Effective date: July 1, 2023
Monocl* (“we” “us” or “our”) operates the Monocl Platform a globally accessible software as a service available at app.monocl.com housing vast database of information about healthcare professionals and academics (“Experts”) which is curated into Expert Profiles. Expert Profiles are made available to enterprise customers who use this information to research which Experts they could potentially collaborate with.
*References to Monocl in this Privacy Policy means collectively Monocl AB and Monocl Company (collectively “Monocl”). Monocl is a wholly owned subsidiary of Definitive Healthcare LLC. References to “you” and “your” mean any individual whose information we collect and process under this Privacy Notice.
This General Privacy Policy (the “Privacy Policy”) explains how Monocl collects, uses, processes and shares your information where:
*(see more in Section 3 entitled What information do we collect about you below)
This Privacy Policy does not apply to:
* Monocl currently acts as data processor (or service provider) in respect of third party or other information Customer uploads or includes in the Monocl Engage module and Customer acts as data controller in respect thereof. Such information is governed by the terms of the applicable subscription services agreement and the applicable data processing addendum, rather than this Privacy Policy. We reserve the right to amend or update this information from time to time or as required.
If you are resident of the EEA and/or Switzerland or the GDPR applies to you, Monocl AB is the data controller in respect of the processing of your personal information. You can find out more specific information about your rights and how to exercise them in the GDPR Privacy Policy Supplement at Section 8 below.
If you are a resident of the State of California, you can find out more about how your information is processed and how to exercise your rights under the California Consumer Privacy Act (“CCPA”) by visiting the California Privacy Disclosure Notice at Section 14 below.
If you are a resident of Virginia, Colorado, or Connecticut, you can find out more about how your information is processed and how to exercise your rights under the Virginia Consumer Data Protection Act (“VCDPA”); the Colorado Privacy Act (“CPA”); or the Connecticut Personal Data Privacy and Online Monitoring Act ("CTDPA”) by visiting the State Supplement Notice at Section 15 below.
For the purposes of this Privacy Policy, reference to personal information includes any information relating to an identifiable person.
We collect information about you in the following ways:
Where you are a Customer employee/representative (Registered User) We license our product to our enterprise customers’ (”Customer(s)”) who nominate certain employees and/or representatives to access the Services on the Customers’ behalf. If you are such an individual nominated by a Customer to access the Services, the Customer may provide us with information such as your name, title, and e-mail address in order to create a credentialed log-in for our Services. You will then further agree to the Monocl End User Licence Agreement (EULA) and become Registered User (“User”). If you are a User, we also collect certain information directly from you such as your password information in order for you to access your user account.
After receiving log-in information, you may choose to use our Service for the purposes for which the license was granted. During your time using our Service as a User, we may collect some or all of the following additional data:
Under your organization’s license agreement, some individuals at your organization (or nominated by your organization) may have the right to access information for all Users at your organization for purposes of tracking usage patterns across the organization. If you have questions about who at your organization can see your data, please contact your organization’s point of contact for Monocl. If you do not know your company’s point of contact, we can if necessary, provide you with that information.
You otherwise submit the same to us. Including for example when you subscribe to Monocl’s newsletter (or updates), request a demo from Monocl or you engage in an instant message “chat” or communicate with one of our representatives you may provide us with your name and email address to enable us to contact you.
Through our support services, Webinars and/or Events. We may receive personal information from or about you such as your name and contact details such as your email address when we meet you at an Event, when you sign up for or participate in a Webinar, or when you contact us for a Support Call. If we receive a question for support, we collect and store the question as well as the answer to the question. We may also collect aggregated statistics connected to support issues.
From third parties or external sources. We may receive your contact information from commercial partners with whom we partner to present Webinars. We may also directly collect personal information about you that is publicly available from publicly available websites.
Cookies. We collect information through the Services using “cookies” and similar technologies As a User you accept that cookies we deploy are required in order that you may use the Services in a way that the Customer and you the User expect. The cookies that we deploy will allow you to access the Services and give you feedback about how you use the services to improve the same for your benefit. For more information please visit our Cookie Policy.
Log Files. We may also collect information through our Internet log files, which record data such as user IP addresses, browser types, and other statistical data involving the use of the Services This information may be used to analyze trends, to administer the Services, to monitor the use of the Services and to gather general demographic information. We may link this information to personal information for these and other purposes such as personalizing your experience and evaluating and improving the Services in general.
From and through our affiliates. Where your information comes to us directly from or via an affiliate
We are committed to protecting the privacy of children. The Services are not designed for or directed to children under the age of 13. We do not knowingly collect personal information from any person under the age of 13.
We use the information collected in the following ways and for the following purposes:
To provide the Services to you. including giving Users access to the Monocl Platform and the Services through each user account.
To enhance, provide support and maintain our Services. We use your information to support delivery of the Services, address service errors or technical issues, to contact you for customer service and for Support Call purposes.
For analytics purposes to improve your experience to help us understand who uses the Services (and how). for internal operations such as operating and improving your user experience. We may also use the information gathered to perform statistical analysis of user behaviour or to evaluate and improve the Services.
To provide you access to particular features. such as a Webinar that you sign up for or participate in
To communicate with you. If you identify yourself to us by sending us an e-mail with questions or comments or requests for customer service or using a chat function, we may use your personal information to respond to your questions or comments, and we may file your questions or comments for future reference.
To tell you about changes to applicable terms and policies technical or other important updates. We may also use your information to let you know about changes to this Privacy Policy or other legal terms of relevance. We may contact you through email, by notices messages and other ways through the Services (or as we see fit) to inform you about technical updates; service-related issues; important changes to, and/or availability of our services. We can also contact you in this way regarding your safety and security when using the Services and send you important security notices about potential fraud or security breaches. We may also if needed reach out to you to find out more about your user experience and to improve our products These communications are part of the Services and you may not opt out of them.
To send you alerts. If you are a User, we use your information (including your email address) to send you alerts about updates, and new information added to the Monocl Platform which may be of benefit or interest to you. You are free to opt out of such communications using the available settings in your account and by unsubscribing from the emails themselves.
To facilitate our marketing activities. and, unless you opt out (to the extent permitted by applicable law, so that we (and where applicable, third parties acting on our behalf) can contact you about products and services that may be of interest to you: In particular, unless you opt out (to the extent permitted by applicable law), we and third parties acting on our behalf may send you electronic newsletters, contact you about particular products, services, information and news that may be of interest to you, and provide you with targeted feedback. Some of this information may be tailored to you based on your usage of the Services. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: privacy@monocl.com.
We generally disclose information we gather under this Privacy Policy to the following categories of third parties and/or as otherwise set forth in this Privacy Policy and/or as specifically authorized by you.
Where required by Law. We may disclose your information (including personal 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 personal 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, the Monocl Platform, the Services or the general public.
Analytics Service Providers. When you use our Services third-party providers of analytics products for example analytics cookies deployed as part of the Services may directly collect information about your activities over time
Service Providers. We may employ third party independent contractors, vendors and suppliers (collectively, “Service Providers”) to provide specific services and products, such as hosting and maintaining the Services, providing fraud screening, and developing applications for the Services. In the course of providing products or services to us, these third-party Service Providers may have access to information we collect about you. While we may seek to require Service Providers to follow appropriate privacy policies and will not authorize them to use your personal information except for the express purpose for which it is provided, we cannot control the actions of such third parties.
To our marketing service providers. We may share your personal information with our marketing vendors and partners to send emails on our behalf, and/or for co-branded and/or co-sponsored marketing and promotional events (such as conference events) offered in conjunction with another company or companies. If you register for or participate in such marketing and promotional events, we and the relevant partner companies may receive information collected in conjunction with the co-branded and/or co-sponsored marketing and promotional events.
Sale of Business. If applicable, 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 affiliates (as defined below), or that portion of Monocl or any of its affiliates to which the Services relate or to which any other activities of Monocl that are subject to this Privacy Policy relate, 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.
Affiliates. We may disclose information (including personal information) about you to our affiliate companies as required.
Where you consent. To any other party should you consent to the disclosure.
Monocl takes the security of your information seriously. We invest considerable resources in implementing technical and organizational measures to secure your information. We value your trust in providing us your personal information and strive to use commercially acceptable means of protecting it. Monocl takes reasonable steps to ensure that personal information is reliable for its intended use and all such information is up-to-date, accurate, and complete, and we remind you however, that no method of electronic transmission or electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
To the extent you are located in the European Economic Area or Switzerland this section of the Privacy Policy sets out our practices and obligations under the General Data Protection Regulation 2016/679 (the “GDPR”).
Data Controller. If processing of your personal information is subject to the GDPR, Monocl AB is the data controller (as defined in the GDPR) in respect of the processing of your personal information to which this Privacy Policy applies.
If you wish to contact the data controller to exercise your rights under the GDPR you can do so using the contact information in Section 13 Contact us below.
Sensitive personal information. We do not request personal information relating to your race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation or criminal record (which is defined as "Sensitive Personal Information" under the GDPR.)
Legal Grounds for processing. Pursuant to the GDPR, legal bases for our processing your personal information may include (without limitation):
Your rights under the GDPR. Please see the section Your Privacy Rights below. If you want to contact the data controller to exercise any of your rights under the GDPR or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the information at Section 13 Contact us below.
In certain circumstances personal information collected under this Privacy Policy may be transferred from time to time to our affiliate offices, personnel, and/or to Service Providers who may be located in various places throughout the world. In addition, the Monocl Platform may be viewed and hosted anywhere in the world, including in countries that may not have laws of general applicability regulating the use and transfer of such information or which may not provide the same degree of protection as the country in which you are resident. Without limitation of the foregoing, you hereby expressly grant consent to the Monocl to: (a) process and disclose such information in accordance with this Privacy Policy; (b) transfer such information throughout the world, including to the United States or other countries that do not ensure adequate protection for personally identifiable information (as determined by the European Commission, each, an “Inadequate Jurisdiction”) and/or countries that may not have laws of general applicability regulating the use and transfer of such information as necessary and required; and (c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you are located in the EEA Switzerland or if the GDPR applies to you, should it be absolutely necessary for us to transfer your personal information to an Inadequate Jurisdiction, we will rely on legally provided mechanisms designed to ensure a similar degree of protection is afforded to your personal information including (but not limited to) where applicable implementation or use of European Commission-approved Standard Contractual Clauses. If you require further information on the specific mechanisms used by us or have any concerns in this regard, please get in touch using the information in Section 13 Contact us below
We endeavour to retain your personal information only for as long as necessary to fulfil the purposes for which we collected it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. If you have any questions about our data retention processes, please contact us at privacy@monocl.com.
We generally use personal information as described in this Privacy Policy as authorized by you or as otherwise disclosed at the time, we request such information from you. In certain other circumstances, you “opt in” and/or give us permission to use your personal information. You may in such a case exercise your opt out rights as for example in the case of marketing communications either by following the directions provided in association with the communication or such other directions we may provide or by contacting us at privacy@monocl.com.
You may have certain rights related to your personal information, subject to local applicable data protection laws in your country. Please note your rights and choices may vary depending upon your location. Certain personal information may be exempt from such requests under applicable law.
If you are a resident of the State of California please see the CCPA Privacy Notice at Section 14 below to find out about your rights and how to exercise them.
If you are a resident of the States of Virginia, Colorado, or Connecticut see Section 15 of the State Supplement Notice below to find out how you can exercise your rights.
If the GDPR applies to you, you may have the following specified rights:
Request access to your personal information (commonly known as ‘subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove your personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personal information in certain circumstances.
Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing the same.
Request the transfer of your personal information to another party.
Lodge a complaint with the relevant supervisory authority (as defined in the GDPR). See details of our lead supervisory authority inSection 13 “Contact us” below. If you have any complaints about the way we process your personal information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.
Please note that Monocl’s lead supervisory authority in the EU is:
The Swedish Data Protection Authority (Sw.Integritetsskyddsmyndigheten)
Box 8114
SE-104 20 Stockholm
Sweden Phone number: +46 8 657 61 00
Email: imy@imy.se
Similar rights as above may be afforded to you under other global applicable data protection laws and regardless of your location. If you wish to review, verify, correct or request erasure of your personal information, object to the processing of same, or request that we transfer a copy of your personal information to another party you can contact us using the information at Section 13 Contact Us below.
Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps to verify your identity before granting you access or making corrections.
You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personal information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personal information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.
To protect your privacy and security, we may take reasonable steps to verify your identity before granting you access or making corrections or otherwise processing your request.
We reserve the right to modify or revise this Privacy Policy from time to time. If we make material changes that result in significant additional uses or disclosures of your personal information, we will provide you notice through the Services and/or or by other means including if necessary, communication with you, to provide you the opportunity to review the changes before they become effective. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal information, for which such communications/notices are not generally required. We encourage you to check this page periodically for any changes; the date for the latest updated version of this Privacy Policy is specified at the top of this Privacy Policy. If any changes to this Privacy Policy are unacceptable to you, you should stop using the Services Your continued use of the Services following the posting of changes to this Privacy Policy constitutes your full acceptance of those changes.
If you wish to exercise your privacy rights and/or if you have questions or concerns about our data use practices or this notice, please contact us as follows:
Residents of all jurisdictions/locations may contact us as follows:
By e-mail:
privacy@monocl.com
By postal mail or courier:
Attn: Data Protection Officer
Monocl AB
Redegatan 1B
426 77 Västra Frölunda
Sweden
If you are a resident of the State of California see Section 14.6 of the CCPA Privacy Notice below to find out how you can exercise your rights.
If you are a resident of the States of Virginia, Colorado, or Connecticut see Section 15.6 of the State Supplement Notice below to find out how you can exercise your rights.
This Privacy Notice (the ”Notice”) for California residents supplements the information in Monocl’s General Privacy Policy It shall (i) apply only to the extent that Monocl is regulated as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the “CCPA”)) under the CCPA, (ii) and it shall apply to you only if you are a California resident.
This Notice shall not apply to any situations where Monocl acts as a Service Provider (as defined in the CCPA) on behalf of a Customer in respect of certain consumer information. See Section 1 Applicability of this Privacy Policy above. In such case(s) the Customer for whom Monocl processes consumer information is responsible for acting in all matters in accordance with all applicable laws and 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. For clarification but not limitation, information we process for our legitimate business purposes, such as for product development or sales and marketing, is not processed solely on behalf of our Customer.
“Sell” and “Selling” As used in this Notice “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 CCPA, (ii) where you intentionally interact with a third party through the Site, provided the third party does not also sell the consumer information, (iii) 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 (iv) 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.
14.1 Consumer Information Collected. 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 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 the activities covered by this Privacy Policy, 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. | Name, e-mail address, job title, company, Support chat transcripts, city, country, continent, postal address, IP address, online identifier, company size, department, prospective use-cases, interests, telephone number, and any other information you may choose to share with us. |
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| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, telephone number, postal address, and job title. |
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| C. Internet or other similar network activity. | IP address, search history, user log-in information, language, internet service provider, demographic information, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the pages you view, content you engage with, the date and time of your visit, location (city, country, continent), the duration of your visit, operating system, domain names, and statistical data involving the use of the Site. |
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| D. Professional or employment-related information. | Name, telephone number, address, and job title. |
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14.2 Use of Consumer Information; Categories of Sources. We use consumer information for the business or commercial purposes described in the table above and in the manner described in Sections 3 and 5 of this Privacy Policy with respect to personal information. We also receive information that is otherwise collected when you engage with us as described in Section 3 of this Privacy Policy. Regarding the categories of sources from which consumer information is collected, we collect consumer information that you submit to us, including when you subscribe to our newsletter, request a demo, or if you engage in an instant message “chat” with one of our representatives on the Site. We may receive consumer information from or about you when we meet you at an Event, when you sign up for or participate in a Webinar, or when you contact us for a Support Call. If we receive a question for support, we collect and store the question as well as the answer to the question. We also collect aggregated statistics connected to support issues. We may also receive lists of contact information from commercial partners with whom we partner to present Webinars. Finally, we receive information about you when you are a Registered User when you register an account as well as from the enterprise customer (“Customer”) you represent.
14.3 Disclosures of Consumer Information for a Business or Commercial Purpose. 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 6 of this Privacy Policy with respect to personal 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 6 of this Privacy Policy):
14.3.1 Service Providers. and
14.3.2 Corporate Affiliates. In the preceding twelve (12) months, Monocl has disclosed internet or other similar network activity to the categories of third parties referenced in Section 6 of this Privacy Policy and captioned as “Service Providers”.
14.4 Sales of Consumer Information. In the preceding twelve (12) months, Monocl has not sold, nor does it or will it sell, consumer information that is subject to this Privacy Policy; however, please see Monocl’s Expert Privacy Policy for details regarding Monocl’s collection and use (including sale) of publicly available information relating to Experts, including sharing of such publicly available information relating to Experts with Monocl’s enterprise customers.
14.5 California Residents’ Rights and Choices. The CCPA provides California residents with specific rights regarding their consumer information. This Section 14.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.
14.5.1 Access to Specific Information and Data Portability Rights. You may have the right to request that Monocl disclose certain information to you about our collection and use of your consumer information over the past 12 months. Once we receive and confirm your verifiable consumer request (in the manner described in Section 14.6 below), to the extent required by the CCPA, we will disclose to you:
We provide the foregoing access and data portability rights for B2B consumer information when applicable law dictates that we shall do so.
14.5.2 Deletion Request Rights. You have the right to request that Monocl delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you (if you are a California resident) in the manner described in Section 14.6 below (“verifiable consumer request”), we will delete (and direct our service providers to delete) your consumer information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We provide the foregoing deletion rights for B2B consumer information when applicable law dictates that we shall do so.
14.6 Exercising Access, Data Portability, and Deletion Rights.
14.6.1 To exercise the access, data portability, and deletion rights described in Section 14.5 above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period.
The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to have or create an account with us. We will only use consumer information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. In the event you make a request under this Section 14, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating video conferencing or telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you.
14.6.2 We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days in total), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.
14.7 Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:
14.7.1 Denying you goods or services.
14.7.2 Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
14.7.3 Providing you a different level or quality of goods or services.
14.7.4 Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
This Privacy Policy supplements the information in Monocl’s General Privacy Policy 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.
15.1 Consumer Information Collected
Personal Information We Collect. In the past 12 months, depending on your use of the Service, we may have collected the following Personal Information about you:
| Category | Examples | Business or commercial purposes for which we collect, use, and sell consumer information |
|---|---|---|
| A. Identifiers. | Name, e-mail address, job title, company, Support chat transcripts, city, country, continent, postal address, IP address, online identifier, company size, department, prospective use-cases, interests, telephone number, and any other information you may choose to share with us. |
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| B. Personal information categories | Name, telephone number, postal address, and job title. |
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| C. Internet or other similar network activity. | IP address, search history, user log-in information, language, internet service provider, demographic information, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the pages you view, content you engage with, the date and time of your visit, location (city, country, continent), the duration of your visit, operating system, domain names, and statistical data involving the use of the Site. |
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| D. Professional or employment-related information. | Name, telephone number, address, and job title. |
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15.2 Use of Consumer Information; Categories of Sources. We use consumer information for the business or commercial purposes described in the table above and in the manner described in Sections 3 and 5 of this Privacy Policy with respect to personal information. We also receive information that is otherwise collected when you engage with us as described in Section 3 of this Privacy Policy. Regarding the categories of sources from which consumer information is collected, we collect consumer information that you submit to us, including when you subscribe to our newsletter, request a demo, or if you engage in an instant message “chat” with one of our representatives on the Site. We may receive consumer information from or about you when we meet you at an Event, when you sign up for or participate in a Webinar, or when you contact us for a Support Call. If we receive a question for support, we collect and store the question as well as the answer to the question. We also collect aggregated statistics connected to support issues. We may also receive lists of contact information from commercial partners with whom we partner to present Webinars. Finally, we receive information about you when you are a Registered User when you register an account as well as from the enterprise customer (“Customer”) you represent.
15.3 Disclosures of Consumer Information for a Business or Commercial Purpose. 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 6 of this Privacy Policy with respect to personal 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 6 of this Privacy Policy):
15.3.1 Service Providers. and
15.3.2 Corporate Affiliates. In the preceding twelve (12) months, Monocl has disclosed internet or other similar network activity to the categories of third parties referenced in Section 6 of this Privacy Policy and captioned as “Service Providers”.
15.4 Sales of Consumer Information. In the preceding twelve (12) months, Monocl has not sold, nor does it or will it sell, consumer information that is subject to this Privacy Policy; however, please see Monocl’s Expert Privacy Policy for details regarding Monocl’s collection and use (including sale) of publicly available information relating to Experts, including sharing of such publicly available information relating to Experts with Monocl’s enterprise customers.
15.5 Your Privacy Rights. 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: Monocl does not engage in the sale of information collected in accordance with Monocl’s General Privacy Notice.
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;;
15.6 Exercising Your Privacy Rights. 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.
15.7 Verifiable requests and authorized agents. 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.
15.8 Questions? 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: