Last revised and effective as of: July 1, 2023
This Privacy Policy relates to personally identifiable information (as defined below) collected by Monocl AB and Monocl Company (collectively, “Monocl” “we” or “us” or “our”) about medical, scientific, and healthcare professionals and academics (“Experts,” “you”, or “your” in this Privacy Policy if we have obtained information about you), which information is made available to Monocl’s enterprise customers through Monocl’s platform, which collects and analyzes data relating to Experts, which is made available to Monocl’s enterprise customers which include companies in the pharma and life sciences industries in order to help such enterprise customers understand (among other things) Experts relevant to various important scientific and clinical research, key collaborations, industrial relationships, as well as Experts’ influence and relevance to our enterprise customers’ initiatives (collectively with any associated databases, the “Monocl Platform”). You should carefully read this Privacy Policy. It is our hope and belief that the Monocl Platform will (a) benefit you as an Expert by providing opportunities for you and life sciences institutions and similar enterprises to connect and engage globally, as well as (b) help life sciences institutions and enterprises easily find relevant research content and resources, identify and engage with Experts, and develop meaningful collaborations across all therapeutic areas and regions in the pursuit of improving healthcare and patient outcomes.
Because Monocl has a publishing certificate under Swedish law the General Data Protection Regulation (EU) 2016/679 (“GDPR”) does not apply to Monocl’s publication of personally identifiable information of Experts included in the database. Specifically, Monocl has obtained a publishing certificate for its database, which has been issued by the Swedish Press and Broadcasting Authority. Felix Jansson is the editor-in-chief. The GDPR allows countries to make exemptions to the GDPR’s rules on personal data processing (including, for example but not limitation, the individuals’ rights to information and erasure) if necessary to protect the freedom of expression (see Article 85 of the GDPR). The Swedish publishing certificate is such a legal exemption made from the GDPR (including, for example but not limitation, its provisions on e.g. the individuals’ rights to information and erasure). More information about publishing certificates is available here: https://www.mprt.se/regelverk/utgivningsbevis/. Databases covered by publishing certificates are not impacted by the GDPR. Thus, the GDPR does not impact the Monocl Platform. We do not include any special categories of personal data (as described and defined in the GDPR) in the Monocl Platform.
When one of our enterprise customers uses the Monocl Platform, such enterprise customer may share information about you with us in connection with our provision of our services to such enterprise customer. To the extent we process (as defined below) such information solely in order to provide our services to that enterprise customer, this Privacy Policy will not apply to the processing of that information and that enterprise customer will be responsible for having a lawful basis for processing that information, for acting in all matters in accordance with all applicable laws, and for providing you with all requisite information as required by applicable law.
As used in this Privacy Policy, the terms “using” and “processing” information include subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Monocl or among our affiliates globally.
This Privacy Policy serves to notify you of the following:
What personally identifiable information about me is collected?
Does Monocl collect information from children under 16 years of age?
What does Monocl do with the information it collects?
When does Monocl disclose information to third parties?
For how long will my personally identifiable information be kept?
How will I know if there are any changes to this Privacy Policy?
Who do I contact if I have any privacy questions?
Special Notice for California Residents.
Special Notice for Colorado, Connecticut and Virginia Residents.
Special Notice for Chinese Residents.
As used in this Privacy Policy, “personally identifiable information” means information that identifies you, your household, or your device, could be used to identify you, your household, or your device, or could be used to contact you. We collect, use, store and transfer different kinds of publicly available personally identifiable information about you which is obtained from third-party sources, such as third-party websites and publicly available databases, including without limitation PubMed, ClinicalTrials.gov, and CMS Open Payments, as well as social media platforms. Such information may include any information manifestly made public on any website or any publicly available database, including, as examples, your name, publicly available contact details (such as email address), business address, city-level location, publishing affiliation and/or associated institution(s), grants received, collaborations and collaborators, publications, clinical trials, conference presentations, Twitter accounts, positions (including on advisory boards and boards of directors), and information regarding payments or items of value received from manufacturers of drugs, biological products, medical devices, or medical supply. We may license certain data from third-party entities. We may also collect any information you share with us, such as if you contact us.
Please be aware that the Monocl Platform uses algorithms to generate Expert professional profiles and to calculate Experts’ relevance based upon search terms input into the Monocl Platform by Monocl’s enterprise customers.
We are committed to protecting the privacy of children. We do not collect personally identifiable information from any person we actually know is under the age of 16.
We use the information collected to provide the Monocl Platform to our enterprise customers, which includes generating professional profiles of Experts that are searchable by our enterprise customers. If you identify yourself to us, including by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.
We generally disclose information we gather from you in connection with the Monocl Platform to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.
We may share your information (including personally identifiable information) with Monocl’s enterprise customers and their users, who may be located throughout the world, through their use of the Monocl Platform. Monocl’s enterprise customers include those in the pharma and life science industries. Once any Monocl enterprise customer has accessed information through the Monocl Platform, such enterprise customer shall be responsible for any obligations under applicable law arising out of such enterprise customer’s usage, sharing, or other processing of such information, including any notice or consent obligations under applicable law; this Privacy Policy does not apply to any such usage, sharing, or other processing by any Monocl enterprise customer or its users.
We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, Monocl’s products or services (including the Monocl Platform), or the general public.
We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products to us, such as hosting and maintaining our products and services (including the Monocl Platform) and developing applications for our products and services (including the Monocl Platform). In the course of providing products or services to us, these Outside Contractors may have access to information collected by Monocl, including your personally identifiable information.
We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of Monocl or any of its Corporate Affiliates (as defined below), or that portion of Monocl or any of its Corporate Affiliates to which the Monocl Platform relates, or in connection with a strategic investment by a third party in Monocl, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.
We may disclose information (including personally identifiable information) about you to our Corporate Affiliates. For purposes of this Privacy Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Monocl AB and/or Monocl Company, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.
We generally will retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it.
We may revise this Privacy Policy from time to time. We encourage you to check this page periodically for any changes.
If you have any questions or comments about this Privacy Policy or how we handle your information, please contact our Data Protection Officer in any of the following ways:
By e-mail:
privacy@monocl.com
By postal mail or courier:
Attn: Data Protection Officer
Monocl AB
Redegatan 1B
426 77 Västra Frölunda
Sweden
This Section 8 shall apply only to the extent that we are regulated as a business (as defined in the CCPA) under the CCPA (as defined below) and shall apply to you only if you are a California resident.
When one of our enterprise customers (described in the notice above) uses the Monocl Platform, such enterprise customer may share consumer information (as defined below) about you with us in connection with our provision of our services to such enterprise customer. To the extent we process such consumer information solely in order to provide our services to that enterprise customer, under the CCPA, to the extent applicable, we will act as a service provider (as defined in the CCPA) on behalf of that enterprise customer in respect of that consumer information; this Privacy Policy will not apply to the processing of that consumer information and that enterprise customer will act as a business (as defined in the CCPA) in respect of that consumer information. The business is responsible for acting in all matters in accordance with all applicable laws, and for providing you with all requisite information as required by applicable law. To the extent we process your consumer information for any other lawful business purpose of ours, under the CCPA, to the extent applicable, we will act as a business with respect to such consumer information and this Privacy Policy will apply to the processing of such consumer information.
As used in this Section 8, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to another business or a third party for monetary or other valuable consideration.
“Selling” does not include (i) disclosing consumer information to a third party at your direction, provided the third party does not sell the consumer information except in accordance with the California Consumer Privacy Act (collectively with any regulations promulgated thereunder, the “CCPA”), (ii) where you intentionally interact with a third party, provided the third party does not also sell the consumer information, (iii) where you have opted out in accordance with Section 8.7, disclosures to third parties for the purposes of alerting such third parties that you have opted out of the sale of your consumer information, (iv) using or sharing your consumer information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on Monocl’s behalf and provided that the service provider does not further collect, sell or use the consumer information except as necessary to perform the business purpose, or (v) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Monocl, provided that information is used or shared consistently with the CCPA.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents, devices or households (“consumer information”). Consumer information does not include deidentified or aggregated information, publicly available information from government records, or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA. In particular, with respect to Experts, we have collected the following categories of consumer information from California residents, households or devices within the last twelve (12) months:
| Category | Examples | Business or commercial purposes for which we collect, use, and sell consumer information |
|---|---|---|
| A. Identifiers. |
Any identifiers that have been manifestly made public, including name, business address, National Provider
Identifier ("NPI"), publicly available contact details (such as email address), current or past employer,
publishing affiliation, and/or associated institution(s), grants received, conferences or events at which
you may have spoken, collaborations and collaborators, abstracts, publications, clinical trials,
conference presentations, Twitter accounts, positions (including on advisory boards and boards of
directors), and information regarding payments or items of value received from manufacturers of drugs,
medical devices, and biologicals. We may also collect any information you share with us, such as if you contact us. |
For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their
users access to the Monocl Platform. If you identify yourself to us, including by sending us an e-mail with questions or comments, we may use your information (including consumer information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Any personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) that have been manifestly made public, including name, current or past employer, publishing affiliation, and/or associated institution(s). | For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their users access to the Monocl Platform. |
| C. Professional or employment-related information. | Any professional or employment-related information that has been manifestly made public, including current or past employer, publishing affiliation, and/or associated institution(s), NPI, grants received, conferences, collaborations and collaborators, abstracts, publications, clinical trials, Twitter account, and positions (including on advisory boards and boards of directors). | For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their users access to the Monocl Platform. |
| D. Inferences drawn from other personal information. | Profile reflecting your expertise (among other things), as well as your influence and relevance to our enterprise customers' initiatives. | For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their users access to the Monocl Platform. |
We use consumer information for the business or commercial purposes described in the table above and in the manner described in Section 3 of this Privacy Policy with respect to personally identifiable information. Regarding the categories of sources from which consumer information is collected, we collect publicly available consumer information about you from third-party sources, such as third-party websites and publicly available databases, including without limitation PubMed, ClinicalTrials.gov, and CMS Open Payments, as well as social media platforms. We may also license certain data from third-party entities. We may also collect any information you share with us, such as if you contact us.
Monocl may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in Section 4 of this Privacy Policy with respect to personally identifiable information. In the preceding twelve (12) months, Monocl has disclosed each of the categories of consumer information described in the table above for a business or commercial purpose to the following categories of third parties (as further described in Section 4 of this Privacy Policy):
The CCPA provides California residents with specific rights regarding their consumer information. This Section 8.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.
This Section 9 shall apply only to the extent that we are regulated as a personal information processor (as defined in the Personal Information Protection Law of PRC, namely PIPL) and shall apply to you only if you are a Chinese resident. In particular, if you are an expert in China, we may collect and disclose your publicly available information for the purposes of the operation of the platform, our business customers will access to your information on the platform, they will be solely responsible for the further processing of your personal information.
Under PIPL, personal information refers to any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding the information which has been anonymized.
For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their users access to the Monocl Platform, we may collect the following personal information of an expert in China:
Name. Publicly available (business) contact details such as: email address; postal address; place of employment; Phone number; city-level location; publishing affiliation and/or associated institution(s); grants received, collaborations and collaborators, publications, clinical trials, conference, presentations; social media links; details about positions held (including on advisory boards and boards of directors).
In addition, we may also collect any information you share with us, such as if you contact us, for the purposes of responding to your questions/comments. we may also file your questions or comments (with your information) for future reference.
Regarding the categories of sources from which expert personal information is collected, we collect publicly available information about you from some third-party sources, as well as social media platforms. We may also collect any information you share with us, such as if you contact us.
Please note, since we collect and use your publicly available information and only disclose it on our platform, thus we will mainly rely on the legal basis of “processing personal information which has been publicly disclosed or legally disclosed by others to the reasonable extent ” according to Article 13 (6) of the PIPL, we do not have to get your consent to our processing, but you still have the right to object our processing and delete your personal information as we have stated in the section 9.2 of this Privacy Policy.
You have the right to access (including inquire and get a copy of your information), correct, update or request deletion of your personal information.
You can object to processing of your personal information, especially the processing of your public available information.
You can also ask us to restrict processing of your personal information or request portability of your personal information where it is technically possible.
We won’t process your personal information ourselves for the purposes of direct marketing.
You have the right to complain to a data protection authority about our collection and use of your personal information.
In addition, you have the right to ask us to explain this Privacy Policy if you have any questions about this Privacy Policy.
If you are a close relative of a deceased, you can access, correct, update, or delete the information of the deceased we hold about for your own lawful reason.
You can contact our DPO via the contact details in Section “7 WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?”. We will respond to your request according to the requirements of PIPL and other Chinese data protection laws, however, for security reason, we may verify your identification before we act your request (s).
This Privacy Policy supplements the information in Monocl’s Expertl Privacy Policy’s for residents of the states of Colorado, Virginia and Connecticut. This policy describes the types of Personal Information that Monocl may collect or process from U.S. residents in those states, how we may use and disclose that information, and how you may exercise any rights you may have regarding our processing of your Personal Information.
This Privacy Policy applies to Personal Information collected or processed by Monocl from or about U.S. residents in states with Comprehensive Privacy Laws, including: the Colorado Privacy Act (“CPA”); the Connecticut Personal Data Privacy and Online Monitoring Act ("CTDPA”); and the Virginia Consumer Data Protection Act (“VCDPA”). Collectively, these laws are referred to as “State Comprehensive Privacy Laws” in this Supplement, and this Supplement only applies to residents in those states unless otherwise noted.
This Supplement uses the terms “consumer,” “personal data” or “personal information,” and “sale” as defined in their respective laws. References to “Personal Information” include personal data or personal information as defined under State Comprehensive Privacy Laws.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with particular individuals (“consumer information”). Consumer information may not include deidentified or aggregated information, or any other information that is excepted from the definition of “personal information” under Comprehensive Privacy Laws In particular, with respect to Experts, we have collected the following categories of consumer information from consumers within the last twelve (12) months:
| Category | Examples | Business or commercial purposes for which we collect, use, and sell consumer information |
|---|---|---|
| A. Identifiers. |
Any identifiers that have been manifestly made public, including name, business address, National Provider
Identifier ("NPI"), publicly available contact details (such as email address), current or past employer,
publishing affiliation, and/or associated institution(s), grants received, conferences or events at which
you may have spoken, collaborations and collaborators, abstracts, publications, clinical trials,
conference presentations, Twitter accounts, positions (including on advisory boards and boards of
directors), and information regarding payments or items of value received from manufacturers of drugs,
medical devices, and biologicals. We may also collect any information you share with us, such as if you contact us. |
For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their
users access to the Monocl Platform. If you identify yourself to us, including by sending us an e-mail with questions or comments, we may use your information (including consumer information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. |
| B. Personal information categories. | Any personal information categories that have been manifestly made public, including name, current or past employer, publishing affiliation, and/or associated institution(s). | For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their users access to the Monocl Platform. |
| C. Professional or employment-related information. | Any professional or employment-related information that has been manifestly made public, including current or past employer, publishing affiliation, and/or associated institution(s), NPI, grants received, conferences, collaborations and collaborators, abstracts, publications, clinical trials, Twitter account, and positions (including on advisory boards and boards of directors). | For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their users access to the Monocl Platform. |
| D. Inferences drawn from other personal information. | Profile reflecting your expertise (among other things), as well as your influence and relevance to our enterprise customers' initiatives. | For the purposes of providing the Monocl Platform and allowing Monocl's enterprise customers and their users access to the Monocl Platform. |
We use consumer information for the business or commercial purposes described in the table above and in the manner described in Section 3 of this Privacy Policy with respect to personally identifiable information. Regarding the categories of sources from which consumer information is collected, we collect publicly available consumer information about you from third-party sources, such as third-party websites and publicly available databases, including without limitation PubMed, ClinicalTrials.gov, and CMS Open Payments, as well as social media platforms. We may also license certain data from third-party entities. We may also collect any information you share with us, such as if you contact us.
Monocl may disclose your consumer information described in the table above to a third party for a business or commercial purpose, as described in the table above and in Section 4 of this Privacy Policy with respect to personally identifiable information. In the preceding twelve (12) months, Monocl has disclosed each of the categories of consumer information described in the table above for a business or commercial purpose to the following categories of third parties (as further described in Section 4 of this Privacy Policy):
As a resident of a state with a State Comprehensive Privacy Law, you may have the following privacy rights, subject to some limitations or exemptions as required or allowed by law:
Right to Opt-Out of the Sharing Your Personal Information for Targeted Advertising: Monocl does not engage in such sharing.
Right to Opt-Out of the Sale of Your Personal Information: Under State Comprehensive Privacy Laws, Consumers have the right to opt-out of the sale of any Personal Information that was collected and retained by Monocl. We will also inform our customers and service providers of your decision to opt-out.
To opt-out of sale of your personal information, please contact us by:
Right to Know and Access Your Personal Information: You may have the right to request that we disclose what Personal Information we collect, use, disclose, or sell. You may request to view a report of the categories of your Personal Information across our systems or a view report of your Personal Information across our systems. To do so, please submit a Privacy Rights Request by:
Right to Obtain a Copy of Your Personal Information: Consumers have the right to obtain a portable copy of their data. You may ask us for a package of your data to be downloaded and transferred to another recipient. To do so, please submit a Privacy Rights Request by:
Right to Delete Your Personal Information: Consumers have the right to request the deletion of any Personal Information that was collected and retained by Definitive Healthcare for certain purposes. To do so, please submit a Privacy Rights Request by:
Right to Correct Your Personal Information: Consumers have the right to request that we correct any Personal Information that was collected and retained by Definitive Healthcare for certain purposes. To do so, please submit a Privacy Rights Request by:
Right to Opt-Out of Sensitive Personal Information Processing or Request to Limit the Use of Sensitive Personal Information: At the time of this Supplement, Definitive Healthcare does not collect or process Sensitive Personal Information subject to the Monocl General Privacy Policy
Right to Appeal: You have the right to appeal any denial of a Privacy Rights Request. You will be provided instructions on how to do so in any response letter that is denying your request. If you have questions, you may contact us at at privacy@monocl.com;;
To exercise your any of Your Privacy Rights in the previous section, please contact us in one of the following designated methods:
For Requests to Know, Access, Obtain, Delete, or Correct:
Definitive Healthcare will not discriminate in pricing and services against a consumer for exercising their State Comprehensive Privacy Laws rights.
We will make reasonable efforts to promptly respond to your requests in accordance with applicable laws, but your rights under State Comprehensive Privacy Laws are not absolute. For example, any such request must provide sufficient information that allows Definitive Healthcare to verify that you are the consumer whose Personal Information we have collected. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
You may be entitled, in accordance with applicable law, to submit a request through an authorized agent through the same mechanisms that you can use to submit a request directly. The request must also include sufficient detail that allows us to properly understand, evaluate, and respond to the request. If we need more information to process your request, we will contact you via e-mail or in writing.
Monocl is committed to protecting the privacy of Consumers’ Personal Information and being transparent about our privacy practices. We welcome questions, comments, or feedback on this supplemental policy or our General Privacy Policy. To obtain more information or submit feedback or questions, please contact us: