NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (“CCPA”) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of Personal Information and of the rights of California residents regarding their Personal Information. This section of the Privacy Statement is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it. 

The CCPA defines “Personal Information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Under the CCPA, Personal Information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern.  

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Statement, have collected the following categories of consumers’ Personal Information: 

• Identifiers, such as name, email address, IP address, government-issued identifier (e.g., NPI number), and online and device identifiers; 
• Contact information; 
• Internet or network activity information, such as browsing history and interactions with our online properties; 
• Geolocation data, such as device location; 
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics; 

We collect Personal Information directly from California residents and from our affiliates, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks. We do not collect all categories of Personal Information from each source. 

In addition to the purposes stated in the “HOW WE USE YOUR PERSONAL INFORMATION” section above, we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes: 

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards 
• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes 
• Debugging to identify and repair errors that impair existing intended functionality 
• Short-term, transient use 
• Undertaking internal research for technological development and demonstration 
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us 
• Advancing our commercial or economic interests, such as by enabling or effecting, directly or indirectly, a commercial transaction  
• Optimizing the use of the Site and paid media campaigns 

Sale, Sharing, and Disclosure of Personal Information

The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of Personal Information under California law. This may include showing you advertisements on other websites.  

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Statement and, for each category, the categories of third parties to whom we sold or shared Personal Information: 

We sold or shared Personal Information to third parties to advance our commercial and economic interests. 

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Statement and, for each category, the categories of recipients to whom we disclosed Personal Information:   

We disclosed Personal Information for all the business or commercial purposes listed above. 

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.  

We do not use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations. 

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. 

Your CCPA Privacy Rights 

If you are a California resident, you have certain rights with respect to your Personal Information. In specific: 

• You may request disclosure of information we collect or share about you. You can submit a request to us for the following data regarding the Personal Information we have collected about you in the 12 months prior to our receipt of your request (a “request to know”):   
  • The categories of Personal Information we have collected; 
  • The categories of sources from which we collected the Personal Information; 
  • The business or commercial purposes for which we collected the Personal Information; 
  • The categories of third parties with which we shared the Personal Information;  
  • The categories of Personal Information we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Information; and 
  • The specific pieces of Personal Information we collected. 
• You may request to correct inaccuracies in your Personal Information. 
• You may request to have your Personal Information deleted. In this case, we may ask you to confirm your request before we delete your Personal Information. 
• You may request to receive a copy of your Personal Information, including, where applicable, a copy in a portable, readily usable format.  
• You may request to opt out of the sale of your Personal Information or the sharing of your Personal Information for cross-context behavioral advertising. 
• If we use or disclose your Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, you may request to limit our use or disclosure. 
• You also have the right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.  

Submitting a Request to Know, Delete, and/or Correct  
You may exercise your rights to know, delete, and/or correct by contacting the Data Protection Officer (DPO) at the following email address: [email protected].   
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident. 
When you make a request to know, delete, and/or correct your Personal Information, we will take steps to verify your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. These steps may include asking you for Personal Information, such as your name, address, or other information we have about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial. Where we provide personal information to you (or someone else on your behalf), we will provide it free of charge except in exceptional circumstances. 

Right to Opt Out of Sale or Sharing of Personal Information 
If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information. 
You may submit a request to opt out of sales or sharing through our interactive webform available by clicking here. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “UNIVERSAL OPT-OUT MECHANISMS” section below for more information. 
Shine the Light: California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California residents asking about the business' practices related to disclosing certain types of Personal Information to third parties for the third parties' direct marketing purposes. We do not disclose Personal Information to such entities, for such purposes.   

NOTICE TO TEXAS AND NEBRASKA RESIDENTS

If you are a Texas or Nebraska resident, you may have certain privacy rights regarding your Personal Information, including (if applicable): 

• The right to confirm whether or not we are processing your Personal Information and to access such Personal Information; 
• The right to obtain a copy of your Personal Information that we collected from you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, if the data is available in a digital format;  
• The right to delete Personal Information that we collected from and/or about you, subject to certain exceptions; 
• The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions; 
• The right, if applicable, to opt out of the processing of your Personal Information for purposes of (1) targeted advertising; (2) the “sale” of your Personal Information (as that term is defined by Texas and Nebraska law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; and 
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights. 

We use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under Texas and Nebraska law. When we engage in those activities, we sell Personal Information (i.e., information from cookies) to third-party advertisers and analytics companies. We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals. 
To exercise your rights, please submit a request by emailing us at [email protected]. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting an opt-out request on behalf of another individual, please use the same contact methods described above. We will process authorized agent requests in accordance with applicable law. If you would like to opt out of targeted advertising, you may alter your cookie preferences here.  
Appeal: If we refuse to take action on your request, you may appeal the refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us via email at [email protected], as described above.   

UNIVERSAL OPT-OUT MECHANISMS 

The Site recognizes the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.  
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

CHILDREN’S PRIVACY 

The Site and services are not intended for children under 13 years of age. Curium does not knowingly collect, use, or disclose Personal Information from children under 13. 

SECURITY

We maintain commercially reasonable security measures to protect the Personal Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. You should always exercise caution when transmitting Personal Information, including any health-related information, through the Site. Although we strive to use commercially acceptable means to protect your Personal Information, Curium cannot guarantee absolute security. 

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites that may provide additional information relevant to users of the Site. Users of the Site should use caution when submitting any Personal Information on such third-party websites. Such third-party websites may adhere to privacy policies that differ from those of this Privacy Statement. Curium does not control or protect any Personal Information submitted on third-party websites or that may have a link provided on the Site. Curium accepts no responsibility or liability for these other websites. It is recommended that you review the privacy policies of any linked third-party websites before submitting any Personal Information. 

OTHER U.S. STATE-SPECIFIC PRIVACY DISCLOSURES

California Residents Under Age 18: If you are a resident of California under age 18 and a registered user of our services, you may ask us to remove any content you have publicly provided to such services by writing to [email protected].  

Nevada Residents as Covered by Nevada Privacy Law: Nevada law allows Nevada residents to opt out of the sale of certain types of Personal Information (“Covered Information”). Subject to several exceptions, Nevada law defines “sale” to mean the exchange of Covered Information for monetary consideration to another person. We do not currently sell Covered Information, as defined under Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may send such opt-out requests to [email protected]. 

Texas Residents: Pursuant to the Texas Health and Safety Code, Sec. 181.154, please be advised that if we receive any data that identifies you and relates to your past, present or future physical or mental health, healthcare or payment for your healthcare, such data may be subject to electronic disclosure by such means as file transfers or email. 

ADDITIONAL NOTICE FOR HEALTHCARE PROFESSIONALS

This section of our Privacy Statement describes our additional information collection and sharing practices involving our services intended for U.S. Healthcare Professionals visiting and using the Site (“HCP Services”). 

What Personal Information Do We Collect? 

• Information You Provide through HCP Services: We collect Personal Information that you voluntarily provide when you use the HCP Services. In this case, we may collect additional Personal Information through HCP Services such as your name, address, age, birth date, gender, email address, phone number, medical license number, zip code, education, professional experience, demographic information, information about health and/or medical specialties, as well as information required to process expense reimbursement (including your Social Security number and/or tax identification number). If you submit Personal Information relating to other people to us or to our service providers in connection with the HCP Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement. 
• Information We Receive From Third Parties about HCPs: We may combine the Personal Information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information, joint marketing partners, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, and other third parties. 

When and to Whom Do We Disclose HCP Personal Information? 

• In addition to the general Personal Information sharing practices described above, the HCP Personal Information we collect may also be disclosed to third parties that provide services to us, such as fulfilling requests for information, administering programs or projects, assisting in research and development, or delivering promotional or other communications. 

REVISIONS TO PRIVACY STATEMENT

Curium will handle Personal Information submitted on the Site, in accordance with this Privacy Statement in effect at the time the information was submitted. Curium reserves the right to amend this Privacy Statement as needed. Any amendments to the Privacy Statement will be posted on the Site with the last updated date identified. Curium therefore invites you to regularly visit the Site to be informed of/if any change. 

QUESTIONS, COMMENTS, AND FEEDBACK

Please submit any questions, comments and/or feedback regarding Privacy by accessing the “Contact Us” link on the Site’s homepage or contacting the DPO reachable at the following email address: [email protected].