Comprehensive Privacy Policy

Comprehensive Privacy Policy

Because your privacy is a priority for the Community Oncology Alliance (“COA”), we want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device, and that enable your identification (the “Personal Information”). This Privacy Policy describes our practices with information that we (or our service providers) collect through the COA’s meetings and events, including live, via conference call, or webinar (collectively “Events”); emails and other communications (collectively “Communications”); and digital platforms, accessible through www.CommunityOncology.org, www.COApharmacy.com, www.COAAdvocacy.org, www.COAnalyzer.net, www.COAConference.org, www.MedicalHomeOncology.org, www.NCTACancer.com, www.CPNCancer.com, or our mobile conference application, (collectively, the “Platforms”). This Privacy Policy only addresses information collected directly through or from the Platforms – it does not address or govern any information-gathering, use, or dissemination practices related to information collected from you other than directly through or from the Events, Communications, and Platforms.

By using or participating in the COA Events, Communications, and Platforms, you agree to the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into the Terms of Service  for the Platforms by reference, as if set forth fully therein, which must also be reviewed and accepted by you. If you have any questions concerning this Privacy Policy or wish to exercise your rights as described in this Privacy Policy, please email us at info@coacancer.org with the subject line “Privacy Policy”.

1. INFORMATION COLLECTION

a. Information You Provide

Some elements of the Platforms may ask you to submit Personal Information in order for you to benefit from the specified features or to participate in a particular activity. For example, we may request Personal Information from you when you create an account and conduct scheduling activities. You will be informed what information is required to utilize these features of the Platforms, and what information is optional.

You may also be permitted to post information to the Platforms, including through an advocacy forum or survey, which will be accessible for other users (collectively, the “Forums”). We collect Personal Information that you knowingly provide to us in the Forums. Please remember that any Personal Information that you disclose in the Forums becomes public information and may be viewed and used by others. You are solely responsible for the content you post online in the Forums. COA has no control over and will not be held responsible for any Personal Information disclosed in the Forums or the use of such Personal Information by third parties. By submitting Personal Information in the Forum, you acknowledge that you have no expectation of privacy with regard to any submission or posting. You should always exercise caution when deciding to disclose your Personal Information.

We may combine the information you submit through the Platforms with other information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, including publicly available information sources (such as publicly available social media profiles) as well as our service partners and data licensors, all subject to applicable laws.

b. Certain Demographic and Educational or Employment Information

Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, health, criminal background, trade union membership, political opinions, religion or other beliefs.  In those cases where we may request or invite you to provide the foregoing information, we will only do so with your express consent, in accordance with applicable data protection law requirements. Where you provide us with such information without request from COA to this end, we reserve the right to erase any such information at our discretion.

c. Passive Information Collection, Use, and Choices

As you navigate the Platforms, certain Personal Information may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:

  • i. Through your browser: Certain information is collected by most browsers, such as your Internet Protocol (IP) address, computer type, operating system type, version screen resolution, and Internet browser type and version.
  • ii. Through your device: If you access the Platforms through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Platforms.
  • iii. Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Platforms, pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Platforms. More specifically, we use cookies to:
    • Recognize your computer or device to make your use of the Platforms easier, such as to remember your locations of interest and other preferences with the Platforms;
    • Gather statistical information about use of the Platforms in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it;
    • Select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Platforms and on other websites, applications, and online services that you use; and
    • Track consumer responses to online advertisements. To learn more about cookies, please visit http://www.allabouorg.
  • iv. Using Monitoring Tools: The Platforms may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies, both on certain aspects of the Platforms and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Platforms usage and response rates, and tracking the activities of users of the Platforms and e-mail recipients.
  • v. IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Platforms, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Platforms usage levels, helping diagnose server problems, and administering the Platforms.
  • vi. Analytic Tools: We may also use tools and third party services to collect information about usage of the Platforms, including Google Analytics. You can learn more about Google Analytics, and its privacy practices, at the Google Analytics Help Page. Generally speaking, Google Analytics collects information on how often users visit the Platforms, what aspects of the Platforms they visit when they do so, and what other websites users visited prior to accessing the Platforms. You may opt out of Google Analytics for Display Advertising or customize Google Display Network ads through the Google Ads Settings page. You may also prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.

If you are uncomfortable with the idea of your Personal Information being collected and used in these ways, most computer systems, devices, and web browsers offer privacy settings and options, such as disabling cookies, resetting your IDFA, turning off location-based services, or opting for “Do Not Track” features. See Section 2(c) below for more information on opting out of Interest Based Advertising. We do not override these settings or options and encourage you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products, or benefits of the Platforms, you may be required to provide us with certain information. If you do not wish to provide that information through the Platforms or if you opt to utilize the aforementioned privacy features, you may be unable to obtain certain content, features, services, products, or benefits of the Platforms. Changing these settings will not prevent you from seeing advertisements and offers, but those advertisements and offers may not be tailored to your interests and needs.

d. Social Media and Other Third Party Platforms

In some cases, you may be able to engage with our content, such as video, applications, and other offerings, on or through social media services or other third party platforms, such as Facebook. When you engage with our content on or through social media services or other third party platforms, plug-ins, integrations, or applications, we may have access to certain information in your profile with that service or platform. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, photos and videos, your list of friends or connections, people you follow and who follows you, and your posts and “likes." For a description on how such social media services and other third party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

2. HOW WE USE AND DISCLOSE INFORMATION

a. Overview of Use and Disclosure

We use Personal Information submitted by you or otherwise collected through the Platforms and through other sources for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Specifically, we may use Personal Information from or about you:

  • i. To respond to your inquiries and fulfill your requests, such as to send you scheduling information and e-mail or push alerts and to perform requested services, including to verify your credentials;
  • ii. To send you important information regarding our relationship with you or regarding the Platforms, changes to our terms, conditions, and policies, and other administrative information;
  • iii. To promote our products and services, and the products and services of our third party business partners; and
  • iv. For our business purposes, such as data analysis, audits, developing new products, enhancing the Platforms, improving our products and services, identifying Platforms usage trends, personalizing your experience on the Platforms by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.

We may use any information that does not personally identify you, your computer, or your device, for any purpose.

In order to provide the features and services made available through the Platforms and accomplish the goals described in this Privacy Policy or at the point when we collect the information, we may disclose your Personal Information as described below and as specifically described elsewhere in this Privacy Policy or at the point we collect information from you:

  • 1. To Administrators, Care Providers and Facilities to provide the Services, as defined in the Terms of Service;
  • 2. To our affiliates for the purposes described in this Privacy Policy;
  • 3. To our third party service providers who provide services to us, such as website hosting and moderating, mobile application hosting, data analysis, payment processing, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, credit card processing, auditing services, and other services, in order to enable them to provide those services;
  • 4. To unaffiliated third parties, including by sharing or selling demographic information, advertising and device identifiers, IP address, and usage statistics to our advertising partners and other third parties, some of whom may use it to offer promotions to you for other products and services; and
  • 5. To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

b. Uses and Disclosures to Comply with Laws

In addition, we use and disclose Personal Information collected through the Platforms as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including healthcare institutions; (iv) to enforce our terms and conditions of use, including the Terms of Use for the Platforms; (v) to protect our operations and those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

c. Interest Based Advertising

As described above, we work with a variety of third party business partners, including Facilities, advertisers, advertising networks, and advertising and analytics companies that use various technologies to collect data about your use of the Platforms. COA and our third party business partners may use the aforementioned technologies to:

  • i. Track how you use the Platforms, how you arrived at the Platforms, and what you do after you leave the Platforms;
  • ii. Record and link your devices, including your personal computer and mobile device (this is called cross-device linking); and
  • iii. Provide you with information and advertisements relevant to your interests, taking into account your use of the Platforms and the other websites and online services that you use. Note that this information and any advertisements may be delivered to you on the Platforms, on third party websites and applications, and on a computer or device other than the device from which the information was collected.

This is called “Interest-Based Advertising” or “Online Behavioral Advertising.” While we work with our third party business partners to improve your experiences with the Platforms, we do not control their business practices.

Section 1(e) (Passive Information Collection, Use, and Choices) and Section 5(a) (Opting Out of Collection and Disclosure) of this Privacy Policy describe various methods of preventing passive collection and use of your information by our third party business partners. To learn more about Interest Based Advertising, please visit www.networkadvertising.org/choices and http://www.aboutads.info/choices.

If you wish to opt-out of participating in Interest Based Advertising, you can use some or all of the following methods:

If you use more than one device to access the Platforms, you should renew your opt-out choices on each such device.

3. THIRD PARTY WEBSITES AND SERVICES

The Platforms may also contain links to or utilize the features of third party websites and other online services for your convenience with locating information, products, or services that may be of interest. If you access a third party service from a link on the Platforms, including any Facility, any information you disclose to that third party is not subject to this Privacy Policy. In addition, it is possible that these links may be used by Facilities or other third parties to collect personal or other information about you.

We are not responsible for the privacy practices of other online services, including Facilities, other websites, advertisers, payment processors, or social media. It is your sole obligation to review and understand the privacy practices and policies of third parties. We do not control the use of cookies or the collection of information by these third parties, nor how they manage such information. The availability of, or inclusion of a link to or interface with, any third party service on the Platforms does not imply endorsement of it by us or by our affiliates. Your use of those other sites and services is subject to the privacy policies of those sites and services, and not this Privacy Policy.

4. SECURITY

The security of your Personal Information is important to us and we are committed to handling that information carefully. We use commercially reasonable organizational, technical, and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of an account you have with us has been compromised), please immediately notify us of the problem.

5. CHOICES, ACCESS, AND RETENTION

a. Opting Out of Collection and Disclosure

The easiest way to stop the collection of Personal Information about you is to discontinue using the Platforms, including by no longer using the Platforms or by deleting the applications, products, and services from your devices. To uninstall our applications from your devices, such as smartphone applications or tablet applications, you may use the standard uninstall processes as may be available as part of your device or via the application marketplace or network.

In addition, except as necessary to obtain the services or information requested, you may opt out of having your Personal Information (that is within our control) prospectively retained by us or used by us for certain purposes by deleting your account. You may contact us for any of the foregoing at info@coacancer.org with the subject line “Privacy Policy”.

b. Opting Out of Direct Communications (Emails and Text Messages)

We want to communicate with you only if you want to hear from us. To that end, we give you choices regarding our use and disclosure of your Personal Information for purposes of sending communications to you, such as by emails or text messages or through push notifications. You may opt out from:

  • i. Receiving Direct Marketing Communications From Us: Where your Personal Information are processed by us or upon our instructions for direct marketing purposes, you have the right to object at any time to such processing, including any profiling conducted for that purpose. If you no longer want to receive direct marketing communications from us on a going-forward basis, you may opt out of receiving them by contacting us at info@coacancer.org with the subject line “Privacy Policy”. In your response to us, please provide your name, identify the forms of marketing communications that you no longer wish to receive, and include the addresses or telephone numbers to which they are sent. For example, if you no longer wish to receive marketing e-mails or direct mail from us, tell us that, and provide your name and e-mail or postal address. In addition, you may opt out of receiving marketing e-mails and text messages from us by following the unsubscribe instructions provided in any such messages.
  • ii. Sharing of Your Personal Information for Direct Marketing: If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates and/or third party partners for their direct marketing purposes (such as direct communications by email, text message, and mailings directed to you), you may opt out of this sharing by contacting us at info@coacancer.org with the subject line “Privacy Policy”. In your response to us, please state that we should no longer share your Personal Information with our affiliates and/or third party partners for their direct marketing purposes, and include your name and e-mail address.

We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your Personal Information from the databases of our affiliates or third party partners with which we have already shared your information (i.e., as of the date that we implement your opt-out request) but we will take reasonable steps, including technical measures, to inform third parties which are processing your Personal Information that you have opted out as described above. Please also note that if you opt out of receiving direct marketing messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to scheduling, available upgrades and other emails relating to your account and/or your use of the Platforms).

c. Accessing, Correcting, and Updating Your Personal Information

At your request, we will provide you with a summary of the Personal Information that we maintain in connection with your account with the Platforms that has been voluntarily provided by you through email, registration forms, or other contact forms. You may contact us for any of the foregoing at info@coacancer.org with the subject line “Privacy Policy”. Upon your request and to the extent required by applicable law, we will update or correct that information. We will try to comply with your request as soon as reasonably practicable. You may also visit the Platforms to update your online profile or change your password.

Additionally, California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared 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 to info@coacancer.org with the subject line “Privacy Policy”.

6. BASED IN THE UNITED STATES

The Platforms are controlled and operated from within the United States. We make no representation that the Platforms are appropriate or available for use outside the United States, or that access and use of the Platforms in accordance with this Privacy Policy complies with the laws of your jurisdiction. Those who choose to access the Platforms from outside the United States do so on their own will and are fully responsible for compliance with applicable laws.

7. UPDATES TO THIS PRIVACY POLICY

COA reserves the right at any time to modify, alter, and update this Privacy Policy. Your use of the Platforms following any changes means that you agree to follow and be bound by the Privacy Policy as changed. Any change to this Privacy Policy shall be effective as to any visitor who has visited the Platforms before the change was made. It is the obligation of users of the Platforms before the change to learn of changes to the Privacy Policy since their last use.

8. NOT FOR USE BY MINORS

The Platforms are not intended for persons under the age of 18. We do not knowingly collect personal information online from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.