ISPE Privacy Policy

Last Modified: May 22, 2019

The International Society for Pharmacoepidemiology (also referred to in this policy as "ISPE" or "we" or "us") is a controller and processor of certain information provided to us by our members, industry contacts, stakeholders, and visitors to our websites and services related to our website. This Privacy Policy describes our general data collection and processing practices.

We collect personal data to support our mission to members and constituents
ISPE is the primary forum by which scientific, data, and health care experts from academic, regulatory, industry and service provider settings engage and collaborate around pharmacoepidemiologic research and methods. We provide our members with resources, education, and networking events that help them engage and collaborate around pharmacoepidemiologic research and methods and stay current in these areas. As part of our mission ISPE:

• advocates on behalf of our members and others in our industry;
• educates through conferences, webinars, and other methods;
• provides access to written resources, databases of information, unique collections of materials and documentation;
• provides the opportunity to grow professionally and to network at industry events and through participation in our numerous committees, special interest groups, chapters, and other internal entities we organize;
• distributes information about the industry through our publications and our websites;
• provides a venue, at our conferences and other meetings, for constituents to meet and learn about service providers and vendors who support the industry;
• provides an online, searchable membership directory;
• maintains certain records of members; and
• maintains a job board.

We collect information from individuals when necessary to our mission or to fulfill certain requests you make of our organization. We collect information in a way that is consistent with our commitment to fair and transparent information practices and data ethics.

ISPE does not collect any personal information from users browsing its website. Users to the public areas of ISPE's website browse anonymously (that is, though your interaction with our website is accompanied with personal information inherent in your browser -- limited by your data settings -- we make no effort to capture that data). Only aggregate data -- such as the number of hits per page -- are collected and reported for our internal use. Aggregate data are only used for internal and marketing purposes and do not provide any personally identifying information (for example, to understand that one area of the website is more popular than another).

Some definitions
The terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization.

"Personal information" is any information that can be used to identify an individual, and may include things such as your name, physical address, email address, phone number, member number, login information, marketing preferences, company affiliation, photo, or payment card information. Personal information can also include information that does not identify you but could be combined with other information in a way that enables you to be identified such as age, gender, job title or function, profession, committee membership or participation, zip/postal code, IP address, and current location.

When is personal information collected?
During our relationship with you, we may collect personal information from you when you:

• apply for membership with ISPE (or when someone applies for membership on your behalf) by voluntarily providing information required to establish an account unique to you;
• register for or attend one of our events;
• sign up for a publication or service we offer;
• pay for a product or service offered through our website or one of our other marketing channels;
• contact us for information about us or our products and services;
• seek to become an exhibitor, speaker, or sponsor at one of our programs or events;
• visit our website; or
• otherwise provide personal information to us.

We may collect personal information from third-party sources and engage third parties to collect personal information on our behalf.

If we receive personal information from someone who reasonably purports to be your representative or acting on your behalf, we will assume that such information is being provided to us in a manner consistent with applicable law, including any applicable privacy rules and internal policies you may have.

How do we use your information?
We gather your personal information (see definition above) to help us fulfill our mission. More specifically, your personal information may be used to:

• inform you of upcoming ISPE events;
• process transactions between you and ISPE, such as event registration and purchase requests;
• monitor participation and performance in our educational programs;
• answer your questions;
• manage committee assignments [or other internal governance bodies];
• compile registration lists, badging, and security for events;
• manage all billing processes;
• assist you with your online account;
• report results or progress in connection with our educational opportunities;
• deliver educational subscription material;
• advertise speaker presentations;
• provide and support requested products or services;
• provide member, sponsor, and exhibitor directories;
• analyze and monitor the use of our products, services, and website;
• offer you other related products and services;
• communicate with you for marketing or member satisfaction purposes;
• invite you to participate in voluntary mailings or other events, which may include product surveys or participation in other initiatives we may announce from time to time; and
• support our legal and compliance obligations.

We will not use your personal information for any other purposes without first disclosing such purposes at the time we collect the information and providing you the opportunity to consent.

Do we share your personal information with others?
We may share personal information with third-party service companies that perform business and administrative operations for ISPE or provide services that help us carry out our mission. These services include:

• headquarter/membership management services (provided by PAI Management Corporation);
• an association management system (AMS) for membership management and ecommerce (provided by Impexium);
• Content Management Systems (CMS) necessary to serve website content (managed by Potomac Digitek);
• email and marketing automation provider as necessary for sending emails to our users (provided by Constant Contact);
• online community platform, ISPE Exchange, that integrates with the above services (provided by Higher Logic);
• providers of payment processing and accounting, as necessary to process payment from our users (provided by First Data, for merchant banking services, and Authorize.net, for credit card processing);
• publication of association subscription material;
• regular communications with members;
• management of our online job board (provided by Boxwood Tech / Naylor, Inc.);
• managing educational programs at our events;
• data management software (SurveyGizmo; Expo Logic);
• processing direct mailings to you;
• managed IT systems;
• meeting and presentation recording/remote viewing; and
• other bodies as required by law or regulation.

Our third-party service providers are prohibited from using your personal information for any purposes other than as necessary to provide the specific services described above or as otherwise provided by law. In addition, we require that our service providers treat your personal information with the same degree of care we use.

If you attend a conference or event hosted by ISPE, we may share your contact information with current or prospective attendees, sponsors, or exhibitors as part of a registration roster. Generally, we will limit such information to your name, title, employer, and office location. We offer you the choice of unsubscribing from these lists during registration for our events. We may take photos, and video or audio recordings at our events and use these recordings to publicize the event, including by posting photos to social media or other public forums. We consider your attendance at our events as evidencing your consent to our use of such recorded media.

Except as set forth in this section and in the "Laws and legal rights" and "Reservation of rights in the case of cessation of the business" sections, below, we will not share your personal information with third parties.

Laws and legal rights
In addition to the third parties mentioned above, we may disclose your personal information if we believe in good faith that we are required to do so to comply with an applicable statute, regulation, rule, law, subpoena, search warrant, court order, or other valid legal process. We may also disclose personal information in special circumstances when we have reason to believe that disclosing this information is necessary to detect fraud or to protect the safety and/or security of our members or the public.

Reservation of rights in the case of cessation of the business
We may transfer your personal information to a third party in the event of a cessation, dissolution, sale, merger, or other transfer of all or substantially all our assets, or if we discontinue or otherwise dissolve our business.

Where do we store and process your personal information?
ISPE and our third-party providers are located in the United States and/or Canada. Transfer to these countries is necessary for us to provide you with the benefits of membership or to manage your registration at our events, and by applying to be a member of ISPE or registering to attend one of our events you consent to have your personal information processed in the United States and/or Canada. We will update this privacy policy if we begin transferring personal information to any other countries.

How is personal information secured?
We restrict access to personal information to those employees who need to know such information. We have implemented appropriate technical and organizational safeguards to protect your personal information from unauthorized use, access, or alteration.

How can you opt-out of certain email communications from ISPE?
Because we are a member-driven organization, we like to inform our contacts (which includes members and non-members) about services and events that may be of interest using the contact information you provide to us. If you or someone acting on your behalf has provided us your contact information, we will send you information on our services and events, as well as other correspondence that you might reasonably expect to receive from a member-based association.

However, you may request at any time that we cease contacting you regarding any services or offerings. You may unsubscribe from communications simply by clicking the unsubscribe link contained in every email we issue. Note that ISPE cannot re-subscribe you to our contacts database once you have personally acted to unsubscribe. You can only be re-subscribed by personally doing so via our online sign-up form. This applies to both members and non-members.

How long do we store your personal information?
ISPE will retain your personal information as needed to fulfill the purposes for which it was collected which may include retaining certain educational records and other professional information for a period that extends beyond the expiration of an individual's membership. We will retain and use your personal information as necessary to comply with our business requirements and legal obligations, resolve disputes, and enforce our agreements.

How will changes to this policy be communicated?
We may update this policy from time to time to reflect any material changes in our privacy practices. You can always see the date this privacy policy was last modified at the top of the page. We encourage you to check this privacy policy regularly. We reserve the right to amend this policy at any time, for any reason, and may do so by posting a new version online. Your continued use of the website and community platforms, and/or continued provision of personal data to us will be subject to the terms of the then-current Privacy Policy.

Tracking technologies
ISPE and its partners use cookies and other technologies to analyze trends, administer the website and its associated online services, track users' movements around the website and associated services, gather demographic information about our user base, and collect information about your browsing habits to improve the organization and functionality of the website and its associated services, as described below.

When you first visit the website and/or ISPE Exchange, you will be asked to consent to the use of cookies and similar technologies in accordance with this policy and, if you accept, we will store cookies and similar technologies on your computer. Our partners operate their own privacy and cookie policies and you will likely be asked to agree to those to use the services of our partners. We advise you to review these policies carefully, as we are not responsible for the policies of our partners.

I. What are cookies/tokens
Cookies and tokens are pieces of data sent to your browser when you visit a website and stored on your computer's hard drive. Cookies and tokens may store user preferences and other information. For example, cookies can store your session information for easy log-in to a website or platform, or your language or user interface customization preferences, or may allow websites to record your browsing activities (for example, number of page views, number of visitors, and time spent on each page). Tokens are used to recognize when you've signed on as a member on ISPE's website and retains that authentication when you move to an ISPE partner service, such as our online community managed by Higher Logic.

We use session ID and persistent cookies, and tokens. Session ID cookies and tokens are usually deleted when you log-out of a service or close your browser or expire after a short time. A persistent cookie remains on your hard drive for a set period of time or until you delete it. For example, a persistent cookie will record that you responded to our cookie notification message when you arrived at our website and not bother you again with that pop-up for a certain period of time.

II. How we use cookies

We classify cookies in the following categories:

III. Other technologies
ISPE may use a tracking technique that employs embedded URLs to allow use of our online platforms. Embedded URLs allow limited information to follow you as you navigate our platforms but are not associated with personal data and are not used beyond the session.

We may use widgets, which are interactive mini-programs that run on our site to provide specific services from another company (e.g., links to bookmarked sites), along with buttons or other tools that link to other companies' services (e.g., a "Like" button or third-party map). The widget, button or tool may collect and automatically send personal data, such as your email address, or other Information (such as your browser information, or IP address), to a third party. Cookies may also be set or used by the widgets, buttons or tools to enable them to function properly or for other purposes, which may include advertising. Information collected or used by a widget, button or tool, including cookie settings and preferences, is governed by the privacy policy of the company that created it.

We may use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone.

IV. Your choices
On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please note that if you reject cookies or disable cookies, your use of certain features or functions on our website or platforms or service may be limited.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org and/or or the Network Advertising Initiative's online resources at http://www.networkadvertising.org, and follow the opt-out instructions there.

Remember the risks whenever you use the Internet
While we do our best to protect your personal information, we cannot guarantee the security of any information that you transmit to us and you are solely responsible for maintaining the secrecy of any passwords or other account information. In addition, other Internet sites or services that may be accessible through our site have separate data and privacy practices independent of us, and therefore we disclaim any responsibility or liability for their policies or actions. Please contact those vendors and others directly if you have any questions about their privacy policies. We are not responsible for the privacy policies or content of external internet sites.

ISPE embraces fair information practices under the GDPR for all customers, member or non-member

ISPE agrees to adopt and will adhere to the fair information and transparency practices found in the EU General Data Protection Regulation 2016/679 (also known as the "GDPR"). We extend to all members, whether a resident of the EU or not, the following rights in personal information held by ISPE:

1. You may request, subject to our legal obligations and other legitimate interests, that we not share your personal information with third parties.
2. You may request a copy of the personal information we currently hold about you and direct us to correct this information as necessary.
3. You may request that we delete all personal information we currently hold about you, subject to our legal obligations and other legitimate interests.
4. You may lodge a complaint with a supervisory authority if we are unable to resolve your data protection complaints.

To exercise any of these rights, you may contact us using the contact information supplied in the "Contact Us" section, below. We will respond to requests as soon as and to the extent reasonably and technically practicable.

Data protection officer (DPO)
ISPE has no regulatory obligations under the GDPR to appoint a data protection officer (DPO); therefore, ISPE has not appointed a DPO. The GDPR sets out guidelines on when the appointment of a DPO shall be required as follows:

• Where the scope or purpose of collecting data requires a regular systematic monitoring of data subjects;
• Where ISPE processes special categories of data on a large scale;
• Where processing is carried out by a public authority.

ISPE does not meet any of these criteria. For questions regarding data protection, please write to us at info@pharmacoepi.org

For data subjects in the EU
For data subjects in the European Union we have appointed GDPR-Rep.eu as our representative according to Art 27 GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/18624129, or contact GDPR-Rep.eu at:

GDPR-Rep.eu

Maetzler Rechtsanwalts GmbH & Co KG

Attorneys at Law

c/o International Society for Pharmacoepidemiology

Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence: GDPR-REP ID: 18624129

Applicable law
This privacy policy is governed by the laws of Maryland, United States, without regard to its conflict of laws provision.

Contact us
You may contact us with any questions or requests at info@pharmacoepi.org