This Policy is intended to explain the conditions under which Proficient Life Pharma collects, uses, and discloses personal and other information in connection with the Site, and your rights in relation to that information. By visiting our Site and/or using the features made available to you on the Site, you are agreeing to the terms of this Policy.
The personal and other information that we collect about you is controlled by Proficient Life Pharma, which is headquartered in the United States at 500 Totten Pond Rd., 6th Floor, Waltham, MA 02451.
What information we collect about you
Proficient Life Pharma collects “non-personal information” about Site users and may also collect “personal information” that you voluntarily provide to us. For purposes of this Policy, “non-personal information” is information that Proficient Life Pharma cannot directly associate with a specific person without the aid of additional information, and “personal information” is information that we can associate with your identity. The non-personal information we collect may include information that others could potentially associate with your identity, which is why we protect it as set out in this Policy.
You can visit the Site without submitting any personal information. However, if you send us an email or submit information in an interactive portion of our Site, then you may voluntarily provide personal information to us. We may combine personal information with other information that we or third parties collect about you in other contexts. If so, we will treat such combined information as personal information and protect it in accordance with this Policy.
Web log data. When you use the Site, we may automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
The Site or the emails that you receive from Proficient Life Pharma may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email.
Third party analytics.
We also may partner with certain third parties to collect, analyze, and use some of the personal and non-personal information described in this section. For example, we may allow these third parties to set cookies or use web beacons on the Site or in email communications from Proficient Life Pharma. This information may be used for a variety of purposes, including online behavioral advertising, as discussed below (see the section entitled “How we share personal and non-personal information with third parties”).
How we use the personal and non-personal information that we collect
Proficient Life Pharma uses the information that we collect for a variety of purposes. If we have personal information about you, we may use it, for example: to respond to your questions or requests concerning the Site or other services offered by Proficient Life Pharma or our partners; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.
We use the non-personal information that we collect for such purposes as: counting and recognizing visitors to the Site; analyzing how visitors use the Site and various Site features; improving the Site and enhancing users’ experiences with the Site; creating new products and services or improving our existing products and services; enabling additional website analytics and research concerning the Site; and managing our business. Proficient Life Pharma may link non-personal information gathered using cookies and web beacons with personal information. But in that event, we will treat the combined information as personal information.
How we share personal and non-personal information with third parties
We share your personal information and non-personal information with other parties for a variety of purposes, as described below.
Third party online tracking.
We partner with certain third parties to collect the non-personal information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of Google Analytics cookies here. If you prefer to prevent all or some third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Our site currently does not respond to “do not track” browser headers, but you can limit tracking through these third-party programs by taking the steps described above.
Third-party service providers and business partners.
Proficient Life Pharma may choose to use other third-party service providers to host and manage the Site, and for other Proficient Life Pharma business activities. These service providers may collect and/or use your information to assist us in achieving the purposes discussed above in the section entitled “How we use the personal and non-personal information that we collect.” For example, we may use third parties to help us target and implement our email communications and direct mailings. We also use third-party platforms to help us manage our relationships with our customers, prospective customers, and research partners.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
We may use or share your personal or non-personal information with third parties when we believe, in our sole discretion, that doing so is necessary:
- to comply with applicable law or a court order, subpoena, or other legal process;
- to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- to establish, protect, or exercise our legal rights or defend against legal claims; or
- to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
From time to time, Proficient Life Pharma may also generate and share anonymous and aggregated information about Site users, such as reports on trends in the usage of our Site, the overall number of Site visitors, and the number of times that individual pages on our Site are viewed.
Proficient Life Pharma uses commercially reasonable physical, electronic, and procedural safeguards to protect personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and thus we cannot guarantee the absolute security of personal or other information.
Reviewing and updating your information
If you want to learn more about the personal information, if any, that Proficient Life Pharma has about you, or you would like to update or change that information, you may contact us by email at firstname.lastname@example.org.
Information for Site users from outside the United States
The information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above. Proficient Life Pharma may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or non-personal information to us, you expressly consent to such transfer and processing.
Links to External Sites
Our Site contains links to external websites that are maintained by third parties, such as clinicaltrials.gov maintained by the U.S. National Institutes of Health. We are not responsible for the information posted on these external sites. We are also not responsible for the collection, use or sharing of information by the operators of these external sites, which are subject to their own privacy policies and terms of service.
The Site is not directed to children under the age of 13, and Proficient Life Pharma will never knowingly collect personal or other information from anyone it knows is under the age of 13.
Changes to this Policy
Technology and the Internet are rapidly changing. Proficient Life Pharma is likely to make changes to the Site in the future and as a consequence will need to revise this Policy to reflect those changes. Proficient Life Pharma will post all such changes on the Site, so you should review this page periodically.
Questions or comments
If you have any questions or comments regarding our Policy, please email us at:
Effective date: November 15, 2016.