Effective Date: May 7, 2018

General
81qd, LLC ("81qd" "we" or "us") takes your privacy seriously. This Privacy Policy informs you about 81qd’s data collection and use practices for the 81qd website (www.81qd.com, the "Site") and the Acuity product ("Acuity," and together with the Site, our "Services"). It also informs you how to contact us with any questions you may have and how to exercise your rights with regard to the Data we collect from or about you.

Data We Collect and How We Use It
81qd considers Personally Identifiable Information ("PII") to be information that clearly and directly identifies a particular individual, such as their name, email address, physical address, phone number, or government issued identifier such as a social security number. That which does not clearly or directly identify a particular individual 81qd regards as non-Personally Identifiable Information ("non-PII"). Examples of non-PII include device or browser data, web pages visited, device ID, and your IP address. We may use our own technologies, or the technologies of service providers, to help us gather and process non-PII. If 81qd links non-PII to PII, then 81qd will treat such non-PII as PII.

When we refer to "Data" in this Privacy Policy, we are referring to both PII and non-PII.

81qd may collect Data from or about:

•	General users of the Site ("Users");
•	Individuals who choose to participate in surveys or medical and research professionals who choose to be included in our databases or research groups ("Participants");
•	Individuals who register to use our Services and agree to 81qd’s Terms of Service during registration ("Clients"); and
•	Selected individuals in the medical, health, or pharmaceutical industries who have either agreed that we could collect their information or have otherwise made their information available for us to contact them for business or professional purposes ("Professionals").

•	When you use our Site: 81qd collects non-PII from Users who access the Site. We collect this information for the purpose of providing and improving the Site and understanding generally how our Users interact with the Site. 81qd does not sell or otherwise use the non-PII we collect when Users visit our Site for online behavioral advertising or for third parties’ marketing purposes. We may, however, aggregate the non-PII we collect and use it for our own direct marketing purposes. 81qd may also collect Users’ PII from our Site if you choose to provide it to us. Our Site requires you to provide your PII before you can contact us with a complaint or question, or before you can download a whitepaper or research material. If you provide us with your contact information, 81qd may use your PII to contact you with answers to your questions, to verify your contact information is correct, or to contact you with additional information about 81qd or our Services.
•	Through cookies and other data collection technologies: We may use cookies, web beacons, and other data collection technologies to help us understand our visitors and improve our Site and the services we offer. "Cookies" are small, often encrypted text files that contain small amounts of information that are stored on your device’s browser directory. Cookies help us track usage behavior so that we can tailor information to make your visits more enjoyable and meaningful. For example, we use Google Analytics to collect information about how often users visit the Site, what pages they visit when they do, and what other websites they used prior to coming to this Site. For more information about Google’s ability to use and share information collected by Google Analytics about your visits to the Site, please see the Google Analytics Terms of Service and the Google Privacy Policy. 81qd does not respond to your browser’s "Do Not Track" signals at this time.
•	To provide and enhance Acuity: 81qd collects PII from public sources or directly from Professionals in order to populate Acuity. PII about Professionals is then used by Clients to build and manage relationships with those Professionals, including to track events and interactions with the Professionals.
•	From our Clients: Our Clients, subject to our Terms of Service and in accordance with applicable laws, may provide us with non-PII about individuals, such as de-identified patient identifiers for processing on or through our Services. Unless otherwise agreed, 81qd does not retain ownership or control of the non-PII our Clients may load onto and process through our Services. We use this non-PII to identify and profile health care networks.

81qd reserves the right to process, aggregate, or de-identify any Data we collect through our Services about Participants or Professionals, and to sell, license or otherwise disclose Data about our Participants and Professionals to our Clients or third parties for their own business purposes.

Our Rights to Disclose Your Data
There are times when 81qd needs to disclose your Data. We may disclose your Data:

•	To our service providers that help us process or store your Data. When we use service providers to help us, we use contractual controls to help ensure your Data is protected.
•	To partners that help us market our products and services. We will only disclose your Data to partners in a manner that complies with applicable laws and the promises we make to you in this Privacy Policy and in our Terms of Use.
•	In the event that 81qd is involved in a corporate transaction, such as an acquisition or merger. If Data is shared through a corporate transaction, our Terms of Use and the promises in this Privacy Policy will still apply to Data that may be transferred via such a transaction.
•	In the event 81qd is subject to legal inquiry or process. Such disclosure may be made subject to lawful requests by public authorities, including meeting national security or law enforcement requirements. A disclosure may also be made to defend ourselves against legal claims, or to assert a claim or defend ourselves against another.

Your Choices

81qd will offer individuals the opportunity to choose (opt-out) whether their PII is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. In addition:

If you are a Client: Upon request, 81qd will provide you with information about whether we hold any of your PII. To review and update your PII to ensure it is accurate, contact us through the following form at http://81qd.com/contact.php. We will respond to all requests for access, to correct inaccurate data, update information or delete information within 30 business days.
If you are a Participant: Participants can choose to limit our collection, use, and sharing of their Data by opting out of our services or by contacting 81qd through the following form: http://81qd.com/contact.php. Upon request, 81qd will provide you with information about whether we hold any of your PII. To review and update your PII to ensure it is accurate, contact us through the following form at http://81qd.com/contact.php. We will respond to all requests for access, to correct inaccurate data, update information or delete information within 30 business days.
If you are a Professional: 81qd acknowledges that you have the right to access your PII. Typically, 81qd acts as a service provider to our Clients. We collect information at and under the direction of our Clients and generally have no direct relationships with the individuals whose PII we process. If you are a Professional whose PII we maintain on behalf of one of our Clients, please contact the Client that you interact with directly. An individual who seeks access, or who seeks to correct, modify or delete PII should direct queries to the appropriate 81qd Client. If an 81qd Client requests 81qd’s assistance in the removal of PII, 81qd will respond to such requests within 30 business days.

To exercise any of the choices mentioned above, please contact 81qd using the contact information below.

Children

81qd never knowingly collects or maintains PII from minors, and no part of our Site is structured to attract any minor. If we become aware that we have collected Data from a child under 13, we will immediately delete such Data.

Participation in Privacy Programs

81qd has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. We are responsible for the processing of PII about individuals in the EEA ("EEA PII") that we receive under the Privacy Shield Framework and subsequently transfer to a third party acting as an agent on our behalf. We also comply with the Privacy Shield Principles for all onward transfers of EEA PII from the EU and Switzerland, including the onward transfer liability provisions. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern with regard to.

81qd is subject to the enforcement and investigatory powers of the United States Federal Trade Commission for our data collection and use practices. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, 81qd commits to resolving complaints about our collection or use of EEA PII. EEA individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Privacy Officer either by phone by dialing 1-212-661-3337 and asking for the Privacy Officer, or online at http://81qd.com/contact.php. 81qd has further committed to referring unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.icdr.org/privacyshield for more information or to file a complaint. The services of the American Arbitration Association are provided at no cost to you. You can also contact them by mail at:

International Centre for Dispute Resolution
Case Filing Services
1101 Laurel Oak Road, Suite 100
Voorhees, NJ 08043 United States
Phone: 1-212-484-4181 or
Email: casefiling@adr.org

If you are a citizen of an EU member country you have the right to invoke binding arbitration if you have a dispute about our collection and use of your EU PII.

Confidentiality & Security

We limit access to your Data to employees who we believe reasonably need to come into contact with that Data to provide our Services or in order to do their jobs. We have reasonable technical and organizational safeguards to protect your Data when we store or process it.

Third Party Websites

At times, our Services may provide links through which you can access other websites. 81qd is not responsible for the data collection practices or the content of these third party links or websites, and we encourage you to review the privacy policies of any third party website prior to sharing your PII with those third parties.

Changes to This Policy

81qd reserves the right to change this privacy notice from time to time. If we do, we will update this page, together with the date of publication. Please check this page periodically for updates to our notice. We will provide notification of material changes through the company’s website or to our Clients via email prior to the change becoming effective.

Contact Us

If you have any questions, complaints, a dispute on the collection or handling of your information, or questions about this Privacy Policy or our practices described herein, you may contact our Privacy Officer either by phone by dialing 1-212-661-7685 and asking for the Privacy Officer, or online at http://81qd.com/contact.php. You may also send registered or certified mail to:

81qd, LLC
Privacy Officer
750 Third Avenue, Suite 1003
New York, NY 10017

Your use of the Site is subject to our Terms of Use. This Privacy Policy is incorporated into and made part of these Terms of Use. If you do not agree to our Privacy Policy or Terms of Use, please do not use or access the Site.