Privacy policy

(a) Registration Information

Before You can register for Sermo, You will need to provide Your name, address, phone number, email address, a copy of Your professional license or credentials, and if required, Your national professional registration number, for example:

• NPI or AMA number, if you are a United States practitioner
• GMC number, if you are a United Kingdom practitioner
• RPPS/ADELI/ORDRE number, if you are a France practitioner
• Numero Colegiado, if you are a Spain practitioner
• CRM number, if you are a Brazil practitioner

We will use this information to set-up, validate and administer Your account. You must agree to the privacy practices set out in this Privacy Policy, as well as agree to our Terms of Service and Code of Conduct in order to register.

In order to verify Your identity and as part of the registration process, You may be asked to provide photo ID, a selfie, and certain information regarding your place of work. Our external identity verification service provider may collect this information directly from You on our behalf and compare the facial geometry of Your photo ID to Your selfie to verify Your identity. To the extent identity verification information is collected by our external identity verification service provider, such provider’s processing of Your information is subject to their own privacy policy. You will be asked to consent to the practices set out in their Privacy Policy. The facial geometry comparison may be considered “biometrics” under the laws of certain states. We will use this information to verify your identity, protect the integrity of Sermo and prevent fraud, ensuring all members in our platform are legitimate healthcare professionals. We may also use the details you provide about your place of work to contact them as part of the verification process. We may periodically ask You to revalidate your credentials, in which case you will be required to re-confirm Your registration information and provide recent copies of your photo ID and selfie. Sermo does not receive the facial geometry comparison from our service provider. However, we will receive and retain your photo ID and selfie for as long as Your membership is in existence or as necessary to comply with relevant legal obligations. You acknowledge and agree that the registration process cannot be completed until you’ve provided the identity verification information.

You agree that your registration information is true, accurate, current, and complete, and you will promptly update it as necessary so that it continues to be true, accurate, current and complete. We may attempt to verify the accuracy of the registration information that You have provided and periodically update it as necessary, notifying you of any such updates and giving you an opportunity to amend them.

We may use Your information to send You information about our services and provide You with information about other goods and services we offer that are similar to those that You have already used or enquired about to market to You. We may also use this information to provide You, or (based on Your consent, if and when required under applicable law) permit selected third parties to provide You, with information about goods or services we feel may interest You. If You are an existing customer, subject to your preferences, we will primarily contact You by electronic means (e.g., email or SMS), with information about goods and services similar to those which You have expressed interest in.

Your information may also be used to help prevent spam, fraud, or abuse. You may use Your settings for email and mobile notifications to control notifications You receive from our services. You may also unsubscribe from a notification by following the instructions provided with the notification or instructions available via the Site.

(b) Personal account information

Once You are a registered member of Sermo, You will be required to select a password that will be associated with your account. You are solely responsible for maintaining the confidentiality and security of Your Sermo password and You may not permit another person to use Your password to access the Site. You are responsible for all activity that occurs under Your Sermo account. If you believe that the security of Your account has been compromised, You should immediately change your password through the account settings feature or notify us at support@sermo.com and we will assist you.

You may voluntarily provide additional information in Your personal account profile which describes You, including but not limited to Your birth date, social network username, medical school, institutional affiliations, credentials, professional experiences, memberships, evidence of Your specialities, academic background, biography, type of practice, place of employment, work address and residential address. Providing additional information in Your personal profile is not required and entirely optional, but if you choose to provide such additional information, it may allow You to derive greater benefits from using Sermo’s services, such as receiving a higher number of profile-targeted invitations to participate in surveys. This information can be updated or removed by You at any time by visiting the “My Account” page, and You may choose whether to make some of this information publicly visible to other social network participants.

(c) Other information we may receive from You

A key part of Sermo involves encouraging the free flow of ideas, opinions, and content between medical professionals, and most of this information provided by users is available to be viewed by other Sermo users and third parties with whom we are conducting business. When You post content such as articles, comments, and photos on Sermo, we collect the information you post. You can also present and provide interviews and webinars on Sermo. You can utilize settings in the platform to control how other users view your profile.

When You post content such as articles, comments, and photos on Sermo, we may also receive additional data (or metadata) related to the content, for example, the time, date, and place You took a photo.

We partner with third parties to provide you with opportunities to participate in paid medical surveys. Sermo may also invite You to complete Sermo surveys in order to better match You with future paid medical surveys and to improve our Sites. We collect personal information You may provide in response to these surveys, such as information about Your work environment and professional experiences. Some surveys may further request sensitive personal information, such as your gender, race and ethnicity. The purpose for such requests will always be informed to you in each survey. We will disclose Your responses to these surveys to our third-party partners only subject to your consent.

To set-up and manage Your Sermo account, we may ask You to provide some financial information in order to allow You to be compensated for participating in paid medical surveys and other Opportunities (see our Terms of Service). If You choose to withdraw these amounts through gift cards or charitable donations, we will need to collect information from You in order to process these transactions. Where such Opportunities are offered by third parties, we will also need to collect information about Your participation in such Opportunities from those third parties, in order to validate payments. We may also need to send the information set out in this section to trusted third parties that we appoint to process and administer such payments.

We also automatically collect information when You use and navigate the Sermo site, for example, when You follow a group or individual, visit a Sermo page, send or receive a message, click on or otherwise interact with content, post content, view or click on ads we display, perform a search, or participate in polls. We may use this information to make inferences, such as about the content, subjects and ads You may be interested in. See our Cookie information section below and our Cookie Policy for more details.

We also collect information when You invite a colleague to use Sermo, such as Your colleague’s name email address and phone number. If You provide us with personal information regarding another individual, such as when You invite a colleague to use Sermo, You represent that You have that person’s consent to give us his or her information and to permit us to use the information in accordance with this Privacy Policy.

Sermo does not collect identifiable personal health information or other health or medical information about individuals. Sermo does not collect or maintain information that would associate a submission with a specific patient. So please ensure that You do not disclose or post anything that would allow a patient to be identified, such as non-anonymized medical records. Note also that Sermo does not possess a data-based key to re-identify patient data. If You post any identifiable personal health information about an individual, please inform us so that such information can be removed or redacted by Us to remove the identifying information from the Sites.

(d) Information we receive from third parties (including partners and affiliates)

In addition to the information You provide during registration and through Your interactions with our Sites, we may supplement Your profile with additional data obtained from external sources. We may obtain data from reputable sources such as our affiliates, our advertising partners, customers, information service bureaus, social media platforms, industry conference or event organizers, public sources and other third parties, such as Definitive Healthcare and IQVIA, which helps us (or them) deliver sponsored content onto Sermo, understand online activity, and generally improve Your Sermo experience. This supplemental data may include, but is not limited to demographic information, educational information, professional or employment information (e.g., Your age, gender, years in practice, career status, job titles, mailing addresses, social media profiles and social media URLs).

We use supplemental data to enhance Your profile and improve our services, including better targeting of surveys, advertising, and membership communications. This allows us to provide a more personalized experience for You on our platform. The supplemental data is integrated with Your profile information in our backend systems and is not disclosed to other members or external parties without your consent, except as described in this Privacy Policy.

Third parties may also share information about You, including a browser cookie ID, website URL visited, mobile device ID, or cryptographic hash of a common account identifier (e.g. usernames or email address), which enables Sermo to provide ads on the Site and monitor Your preferences and Your interest in them. However, You can choose to block certain ads by enabling an ad blocker to Your web browser so that Your information will not be matched to information shared by ad partners for this purpose. Please see the “Cookie information” section below and our Cookie Policy for more information.

(e) Other Information We Collect

We also receive and use Your information when You decide to contact us. If You email us, we may keep Your message, email address and contact information. We need this to categorise Your enquiry, respond to it and, if applicable, investigate any breach of our Terms of Service, Code of Conduct, or this Privacy Policy. We may also use this information to customise and improve our services over time. We do not use this information for external advertising.

(f) DMD Healthcare Communications Network℠ Privacy Statement

Sermo and its related digital services participate in the DMD Healthcare Communication Network℠ (the “DMD Network”) and as such have implemented various technologies for universal registration/login among all Network member websites. These technologies are managed by DMD Marketing Corp. (“DMD”), and may involve the collection, receipt, and sharing of information with DMD, its clients and other Network members. As a result, Sermo may receive your personal information from DMD. If You would like to understand how this digital service’s participation in the DMD Network affects Your privacy, please click here. Please note that the DMD Network registration/login system may be different from the registration/login used by this digital service for other products and services. To the extent that your information has been provided to Sermo by DMD, and there is a conflict between anything in this Privacy Policy and the policy for the DMD Network technologies, the conflict will be resolved in favour of the policy applicable to the DMD Network technologies.

(g) Cookie information

We and our third-party partners, such as advertising partners and analytics providers, collect information by automated means. We use cookies and similar technologies to collect your IP address, information about your device (such as your browser characteristics, device IDs and characteristics, and operating system version) and information concerning your usage of our Site (including the link you used to reach a given webpage and content accessed). We use this information to improve Your experience on the Site, to determine how many users have visited particular webpages, viewed particular content, or opened messages or alerts, to improve our marketing activities, to maintain your preferences, and to and to enforce our Terms of Service and prevent malicious conduct. For example, by setting a cookie on Your browser, You may not have to log in a password more than once (for a certain period of time), thereby saving time. We may also share cookie information with online advertising partners who use advertising cookies to deliver personalized advertising to You when You visit our Sites. These partners may collect or receive information from our Sites and elsewhere on the internet to serve You relevant advertising and to help us develop more effective marketing campaigns. Cookie information may be connected to other personal information we collect from You, such as your name, contact information, and location, to improve the accuracy and quality of our insights, reporting and marketing campaigns.

You may be able to change the settings of Your browser to block or delete cookies. You may be able to reset Your browser to refuse all cookies or allow Your browser to show You when a cookie is being set. You can update your cookie preferences by using the link provided in the footer of our website. Remember to set your preferences on each device you use to access our Site. If You reject the cookies on the Site, You may still be able to use the Site, but Your use may be limited in some areas or limited to certain functions of the Site. In some cases, our third-party partners may process information collected by cookies and similar technologies on the Sites. Please see our Cookie Policy for more information.

The Sermo Site uses session cookies and persistent cookies to better understand and track how You interact with the Site each time You visit and on various devices, to monitor aggregate usage by and web traffic, to enable You to access surveys and to make improvements the Site. You can learn more about our use of cookies and how to opt out tracking by cookies or control how information collected by cookies is used in our Cookie Policy. Your browser or device may include “Do not Track” functionality; please note that we do not respond to such signals unless required by applicable law.

(h) Log information

When You use our Site, Sermo may use information, such as Your IP address, browser type, operating system, referring web page, pages previously visited, location (see below), mobile carrier, device and/or application identifiers, search terms, and cookie information to align our services with changes in Your device usage patterns, to administer the Site and to gather certain demographic information for aggregate use. We may also receive log information when You view or interact with links on the Sermo site, including sites operated by third parties.

(i) Location information

We may receive information concerning Your location if, for example, You choose to post content which reveals this information. We may also determine Your general location (e.g., city, state) using information from Your device, such as GPS data, information about wireless networks or cell towers near Your device, or IP address. We may use this to improve and customise our service to You, for example by making You aware of content, people, and ads more relevant to Your location. You can choose to turn off location services on Your device at any time if You prefer, however if You do so You will not benefit from such tailored content.

Subject to implementing relevant safeguards under data protection laws, the personal information and other data we collect from You may be transferred to and stored at a destination outside your country of residency. It may also be processed by staff operating outside of your country of residency who work for us or for one of our service providers. We have implemented technical and organisational measures as required under applicable law and treat Your Information in accordance with this Privacy Policy.

We retain the personal information you provide while your membership is in existence or as needed to provide you services as described in this Privacy Policy. It may persist in copies made for back up and business continuity purposes for additional time, including information required for regulatory and legal compliance.

If you choose to end your relationship with us, we generally dispose of account information consistent with our Terms of Service, corporate data retention policy or other legitimate business needs. We may retain some of your personal information even after you have closed your account, or after our contractual relationship ends, if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to “unsubscribe” from further messages from us.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to information. When you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.

We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

(a) EEA, Switzerland, or UK Residents

Sermo believes that it is important that individuals are given the opportunity to exercise choice with respect to how their personal information is collected and used. Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“UKDPA”), provide you with certain rights in connection with personal information you have shared with us.

Lawful Bases to Process Your Information under the GDPR and the UK Data Protection Act 2018. Sermo acts as the data controller of Your information, relying on Your consent or our legitimate business interests as the legal basis for collection and processing. In specific instances where we receive Your personal information from third parties, or are instructed to collect and process Your personal information for purposes not defined by Sermo, we may act also as a data processor, following the directives of such third parties and applicable laws.

The GDPR and UKDPA provide for six legal bases that permit an organisation like Sermo to lawfully process Your information. The six legal bases are:

1. You have given consent to the processing of Your information for one or more specific purposes. For example: turning on certain cookies on our Site or consenting to a specific information processing request contained within an online survey.
2. Processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract. For example: when You agree to be a Sermo member, Sermo will then process Your information to: (1) verify Your identity, location and professional specialisms;(2) determine the medical market research opportunities You are eligible for; (3) match You with third party medical market research targeting lists and related pre and post market research analytics data, provided that Your personal information will not remain with a third party or be used for any other purpose; use Your data to respond to regulatory requests; (4) create and administer an incentives account for the incentives You earn as a Sermo member, and; (5) respond to Your queries via our Community team.
3. Processing is necessary for compliance with a legal obligation to which Sermo is subject. For example: accurately reporting taxes, complying with financial transparency laws (e.g. Loi Bertrand and Loi Anti-Cadeaux in France, the USA Sunshine Act, the EPFIA Disclosure requirements in Europe or the ABPI Disclosure requirements in UK) or reporting adverse events and product safety information to our customers.
4. Processing is necessary in order to protect the vital interests of You or of another natural person. For example: reporting Your information as part of a potentially life-saving or life-threatening event, via Sermo’s obligation to report adverse events and other product safety information.
5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Sermo. This legal base will probably not be used by Sermo.
6. Processing is necessary for the purposes of the legitimate business interests pursued by Sermo or by a related third party, except where such interests are overridden by Your interests or fundamental rights and freedoms. For example, (1): Your information is an important element in Sermo’s provision of a global social network, free at the point of access. As a result, Sermo is able to provide its social platform-based tools and products, such as Sermo Drug Ratings™ tool that is based upon the drug ratings You provide and then You have the right to use the Sermo Ratings results via the Site. The Sermo Community team also uses Your information to help administer this Site and Sermo’s market research and social network activity that are in part generated form this Site; (2) We may research publicly available sources (e.g. websites such as LinkedIn) and use external provider services, to identify healthcare professionals who are likely to be interested in the products and services we have to offer. We will only process the minimal amount of information required for this purpose (e.g. name, job title, company and contact details) and when we contact you we will always provide you with an easy way for You to object to us processing Your personal information in such manner or retaining it for such purpose.

If you are resident in the EEA, Switzerland, or the UK, you have the following rights:

1. The right to be informed. The general section of this Privacy Policy describes the types of personal information we collect, how we collect it, and how we use it. For information on our retention practices, please see “Data, Storage, and Retention” section above. We rely on a variety of legal bases to process your personal information, as described above.
2. The right of access. You have the right to request a copy of your personal information which we hold about you.
3. The right of correction. You have the right to request correction or changes of your personal information if it is found to be inaccurate or out of date.
4. The right to be forgotten. You have the right to request us, at any time, to delete your personal information from our servers and to erase your personal information when it is no longer necessary for us to retain such data. Note, however, that the deletion of your personal information will likely impact your ability to use our services.
5. The right to object (opt-out). You have the right to opt-out of certain uses of your personal information, such as direct marketing, at any time
6. The right to data portability. You have the right to a “portable” copy of your personal information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your personal information stored on our servers / IT environment to another service provider’s servers / IT environment.
7. The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
8. The right to lodge a complaint with a supervisory authority. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law:

• Contact Us, choosing the specific Privacy Inquiry type;
• Send us an e-mail at support@sermo.com from the e-mail address You registered with, or;
• Send us a postal letter to:
  • Data controller: WorldOne Research Limited, WorldOne, Inc. and Sermo, Inc. (“Sermo”)
  • Data controller address: Fora 42 Berners Street London W1T 3ND, United Kingdom
  • Data controller primary contact: Data Protection Officer, sermo.dpo@sermo.com

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process personal information about you in order to provide our services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

(b) California Residents

During the last twelve (12) months, we have collected the following categories of personal information from California residents. Some of the categories of information collected specifically concerns our employees or contractors as opposed to consumers who purchase our products.

Please see our Cookie Policy for information about the collection and use of personal information by third parties who process information collected by cookies and related technologies that we permit them to use on the Site. Except as indicated below in the “California Job Applicants” section and the Information Collection and Use section, we do not seek to collect any additional “sensitive personal information” (as defined in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”)).

• via our online form, choosing the option ‘Privacy Inquiry’;
• via email, at support@sermo.com; or
• via written post directed at one of the below locations as convenient:

Sermo
Attn: Data Protection Officer
8 Crosby Street 
New York, NY 10013
United States

Sermo
Attn: Data Protection Officer
Fora, 42 Berners Street
London W1T 3ND
United Kingdom

We will use all reasonable efforts to respond promptly to requests, questions or concerns You may have regarding our use of Your personal information. Except where required by law, Sermo cannot ensure a response to questions or comments regarding topics unrelated to this Privacy Policy or Sermo’s privacy practices.