Last Updated: 27 July 2023

We at Lyceum CME USA Inc., operating as Lyceum Health (“Administrator”) are committed to protecting your privacy, and we take great care with your personal information that we gather when you access or use our site and related websites, applications, and services owned and operated by and that link to this Privacy Policy (collectively, the “Services”). This Privacy Policy is meant to help those that use our Services understand how we treat your personal information.

You are receiving this Privacy Policy because you are visiting a website (“site”) or using a mobile application (“app”) administered by Administrator. The Services delivered through the website or app is collectively known as the “Program” and is offered and administered by the Administrator. As a result, we are processing information about you which constitutes "personal information" and we consider the protection of your personal information and privacy a very important matter.

BY USING OR ACCESSING THE SERVICES IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

This Privacy Policy is divided into two parts. Part I contains practical information about the specific personal information we process when you use the Program at the “Site”, why we process this data and how. Part II contains more general information about the standard technical or transactional personal information which we are processing about visitors of our websites, the legal basis for using your personal information, as well as your rights in respect to all personal information collected about you.

Please note that we may revise this Privacy Policy from time to time, we invite you to carefully read this Privacy Policy and be sure to review this policy for any updates and changes. Any changes will be effective upon posting. The date of the last revisions will be posted at the top of this Statement. For any further questions in relation to the processing of your personal information, we invite you to contact the Privacy Officer by emailing us  here.

Part I – Key information

The Administrator is processing personal information about you when you are visiting the “site” and if you are registering to receive updates and information from the “site”. This “site” is intended to provide better healthcare when your personal health information and personally identifiable information is shared appropriately through the use of new technologies with your healthcare team members.

Specific personal information to be collected

For this purpose, we will collect the following specific personal information about you further to your consent:

• Your first and last name, date of birth, address information (State and Zip Code), Gender,

• your email address (and/or valid phone phone) when registering to receive updates and information from our website,

• your diagnosis, medical treatment, and care services

• the name and contact information of your prescribing physician and your extended healthcare team members as directed by your prescribing physician

• your health insurance information

This information may either be directly provided by you (e.g., when filling a web form or interacting with a website or app), provided by third-parties or obtained through trusted publicly available sources, having obtained your consent to provide us with such personal information where necessary under applicable law.

The consent is sought when you register to participate in the Program via a separate web page incorporated into the Program registration process. You may revoke your consent at any time. Withdrawing your consent will result in the termination of your participation in the Program and its Services. Upon such termination, no new personal information will be collected, the file containing your Personal Information will be maintained during the term of the Program for monitoring and regulatory purposes, de-identified, aggregated or anonymized data may continue to be used as described above.

Specific purposes for which we require your personal information

The collected information will be used by us for the following specific purposes:

• to allow you to receive the Program services including digitized assessments, reminders, other services, or information relevant as directed by your healthcare team, including but not limited to health assessments, health outcomes, reimbursement inquiry, reimbursement support, financial assistance, referrals to other healthcare services;

• to allow you to receive updates and information from our website further to your registration to receive these electronic communications;

• de-identified aggregated data to improve the website and support the Program services; and

• Any other purposes imposed by law and authorities.

Please note that the collected data may also be used by us for a number of other standard purposes (e.g., to measure the usage of our website and app), as set out in Part II below.

Specific third parties with whom we share your personal information

Other than as detailed below in Part II, section 2, we may disclose your personal information to a third party if we required to do so pursuant to applicable law or regulation, such as responding to requests from public and government authorities (including court order, subpoena, or governmental regulation).

Please note that we may also have to share your data with a number of other recipients (e.g., another entity of the Administrator if the entity collecting the data is not the same as the one using it) but always under strict conditions, as further explained in Part II.

Duration of storage

We will only store the above personal information and the personal information listed in Part II you share with us is stored on our database servers at Lyceum Health data centers (in whatever country they may be located) or hosted by third parties in contract with the Administrator who have entered into agreements with us that require them to observe this Privacy Policy. We have implemented technological measures to prevent individuals from accessing information without authorization. Data centers are designed to be physically secure and protected from unauthorized access by unauthorized persons. Information is stored for as long as is necessary to fulfil the purposes for which the information was collected and to comply with legal and regulatory requirements.

Cookies and other similar technologies

Please note that we rely on the usual cookies and other technologies for the standard purposes set out in Part II below (e.g., to ensure the proper functioning of our website or app).

Dedicated point of contact

Should you have any question in relation to the processing of your personal information in the above context, please contact the Privacy Office by emailing us  here.

Part II – General information

The second part of this Privacy Policy sets out in more detail in which context we are processing your personal information and explains your rights and our obligations when doing so.

1. On what basis do we use your personal information?

We will not process your personal information if we do not have a proper justification foreseen in the law for that purpose. Therefore, we will only process your personal information, if we have obtained your prior consent or, as permitted if the processing is necessary to comply with our legal or regulatory obligations.

2. Who has access to your personal information and to whom are they transferred?

We will not sell, share, or otherwise transfer your personal information in any identifiable way to third parties other than those indicated in this Privacy Policy. The Administrator limits the receipt of personal information that it collects to that which is necessary for the purposes of the Program. De-identified information in aggregated format may be periodically used to improve the website and deliver Program services to Lyceum’s clients.
Unless otherwise required by an applicable law, requests from public and government authorities (including court order, subpoena, or governmental regulation), your data is aggregated, de-identified (e.g., encrypt) or anonymized before sharing or transferred to other entities of the Administrator or those third parties indicated in the Privacy Policy.
In the course of our activities and for the same purposes as those listed in this Privacy Policy, your personal information can be accessed by or transferred to the specific third parties identified in Part I of this Privacy Policy and the following categories of recipients, on a need-to-know basis to achieve such purposes:

• our personnel (including personnel, departments or other companies of Administrator);
• health care professionals, health insurance providers or other third parties as needed for the Program’s administration and Services, including adjudication and processing financial assistance of claims paid on your behalf;
• our other suppliers and services providers that provide products and services to the Administrator;
• IT systems providers, cloud service providers, database providers and consultants of the Administrator;
• our business partners who offer products or services jointly with the Administrator;
• any third party to whom we assign or novate any of our rights or obligations; and
• our advisors and external lawyers in the context of the sale or transfer of any part of our business or its assets.

The above third parties are contractually obliged to protect the confidentiality and security of your personal information, in compliance with applicable law.
Your personal information may also be accessed by or transferred to any national and/or international regulatory, enforcement, public body or court, where the Administer is required to do so by applicable law or regulation or at their request.
If we transfer your personal information to external companies in other jurisdictions, we will make sure to protect your personal information by (i) applying the level of protection required under the local data protection/privacy laws applicable to the Administrator, (ii) acting in accordance with our policies and standards. You may request additional information in relation to international transfers of personal information and obtain a copy of the adequate safeguard put in place by exercising your rights as set out in Section 6 below.

3. How do we protect your personal information?

We have implemented appropriate technical and organisational measures to provide a level of security and confidentiality to your personal information.

These measures take into account:

• the state of the art of the technology;
• the costs of its implementation;
• the nature of the data; and
• the risk of the processing.

The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
Moreover, when handling your personal information, we comply with the following obligations:

• we only collect and process personal information which is adequate, relevant and not excessive, as required to meet the above purposes;
• we ensure that your personal information remains up to date and accurate (for the latter, we may request you to confirm the personal information we hold about you and you are also invited to spontaneously inform us whenever there is a change in your personal circumstances so we can ensure your personal information is kept up-to-date); and
• we may process any sensitive data about yourself you voluntarily provide in compliance with applicable data protection rules and strictly as required for the relevant purposes listed above, the data being accessed and processed solely by the relevant personnel, under the responsibility of one of our representatives who is subject to an obligation of professional secrecy or confidentiality.

4. How long do we store your personal information?

We will only retain your personal information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements.

5. How do we use cookies and other similar technologies on our websites and apps?

5.1. Cookies

Cookies are small text files which are sent to your computer when you visit our websites or use our apps. We use cookies for the purposes set out above and in accordance with this Privacy Policy.
We do not use cookies to track individual visitors or to identify you but to gain useful knowledge about how our website and apps are used so that we can keep improving them for our users. Personal information generated through cookies are collected in a pseudonymized form and subject to your right to object to such data processing, as set out below.
In particular, in addition to the cookies listed in Part I of this Privacy Policy, we may also use the following types of usual cookies:

• user interface customization cookies (e.g., cookies memorizing your preferences);
• authentication cookies (e.g., cookies allowing you to leave and return to our websites without having to re-authenticate yourself);
• video player cookies (e.g., cookies storing data needed to play back video or audio content and storing your preferences);
• first party analytics cookies (e.g., cookies memorizing the pages you visited and providing information about your interaction with those pages); and
• third party analytics cookies (e.g., cookies from third party suppliers tracking our website's statistics and vice versa).

Please note that you can modify your browser so that it notifies you when cookies are sent to it. If you do not want to receive cookies, you can also refuse cookies altogether by activating the relevant settings on your browser. Finally, you can also delete cookies that have already been set.
For more information as to how to manage cookies on your device, please consult the Help function of your browser or visit www.aboutcookies.org, which contains comprehensive information on how to do so on a wide variety of browsers (link is external).

5.2 Other technologies

We may also use other technologies on our websites and apps to collect and process your personal information for the same purposes as set out above, including:

• Adobe Flash technology (including Flash Local Shared Objects, unless you set your setting otherwise).

6. What are your rights and how can you exercise them?

You may exercise the following rights under the conditions and within the limits set forth in the law:

• the right to access your personal information as processed by us and, if you believe that any information relating to you is incorrect, obsolete or incomplete, to request its correction or updating;
• the right to withdraw your consent at any time, without affecting the lawfulness of the processing before such withdrawal; and
• any other privacy right afforded to you under an applicable law.

Please note however that, in certain circumstances, your refusal to accept cookies or your browser settings may affect your browsing experience and prevent you from using certain features on our websites or apps.
Please be aware that if you withdraw your consent, you will not be able to continue to participate in the Program.
If you have a question or want to exercise the above rights, you may send an email to the Privacy Office by clicking here and providing relevant information for us to be able to reply to your query.

7. What technical and transactional data may we collect about you?

7.1 Categories of technical and transactional data

In addition to any information collected about you under Part I of this Privacy Policy, we may collect various types of standard technical and transactional personal information about you during your use of our websites and apps which are necessary to ensure a proper functioning of our websites and apps, including:

• information regarding your browser and device (e.g., internet service provider's domain, browser's type and version, operating system and platform, screen resolution, device manufacturer and model);
• statistics in relation to your use of our website and our app (e.g., information regarding the pages visited, information researched, time spent on our website);
• usage data (e.g., date and time of access of our website and app, files downloaded);
• your device's location when using our app (unless you disabled this function by changing your device's settings); and
• more generally, any information you provide to us when using our website and app.

Please note that we will not knowingly collect, use or disclose personal information from a minor without obtaining prior consent from a parent or legal guardian.

7.2 Why are we collecting technical and transactional data?

We always process your personal information for a specific purpose and only process the personal information which is relevant to achieve that purpose. In addition to any purposes already communicated to you in Part I of this Privacy Policy, we also process your personal information collected during your use of one of our websites or apps for the following standard purposes:

• manage our users (e.g., registration, account management, answer questions and provide technical support);
• manage and improve our website and apps (e.g., diagnose server problems, optimize traffic, integrate and optimize web pages where appropriate);
• measure the usage of our website and apps (e.g., by drawing up statistics about the traffic, by gathering information regarding the users' behaviour and the pages they visit);
• improve and personalize your experience and better tailor content to you (e.g., by remembering your selections and preferences, by using cookies);
• send you personalized location-based services and content;
• improve the quality of our products and services and expand our business activities;
• monitor and prevent fraud, infringement and other potential misuse of our website or app;
• reply to an official request from a public or judicial authority with the necessary authorisation;
• manage our IT resources, including infrastructure management and business continuity;
• preserve the company's economic interests and ensure compliance and reporting (such as complying with our policies and local legal requirements, tax and deductions, managing alleged cases of misconduct fraud, conducting audits, defending litigation);
• archiving and record keeping; and
• any other purposes imposed by law and authorities.

8. How will you be informed of the changes to our Privacy Policy?

Any future changes or additions to the processing of your personal information as described in this Privacy Policy will be notified to you in advance through an individual Policy using our usual communication channels (e.g. by email) as well as through our websites or apps (via banners, pop-ups or other notification mechanisms).

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