Last updated: July 6, 2020
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About this Policy
We’ve broken this policy down into the following sections, so you can easily find the details you need.
- Who We Are
- How This Policy Applies
- Who Collects Information
- How We Collect Your Information
- What We Collect
- How We Use Your Information
- How We Share Your Information
- Keeping Your Personal Information Secure
- Your Rights And User Restrictions
- How To Contact Us
- International users
- CancerLinQ Platform System Terms and Patient Information Flyer
2. Who We Are
We are CancerLinQ LLC and its corporate affiliates and their subsidiaries, including American Society of Clinical Oncology, Inc., ASCO Association, Conquer Cancer Foundation of the American Society of Clinical Oncology, and QOPI Certification Program, LLC (collectively, “CLQ”).
- “we/us/our” means CLQ as described above; and
- “third party” means someone who is not you or us.
Our registered office is CancerLinQ, 2318 Mill Road, Suite 600, VA, 22314, USA. We are a non-profit limited liability company registered in the United States of America with the Virginia State Corporation Commission under SCC ID S5323318.
3. How This Policy Applies
- When you visit the Website, including collection through tracking technologies.
- Through email, text, other electronic messages, paper registrations, telephone inquiries or communications between you and the Website or CLQ. Note that “Website” is further defined in Section 14, Glossary.
- When you complete online forms available through our Website or upload information to the Website portal.
- We collect through any other means not referred to above.
- We collect through any other means not referred to above.
4. Who Collects Information
CLQ Pages and Content Managed by Third Parties
The Website may link to or contain certain Third Party Managed Pages hosted, operated, or managed on CLQ’s behalf. Our contracted third-party service providers may directly collect PII and other information from you as necessary or recommended for completing authorized transactions or other engagements you undertake with CLQ on these pages, including through interactions with you. For additional information on “PII” see Section 14, Glossary.
Examples of these Third Party Managed Pages can be found below in the Glossary.
The Website also makes use of third-party Cookies, Web Beacons, Pixels, and dynamic tags, which may allow third parties to collect information about you and your activities on the Website and provide you, or enable others to provide you, with functionality within our Website, additional personalization, or with advertising. For additional information concerning Cookies, Web Beacons and Pixels, see Section 14, Glossary.
Links to External Sites
Third Party Cookies
Third party websites that you visit from time to time may drop their own Cookies, Web Beacons, Pixels, or other tracking technologies on your browser or device. CLQ is not responsible for the information collected by those third parties or their privacy practices.
5. How We Collect Your Information
We will collect your personal information when you, for example:
- Buy or use any of our products and services;
- Use the CancerLinQ Platform;
- Become an ASCO member or CancerLinQ subscriber;
- Register for or select a specific product or service;
- Subscribe to email communications, newsletters, alerts, community forums, or other similar services from us;
- Contact us through various channels, or ask for information about an event, publication, product, or service;
- Submit a request for access to CancerLinQ Discovery data;
- Take part in an award, grant, or survey involving CancerLinQ;
- Use the Third Party Managed Pages;
- Visit or browse our Website or other CLQ digital properties; or
- Have given permission to other companies to share information about you.
We may collect your information when such information is available from another public source. We also collect information from certain organizations, where appropriate and to the extent we have legal grounds to do so. These include our affiliates, fraud-prevention agencies, business directories, billing calculating agencies, and connected network providers.
6. What We Collect
The types of information we may collect depend on the ways in which you engage with CLQ as well as the products and services you elect to receive. This may include, where applicable:
- Your title, name, address, phone and/or mobile number, your date of birth, gender, employer, and email address;
- Your credit or debit card information, information about your bank account and other banking information – for example, we’ll collect any data necessary to process a payment whenever you make a purchase or if you elect to have grant funds directly deposited in connection with Mission Endowment grants;
- Your location data. For example, a location is derived from your IP address, geolocation, or other data such as a zip code or name of a town or city;
- The content of your contact with us, such as a note or recording of a call you make to one of our customer service centers, an email sent, feedback you submit to us, content you submit to us in connection with a CancerLinQ Discovery request; or other records of any contact with us;
- Your affiliation with a CancerLinQ subscriber or potential subscriber;
- Your account information, such as payment data, membership status, account numbers, or other information related to your account.
- Credential information – we’ll collect passwords, hints, and similar security information used for authentication and access to accounts and services;
- Your preferences for particular products, services, communications, and lifestyle activities based on how you use our products and services (personalization);
- See the “Cookies” section for details on what we collect using Cookies, Web Beacons, Pixels, and other technologies, including digital advertising.
- Your browsing history. Based on your browser and device settings, CLQ may collect the categories of our Websites you have browsed on your device(s), e.g., About Us, Services, News & Info, and use these interests to send you personalized marketing or advertising. We may also collect information on the website you were on before and after you visited our Website. You can opt-out of targeted advertising through Cookies and by updating your preference center. See, Section 10, “Your Rights and User Restrictions”.
- Information we obtain from other sources, such as fraud-prevention agencies, publicly available sites, and from other data providers. This includes demographic data, interest-based data, and internet browsing behavior.
7. How We Use Your information
- Responding to your questions or providing information that you request.
- Providing you with products, services, or other information you select or request, including associated benefits.
- Providing you with account notifications.
- Managing your account functions, including user contributions.
- Carrying out our obligations and enforcing our rights arising from any contracts entered between you and us, including for billing and collection.
B. CLQ’s Legitimate Business Interests. We use your information in connection with CLQ’s legitimate business interests: including, without limitation, fraud prevention, maintaining the security of our network and services, direct marketing, personalizing your experience with us, and improving our Website, products, and services. This also includes use of your Non-Personal Information (“NPI”) (see Section 14, Glossary). The NPI we automatically collect from you is generally used to render, administer, and improve the Website, our services, and our business. It helps us to improve our Website and to deliver a better and more personalized service. Purposes for which we may use your information include, but are not limited to, the following:
- Presenting our Website and its contents to you.
- Helping dynamically generate content on web pages or in electronic communications and newsletters.
- Statistically monitoring how many people are using the Website or interacting with communications from us.
- Tracking generic user behavior.
- Helping us evaluate the purpose for which our users undertake certain activities, including those listed immediately above.
- Determining the popularity of certain content.
- Restricting underage use of our services.
- Speeding up your searches and facilitating log-in and navigation, including using session timers.
- Enabling us and our advertisers and social media partners to display advertisements to appropriate target audiences, including through Online Behavioral Advertising.
- Storing information about your preferences, allowing us to personalize your content.
- For other commercially reasonable purposes, including measuring advertising and promotional effectiveness and assessing which areas of the Website to remarket to you after you leave our site.
- To advise you of products or services that may be available through CLQ.
- To notify you about Website maintenance, updates, changes, and new features, including products or services we offer or provide through the Website.
- To allow you to participate in interactive features on our Website.
- To solicit user feedback to assess user-satisfaction or other needs and interests.
- To help us in creating new tools, features, and services.
- To monitor performance of our website and user experiences in order to trouble-shoot errors and performance issues and respond more effectively to customer inquiries.
- To offer you live assistance and other tools designed to improve your experience on our Website.
Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they are legitimate, that our use is reasonably necessary for the applicable purpose, and does not materially impact your privacy rights. Additionally, in some cases you have the right to object to this processing. See also, Section 10, “Your Rights and User Restrictions”.
C. Compliance with a Mandatory Legal Obligation. We use your information in compliance with mandatory legal obligations, including for example accounting and tax requirements, or as may be required by law enforcement agencies, government bodies, regulatory organizations, courts or other public authorities, or any other third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement .
D. Consent. We use your personal information when you give us consent to do so. When you give your consent for the processing of your personal information, you will be given details on how to change your mind at any time. Consent may be withdrawn or modified at any time. Visit Section 10, “Your rights” for more information.
E. Other Potential Uses For Your Personal Information
In addition to the above use cases, we may lawfully process your personal information for the following purposes:
1. Use of Third Party Cookies and Other Tracking Technologies
The Website makes use of automatic data collection technologies including first and third-party cookies, log files, Web Beacons, Pixels, dynamic tags, and/or other technical means (we refer to these collectively as “Cookies”), including through Google advertising services and similar search engine services. We may use these technologies to collect information about your online activities over time and across third party websites or other online services to deliver content and advertising tailored to your interests, both on the Website and on third-party websites (including but not limited to search engines and social media websites). This practice is commonly known as “Online Behavioral Advertising.”
The third parties who provide us with third-party Cookies, may use these technologies to collect information about you when you use the Website to provide you with advertising based on your visit to the Website or to collect impressions data regarding the efficacy of advertising placed with us. Third parties, including those operating the Third Party Managed Pages, may have the ability to link the information they collect about you when you use the Website with other information they collect about you elsewhere on the Internet or information about the device you are using. Third parties may also collect information about your online activities over time and across different websites and other online services or mobile devices and may use this information to provide you with Online Behavioral Advertising or other targeted content.
We currently use a Cookie consent manager, providing you with more transparency about the types of Cookies we place on our website and how they function, and granting you more control over how your data is used. You can update your preferences at any time by clicking here or visiting the "Cookies" link at the bottom of our Website. Please remember that Cookie preferences are browser and device specific, which means that each time you use a different browser or device, you will need to set your preferences on that specific browser or device. CLQ reviews our Cookie consent manager settings on a periodic basis to capture and react to new Cookies and changes in Cookie performance on our Website, so please be aware that any such changes will be reflected in the consent manager on the next available update. Our Cookie consent manager addresses Cookies we place (including third party cookies we place) on our Website – it does not address Cookies that may be placed on your browser or device by Third Party Managed Pages or by third parties unaffiliated with CLQ based on your prior or subsequent browsing history.
Please contact us at firstname.lastname@example.org should you have any questions or concerns.
2. Disclosure of Information to Third-Party Vendors and Service Providers
CLQ has engaged third-party vendors and service providers to provide content and services in connection with the Website (including without limitation technology and application providers), outreach for our programs and services, and to help us manage our web presence and improve performance. We may share PII or other information with these third-party vendors and service providers as necessary so that they may provide the services for which they have been engaged. PII and other information submitted to CLQ through Third Party Managed Pages are also shared with the relevant third-party vendor as necessary for completing authorized transactions.
3. Social Networking
4. Research and Analytics
For example, analytics are used to:
- Conduct market research and carry out research and statistical analysis including to monitor how subscribers and visitors use our networks, products, and services;
- Frame our marketing campaigns and personalization efforts; and
- Provide reports to third parties (such reports do not contain information which may identify you as an individual).
8. How We Share Your Personal Information
Where applicable, we share information about you with:
- Our corporate affiliates and their subsidiaries, including American Society of Clinical Oncology, Conquer Cancer Foundation of the American Society of Clinical Oncology, ASCO Association, and QOPI Certification Program, LLC;
- Partners, suppliers, vendors, and agents involved in developing or delivering the products and services you’ve ordered or used, or the benefits attendant to those products and services (e.g., member and subscriber benefits), including those operating our Third Party Managed Pages;
- Volunteer groups advising CLQ on content, products and services, such as CLQ’s Physician Advisory Committee;
- Companies who are engaged to perform services for, or on behalf of, CLQ or its affiliates;
- Law enforcement agencies, government bodies, regulatory organizations, courts or other public authorities if we must, or are authorized to by law; and
- A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.
A. Promotional Offers from CLQ and Third Parties
When you register or otherwise interact with our Website, you may be asked whether you want to receive special announcements and future communications by email. If you check “yes” (or the equivalent) but change your mind at any time in the future and no longer wish to receive correspondence by email, you will be able to opt-out of these services. See Section 10, “Your rights and user restrictions”, below, or send us an email at email@example.com.
We occasionally survey visitors to our Website. Survey responses are used in aggregated, de-identified form to help us understand the needs of our visitors so that we can improve our site. The information may be shared on a de-identified and/or aggregated basis with third parties with whom we have a business relationship. While you may always decline to share personal information, if survey respondents provide personal information (e.g., personal email) in a survey, it is shared only with those people who need to see it to respond to the question or request, or with third parties who perform data management services for our Website, product or service. Those third parties have agreed to keep all data from surveys confidential.
D. IP addresses
The Web server automatically collects the Internet Protocol (IP) address of the computers and devices that access our Website. By itself, an IP address merely indicates which computer or device sent a query, which is not PII. Only when correlated with information like user logs, query patterns, and other contextual information do IP addresses potentially convert to PII. Typically, we use this information in aggregate form to understand how our Website or advertisements are being used and to analyze how we can better serve visitors. See Section 14, Glossary, for additional information on PII.
E. Chat and Troubleshooting Technologies
Our Websites may contain “live chat” technologies that you can elect to interact with in order to troubleshoot your experience on the website or find information, products, and services more easily. Additionally, we use tracking technologies that record user sessions on an anonymous basis solely for the purpose of troubleshooting Website performance, including identifying and correcting functionality and performance issues.
F. Support Services and Forums
9. Keeping Your Personal Information Secure
Access to data and technology relating to user information is password-protected and limited to authorized personnel and those vendors that require access to the information in order to furnish services to CLQ and our customers. In addition, CLQ uses industry standard technology to keep users’ information secure while residing on CLQ’s servers. We have specialized security teams who regularly review and improve our measures to protect your personal information from unauthorized access, accidental loss, disclosure, or destruction.
Communications over the internet (such as e-mails) are not secure unless they have been encrypted. Your communications may go through several countries before being delivered, as this is the nature of the Internet. We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.
We will never ask for your secure personal or account information by an unsolicited means of communication. You are responsible for keeping your personal and account information secure and not sharing it with others.
Our Website may provide links to third-party websites and Third Party Managed Pages. We cannot be responsible for the security and content of such third-party websites. Please be sure to read that company’s privacy and cookies policies before using or putting your personal information on their site. The same applies to any third-party websites or content you connect to using our products and services.
10. Your Rights and User Restrictions
A. Your California Privacy Rights
CLQ is a non-profit organization and a wholly-owned subsidiary of American Society of Clinical Oncology, Inc., a 501(c)(3) organization. California Civil Code Section 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email to firstname.lastname@example.org or write us at CancerLinQ, 2318 Mill Road, Suite 800, Alexandria, Virginia 22314, Attn: Privacy or Security Officer.
B. Right to Correct Personal Data
You have the right to have information held about you corrected if it is not accurate. If what we hold on you needs updating, or you think it may be inaccurate, please contact our CLQ Customer Services team:
Monday–Friday, 8:30am–5:00pm (ET)
2318 Mill Road, Suite 800
Alexandria, VA 22314
P: 888-282-2552, 703-299-0158
C. Right to Access Personal Data
You have the right to make a request for a copy of the personal data that CLQ holds about you. To make this request as an individual or an authorized third party, you can contact our CLQ Customer Services Team at the above-referenced contact information.
D. Right to Object to Use of Personal Data
You have the right, in certain circumstances, to object to CLQ processing your personal information. If you have questions about this right, please contact our CLQ Customer Services Team at the above-referenced contact information.
E. To Opt-Out of Marketing Messages
If you no longer want to receive marketing messages from CLQ, you can elect to opt out of all marketing communications or only selected methods (e.g., email, phone or post).
There are various ways to opt out:
- Contact our CLQ Customer Services Team
Monday–Friday, 8:30am–5:00pm (ET)
2318 Mill Road, Suite 800
Alexandria, VA 22314
P: 888-282-2552, 703-299-0158
- Click the link at the end of a marketing email to unsubscribe from that type of communications
- Use the Email Subscriptions link within an e-mail to access the appropriate preference center, and update your preferences there;
- Visit the ASCO Customer Preference Center by logging in to your ASCO.org profile and select “Manage Email Subscription” to control those communications sent to you as a result of your status as an ASCO member, and revise your selections; or
- Send us an email at email@example.com.
Opting out does not mean that you will not still receive service-related messages, other communications from us regarding transactions you undertake with us (including fulfillment of benefits associated with those transactions), or messages that we have another lawful basis for sending. You may continue to receive those (unless we have indicated otherwise). If you do not wish to receive personalized marketing, or you subsequently change your mind, email us.
Please recognize that Third-Party Managed Pages (and their products and services) may have their own preference centers for communications with you relating to those specific products and services. If any questions arise, contact us at firstname.lastname@example.org or email@example.com so that we can discuss your preferences.
F. How to Lodge a Complaint
If you want to contact us about any of your rights or complain about how we use your information, contact our Customer Services team or email us at firstname.lastname@example.org or email@example.com.
G. Right to restrict use of your data
If you feel data we hold on you should not be processed in a particular way or for a particular purpose, please contact our Customer Services team to discuss your rights. In certain circumstances you will have the right to ask us to restrict processing.
H. Right to erasure
CLQ strives to only process and retain your data for as long as we need to. In certain circumstances you have the right to request that we erase personal data of yours that we hold. If you feel that we are retaining your data longer than we need, it is worth first checking that your contract with CLQ has been terminated or completed, which you can do with the Customer Services center. If your contract with CLQ has been terminated or completed, then we may still have lawful grounds to process your personal data.
I. CLQ Restrictions: Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Website. We do not knowingly collect PII from children under the age of 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
11. How to Contact CLQ
12. International Users
CLQ and the Website is based in the United States and, regardless of where you access the Website, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Currently, CLQ products and services are only available to practices in the United States. Any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using the Website, you consent to this collection, transfer, storage, and processing of information to and in the United States in accordance with the foregoing.
If you are an International User, the GDPR (and related international regulations) requires CLQ to inform you of its use of automated decision-making tools. CLQ uses various tools, such as Google Analytics® and Adobe Analytics Cloud (https://www.adobe.com/privacy/marketing-cloud.html), to track your online activities to provide you with tailored advertising.
13. CancerLinQ Platform System Terms and Patient Information Flyer
Use of the CancerLinQ platform and suite of services incorporated therein is also subject to the System Terms made available to authorized users within the CancerLinQ platform itself.
Patients can learn more about how their practices interact with CancerLinQ and how CancerLinQ stewards their data on our website at https://www.cancerlinq.org/news, and by reviewing our patient information flyer here. If a patient does not want their data to be included in CancerLinQ, they should notify their doctor or another member of their healthcare team of their request. CancerLinQ staff can then assist the doctor with the necessary steps to have patient identifiable data removed from the CancerLinQ system. Contact us with any questions at email@example.com.
Non-Personal Information (“NPI”). Information that may relate to an individual but does not by itself identify that individual. For example, browser information is Non-Personal Information, as is information such as gender, age, city, and physical location, when not linked with other data. NPI may be “re-identified” through certain processes by linking it to other information, including PII relating to the same individual.
Personally Identifiable Information (“PII”). Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Further, PII is defined as information: (i) that directly identifies an individual (e.g., name, address, SSN or other identifying number or code, telephone number, email address, etc.) or (ii) by which an organization intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, CLQ Subscriber ID, ASCO Member ID and/or other descriptors). Additionally, information permitting the physical or online contacting of a specific individual is the same as PII. This information can be maintained any form. For the purposes of GDPR, PII includes personal data as defined by GDPR.
Web Beacons or Pixels (also often referred to as “clear GIFs,” “pixel tags,” “1-by-1 GIFs,” “Single-Pixel GIFs,” “1 x 1 Pixels” or “clear Pixels”). Pages of the website and our e-mails may contain small electronic files known as web beacons that permit us and/or third parties to collect Web Information during your visit to the Website. For example, Web Beacons may be used to count the number of users who have visited a page or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Web Beacons send information back to their home server (which can belong to the host site, a network advertiser, or some other third party) from the users’ Browser, such as the IP address, the URL of the page on which the beacon is located, the type of Browser that is accessing the site, and information stored in any Cookies on the users’ computer previously placed by that server. Web Beacons can also be used to place a Cookie on the users’ Browser. Third parties who provide us with web beacons or pixels may have the ability to link the information they collect about you when you use the Website with other information they collect about you elsewhere on the Internet, including but not limited to your PII or information about the device you are using.