Effective Date: May 7, 2018
81qd, LLC ("81qd
" or "us
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
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").
81qd collects this Data in order to provide our Services, ensure the security and operability of our Services, update and improve upon our Services, or to provide new Services. Specifically, 81qd collects and uses Data in the following ways:
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
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
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
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
||In the event that 81qd is involved in a corporate transaction, such as an acquisition or merger.
||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.
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:
. 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
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
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
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
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.
If you have any questions, complaints, a dispute on the collection or handling of your
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:
750 Third Avenue, Suite 1003
New York, NY 10017
do not use or access the Site.