We self-certify compliance with the U.S.-EU Privacy Shield Framework.
1. Information We Collected Via our Sites
Information We Collect from Unregistered Visitors
Information We Collect from Registered Users
You must register to access our full Services. When you register for the Services, you are asked to provide identifying information such as your name, email address, zip code and other professional information, e.g. specialty and profession. Additional information may be requested, which may be required to access some Services. We may collect additional information about registered users from third party sources to assist us in providing the Services. For example, we use such third party sources to verify and update registration information and confirm licensure status
Other Information We Collect through Services We Offer
Electronic Newsletters: The Services include free electronic newsletters sent to users to provide specific information on the appropriate or selected topics. We must gather the email addresses of users who register for and voluntarily subscribe to said Services. You may remove yourself from a mailing list at any time by following the instructions provided at the end of every newsletter.
Other Promotions: By registering with our Service(s) you agree that we may send you emails regarding information specific to such Service(s), surveys, or other opportunities that involve M3 Services. We must gather the email addresses of users to register for said Services. You may remove yourself from a mailing list at any time by terminating the Service.
Reporting Honorarium and Tax Information
If you participate in a survey that pays an honorarium, M3 may have an obligation to report your honorarium payments. By participating in a market research survey, you are permitting us to disclose your earned honorarium as appropriate to comply with all laws and other reporting requirements. In addition, IRS regulations prevent us from paying individuals in excess of $600 in any given tax year without valid tax information. If tax information is not provided within 12 months after completing a survey, honoraria amounts above $600 in any tax year are forfeited.
Industry Sponsored Programs: Registered users are encouraged to support delivery and development of Services by participating in industry-sponsored programs, such as our “Messages” programs, or other industry-supported events and offers. Registered users who participate agree that their name, specialty, profession, and the content they participate in along with their answers to any questions to which they choose to respond, can be shared with the industry sponsor. Registered users may cease participating in these programs at any time.
Discussion Lists: Use of discussion lists requires separate opt-in and additional registration and agreement to the terms and conditions for this Service. Subscribing to any other Service does not also subscribe users to affiliated discussion lists. You may remove yourself from a discussion list at any time by following the instructions provided.
Category 2 CME Recorder: This tool may be available through the Services. It collects your usage of select Category 2 CME-appropriate content, such as date and time you read an article summary or took a quiz, and length of time you spent on a quiz. These data are used to create a customized report that is available to you upon your request.
Additional Forms and Emails: We may also ask you to provide additional information after you register if you want to obtain additional services or information, or to resolve complaints or concerns.
Your email address will not be sold to a third party if you sign up to be included on our email distribution list. Our periodic email distributions include emails announcing job openings, email newsletters, discussion lists, market research programs, quiz programs, and information about other PM services. You may opt out or unsubscribe at any time.
Usage Tracking and Cookies
M3 collects information about your activity on the Sites and through our advertisements using technologies such as cookies, including third-party cookies, web beacons and server log files.
Usage Tracking: M3 uses traffic analysis software on our servers to track user traffic patterns throughout the Services. M3 uses this data to break down overall usage statistics according to IP address, domain name, browser type, and MIME type by reading this information from the data automatically sent by the browser whenever a web page is requested. Additionally, solely in connection with your voluntary participation in a market research study or screening, your computer may (i) be tracked by digital fingerprinting or watermarking to help ensure unique responders to a survey, and (ii) accessed to assess browser compatibility and/or video cam usability.
Cookies: A cookie is a small text file placed in your computer’s browser to store your preferences. A cookie can be accessed only by the server that originally created the cookie. A cookie cannot store or send back any information to us that you have not specifically and voluntarily provided while on a Site, or that is not among the information mentioned above that is contained in every user’s browser (e.g., domain name, browser type). Cookies do not contain personally identifiable information; however, once you choose to furnish a Site with personally identifiable information, this information may be linked to the data stored in the cookie.
Our Sites may also contain third-party cookies from advertising partners who help serve ads for M3 and other third parties on the Sites and elsewhere on the web.
Web Beacons: M3 and our third party business partners may also use “web beacons” or clear .gifs, or similar technologies, which are small pieces of code placed on a web page, to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We and our third party business partners use the information automatically generated by cookies and web beacons, as well as other information that we or they have, to provide you with an optimal website experience. This includes measuring the effectiveness of our ads and your interactions them, and tailoring offers and advertisements to you for products or services you may find helpful on the Sites and third-party sites.
2. Information Sharing and Disclosures
Marketing and Advertising
M3 may target Services, advertising, and marketing (e.g. email and website communications) based on information that you provide when you register for the Services, information that M3 receives from third party sources, and on your history of usage of the Services or other personal information that you provide to M3. For example, a user that registers with oncology as his/her specialty, or frequently uses oncology-related Services, or informs M3 that oncology is a significant component of his/her practice may be served oncology-related advertisements and invitations to participate in oncology-related sponsored programs, on both M3 and third party Services.
In addition to aggregate information, we may share some kinds of personally identifiable information with third parties as described below.
Advertisers: When you are exposed to an advertisement through the Services (whether on the Sites or in an email, mobile ad or another Service), M3 may provide your personal information (such as name, specialty, NPI number, and country of residence) and information about your engagement with the Services (e.g., whether you viewed, interacted with or requested information about promotional content) to advertisers and/or such advertisers’ agents as well as to potential advertisers and their agents. Additionally, when you become a registered user of the Services, we may provide your personal information to potential advertisers and their agents.
We will NEVER provide these Advertisers with your personal contact information such as email, phone number or mailing address without your consent. We are not responsible for how these third parties use your information and manage your privacy.
Market Research Studies: From time to time, we may invite you via e-mail to participate in sponsored or unsponsored market research studies. When you agree to participate in a study, you agree to share with M3 personally identifiable information, such as your name, email address, zip code and professional information. Generally, these studies provide specific feedback using aggregated, de-identified data to third parties used to analyze trends and statistics for medical marketing, research, and development purposes, and neither your identity nor your specific feedback is shared with third parties. However, under the following circumstances, your identity may be shared with third parties and/or associated with specific feedback: (i) when we have your permission, (ii) when we match user information with such third party’s data, and (iii) when we believe in good faith that the law requires it. In all circumstances, the privacy of our panel members is protected, and if such sharing is permitted or required, your answers and identity will remain confidential.
Industry Sponsored Programs: Registered users will be asked to engage in industry-sponsored information programs from time to time in accordance with the Terms of Service. Examples of Sponsored Programs include custom-developed emails or web-based information resources featuring branded or unbranded commercial content, or interactive programs that provide information about medical conditions, treatments and products. Other types of Sponsored Programs may be made available to you through the Services via emails and website communications.
Career Center: By electing to use the Career Center, you are able to search for jobs in your area, register to receive emails about future job postings, and/or to permit employers and recruiters to contact you directly regarding job offerings. You may search job postings without being a registered user, but in order to apply for a job, receive email communications, participate in the interactive areas to be found at the Career Center or be contacted by an employer or recruiter interested in you for employment, you must be a registered member.
If you elect to use the “Post My CV” service [and/or the “M3 Career Consult” service], we will collect the following personally identifiable information:
- Email address
- ZIP code
- Phone number
- Board Status
- Years in practice
- Citizenship status
- Licensure information
- Job preferences
- Work experience
Your personally identifiable information allows us to share your job preferences and work experiences with prospective employers and recruiters, and communicate with you about potential employment opportunities.
This option gives you the most visibility to the broadest employer and recruiter audience possible by making your CV searchable in our CV database. If you select this option, any registered employer or recruiter who purchases access to the database can view your CV and contact details (to the extent you include them in your CV).
Private Posting For Apply Online Only
This option allows you to post your CV on the Sites without having it searchable by or viewable to employers and recruiters. The benefit is that you can quickly and easily apply for jobs without retyping your information, and you provide your CV only to those employers you are specifically interested in.
We attempt to limit access to our searchable CV database to legitimate users such as paying employers, recruiters, hiring managers, headhunters and human resource professionals, but cannot guarantee that other parties will not gain access to this database. We cannot control the use of CVs by third parties who access such CVs while they are in our searchable database. You may remove your CV from our searchable database at any time. However, employers, recruiters and others who have paid for access to that database, as well as parties who have otherwise gained access to the database may have retained a copy of your CV in their own files or databases. We cannot control the retention, use or privacy of CVs or profiles that have been downloaded by third parties. Accordingly, you should not put information you would not want made public in your CV.
Affiliated Companies: M3 and its wholly-owned subsidiaries are part of the M3, Inc. group of companies that provide Internet services for physicians and other healthcare professionals around the world (collectively, “Affiliates”). M3 may share your personal information with Affiliates, which may use your personal information to send you emails about services they provide, new programs and selected information from their sponsors as it relates to your specialty or area of clinical practice.
Quiz Games: If you rank highly, your named or registered pseudonym may appear on the live leaderboards, and in certain circumstances, to our members. Your answers to the quiz questions are not shared.
Change of Control: M3 shall have the right to transfer, sell and/or distribute all personal information collected through the Services to an affiliate, subsidiary, or third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock.
4. Opt Out
M3 USA engages with users who register on our sites and elect for e-mail communication. For example, we may use your email address to send newsletters or discussion group updates, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law.
We provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from us, such as emails or updates from us regarding new services and products offered on the Sites or if you do not want us to share your personally identifiable information with third parties.
Users always have the opportunity to “opt– out” or change preferences via a link in the footer of all non–transactional email messages or by accessing the “My Account” page on the registered site. These options are made available in email messages delivered from our company. Alternatively, you may request to have your personal information modified or removed from our databases by sending a request via email at email@example.com or by fax to 202-293-1690, including your first and last names and email address with which you originally registered.
5. Security of Information
M3 USA uses generally accepted industry standards and commercially reasonable security technology to protect the personal information collected by us, both during transmission and in storage. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security.
Note to Users Outside of the United States
6. EU Privacy Shield Compliance
In accordance to the U.S. – EU Privacy Shield principles, M3 USA has a liability in cases of onward transfers to third parties and complies with the Notice and Choice principles for all data disclosed or transferred to a third party.
Enforcement: M3 USA submits to being subject to the investigatory and enforcement powers of the FTC, the Department of Transportation, or any other U.S. authorized statutory body with regards to our self-certification and implementation of the Principles, and acknowledges the right of the EU individual, under certain conditions, to invoke binding arbitration, at no cost to the individual, in filing a complaint disputing M3 USA’s adherence to these practices
Dispute Resolution and Arbitration: In the event of any controversy, claim or dispute related to or arising out of your use of the Sites, EU citizens may initiate the following dispute resolution procedure:
- Contact our organization directly at firstname.lastname@example.org; we will respond to your request within 45 days
- Alternatively, individuals may also contact our Third Party Dispute Resolution Body, TRUSTe, as defined in the “Independent Dispute Resolution Body”; see Section C below.
Independent Dispute Resolution Body: In compliance with the Privacy Shield Principles, M3 USA commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Private Shield policy should first contact M3 USA at:
M3 USA Corporation
ATTN: Privacy Shield Compliance
501 Office Center Drive
Fort Washington, PA 19034
Or via e-mail at: email@example.com
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Accessing and Updating your Personally Identifiable Information and Privacy Preferences: M3 USA will make commercially reasonable efforts to provide you reasonable access to any of your personally identifying information we maintain within 45 days of your access request. We provide this access so you can review it, make corrections or request deletion of your data. If we cannot honor your request within the 45-day period, we will tell you when we will provide access. In the unlikely event that we cannot provide you access to this information, we will explain why we cannot do so.
- M3 USA Corporation
ATTN: Privacy Shield Compliance
501 Office Center Drive
Fort Washington, PA 19034