Privacy Policy
Privacy Policy
- Privacy Policy
- 1. WHAT INFORMATION DO WE COLLECT?
- 2. HOW DO WE USE YOUR INFORMATION?
- 3. WILL YOUR PERSONAL INFORMATION BE SHARED WITH THIRD PARTIES?
- 4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
- 5. IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
- 6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
- 7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?
- 8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
- 9. WHAT ARE YOUR PRIVACY RIGHTS?
- 10. CONTROLS FOR DO-NOT-TRACK FEATURES
- 11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- 12. DO WE MAKE UPDATES TO THIS NOTICE?
- 13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?
Last updated: April 17, 2024
Privacy Policy
This “Privacy Policy” describes the privacy practices of Resonance, Inc. (“Resonance”, “us”, “our”, or we“) including how we collect, use, disclose and otherwise process personal information in connection with our websites, mobile apps, and other services. It also governs when we process your personal information for incidental business-related purposes e.g., answering your enquiry, your attendance at events or our direct marketing activities. It explains the rights and choices available to individuals with respect to their information. For convenience, our website, web apps, and mobile apps are collectively referred to as the “Sites”, and, together with our other services, collectively referred to as the “Services”. This Privacy Policy governs any of the Services on which the Privacy Policy is posted or available to link from. We are committed to protecting your personal information (including “personal data” as defined by the GDPR) and your right to privacy.
Individuals located in the European Union, the European Economic Area, the UK and/or Switzerland (“GDPR Countries”) should be sure to read the important information provided below in the “Is your personal information transferred internationally?” section. Capitalized terms used but not defined herein have the meaning given to them in the EU’s General Data Protection Regulation 2016/679 as amended from time to time, (the “GDPR”).
Resonance is the Controller of your personal information in the context of our Sites and related Services.
RESONANCE’S PLATFORM, APPLICATIONS, AND CUSTOMER DATA
However, please note that Resonance’s customers are the Controllers of their Data Subjects’ personal information when they choose to use our Sites and related Services (e.g. Resonance Patient Center). For example, if you are a patient in a clinical trial, or a patient being treated by a hospital or healthcare provider which uses our platform, Sites and related Services, or an investigator who logs into our Sites, your Controller is the Sponsor of that clinical trial and/or the participating healthcare provider. In these instances, Resonance is the Controller’s Processor.
As part of Resonance’s platform, Sites and related Services, our customer’s employees and authorized users may enter personal information from or about their authorized users, employees, clinical trial subjects or patients (collectively, “Customer Data”), into their instances on our servers.
This Privacy Policy does not apply to Customer Data, and we are not responsible for our customers’ handling of their Customer Data. Our customers have their own policies regarding the collection, use and disclosure of any personal information contained in their Customer Data. Our use of Customer Data is subject to the written agreement between Resonance and the customer. Resonance’s responsibility under that agreement is the obligation to keep Customer Data safe and secure as its customer’s Processor or sub-Processor.
To learn about how a particular customer handles your personal information, we encourage you to read that customer’s privacy statement or equivalent or contact that customer. We cannot answer questions about our customers’ Customer Data.
Resonance has no control or ownership of Customer Data. Please direct any questions regarding Customer Data to the customer for which you work, or who collected your information using a Resonance platform or Site.
For further clarification on our use and processing of Customer Data and to understand the terms and conditions of using our software platform, please read our General Terms and Conditions of Service.
By using any of our Services, you accept the provisions of this Privacy Policy.
Please read this Privacy Policy carefully, as it will help you understand what we do with the personal information that we collect.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on one of our Sites, express an interest in obtaining information about us or our products and Services (“Enquirer”), when you participate in activities on the Site (such as by posting messages in our online forums) (“Participant”) or otherwise when you contact us (“Contact”) taken together collectively (“Everyone”). When using any of our Sites or Services after having agreed to our Terms and Conditions, everyone is considered a User.
The personal information that we collect depends on the context of your interactions with us and our Sites, the choices you make and the products, features and Services you use. The personal information we collect may include the following:
Personal information provided by you. We collect names; phone numbers; email addresses; mailing addresses; job titles; contact preferences; contact or authentication data; billing addresses; account information; and other similar information (“Contact Data”), as applicable from potentially Everyone.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected from Everyone
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit any of our Sites.
We automatically collect certain information when you visit, use or navigate any of our Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, approximate location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. For more information on Cookies, please read our Cookie Policy.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Sites and which we record in log files. Depending on how you interact with our Sites and/or Services, this log data may include your IP address, device information, browser type and settings and information about your activity on the Site (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access any of our Sites. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, approximate location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
Collectively these types of data are referred to as (“System Data”).
Information received from third parties
Occasionally, in line with applicable law and any preferences you have expressed to the seller, we may buy the following types of information: contact information, professional title or designations, affiliations (“Received Data”) from third parties on Users or potential Users for the purposes described herein.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for the purposes described below based on our Legitimate Interests, the fulfillment of any contract we have with you, Compliance with our Legal Obligations, and/or your Consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our Legitimate Interests, to enter into or Perform your Contract, with your Consent, and/or for Compliance with our Legal Obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use User and/or Participant information we collect or receive to facilitate account creation and logon processes. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate the account creation and logon process for the Performance of your Contract with us.
To post testimonials. We post testimonials on our Sites that may contain User or Participant personal information. Prior to posting a testimonial, we will obtain your Consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at legal@resonancehealth.org and be sure to include your name, testimonial location, and contact information.
Request feedback. Based on our Legitimate Interest in improving our Sites and/or Services, we may use Users’ Contact Data to request feedback and to contact you about your use of our Sites and/or Services.
To enable User-to-User communications. With your Consent, we may use your Contact Data to enable User-to-User communications.
To manage User accounts. To Perform your Contract with us, we may use User’s Contact and System Data for the purposes of managing your account and keeping it in working order.
To send administrative information to you. Based on our Legitimate Interest in improving our Sites, Services and in growing our business, we may use Users’ Contact Data to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our Services and customers. Based on our Legitimate Interest in protecting our and our customers’ confidential information, the Performance of your Contract with us or to Comply with our Legal Obligations, we may use Everyone’s System Data: (a) as part of our efforts to keep our Sites and Services safe and secure (for example, for fraud monitoring and prevention); and (b) to enforce our terms, conditions and policies against Users and Participants.
To respond to legal requests and prevent harm. To Comply with our Legal Obligations, if we receive a subpoena or other legal request, we may need to inspect any and all data (including personal information) we hold on Everyone to determine how to respond.
Fulfill and manage your orders. To Perform your Contract with us, we may use Users’ and/or Participant’s Contact Data to fulfill and manage your orders, payments, returns, and exchanges made through the Sites and/or use of the Services.
To deliver and facilitate delivery of Services to the User. To Perform your Contract with us, we may use User’s and/or Participant’s Contact and/or System Data to provide you with the requested Service.
To respond to User inquiries/offer support to Users. To Perform your Contract with us, we may use User’s and/or Participant’s Contact and/or System Data to respond to inquiries and solve any potential issues you might have with the use of our Sites and/or Services.
To send you marketing and promotional communications. Based on our Legitimate Interests in maintaining and growing our business, we and/or our third-party marketing providers may use Everyone’s Contact Data to send you direct marketing materials, only if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us, our Services or our Sites, when subscribing to marketing or otherwise contacting us, we will collect Contact Data from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).
For other business purposes. Based on our Legitimate Interests in improving our Sites and/or Services to maintain and grow our business, we may strip of direct identifiers and aggregate Everyone’s personal information so that it is no longer associated with individuals and no longer contains personal information. Once anonymized and aggregated we may use such data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, Services, and other products.
5. IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your personal information in countries other than your own.
Our servers are located within the EU, in France. If you are accessing one of our Sites from outside the EU, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR PERSONAL INFORMATION BE SHARED WITH THIRD PARTIES?” above), in the United States, the UK, and potentially world-wide. If you are a resident in the GDPR Countries, then these recipient countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take the measures necessary to protect your personal information in accordance with this Privacy Policy and applicable law, unless these restricted transfers are made with your Consent, or to countries deemed adequate by the EU Commission, the UK Secretary of State or the Swiss equivalent (as appropriate).
European Commission’s Standard Contractual Clauses:
For residents of the GDPR Countries, where specified in our General Terms and Conditions of Service, the Personal Data Processor Addendum thereto and/or as necessary under applicable law, we have implemented the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from within the GDPR Countries in accordance with the GDPR. A suitably redacted copy of these Standard Contractual Clauses can be provided upon request.
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
In Short: We keep your information for only as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by applicable law, judicial or other governmental demand or order, subpoena, or law enforcement request.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by judicial or other governmental demand or order, subpoena, law enforcement request or applicable law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us to keep your personal information for longer than sixty (60) months past the termination of the User’s or Participant’s account. “User” is defined in our General Terms and Conditions of Service as “any individual who (is a member of the Authorized Workforce as applicable) uses the Software on Customer’s behalf or through Customer’s account or passwords).
When we have no ongoing Legitimate Interests in processing your personal information, we will either delete or anonymize and aggregate such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will continue securely storing your personal information until deletion is technically feasible.
7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures which comply with applicable laws, including the GDPR.
We have implemented GDPR-appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be one hundred percent (100%) secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites and within our Software is at your own risk. You should only access our Sites from within a secure environment.
8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from, or direct market to children under 18 years of age.
We do not knowingly solicit personal information from, or direct market to children under eighteen (18) years of age. By using the Sites and Services, you represent that you are at least eighteen (18) or that you are the parent or guardian of such a minor and Consent to such minor dependent’s use of the Sites. Unless it forms part of Customer Data, if we learn that personal information from Users or Participants less than eighteen (18) years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age eighteen (18) (excluding as part of Customer Data), please contact us at legal@resonancehealth.org.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the EU, the European Economic Area (EEA), the UK and Switzerland, you have rights that allow you greater access to and control over your personal information than in other regions. Users and Participants may review, change, or terminate their account at any time.
In some regions (like the GDPR Countries), individuals have certain rights under applicable data protection laws. These may include the right: (a) to request access and obtain a copy of your personal information; (b) to request rectification or erasure; (c) to restrict the processing of your personal information; and (d) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with the GDPR. Please note that the rights which you have under the GDPR vary according to the legal basis we are relying on to legitimate the processing, see Section 3 (WILL YOUR PERSONAL INFORMATION BE SHARED WITH THIRD PARTIES?).
If we are relying on your Consent to process your personal information, you have the right to withdraw your Consent at any time. Please note, however, that this will not affect the lawfulness of our processing before such withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than your Consent.
If you are a resident in the GDPR Countries and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here. If you are a resident in the UK or Switzerland, the contact details for the data protection authorities are available here here and here.
If you have questions or comments about your privacy rights, we encourage you to email us at legal@resonancehealth.org first, before complaining to your local supervisory authority, or exercising your right to seek a judicial remedy, so that we may attempt to resolve the issue(s) raised.
Account Information: If Users or Participants want to review or change the information in their account or terminate it, they can: Log in to “your account settings” and update their account, or contact us at legal@resonancehealth.org. Upon receipt of a request to terminate an account, we will deactivate or delete it and the personal information from our active databases. However, we may retain some personal information in our files as permitted by applicable data protections laws to prevent fraud, troubleshoot problems, assist with any internal investigations, enforce our General Terms and Conditions of Service and/or purposes necessary to comply with applicable law, judicial or other governmental demand or order, subpoena, or law enforcement request (including in response to public authorities to meet national security or law enforcement requirements).
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you Services-related emails that are necessary for the administration and use of your account, to respond to your service requests, or for other non-marketing purposes.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have personal information about your online browsing activities monitored and collected. Currently, no uniform technology standard for recognizing and implementing DNT signals has been finalized industry-wide. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our Users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under eighteen (18) years of age, reside in California, and have a registered account with one of our Sites, you have the right to request removal of unwanted data that you publicly post on our Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from all our internal systems (e.g., from backups, etc.) or the world-wide web. CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
every individual who is in the State of California for other than a temporary or transitory purpose and
every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents”.
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name | YES |
| Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history and financial information | YES |
| Protected classification characteristics under California or federal law | Gender and date of birth | YES |
| Interactions with Resonance websites | Interactions with our websites, applications, systems and advertisements | YES |
| Professional or employment-related information | Business contact details to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us | YES |
We may also collect other personal information outside of these categories where you interact with us in-person, online, or by phone or mail in the context of: (a) receiving help through our customer support channels; (b) participation in customer surveys or contests; and (c) facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this Privacy Policy.
Will your information be shared with anyone else?
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data. Only anonymized and aggregated data will be used for this purpose. Resonance, Inc. has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Resonance, Inc. will not sell personal information in the future belonging to Users.
Your rights with respect to your personal data:
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by applicable law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal and/or regulatory obligation or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know: (a) whether we collect and use your personal information; (b) the categories of personal information that we collect; (c) the purposes for which the collected personal information is used; (d) whether we sell your personal information to third parties; (e) the categories of personal information that we sold or disclosed for a business purpose; (f) the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and (g) the business or commercial purpose for collecting or selling personal information. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights you may object to the processing of your personal data. You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the data. You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. To exercise these rights, you can contact us by email at legal@resonancehealth.org, or by referring to the contact details at the bottom of this Privacy Policy. If you have a complaint about how we handle your data, we would like to hear from you.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this Privacy Policy as necessary to stay compliant with relevant laws and/or as our business and its associated processing activities evolve.
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?
If you have questions or comments about this Privacy Policy, you may contact our Data Protection Officer (DPO), Ellis Parry, by email at ellis_dpcsl@outlook.com.
If you have questions or comments about this notice, you may also contact our Data Protection Representative, DataRep, by sending an email to datarequest@datarep.com quoting <Resonance,Inc.> in the subject line, or by contacting DataRep on their online webform.