and support
• To provide analysis or valuable information so that we can improve the Service
• To monitor the usage of the Service
• To detect, prevent and address technical issues
• To score based on behavior and demographics and job profile
• To nurture based on scores
• To email marketing with segmentation based on demographics and job profile
• To optimize LinkedIn ads
• To retarget website visitors on LinkedIn
• To optimize advanced audience insights

In accepting the Privacy Policy, you understand that Alira Health undertakes to process your information in accordance with applicable laws, in particular the General Data Protection Regulation (“GDPR”), and:

• You authorize Alira Health to the processing of your personal data for marketing purposes (namely direct sale, sending of advertising material, market research, newsletters, and commercial communication).
• You authorize Alira Health to the processing of your personal data for profiling activities.
• You authorize Alira Health to the processing of your personal data for communicating data to third parties for marketing purposes.
• You understand that these authorizations are voluntary, and you can customize your approval at any time by contacting [email protected].

Processing of Personal data

Alira Health and its subsidiaries and other affiliates provide healthcare consulting services to clients in the pharmaceutical, biotech, medical device, digital health, medical services and other healthcare related industries. For the purpose of providing services, Alira Health and its subsidiaries, including Care Factory may process data from the national health data system (SNDS), as well as subsets of this system such as the program for medicalization of information systems (PMSI; MR006) or the permanent sample of health insurance beneficiaries (EGB). We inform the persons concerned that their rights of access, rectification and opposition may be exercised with the director of the managing body of the compulsory health insurance scheme to which the persons are attached, in accordance with the provisions of Article R. 1461-9 of the french Code of Public Health.

Sharing of Information

Service Providers

We rely on third parties to perform a variety of services for us, such as sending postal mail and providing data analysis. To do so, we will only provide those companies the personal information they need to deliver the service.

Other Parties When Required by Law or As Necessary to Protect Our Services

We reserve the right to disclose visitor information in cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other visitors, or anyone else that could be harmed by such activities. We also reserve the right to disclose visitor information when we believe in good faith that the law requires it or when doing so is necessary to respond to a government request.

Other Parties in Connection with a Corporate Transaction

We reserve the right to transfer any information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization.

Otherwise with Your Consent or at Your Direction

In addition to the sharing described in this Privacy Notice, we may share information about you with third parties whenever you consent to or direct such sharing.

We also may share other information with third parties in a manner that does not identify particular visitors, including, for example, aggregate information about how the Services are used.

Legal Requirements

Alira Health may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Alira Health
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Alira Health will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Alira Health has implemented an intra-group data sharing agreement to regulate the transfer of personal data between group companies.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Recruiting Management

We collect various types of information in connection with job applications. In particular, this includes your personal information, i.e., contact data and a description of your education, work experience, and skills. In addition, you may submit electronically stored documents such as certificates, diplomas, or cover letters.

We do not require any information from you that may not be processed in accordance with the General Equal Treatment Act (race, ethnic origin, sex, religion or belief, disability, age, or sexual orientation). Please do not submit any information on diseases, pregnancy, ethnic origin, political views, philosophical or religious beliefs, membership in a trade union, physical or mental health, or sexual activities. The same applies to any content that may infringe on third-party rights (e.g., copyrights, press rights, or general third-party rights).

The personal information will only be collected, stored, processed and used for purposes that are related to your interest in a current or future employment with us, or the processing of your application. It will not be disclosed to third parties. In the course of the online recruitment process data such as name, postal address, phone number, email address, etc. will be collected. Basically, this data will be used to contact you in connection with your application.

If your application is successful, the disclosed data may be used for administrative tasks concerning your employment.

Your online application will be exclusively read and processed by our relevant contact persons. All employees assigned with data processing tasks are bound to data secrecy. In no event will third parties take notice of your data. The processing of personal information will only take place in the United States.

If we should be unable to offer you a position, we will retain the information you submitted for up to six months subject to statutory retention periods for the purpose of answering questions regarding your application and our rejection of your application.

In the event you grant your express written consent to the retention and storage of your information, we will be able to consider you for future job opportunities. Otherwise, we will fully delete your application data.

To access our applicant information notice, please click here.

Marketing Permissions

Alira Health will use the information you provide on this form to be in touch with you and to provide updates and marketing.

You can change your mind at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at [email protected]. We will treat your information with respect. For more information about our privacy practices please visit our website. By clicking below, you agree that we may process your information in accordance with these terms.

We use Zoho as our marketing platform. By clicking below to subscribe, you acknowledge that your information will be transferred to Zoho for processing. Learn more about Zoho’s privacy practices here.

Newsletter

When mailing our newsletter, we use the so-called double opt-in procedure, i.e., we will not send you a newsletter by email unless you have expressly confirmed to us that you wish us to activate the newsletter service. We will send an email notification and ask you to confirm that you wish to receive our newsletter by clicking on the link contained in this email. When you register for our newsletter we will store your IP address and the date of registration. This information is stored as evidence in the event that a third party abuses your email account to register you for this newsletter without your knowledge or consent. In the event that you should decide not to receive any further newsletters from us, you may object at any time without incurring any charges other than the basic rate transmission charges.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Specific Privacy Notices

Notice to California Users

California Residents Under Age 18: If you are a resident of California under age 18 and a registered user of the Services, you may ask us to remove content or data that you have posted to the Services by emailing: [email protected].

Please note that your request does not ensure complete or comprehensive removal of the content or data, if, for example, Alira is required by law to maintain the data.

California Consumer Privacy Act Notice

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we provide the following details regarding the categories of Personal Information about California residents (excluding business-to-business and employee data) that we have collected or disclosed within the preceding 12 months:

We collect the following categories of Personal Information:

• Identifiers, such as name and government-issued identifier (e.g., Social Security number);
• Personal information, as defined in the California safeguards law, such as contact and financial information;
• Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status;
• Commercial information, such as transaction information and purchase history;
• Biometric information, such as fingerprints and voiceprints;
• Internet or network activity information, such as browsing history and interactions with our websites;
• Geolocation data, such as device location;
• Audio, electronic, visual and similar information, such as call and video recordings;
• Professional or employment-related information, such as work history and prior employer;
• Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
• Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We collect this Personal Information directly from California residents themselves, as well as from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, caregivers, companies and other third parties that help us screen and onboard individuals for hiring purposes, and other third parties.

We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment purposes, and to otherwise accomplish our business purposes and objectives.  Our business purposes and objectives include, for example, developing, improving, repairing, and maintaining our products and services; personalizing, advertising, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.

We disclose the following Personal Information to our affiliates and third parties, such as our service providers, for our operational business purposes:

• Identifiers, such as name;
• Personal information, as defined in the California safeguards law, such as contact and financial information;
• Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status;
• Commercial information, such as transaction information and purchase history;
• Biometric information, such as fingerprints and voiceprints;
• Internet or network activity information, such as browsing history and interactions with our websites;
• Geolocation data, such as device location;
• Audio, electronic, visual and similar information, such as call and video recordings;
• Professional or employment-related information, such as work history and prior employer;
• Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
• Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We have not “sold” Personal Information for purposes of the CCPA. We support the CCPA and wish to provide you with control over how your personal information is collected and shared.

For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

Your California Privacy Rights

If you are a California resident, you have the rights listed below.

Information. Disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting Personal Information about you; and
• The categories of Personal Information about you that we otherwise shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.

Access. Request a copy of the Personal Information that we maintain about you.

Deletion. Delete Personal Information we collected from you.

Opt out of sales. You can ask us not to sell your Personal Information.  If we know that you are younger than 16 years old, we will ask for your permission (or if you are under 13 years old, your parent or guardian’s permission) to sell your Personal Information before we do so.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as:

• Denying you goods or services
• Increasing the price/rate of goods or services
• Decreasing the service quality
• Suggesting that we may penalize you as described above for exercising your rights

To make a request for the disclosures or deletion described above, please contact us at [email protected].However, these rights are not absolute, and we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Notice to Nevada Users

Nevada Residents as Covered by Nevada Privacy Law.

We do not sell Covered Information as defined under Nevada law.  If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact us at [email protected].

Notice to Texas Users

Texas Residents

Pursuant to the Texas Health and Safety Code, Sec. 181.154, please be advised that if we receive any data that identifies you and relates to your past, present or future physical or mental health, healthcare or payment for your healthcare, such data may be subject to electronic disclosure by such means as file transfers or email.

Notice to Canadian Users

Whenever you browse our website, we might collect your Personal Information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

We only collect Personal Information that are necessary to fulfill the purposes further detailed above in the section “We use the collected data for various purposes”. We may for example, collect your name, contact information or IP address directly from you. We may also collect your Personal Information from other sources as specified in section “Information From Third-Party Sources”.

In addition to personal information you directly provide us, we may use various tracking technologies, including cookies, that passively collect certain information as you interact with our website. For more information regarding how we use cookies, see the section “Cookies” above.

Wherever possible, we always seek your consent before collecting your personal information.

We will retain your personal information for at least one year and no longer than the time necessary to achieve the collection’s purpose. It should allow us sufficient time to use the personal information, satisfy any legal or contractual requirements, and also allow time for you to exercise your rights.

You have the rights to withdraw your consent for the processing of your personal information, request an access to your personal information and request the accuracy and completeness of your personal information. To exercise your rights, please contact [email protected].

You have also the right to lodge a complaint to the Office of the Privacy Commissioner of Canada.

Cookies

The Privacy Preference Center enables you to adjust your cookie preferences, to accept or reject cookies across a range of categories. Please click below to access the Preference Center and indicate your cookie preferences.

Cookie Settings

Cookies are small files that are placed on your computer when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example, some of the Services allow visitors to increase the font size of the text contained on the applicable Service to make it easier to read. Cookies enable the Service to automatically use your preferred font size the next time you visit the Service. Most browsers are initially set up to accept cookies. Your browser or device may offer settings that allow you to choose whether browser cookies are set and to delete them. For example, you may be able to configure your browser not to accept cookies or to notify you when a cookie is being sent. For more information about whether these settings are available, what they do, and how they work, visit your browser help material. Please be aware that some features of the Services may not function properly or may be slower if you disable cookies.

What are your choices regarding cookies

• For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
• For the Internet Explorer web browser, please visit this page from Microsoft:http://support.microsoft.com/kb/278835
• For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
• For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
• For any other web browser, please visit your web browser’s official web pages.

Where Can You Find More Information About Cookies

You can learn more about cookies from the following third-party websites:

• AllAboutCookies: http://www.allaboutcookies.org
• Network Advertising Initiative:http://www.networkadvertising.org

Web Beacons and Other Tracking Technologies

We, along with third parties, also may use other tracking technologies. For example, we may use technologies called web beacons (or “pixels”) that communicate information from your device to a server. Web beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the web beacon, and the IP address of your device. We and third parties use web beacons for a variety of purposes, including to analyze the use of our Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.

Your Choices

E-mail Choices

If you have subscribed to our e-mail list and wish at any point to stop receiving commercial e-mails from us, simply follow the opt-out instructions that are included in each e-mail. If you have any questions relating to your choice to “opt-out” at any time, please Contact Us at the e-mail address or phone number provided below.

Additional Choices with Respect to Targeted Advertising

In addition to disabling cookies as described above, you may be able to opt-out of receiving targeted advertising from participating ad networks, audience segment providers, ad serving vendors, and other service providers by visiting https://optout.networkadvertising.org/?c=1 .

Do Not Track Signals

Some web browsers may transmit “do not track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our Notice on responding to these signals.

Notice to Persons Located in the EU and UK

This section takes into account the application of the General Data Protection Regulations (EU) 2016/679 (“GDPR”) and the The UK Data Protection Act 2018 UK GDPR.

Purposes and Legal Basis for Processing

We also collect data from cookies and other trackers, for more information, please, see our Cookies Notice section of the Privacy Policy.

How Long Do We Keep Your Data?

We store the data for as long as it is necessary to reply to your request and in any case for a maximal period of 3 years. We may archive for a longer period information when we are subject to a legal obligation or when it is relevant to keep a follow-up of our exchanges, e.g., in case of litigation.

When we no longer require the personal data we have collected about you, we will either delete or anonymize it.

Data Transfer

We may transfer your personal data to:

• Zoho suite (CRM, Zoho Campaigns, Zoho Meetings, Sales IQ)
• GoToWebinar
• Google Analytics, including demographics
• Google Search Console
• Hot Jar
• Zappier
• WordPress
• Power BI
• OneTrust

In any case, if such transfer is done, your data will not be transferred in a third country before having introduced appropriate measures to ensure a suitable level of protection (e.g., EU/UK Commission’s Adequacy Decision or appropriate safeguards such as standard contractual clauses).

Security Measures

To protect the personal data that you transmit through the use of this website, we maintain physical, technical and administrative safeguards. You can ask for a copy of those appropriate safeguards.

Your Rights Under GDPR and How to Exercise It

By collecting your personal data through the contact form, you may request that we take the following actions in relation to your personal data according to the GDPR:

• Access. Provide you with information about our processing of your personal data and give you access to your personal data.
• Rectification. Update or correct inaccuracies in your personal data.
• Erasure. You have the right to require deletion of your personal data, but this right may be limited depending on the specific circumstances.
• Restrict processing. Ask that the use of your data is “frozen” to leave you the possibility to exercise other rights. Your information shall not be used anymore but must be kept by us during this period.
• Data portability. You have the right to retrieve your data in a structured, commonly used, machine-readable format for personal use or send to another service provider.
• Objection. Object to our legitimate interests as the basis of our processing of your personal data.
• Right to withdraw consent. When you have given your explicit consent for the processing of your data, you can withdraw it at any time without justification.

If you want to exercise your rights, please contact our DPO at [email protected]. Please, note that all of these rights are not absolute and will be assess on a case-by-case basis.

You also have the right to lodge a complaint about how your personal information is handled with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.

To obtain contact details of UK and all EU Member States Data Protection authorities, please, follow this link:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

https://ico.org.uk/make-a-complaint/

Cookies Notice

European laws, including the General Data Protection Regulation (“GDPR”) and the e-Privacy Directive 2002/58/EC, create obligations for digital publishers such Alira Health to give visitors of their sites and apps information about how they will use and share their personal data, as well as about the use of cookies, mobile ad IDs, and other forms of local storage.

Since Alira Health is using cookies on its website, clear and mandatory information must be mentioned in this Cookies notice, as set out below. 

Information About Cookies

1. What Are Cookies?

A cookie is a text file, normally consisting of letters and numbers, sent by a web server to a web browser and stored by the browser on the user’s device (e.g., computer, telephone, tablet). These cookies can be used to identify or to collect information about you.

2. What Types of Cookies Are There?

Cookies can be classified as follows, depending on the owner:

• First-party cookies: They are created, sent to your device and stored by the website you are visiting directly. They allow Alira Health to collect customer analytics data, remember language settings, and carry out other useful functions that help provide a good user experience.
• Third-party cookies: They are created and placed by third parties other than the website you are visiting directly. They are not managed by Alira Health, but by the third party that processes the data obtained from the cookies.

Cookies can also be classified depending on the purpose of their placement. Main categories are:

• Strictly necessary cookies (also called “technical cookies”): they allow you to browse a website, a platform or an app, and to use the various options or services on it (e.g., control traffic, identify data or session, access to restricted access sections or content, etc.).
• Functional cookies: they help Alira Health to make the website usable by providing you some basic features and by remembering your preferences and choices of using Alira Health’s website (e.g., language, the region from where the service is accessed, etc.). Not accepting cookies may cause slow website performance or poorly adapted recommendations.
• Statistics cookies: they allow Alira Health to have a better understanding of how you interact with the website (e.g., which pages are visited the most) in order to optimize the functioning of the website.
• Marketing cookies: they enable Alira Health to monitor your behaviour on the website. The aim is to display advertisements that are meaningful and attractive to you and therefore more useful to third party publishers and advertisers, as well as to make promotional and specific information available to you on the website.

Cookies may also be divided into two categories depending on the period for which they are stored:

• Session cookies: they allow Alira Health to recognize and link your actions during a browsing session. When you go to the login page, these temporary cookies will be created to determine whether or not your browser accepts cookies.
• Persistent cookies: they are placed on your device between sessions. They can be used to remember your preferences or actions on Alira Health’s website.

3. How to Use Cookies?

Cookies in no way give Alira Health access to your device or any information other than the data you choose to share with Alira Health.

Concretely, these cookies help to improve the functioning of the website of Alira Health and can be used for several purposes:

4. How to Manage Cookies?

You are able to accept or decline cookies when you enter Alira Health’s website and see the cookies notice. Alternatively, you can manage your cookie preferences through your browser settings. However, in some cases, some functions of the website may not work.

To find out more about cookies, including seeing what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org or https://www.aboutcookies.org/.

Find out how to manage cookies on those popular browsers:

• Google Chrome
• Mozilla Firefox
• Internet Explorer
• Safari

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit –  http://tools.google.com/dlpage/gaoptout.

5. Who Placed Cookies?

The information stored through cookies is only used by Alira Health, except those identified in section II as “Third-party cookies”, which are used and managed by external entities aiming to improve Alira Health’s services and your experience when browsing on the website.

Alira Health collaborates with the following third-parties:

• Google Analytics
• YouTube
• DoubleClick
• Indeed
• CloudFlare
• Zoho

Please note that Alira Health do not have any control over how the information in these cookies is used nor do Alira Health have access to it. Please refer to the cookies policies of the relevant provider for more information.

6. How to Contact Us?

For any question regarding this Cookies notice, you may contact Alira Health, who, if required, will contact its Data Protection Officer (“DPO”).

Event and Webinar Data Processing

Information Notice Pursuant to Art. 13 Regulation (EU) 2016/679 on 27th April 2016

Alira Health (or “Alira”), as the Controller of personal data, is committed to comply with the GDPR and all applicable data protection laws and regulations.  Alira wants to ensure that you understand what personal data is collected in connection with your participation in the Event, how this information is used, and how it is stored.

Personal Data will be processed lawfully, fairly and in a transparent manner; will be collected for specified, explicit and legitimate purposes and processed in a manner that is not incompatible with such purposes; they will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed, accurate and up-to-date; they will be processed with the utmost confidentiality, mainly with electronic and automated means, and stored both electronically and on paper, and on any other type of suitable means, in accordance with the principles of the General Data Protection Regulation 2016/679 (GDPR), the requirements given by the supervisory authority and, in any case, in such a way as to ensure adequate level of security, including protection, with adequate technical and organizational measures, from non-authorized or unlawful processing, or even accidental loss. Data will be stored in a manner that permit the identification of the data subjects for the extent strictly necessary to the achievement of the purposes for which they were processed.

Alira Health, as defined below, undertakes the responsibility to observe specific security measures in order to prevent data loss, illegitimate or unfair use and unauthorized access, in full compliance with statutory and regulatory provisions.

The Personal Data voluntarily provided by yourself will be stored in Alira Health database exclusively for the purposes specified below and for a limited time or for the time required by the relevant legislation.

1. Identity and Contact Details of the Data Controller

For the purposes of this Notice, Data Controller(s), independently or jointly, are the companies of Alira Health Group separately or together referred to as “Alira Health” and/or “Data Controller”.

Alira Health companies have signed an agreement as Joint Controllers available for your consultation, on request.

2. Contact Details of the Data Protection Officer

In accordance with the GDPR, Alira has appointed a Data Protection Officer (DPO).

For the purposes of exercising the rights provided for in the GDPR, and for any request relating to your personal data, you may contact Alira’s DPO by sending a communication to the following e-mail address: [email protected]

3. What Data Do We Process?

• General information collected: surname, first name, company, job title, business e-mail address, signature, country/region of residence, bank details (if necessary for payment);
• Photographs taken during the Event (if you attend the Event in person) with your consent;
• The recording (which may include your face and voice) of your presentation is made during the Event.

4. How and Why Do We Use this Information?

• Organize your participation in the event: allow you to register for the event, confirm your registration, communicate about the organization of the event, check that you are registered when you arrive at the event, …
• External communication about the event:

With your authorization, Alira Health SAS and its Affiliates, will process your   photos, videos and recordings (Images) taken during the event organized by Alira Health

Namely through publication by means of company advertising channels; through publication on the website, in company presentations and on company advertising material (brochures, advertisements).

• Provision to participants of a recording of the presentations, for a limited time, after the
• If you agree, we may also use your personal data for:
  • marketing purposes (namely sending of advertising material, market research, newsletters, and commercial communication)

As a general rule, you can always withdraw your consent, opt-out of an application or unsubscribe from a newsletter.

5. On What Legal Basis Do We Use Your Personal Data?

• The legal basis for the processing of your data in order to organize your participation in the Event is the contractual obligation of Alira, in the context of your registration for the Event. If you do not provide us with the necessary data in this context, it will not be possible to properly manage your registration for the Event.
• The legal basis for the processing of your data in order to externally communicate about the Event (via the taking and use of photographs taken during the event where you may appear) is your consent.
• The legal basis for the recording and making available of the recording of presentations made during the Event (on which you may appear) is your consent. Two situations must be distinguished:

You Attend the Event in Person: If you attend the event in person, your consent to the use and disclosure of your image, as well as consent to the processing of your personal data, will be requested through a form provided upon arrival.

You Attend the Online Event: If you participate in the Online Event, we draw your attention to the fact that your camera is turned off by default and that, if you turn it on, you may appear as part of the recording of presentations. If you do not wish to appear on the recording, please keep your camera off. However, if you turn on your camera, you change the initial settings set by default, which means that you perform a clear positive action by which you understand and accept that your face may appear on the recording that will be provided to the participants. You will be reminded of this at the beginning of the event.

• With regard to promotional activity, Alira, as Data Controller, hereby informs that the personal data you voluntarily provide will be processed for the following purposes, with your consent:
• Marketing Activities (sending of advertising material, market research, commercial communication);

The legal basis related to Data processing for marketing purposes is your consent.

Following this information notice the consent for promotional activity can be accorded. The refusal to give consent for promotional activities will not prevent from the participation to the webinar.

6. Data Sharing – Recipients or Categories of Recipients of Personal Data

We do not sell, trade or transfer your personal data to third parties. However, if you agree that your photographs may be used to communicate about the event after it has taken place, you should be aware that these photographs may appear on Alira websites and/or on social networks.

Recordings of presentations made during the event will be provided to participants for a limited period after the event.

Third parties involved in the webinar which will process personal data for the aforementioned purposes are entitled to process such data and will act in accordance with the principles of the GDPR. It is hereby specified that the third parties to whom personal data are provided for the aforementioned marketing purposes will act in accordance with the principles of the GDPR.

Personal data acquired by Alira Health are not subject to dissemination. These data may be communicated within the Alira Health group and be known by the persons tasked with data processing in accordance with the principles of the GDPR.

For the purposes of maintenance of this website, Alira Health may use third parties, who therefore may have access to your data. However, these individuals will be appointed as Data Processors or authorized persons tasked with data processing, and will receive adequate operating instructions, particularly in relation to the adoption of minimum security measures.

Your personal data can only be processed by Zoho (website host and payment provider). For more information on the data processing carried out by Zoho, you can consult the privacy notice available on their website at https://www.zoho.com/privacy.html

7. How Long Do We Keep Your Information?

Alira will keep your personal data for a period not exceeding that necessary for the aforementioned purposes and in any case, no more than 3 years after the end of the event and in any case until the data subject withdraws the consent to data processing when applicable.

8. Transfer of Personal Data to Third Countries

Data processing may be carried out in a Member State of the European Union (EU), in a Member State of the European Economic Area (EEA) or in a Third Country. In case of transfer of data to a recipient established in non-EU third countries, the transfer is subject to specific provisions to protect personal data in compliance with the GDPR. Therefore, Alira has committed to comply with those provisions (Chapter V of the GDPR).

For the purposes specified, Alira Health uses the platform Zoho CRM, which is managed by the company ZOHO CORPORATION B. V, with registered office at Beneluxlaan 4B, 3527 HT Utrecht, the Netherlands including ZOHO CORPORATION PVT. LTD. incorporated and registered in India whose registered office is at Estancia IT Park, Plot No. 140 & 151, GST Road, Vallancherry Village, Chengalpattu Taluk, Kanchipuram District 603 202, INDIA by adopting data protection clauses set forth by the European Commission.

9. Mandatory or Optional Nature of Data Communication

The communication of your personal data is a contractual requirement. The refusal to communicate them will prevent Alira to register you to participate to the webinar.

For purposes that rely on your consent, the provision of your personal data is optional. The refusal to communicate them will not prevent you to participate to the webinar.

10. Existence of an Automated Decision-Making Process

Alira Health does not use any automated decision-making process.

11. How Do We Protect Your Information?

ALIRA treats your personal data confidentially and uses at least the same level of care in safeguarding your personal data as used with its own confidential information of a similar nature.

Your personal data is stored on secure systems and is only accessible by a limited number of people with special access rights and who are bound by confidentiality obligations.

12. Your Rights

Based on the GDPR, you have the following rights:

• Information: You have the right to be informed about the processing of your personal data;
• Access: You have the right to obtain confirmation that personal data concerning you are or are not being processed and, where applicable, all the information necessary to make the processing of your data transparent;
• Rectification: You have the right to demand the rectification of inaccurate or incomplete data concerning you;
• Erasure: You have the right to request the erasure of your personal data incertain circumstances;
• Restriction of processing: You have the right to restrict the processing of your data in certain specific circumstances;
• Data portability: You have the right to receive or have your personal data transferred to another organisation in a machine-readable form;
• Objection: You have the right to object at any time, for reasons relating to your particular situation, to the processing of your data;
• Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling; and
• Right to withdraw your consent: Where you have given your consent for the processing of your data, you may withdraw it at any time without justification.

Please, note that these rights are not absolute and will be assessed on a case-by-case basis.

If you wish to exercise any of these rights, you can contact Alira’s Data Protection Officer: [email protected]

You also have the right to lodge a complaint with the data protection authority of the state of your habitual residence, place of work, or place of alleged infringement if you believe that your personal data is not being processed in accordance with the GDPR.

13. Contacts

Alira Health
1 Grant Street, Suite 400
Framingham, Massachusetts 01702
United States
[email protected]
+1 (774) 777 5255

Alira Health DPO
[email protected]

Data Protection Authorities
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Event Photos and Presentation Recordings

In accepting the Privacy Policy, you understand that Alira Health undertakes to process your information in accordance with applicable laws, in particular the General Data Protection Regulation (“GDPR”), and:

• You authorize Alira Health SAS (Alira), whose registered office is located at 1 Grant Street to take photos where you will appear during the Event.
• You authorize Alira Health to use, reuse, copy, reproduce, publish, display, distribute and disclose the photographs taken at the event on which you would appear. These photographs may only be used for the following purpose: communication about the event, through publication by means of company advertising channels; through publication on the website, in company presentations and on company advertising material (brochures, advertisements).
• You authorize Alira Health to record and disclose to participants for a limited time the recording of presentations made during the event, where you may appear.
• You authorize Alira Health to the processing of your personal data for marketing purposes (namely direct sale, sending of advertising material, market research, newsletters, and commercial communication).
• You authorize Alira Health to the processing of your personal data for profiling activities.
• You authorize Alira Health to the processing of your personal data for communicating data to third parties for marketing purposes.
• You understand that these authorizations are voluntary, and you can customize your approval at any time by contacting [email protected].
• You understand that you will not receive any financial compensation of any kind based on this authorization, or as a result of any publication of the photographs where you appear.

Alira Health Code of Business Conduct and Ethics

The Alira Health Code of Business Conduct and Ethics defines the framework for business and personal behavior across our organization. To access our Code of Ethics, please click here.

Updates to this Privacy Notice

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

Please contact us at any time if you have any questions about this Privacy Policy, or wish to exercise your rights.

Our data protection officer will be glad to answer any questions regarding data protection matters: [email protected]

In the event our data protection officer should be unable to answer your enquiry to your full satisfaction you may complain to the data protection supervisory authority having competence at your place of residence.