Last revised and effective as of: June 30, 2020
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. Jens Wictorinus 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.
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?
Who do I contact if I have any privacy questions?
Special Notice for California Residents.
1. WHAT PERSONALLY IDENTIFIABLE INFORMATION ABOUT ME IS COLLECTED?
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.
2. DOES MONOCL COLLECT INFORMATION FROM CHILDREN UNDER 16 YEARS OF AGE?
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.
3. WHAT DOES MONOCL DO WITH THE INFORMATION IT COLLECTS?
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.
4. WHEN DOES MONOCL DISCLOSE INFORMATION TO THIRD PARTIES?
Monocl Enterprise Customers.
Laws and Legal Rights.
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.
Sale of Business.
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.
5. FOR HOW LONG WILL MY PERSONALLY IDENTIFIABLE INFORMATION BE KEPT?
We generally will retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it.
7. WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
By postal mail or courier:
Attn: Data Protection Officer
426 77 Västra Frölunda
SPECIAL NOTICE FOR CALIFORNIA RESIDENTS.
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.
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.
8.1 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, 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.|
8.2 Use of Consumer Information; Categories of Sources:
8.3 Disclosures of Consumer Information for a Business or Commercial Purpose:
- 8.3.1 Monocl enterprise customers;
- 8.3.2 Outside Contractors; and
- 8.3.3 Corporate Affiliates.
8.4 Sales of Consumer Information:
- 8.4.1 Your consumer information (as described in the table above) may be sold (as defined above) for the business purpose of providing the Monocl Platform and allowing Monocl’s enterprise customers and their users access to the Monocl Platform.
- 8.4.2 In the preceding twelve (12) months, Monocl has sold each of the categories of consumer information described in the table above to its enterprise customers.
- 8.4.3 Monocl does not have actual knowledge that it sells the consumer information of minors under the age of 16.
8.5 California Residents’ Rights and Choices:
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.
- 8.5.1 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 8.6 below), to the extent required by the CCPA, we will disclose to you:
- 18.104.22.168 The categories of consumer information we collected about you.
- 22.214.171.124 The categories of sources for the consumer information we collected about you.
- 126.96.36.199 Our business or commercial purpose for collecting or selling that consumer information.
- 188.8.131.52 The categories of third parties with whom we share that consumer information.
- 184.108.40.206 The specific pieces of consumer information we collected about you (also called a data portability request).
- 220.127.116.11 If we sold or disclosed your consumer information for a business or commercial purpose, two separate lists disclosing (i) sales, identifying the consumer information categories that each category of buyer purchased; and (ii) disclosures for a business or commercial purpose, identifying the consumer information categories that each category of recipient obtained.
- 8.5.2 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 8.6 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:
- 18.104.22.168 Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- 22.214.171.124 Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- 126.96.36.199 Debug products or services to identify and repair errors that impair existing intended functionality.
- 188.8.131.52 Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- 184.108.40.206 Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 220.127.116.11 Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- 18.104.22.168 Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- 22.214.171.124 Comply with a legal obligation.
- 126.96.36.199 Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
8.6 Exercising Access, Data Portability, and Deletion Rights:
- 8.6.1 To exercise the access, data portability, and deletion rights described in Section 8.5 above, please submit a verifiable consumer request to us by either: (1) calling us at 888-211-9007; (2) visiting https://www.monocl.com/; or (3) contacting us in accordance with Section 7. 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 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 8, 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. For instructions on exercising sale opt-out rights, see Section 8.7 below.
- 8.6.2 We endeavor 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), 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 (which may be in the form of a Microsoft excel spreadsheet or plain text document) 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.
8.7 Consumer Information Sales Opt-Out and Opt-In Rights:
- 8.7.1 If you are 16 years of age or older, you have the right to direct us to not sell your consumer information at any time (the “right to opt-out”). We do not sell the consumer information of California residents we actually know are less than 16 years of age. California residents who opt-in to consumer information sales may opt-out of future sales at any time.
- 8.7.2 To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Do Not Sell My Personal Information
- 8.7.3 Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize consumer information sales. However, you may change your mind and opt back in to consumer information sales at any time by visiting the following Internet Web page link: Link
- 8.7.4 You do not need to create an account with us to exercise your opt-out rights. We will only use consumer information provided in an opt-out request to review and comply with the request.
- 8.8.1 We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:
- 188.8.131.52 Denying you goods or services.
- 184.108.40.206 Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- 220.127.116.11 Providing you a different level or quality of goods or services.
- 18.104.22.168 Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.