AMPLITY HEALTH PRIVACY NOTICE

Last update: 30^th April, 2023

INTRODUCTION

Amplity Health understands that your privacy is important to you. Our commitment to ensuring that the processing of all Personal Information is carried out with integrity and in accordance with all relevant data protection law is explained in our company’s Data Privacy Policy, which can be found here.

This Privacy Notice relates to your use of this website at Amplity.com and all related sites operated by Amplity Health, its affiliates and subsidiaries (“the Site” or “Sites”). It explains the types of Personal Information that we may collect and store, how we collect it, how we use and share your information and your rights and the choices available to you.

By visiting the Site, or by using one of the services offered, you are accepting the practices described in this Privacy Notice and the other Terms of Use of this Site, which can be found here.

Except where specifically stated below, this Privacy Notice does not relate to Personal Information gathered in other ways, or through channels unrelated to this Site.

DEFINITIONS USED IN THIS PRIVACY NOTICE

“Amplity Health”, “we”, “us” means Amplity Inc and all of its affiliated and subsidiary companies.

“Cookies” means cookies, web beacons, pixel tags, clear gifs, and other similar functional and tracking technologies typically used by websites and stored by a browser on the host device during, and possibly after, use of a website.

“Personal Information” is any information that identifies, or may be used to identify, an individual, where “individual” means any natural person. Typically, this may include: your name; your home or other physical address; telephone number; email address or other identifiers such as social media accounts and /or usernames but can also include information automatically collected by Cookies.

PURPOSE OF COLLECTION: OUR USE OF PERSONAL INFORMATION

Personal Information which you voluntarily submit on the Site (for instance during registration to the Site or for services offered) may be used by Amplity Health for a variety of legitimate business purposes which could include, for example:

• verifying your identity
• obtaining your consent, as appropriate
• providing you with access to certain sections and features of the Site
• providing you with access to certain services or subscriptions that may be offered, and which you have opted to receive
• communicating with you about your use of, and activities on, the Site, including notification of maintenance, updates and new features
• contacting you regarding conferences, educational activities, news and helpful resources
• completing requested transactions (and any related business operations)
• responding to your questions, comments, suggestions and requests
• providing offers or information about products and services to you
• requesting your feedback, for instance to assess user satisfaction, needs and interests, to help us create new tools, features and services or to evaluate effectiveness of the services that we offer
• delivering content or ads of interest to you or for other marketing purposes
• sending you materials on behalf of trusted third parties
• informing you of significant changes to our Terms of Use or Privacy Policy

We ensure an appropriate lawful basis to allow us to use your Personal Information. Typically, these may be

• our legitimate interest
• your explicit consent
• a requirement on us to fulfill a statutory obligation
• a requirement on us to fulfill a contractual obligation with you, or because you have asked us to do something before entering a contract with us.

You may choose to access certain additional services via this website (e.g. registration to our recruitment process, registration to educational activities etc.). Where necessary, through supplementary privacy notices, we will provide additional, specific detail regarding the use of your Personal Information for that purpose, your rights and how to exercise them. Where required we will also gather your further consent.

We gather information related to your use of the Site itself, automatically, through the use of Cookies. This information helps us to tailor and improve Site content, advertisements, market research, Site analytics and operations, and to maintain Site security. A detailed explanation of our use of Cookies within this website, and of the choices available to you regarding their use, can be found here.

SHARING YOUR PERSONAL INFORMATION

We may share your Personal Information with our affiliates and subsidiaries, all of whom operate under the Amplity Health Data Privacy Policy.

We may also share your Personal Information with third-party processors who, acting as our agents, under our instructions, provide specific services and perform functions on our behalf. These third-party processors include companies or individuals that host or operate our Site, provide platforms that we use to store, manage or analyse data, provide customer services, administer our promotions, provide tools and online software and perform other similar functions for us. They are contractually bound to meet standards consistent with our Data Privacy Policy, to use the shared Personal Information only for the limited purposes we have defined and to provide at least the same level of protection for your data as we do.

On certain pages of our Sites, you may have opportunities to request, and consent to receiving, additional services, information or marketing offers directly from partners, sponsors and other third parties not acting directly on behalf of Amplity Health (See ‘Further Information about Specific Services’ below). Necessary Personal Information will be shared with your consent. These parties will become independent controllers of your Personal Information, which will become subject to the service provider’s own Privacy Policy and business practices. Amplity Health takes reasonable and appropriate steps to ensure the quality and integrity of such services, including agreements to ensure compatibility with our own Data Privacy Policy which: specify that the Personal Information is shared only for limited and specified purposes; oblige the third party to comply with, and provide levels of privacy protection required by applicable law (and to notify us if this becomes impossible) and; oblige the third party to implement reasonable security procedures and practices appropriate to the nature of the Personal Information to protect it from unauthorized or illegal access, destruction, use, modification, or disclosure.

Information (including Personal Information) gathered automatically through the use of Targeting Cookies may also be shared with service providers, partners, sponsors or advertisers for the purposes described. A detailed explanation of how this information may be shared can be found here.

Our Sites carry convenient mechanisms to allow users to easily control their choices as to what information is automatically collected and shared, including

• options to control the use of Cookies
• an option to opt out of sale or sharing of Personal Information collected to third parties acting as a controller.
• an option to opt out of marketing communications.

Note: Under certain circumstances, we may be required to disclose your Personal Information to meet our legal obligations in response to valid requests by public authorities or law enforcement agencies.

SECURITY

Amplity Health maintains appropriate administrative, technical and physical information security measures to protect, as far as reasonably possible, the Personal Information in our care from threats such as theft, unauthorised access and misuse. Amplity Health has SOC2, Level 2 compliance.

Unfortunately, no company or service can guarantee complete security: Users of these Sites are responsible for the strength and security of any registration or account passwords and are encouraged to take other sensible steps to protect themselves and their Personal Information online, such as utilising appropriate local anti-viral and security software, limiting access to their devices and signing off after accessing their account.

INTERNATIONAL DATA TRANSFERS

Amplity Health is headquartered in the United States and our Site and service are hosted and administered in the United States, or hosted with cloud service providers who are headquartered in the United States. Users located outside the United States should be aware that the Personal Information that you provide to us, or that we obtain through your use of our Site and services may be transferred to, stored and processed in the United States and will be subject to U.S. privacy and data protection laws which may not be equivalent to the laws of your country of residence. However, your Personal Information will be protected to an adequate level as described in this Statement.

By using our Site and services, or by providing us with your information, you consent to the collection, transfer, storage, and processing of information to and in the United States.

FURTHER INFORMATION ABOUT SPECIFIC SERVICES

Registration

We offer some services that require registration. For the registration process, we collect only the information necessary, which may include name, address, telephone number, email address, and professional information and similar, depending upon the service you wish to access.

Registration provides you with choices regarding the types of membership updates, newsletters, event invitations, marketing and promotional materials, and other information that we send to you as a registered user. By registering with us, you agree that we may send you emails and other communications regarding information specific to our service(s) or other opportunities that we may provide at any given time according to your wishes. You may remove yourself from a mailing list at any time by clicking the opt-out or unsubscribe links provided at the bottom of every email we send you, and following the instructions.

Chat Rooms, Message Boards and News Groups and other such “Forums”

We may offer access to Forums where you can share information with other users and have a free exchange of ideas. Forums may include, but are not limited to, our social media channels such as LinkedIn, Facebook, Twitter, and Instagram. These discussions are open to the public and are not to be considered private: Any and all information that you provide on a Forum of any kind is public and may be collected by us and/or by third parties. Amplity Health has no responsibility for its subsequent use or dissemination. Users of any Forums do so at their own risk and should take care when posting any personal information.

Research

You may be invited to participate in research studies to help us to meet the mission and vision of Amplity Health or its Sites. You may also be invited to participate in program or market research studies and surveys conducted, on behalf third-party sponsors, by us or by a third party. Participation may require provision of additional Personal Information that may be combined with information already provided at registration or that we have received from a third-party source.

Notification of how your Personal Information will be used and shared will always be provided, and appropriate consent will be sought.

Where categories of sensitive information are involved higher standards of consent and additional measures will be implemented to protect against improper use, consistent with applicable law.

Continuing Education and Conference Attendance

By participating in Continuing Education (CE) activity through our Sites, requesting a credit for completing a CE activity or registering to attend conferences, you may be asked to provide Personal Information that may include name, address, telephone number, degree or certification, occupation or title, email address, company or organization, average number of patients per week, license details and other similarly necessary information.

The Information collected may be used to provide necessary reporting to the appropriate monitoring bodies and involved providers (see the section on ‘Sharing of Your Information’); to study the conferences and CE activities to improve effectiveness and understand educational needs; and to address your suggestions, comments and questions.

Marketing and Advertising

We may use Personal Information provided by you, or obtained from third-party sources, to target advertising and our marketing communications to your needs, interests, demographic information, and geographic location. We may also provide advertisements to you within our Sites based on information that our advertisers have collected from third-party sources and with the use of Cookies (Please see the supplementary statement regarding our use of Cookies and Similar Technologies available here.

Event Notifications and Invitations

We may send you notifications and invitations to conferences, awards ceremonies, webinars and other online events hosted by us, or where we are in attendance as guests, sponsors, exhibitors and/or speakers. We utilize third-party email marketing tools for the delivery of such notifications and invitations that comply with our Privacy Policy and all applicable data privacy legislation.

Please note: Registrations and/or sign-ups for the notified events may be made available on the Site, which may be managed by a third party, collected by the third party’s event management software, and subject to the third-party service provider’s own privacy policy. Users are strongly advised to read the relevant privacy policies and notices.

Promotional Offers

We may send offers to you on behalf of other partners and our sponsors. When we do this, we will do so per your request, and we will not share your Personal Information with that partner or sponsor. You may opt out to receive such offers or change the frequency in which you receive them by clicking on the opt-out or unsubscribe link provided in the promotional emails.

RETENTION OF PERSONAL INFORMATION

Your Personal Information will be retained only for as long as necessary to fulfil the purposes explained to you (a period which may in some cases be determined by your provided consent), to comply with applicable laws and regulatory requirements, or to allow establishment, exercise or defence of legal claims within any relevant statute of limitation.

Retention schedules are documented in Amplity Health’s Data Retention and Destruction Policy. Personal Information that is no longer necessary will be securely destroyed or anonymised and archived in accordance with the policy.

YOUR RIGHTS

You may always choose not to disclose information to us, but this may limit our ability to provide certain services to you.

Your rights regarding access to, and control of, your Personal Information vary depending on where you live and the applicable data privacy legislation. Typically, they will include rights to access, review, update, rectify, limit the use of, and delete the Personal Information we hold about you, Amplity Health is committed to helping you to understand your rights and to providing access to allow you to exercise those rights should you so wish. We will respond to all legitimate requests in full compliance with the relevant law.

If you would like exercise any data subject right available to you under the EU General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act, California Privacy Rights Act or any other applicable data privacy legislation, please contact us via one of the channels provided at the end of this Privacy Statement. We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests.

Supplemental US State Privacy Notice

Related to California (CCPA & CPRA), Virginia (VCDPA) and others

The following information and provisions apply to the Personal Information of residents of US States (inc California and Virginia) that we may collect and use. These provisions are supplemental to the other sections of this Privacy Statement.

The categories of Personal Information that may be collected, processed or disclosed for operational business purposes are shown below. This list includes information collected processed and shared within the 12 months preceding the date of this notice.

A. IDENTIFIERS: such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, government issued identifiers (e.g. social security number, device identifiers).

Shared with, for cross-context behavioural or targeted advertising: Ad networks and other third parties in the online advertising ecosystem.

B. CUSTOMER AND OTHER RECORDS: Paper and electronic customer records containing personal data, such as name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

C. PROTECTED CLASSIFICATIONS (as per California and Federal law): Characteristics of protected classifications under California or federal law such as race, colour, sex, gender, age, national origin, disability, and citizenship status.

D. COMMERCIAL INFORMATION: including records of products or services considered, purchased or owned.

E. BIOMETRIC INFORMATION: Physiological, biological or behavioural characteristics that can be used alone or in combination with each other to establish individual identity e.g. DNA, finger-print, diagnostic or lab results, imagery of the face and health or exercise data that contain identifying information.

F. USAGE DATA: Internet or other electronic network activity information, such as browsing and search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.

Shared with, for cross-context behavioural or targeted advertising: Ad networks and other third parties in the online advertising ecosystem.

G. GEOLOCATION DATA: Precise geographic location information about a particular individual or device.

H. AUDIO/VISUAL: Audio, electronic, or visual recordings, or similar information.

I. EMPLOYMENT HISTORY: Professional or employment-related information.

HCP personal data only shared with, for cross-context behavioural or targeted advertising: Ad networks and other third parties in the online advertising ecosystem.

J. EDUCATION INFORMATION: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

K. PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

CCPA, as amended by CPRA, gives residents of California certain rights, subject to some exceptions, regarding Personal Information held by businesses:

1. Your right to request disclosure:
   You may request disclosure of the following information regarding our use of your Personal Information covering the 12 months preceding your request, at no charge, up to twice every 12 months:
   
   • the categories of Personal Information that that we have collected about you
   • the categories of sources from which that we have collected your Personal Information
   • the categories of Personal Information that we have sold or disclosed
   • the business or commercial purpose for collecting or selling your Personal Information
   • the categories of third parties to whom your Personal Information was disclosed or sold
   • the specific pieces of Personal Information that we have collected about you in the previous 12 months
   (You may request a copy and have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance).


2. Your right to request deletion:
   You may request that we delete any Personal Information that we have collected about you (but please note that there are lawful exceptions which allow us to decline such a request, for instance where the deletion of information would hinder the completion of a transaction or prevent compliance with a contractual or other legal obligation).


3. You may request that we correct inaccuracies in your Personal Information.


4. You may request to receive a copy of your Personal Information in a portable, usable format.


5. You may request to opt-out of the processing of your Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
   If you are a Resident of California and would like to exercise any of the rights above, please contact us via one of the channels provided at the end of this Privacy Statement.


6. Your right to prevent sale or sharing of your Personal Information:
   You may request to opt out of the sale or sharing of your Personal Information by Rejecting All Cookies. Our websites carry a simple opt-out option upon arrival to allow you to do this.

We will not discriminate against you for exercising these rights.

CHILDREN

Amplity Health is committed to protecting the privacy of children. Our sites and services are designed and intended for use by adults. We do not knowingly collect personally identifiable information from any person under the age of thirteen (13). Accordingly, we request that individuals under the age of thirteen (13) not provide information or data through the Site or any other form of communication. As part of our commitment to protect the privacy needs of children, we also encourage parents/guardians to employ any and all parental tools available to monitor their children’s online activities.

CONTACT US

If you wish to exercise you rights or have questions or concerns regarding this Privacy Notice, please contact us at:

UPDATES TO THIS PRIVACY NOTICE

Our Data Privacy Policy and this Privacy Notice will be reviewed periodically to ensure that the principles accurately reflect the legal and business requirements for data privacy management: Changes may be made at any time and without prior notice to you. We will alert you to material changes when required to do so by applicable law by placing a notice on the Site, otherwise please note the “Last Updated” date at the top of the Privacy Notice indicates when this was last amended, which is also the “effective” date of the amendment.

 

V3 - Revision Date: 30th April, 2023