PharmaCCX Privacy Policy

Effective Date: December 10, 2018

Welcome to PharmaCCX!  PharmaCCX (“PharmaCCX,” “we,” “us,” “our”) respects the privacy of individuals.  This Privacy Policy describes how we collect, use, and share certain information about you and your company or organization (“you,” “your,” “user”) in connection with our website, which is located at https://pharmaccx.com/ (“Website”) and our online Exchange platform (“Exchange”) which is comprised of “Terminal” (ccxterminal.com) and our Role-Playing Platform “Sandbox” (ccxsandbox.com), collectively, the “Services”.  It also explains your rights and choices with respect to such information and the steps you can take to protect your privacy.

Please read this policy carefully.  By visiting or using the Services, clicking “I agree” or any other button indicating your acceptance of this Privacy Policy, or otherwise providing information to PharmaCCX, you are consenting to the collection, use, and sharing of your information as described in this Privacy Policy.

Certain portions of our Services may be subject to amendments to this Privacy Policy, as may be expressly set forth in any separate terms and conditions applicable to those portions of our Services. 

The information that we collect in connection with our Services is controlled by PharmaCCX, which is headquartered in the United States at 200 Portland Street, Boston, Massachusetts 02114.  As a result, such information may be transferred to and processed in the United States, as described in the section below titled “Information for Individuals Outside the United States.”

Information that We Collect

We and our service providers collect a variety of information through the Services.  We collect information from you directly when you provide it to us through the Services or when your company or organization or other users of the Services provide it to us.  We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Services.  This information includes, but is not limited to:

●      Account and profile information.  We collect information when you create an account, such as the name and address of your company or organization, your first and last name, telephone number, and email address, and the password for your account.

●      Information about your company or organization.  We collect information about your company or organization such as company or organization name, contact details, departments, and pharmaceutical products sold or sought for purchase by your company or organization.  

●      Information you provide to us directly or through the Services.  We collect information that you provide to us directly or through the Services, such as when you post information within the Exchange, including indications or conditions and populations targeted by a therapy, as well as contingencies for a bid, such as price point, or when you communicate with us through the Services, such as through the “Contact” feature on the Website or “Help” form on the Exchange.

●      Information provided to us by other users of the Services.  We may collect your name and contact information from other users of the Services, for example, when a company or organization is interested in negotiating or bidding with your company or organization and identifies you as the contact, or when your company or organization designates you as a user and/or sets up a profile for you.  We then use your information to invite you to the Exchange.

●      Information collected automatically.  When you use our Services, we or our third-party service providers may automatically receive and record certain information.  For example, this may include your device’s IP address, information about your use of the Services during your current session and over time (including the pages you view and the files you download), the date and time of your visit, links you click, searches conducted, the website visited before navigating to the Services, your software and hardware attributes (including browser and operating system type and version, device type, and device identifiers), and your general location inferred from IP address.  To obtain such information, we or our third-party service providers may use the following technologies to recognize your device and collect information about your Services usage:

o   Server logs.  When you use the Services, we automatically receive and record certain information from your computer (or other device) and your browser.  To obtain such information, we may use server logs or applications that recognize your device and gather information about its online activity.

    • Cookies.  We also use cookies on the Services.  Cookies are small files that are stored on your device by your web browser.  A cookie allows us to recognize whether you have visited before and may store user preferences or other information.  We also use cookies for analytics purposes.  If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it.  You can also delete cookies from your device.  However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.   

    • Web beacons, tags, pixels, and similar technologies.  The Services or the emails that you receive from PharmaCCX may use an application known as a “web beacon” (also known as a “tag” or “pixel”) and similar technologies.  Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data.  For example, it may allow an email sender to determine whether a user has opened a particular email.

We may combine information collected through the Services with information that we collect in other contexts, such as information from our email communications or phone calls with you, and data we collect offline, such as payment information from your company or organization.  We will treat such combined information in accordance with this Privacy Policy.

How We Use Information that We Collect

We and our service providers use the information that we collect for a variety of purposes, including:

●      Providing the Services.  To invite you to the Exchange, provide our Services to you, fulfill the terms of any agreement you have with us, respond to your requests, and for other purposes related to managing our business;

●      Communicating with you.  To communicate with you regarding your account, important updates regarding our Services, and other administrative issues;

●      Sending newsletters or other promotional messages.  To send you newsletters or other promotional messages regarding our Services.  We will seek your consent before sending such messages to the extent required by law;

●      Conducting analytics and improving our services.  To count and recognize users of the Services, analyze how the Services are used, improve the Services, create new products and services, and conduct analytics, including as described in the section below titled “Analytics”;

●      Compiling aggregated and de-identified information.  To compile aggregated and de-identified statistics or reports that we may share with our partners or other third parties;

●      Legal purposes.  For legal or other necessary purposes, including as described below in the section below titled “How We Share information.”

How We Share Information

We share information with third parties for a variety of reasons, including as follows:

●      Service providers.  We use third-party service providers to help us manage and improve our Services.  These service providers may collect and use your information only to assist us in achieving the purposes discussed in this Privacy Policy.  For example, we may use third parties to host our Website and Exchange platform, perform data storage and processing services, and perform analytics.

●      Other users of the Services.  We may, in limited circumstances, share information directly with other users of the Services.  For example, when you or other users open a bid or negotiation on the Exchange, you or the user who opened the bid or negotiation can invite other users to the bid or negotiation and, as a result, all users will be able to view the names of the other users in the bid or negotiation.  We may also allow users of the same company or organization to view the names of other users of the Services within that company or organization. 

●      When you directly share information.  In addition, you may directly share your information with other users when you participate in negotiations or when you post questions or comments to other users through the Services.  Companies or organizations may also share through the Exchange information about indications and populations targeted with a specific therapy, and other information relevant to the Exchange bid process.  Please ensure when using these features that you do not submit any information that you do not want to be shared with other users.      

●      Legal purposes.  We may use or share your information with third parties when we believe, in our sole reasonable discretion, that doing so is necessary:

o   To comply with applicable law or a court order, subpoena, or other legal process;

o   To investigate, prevent, or take action regarding illegal or prohibited activities, suspected fraud, violations of our rules or terms and conditions, or situations involving threats to other athletes, volunteers or users, our property, or the property or physical safety of any person or third party;

o   To establish, protect, or exercise our legal rights or defend against legal claims.

●      Organizational transfers.  We may share your information with third parties to facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our organization or assets.

●      Aggregated and de-identified information.  We may share aggregated and de-identified information with third parties, such as by publishing or sharing reports with third parties about trends in the usage of the PharmaCCX Services.

●      With your consent.  Other than described in this Policy, we will share your information with third parties only with your consent.

Contact Information

You may choose to provide us with another individual’s name, email address, and/or phone number in order to invite the individual to the Exchange and Services.  By providing another individual’s information, you represent that you have obtained the consent of the individual concerned, where necessary, regarding such disclosure to us and our use of that information to contact the individual.

Analytics

We partner with certain third-party service providers to collect information to engage in analytics, auditing, research, and reporting.  These third parties may use server logs, web beacons, tags, pixels, and similar technologies, and they may set and access cookies on your computer or other device. 

In addition, we may use Google Analytics on our Website (but not other areas of our Services) to help collect and analyze certain information for the purposes discussed above.  You can learn more about Google Analytics’ data practices by clicking here and opt out of the use of cookies in web browsers by Google Analytics by clicking here.  We do not use Google Analytics on the Exchange platform or in the Terminal or Sandbox

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy.  If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies.  Although our Site currently does not respond to “do not track” browser headers, you can limit tracking by taking the steps discussed above.

Third-Party Links, Websites, and Apps

The Services may contain links to websites of other third parties.  If you follow a link to any of these websites, please note that these websites (and any services that may be accessible through them) have their own privacy policies.  We are not responsible for the privacy practices of other websites or the information you share through such other websites.  We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites.  This Privacy Policy applies solely to information collected in connection with the Services.

Data Security and Retention

PharmaCCX uses reasonable physical, technical, and administrative safeguards to protect your information against loss or unauthorized access, use, modification, or deletion.  However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your information. 

PharmaCCX retains your information for as long as reasonably necessary for its legitimate business purposes, to provide the Services to you, to fulfill the purposes described in this Privacy Policy, or as required by law.

Your Rights and Choices

You may review your account information on the PharmaCCX Exchange at any time by logging in and viewing your profile.  You may reset your password at any time through your account profile.  To update or revise any other information about you within your account please contact us at privacy@pharmaccx.com

If you have subscribed to newsletters or other promotional communications from us, you may unsubscribe by clicking the “Unsubscribe” link at the bottom of each message.  Please note, you will still receive administrative messages related to your account from us.

You may have additional rights under applicable laws to request access to, correction of, deletion of, or restrictions on the processing of certain information.  You may have rights under applicable laws to opt out of or withdraw consent to further processing, request copies of your personal data, or lodge a complaint with a data protection authority in your jurisdiction.  To make such request and/or inquire about such rights, please send us an email at privacy@pharmaccx.com.  For your protection, we may only implement requests related to information that we have associated with the email address used to send us your request, and we may need to verify your identity before implementing your request.

Information for Individuals Outside the United States

The data that we collect through or in connection with our Services is stored in the EU.  However, we may transfer and process that data in the United States for the purposes described above.  PharmaCCX also may subcontract the processing of your data to, or otherwise share your data with, third parties in the United States or other countries outside 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 visiting or using the Services, clicking “I agree” or any other button indicating your acceptance of this Privacy Policy, or otherwise providing information to PharmaCCX, you explicitly consent to such transfer and processing.

We may implement standard contractual clauses, contractual arrangements, or other mechanisms, as appropriate, to safeguard your information during such cross-border transfers.  We also may transfer information to the United States or another country as necessary for the performance of our agreements with you or to establish, exercise, or defend legal claims.

If you are an EU resident, our legal basis for processing information will depend on the type of information at issue and the purpose for which it is collected and used.  In some cases, we rely on your consent to process information, or we process information as necessary for the performance of our agreements with you. We also may rely on our legitimate interests to process your information, for the purposes described in this Privacy Policy, except where such interests are overridden by your data protection interests or fundamental rights and freedoms.

Children’s Privacy

The Services are not intended for nor directed to under the age of 18.  We request that such individuals do not provide information to us through any of the Services.

Changes to This Privacy Policy 

We may revise this Privacy Policy periodically in the future.  If we make any material changes, we will post the revised Privacy Policy on our Website with an effective date indicating when the revised Privacy Policy will take effect.  We encourage you to review this Privacy Policy periodically.

Contacting Us

If you have any questions or comments regarding our Privacy Policy, please email us at privacy@pharmaccx.com.