Privacy Policy

Last Updated: April, 2023

This Privacy Policy aims to explain how, why, and what personal data Engage processes and the rights you have, as a data subject, related to the processing of your personal data.

This Privacy Policy does not consider the processing that our partners perform. For the way that your personal data is processed by our trading partners, as controllers, please refer to their policies on the processing of personal data.

1. WHO ARE WE?

   “Engage is owned by Engage Technologies Group Inc, a company incorporated by United States laws, headquartered at 3540 E Longwing Lane, Suite 300, Meridian, Idaho, 83646, United States, hereinafter as “Engage”, “we” or “us”.

   Engage helps medical providers to strengthen their relationships with patients by empowering them with expert-curated knowledge through mobile-guided Journeys that anticipate and answer their questions at their time of interest and time of need.

2. DEFINITIONS
   1. “Website” means www.engagetg.com and platform.engagetg.com
   2. “You”, “your” or “user” means any natural person using the Website, for private or business purposes, without necessarily having subscribed to our service.
   3. “Personal data” or “personal information” means any information regarding a physical identified or identifiable natural person.
   4. “Controller” means the natural or legal person that determines the purposes and means of the processing of personal data processing.
   5. “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, storage, adaptation, consultation, use, disclosure or deletion.
   6. “Communication” means any information exchanged or conveyed between you and us.
   7. “Consent” by a user means any freely given, specific, informed, and unambiguous indication of the user’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
   8. “Data Protection Law” refers to the California Privacy Rights Act of 2020 (CPRA), Connecticut Data Privacy Act (CTDPA), Colorado Privacy Act (CPA), Utah Consumer Privacy Act (UCPA), Virginia Consumer Data Protection Act (VCDPA), Act on the Protection of Personal Information (APPI), Personal Information Protection and Electronic Documents Act (PIPEDA), Brazilian General Data Protection Law (LGPD), General Data Protection Regulation (GDPR).
   9. “EU Representative” means the designated Engage representative in European Union.
3. HOW DO WE COLLECT DATA?

   In general, we will collect your personal data directly from you. However, there may be situations where data will be collected indirectly from social networks such as LinkedIn, from the website of the company you represent, from your employer as a contact person, from a third party who recommended you or from various public platforms (for trade association websites). When we do not receive personal data directly from you, we will inform you within the legal term on their processing.

4. CHILDREN AND SENSITIVE DATA

   Our Website and services are not intended for individuals below the age of 13. We do not want nor is our intention to solicit and collect personal information for this type of audience.We do not intentionally collect Personal Information from children below the age of 13. If you are the parent or guardian of a child below the age of 13 and you believe your child has provided us with personal information, please contact us to request the deletion of their personal data. If we confirm that we have collected this kind of personal information, we will delete that information as soon as possible.We do not collect nor is our intention to collect personal data regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, or personal data relating to criminal convictions and offenses.

5. OUR PURPOSES FOR PROCESSING PERSONAL DATA, LEGAL GROUNDS AND RETENTION PERIODS
   1. Purpose: B2B contractual relationship to initiate or carry out the contractual relationship with your employer or company that you represent
      1. Data collected: the data collected for this processing are your first and last name, e-mail address, phone number, signature, role, the company you represent, and that company’s address.
      2. Legal basis for processing: based on our legitimate interest to conclude the service agreement and provide services to the company that you represent, and our legitimate interests to defend our interests and rights, or to sustain our claims resulting from or regarding the signing and executing the service agreement with the company that you represent.
      3. Retention period: we will retain your personal data as long as there is a service agreement with the company that you represent.
   2. Purpose: Using our Services
      1. Data collected: the data collected for this processing are IP, first and last name, phone number, e-mail, practice name, billing information, billing address.
      2. Legal basis for processing: performance of the contract and provision of our Services through the Website.
      3. Retention period: the entire period of the service agreement, and for 2 additional years after the service agreement has ceased.
   3. Purpose: User profile customization on your account
      1. Data collected: the data collected for this processing are first and last name, address, title, contact details, username, account details, employer, job title, geographic location, area of responsibility.
      2. Legal basis for processing: performance of the contract and provision of our Services through the Website.
      3. Retention period: the entire period of the contract.
   4. Purpose: Provide support and answer your questions received via contact form, e-mail, or phone
      1. Data collected: the data collected for this processing are your first and last name, e-mail, phone number, your company, and any other information that you will willingly provide to us when you are contacting Engage, depending on the request type.
      2. Legal basis for processing: our business’s legitimate interest to communicate with you and provide our support for using our services on the Website.
      3. Retention period: your personal information will be retained for 1 year from the date of your question. Your refusal to provide one or more details presented above will make it impossible for us to provide you with the requested support. Your enquiry may be stored and processed through a third-party Customer Relationship Management (CRM) software provider that ensures that we do not miss any messages from you and that we follow through on your enquiries until they are resolved.
   5. Purpose: Comply with legal obligations such as invoicing, accounting records, archiving, etc.
      1. Data collected: according to the legal provisions, the data collected for this processing are your first name, last name, company, role or representation powers, bank account information and any other personal information required by law.
      2. Legal basis for processing: compliance with a legal obligation.
      3. Retention period: the data will be retained according to the current legislation.
   6. Purpose: Answer your Demo request via a contact form, e-mail, or phone
      1. Data collected: the data collected for this processing are your first name, last name, company, telephone, e-mail, country, industry, and any other information that you will willingly provide to us when you are requesting a demo.
      2. Legal basis for processing: our business’s legitimate interest to communicate with you and provide our demo.
      3. Retention period: your personal information will be retained for 3 years from the date of your request. Your refusal to provide one or more details presented above will make it impossible for us to provide you the requested support.
   7. Purpose: Sales efforts, directly or through partners
      1. Data collected: the data collected for this processing are first and last name, phone number, e-mail, company and company’s address, role, or other public details.
      2. Legal basis for processing: our business’s legitimate interest to promote our services and extend our client portfolio.
      3. Retention period: your personal information will be retained for up to 2 years after the time you opposed to this processing or from the last communication you received from us. There may be situations when your personal data will be collected again after this period, when, for example, we find your public data again when we prospect the market or if you were referred by an individual. In this case, we will inform you again regarding the processing of your personal data.
   8. Purpose: Selecting and recruiting for filling vacant roles
      1. Data collected: the data collected for this processing are your first name, last name, phone number, e-mail, education, professional experience, targeted role, profession or qualification, professional and social skills and any other relevant information provided by you, as a candidate.
      2. Legal basis for processing: to conclude an employment contract with us and our legitimate interest to contact you for future vacant jobs.
      3. Retention period: the data will be retained according to the current legislation and up to 1 year from the ending date of the selection and recruitment process, based on our legitimate interest to contact you for future vacant jobs. Your refusal to provide one or more details explained above will make it impossible for us to include you in our selection and recruitment process and to hire you at Engage.
   9. Purpose: Improvement of the Website
      1. Data collected: the data collected for this processing are Website usage details such as preferred language, type and date of access, website section or time spent.
      2. Legal basis for processing: our business’s legitimate interest to improve the performance of our Website.
      3. Retention period: your personal information will be retained for 2 years.
6. COOKIES

   Engage uses cookies, plug-ins, and other online identifiers in order to ensure functional browsing or to provide a better browsing experience, to perform statistical analysis on accessing information on the Website, or to provide you with content and advertising appropriate to your interests.

   Online identifiers may be placed by Engage or by third parties. If you consented so, these third-party sites would place cookies that will allow you to view content from these third-party websites on our Website and to share the content from our Website. Third-parties may collect and use your personal data through their cookies for the purposes they have determined in accordance with their privacy policy. Engage provides you with the identity information and links to these third-parties, as well as the option to accept or reject their online identifiers.

   Personal data may be processed through cookies on the basis of the users’ prior consent, excepting those situations when the cookies  are essential for browsing the website and using its functions, or for enforcing its security. In such cases, the processing of personal data is carried out in accordance with the legislation in force on personal data processing and privacy protection in the electronic communications sector on the basis of our legitimate interest of ensuring safe browsing of our Website, both for us and for our users, by implementing appropriate technical and organizational measures.

   Depending on the cookie type, the categories of personal data processed by cookies may be information about the used device, journal information like IP, searches, browser, browser’s language, hardware settings, date and time of the request, the method used to send requests to the server, file capacity obtained in response, and other parameters regarding the user’s operating system.

   Detailed information on the cookies our Website uses may be found in our Cookie Policy at https://www.engagetg.com/cookie-policy.

AUTOMATED DECISION MAKING

We do not make decisions based solely on automatic data processing of your data (including profiling) that will have legal effects on you or that will affect you in a similar way to a significant extent.

DISCLOSURE AND TRANSFER OF PERSONAL DATA

We may transfer your personal information, to the extent that this is necessary to the following categories of recipients: companies from the same group, service partners, subcontractors, payment providers, archiving companies, IT service providers, software or hardware vendors, market research companies, marketing companies, public authorities, court, or arbitral tribunals, as well as competent authorities to investigate criminal offenses. The data may be disclosed or transferred to the mentioned categories of recipients to provide our services at a high standard by outsourcing part of our work to specialists or to comply with specific legal obligations Engage is subject to.As a rule, the transmission of your personal data to the above recipients will be done in accordance with applicable law and only based on a commitment of confidentiality and ensuring an adequate level of security on their part, which guarantees that personal data is kept secure.

SECURITY OF PERSONAL DATA

The security of your Personal Data is important to us. Therefore, we maintain a variety of appropriate technical and organizational measures to protect your Personal Data from loss, misuse, and unauthorized access or disclosure. We limit access to Personal Data to staff whom we believe reasonably need to retrieve that information to provide our services. Considering the current state of technology, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect your Personal Data, such as limiting access, encrypting, anonymizing, or storing it on secure media.No method of transmission over the Internet, method of electronic storage or other security methods is one hundred percent secure. Despite our best efforts to protect your Personal Data, no safeguards can guarantee a perfect level of security and we cannot guarantee their absolute security.

YOUR RIGHTS AND HOW TO EXERCISE THEM

Each data protection legislation recognizes specific rights for the data subjects in relation to the processing of their personal data. Depending on the legislation applicable in your country, you may have all or part of the right mentioned below:

Right to be informed: You have the right to be informed regarding the processing of your personal data, as we are doing through this Privacy Policy. This right may also concern the right to be informed about public and private entities with which Engage has shared your data and the right to be informed about your possibility of denying consent and the consequences of such denial.

Right of access: You have the right to obtain confirmation from us that we process your Personal Data, as well as information on the specifics of processing, such as: purpose of processing, categories of data processed, recipients of personal data, period for which the data is kept, if it is transferred abroad and how we protect it, the source of your personal data.

Right to rectification: At any time, you have the right to request the rectification of your Personal Data. In the event of errors, after notification, we will immediately rectify your personal data.

Right to erasure: You have the right to request the deletion of personal data, provided that your request comply with applicable legal requirements. Personal data will be erased when the legal requirements are met. This right may also concern the right to anonymize, block or delete personal data when it is unnecessary or excessive data or data processed in noncompliance with the provisions Data Protection Law and the right to delete the personal data processed with the consent of the data subject, except in the situations provided by the Data Protection Law.

Right to restriction of processing: If the applicable legal provisions are met, you can request that we restrict the processing of your personal data.

Right to data portability: If the applicable legal provisions are met, you have the right to receive your Personal Data in a structured, commonly used and automatically readable format and the right to transmit it to another data controller.

Right to object: In certain situations, such as when we process Personal Data based on legitimate interest, you have the right to object to our processing of your Personal Data.

Right not to be subject to decisions based solely on automated processing: If the applicable legal provisions are met, you have the right not to be subject to a decision based solely on automatic processing, including profiling, which has legal effects on you or affects you similar to a significant extent.

Right to Opt-Out of Sale or Sharing of Personal Information: You have the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.

Right to address to the Supervisory Authority: You have the right to file a complaint with the Personal Data Authority regarding any violation of your rights regarding the processing of your Personal Data.

If you want to contact the Data Protection Authority from your place of residence, for the EU you may find the contact details at https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-ie.

Consent withdrawal: To the extent that we process your personal data based on your given consent, you can withdraw your consent at any time, without affecting the legality of the processing based on the consent before its withdrawal. You have the right, at any time, to revoke your consent through a facilitated and free of charge procedure.

You may exercise anytime your rights in relation to Engage by e-mailing us at dpo@engagetg.com.

EUROPEAN UNION REPRESENTATIVE

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons regarding the processing of personal data and on the free movement of such data (GDPR), Engage’s designated representative in the European Union is Mr. Alexandru Ganea. If you are based in European Union, you may contact our representative by e-mail at dpo@engagetg.com?

UPDATES

We have the right to change and update this Privacy Policy from time to time, and when we will have substantive or material additions or changes, we will bring them to your attention. Accordingly, we urge you to review this page periodically to stay updated with how we use your Personal Data. If we are to change this Privacy Policy, we will make available the last updated version on the Website. Any changes to this Privacy Policy will be effective upon posting on this page, except those situations where your consent is expressly needed, in which case the changes will apply from the date of your consent.

CONTACT

If you have any questions or concerns regarding the processing of your personal data, this Privacy Policy or how it applies, or you wish to exercise any of your rights, you can contact our Data Protection Officer directly at:

• Email: dpo@engagetg.com
• Address: 3540 E Longwing Lane, Suite 300, Meridian, Idaho, 83646, United States