Privacy Statement EU
General Statement
The HealthProMatch (HPM) platform is a novel proactive pilot aimed at improving senior high-impact leadership, innovation and staff retention within healthcare systems. The mission is to create a global community of health professionals who share and enhance their knowledge, skills and attitudes,
This Privacy Policy applies to all Services and websites that are offered and provided by EHE, its divisions and its affiliates.
If you are a US resident, the collection, use and disclosure of your personal information, as well as your individual rights, are subject to our Privacy Statement – US.
This Privacy Policy (“Privacy Policy”) discloses the privacy practices for EHE (sometimes referred to as “EHE”, “we”, “our” or “us” or “HPM”) with regard to your (“You” or “Your”) use of the website (www.healthpromatch.com ) (the “Site” or “Sites”). This Privacy Policy has been updated for the European General Data Protection Regulation in force as of May 25, 2018 (“GDPR”)
Please read this Privacy Policy carefully so You understand how HPM processes and protects Your information and also in order to ensure that the benefits and obligations of membership are understood. We also encourage members talk to us with any questions, comments or suggestions having read this Privacy Policy.
Our Privacy Policy
In the course of providing You a high quality HPM experience and through Your interactions with us, HPM collects information about You and about Your use of our Site.
HPM takes your privacy and its obligations under data protection laws very seriously, and we strive to be transparent at all times about our treatment of your information.
1.Information collection and use
Registration information
Before You can register for HPM, You will need to provide Your name, address, phone number, email address and professional credentials. We will use this information to set-up, validate and administer your account. You must also consent to the privacy practices set out in this Privacy Policy, as well as agree to our Terms of Use and Code of Conduct in order to register.
We may use your information to send you information about our services, and provide you with information about other goods and services we offer that are similar to those that you have already used or enquired about to market to you. We may also use this information to provide you, or (based on your explicit consent, if and when required under applicable law) permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will primarily contact you by electronic means (email or SMS) with information about goods and services similar to those which you have expressed interest in.
Your information may also be used to help prevent spam, fraud, or abuse. You may use your settings for email and mobile notifications to control notifications you receive from our Services. You may also unsubscribe from a notification by following the instructions provided with the notification or instructions available via the Site.
Personal account information
Once a registered member of HPM, You may provide additional information in Your personal account profile which describes You, including Your birth date, social network username, medical school, institutional affiliations, credentials, professional experiences, memberships, evidence of Your specialism(s), academic background and biography. Providing additional information in Your personal profile is not required and entirely optional, but it may allow You to derive greater benefits from using HPM, such as receiving profile-targeted invitations to participate in surveys, if you choose to provide it. This information can be updated or removed by You at any time, and You may choose whether to make some of this information publicly visible to other social network participants.
Information we receive from you
A key part of HPM involves encouraging the free flow of ideas, opinions and content between medical professionals, and most of this information provided by users is available to be viewed by other HPM users and third parties with whom we are conducting business. However, regardless of the nature of your posts, we ensure your opinion will remain anonymous if you wish it to be.
When You post content such as articles, comments and photos on HPM, we may also receive additional data (or metadata) related to the content, for example, the time, date, and place You took a photo.
We also collect information when you navigate the HPM site, for example, when You visit a HPM page, send or receive a message, click on or otherwise interact with content, post content, view or click on ads we display, perform a search, or participate in polls. We may use this information to make inferences, such as about the content, subjects and ads You may be interested in. If You have agreed to our use of cookies (see our Cookie section and policy below) and one of our cookies on your device identifies You, Your usage information and the log data described below, such as your IP address, will be associated by us with Your account.
We also receive and use Your information when You decide to contact us. If You email us, we may keep Your message, email address and contact information. We need this to categorise Your enquiry, respond to it and, if applicable, investigate any breach of our Terms of Service, Code of Conduct or this Privacy Policy. We may also use this information to customise and improve our services over time. We do not use this information for external advertising.
To set-up and run Your HPM account, we may ask you to provide some financial information in order to allow You to be compensated for participating in Opportunities (see our Terms of Service). If You choose to withdraw these amounts through gift cards or charitable donations, we will need to collect information from You in order to process these transactions. Where such Opportunities are offered by third parties, we will also need to collect information about Your participation in such Opportunities from those third parties, in order to validate payments. We may also need to send the information set out in this section to trusted third parties that we appoint to process and administer such payments.
HPM does not collect personal health information about individuals. HPM does not collect or maintain information that would associate a submission with a specific patient. So please ensure that You do not disclose anything that would allow a patient to be identified. Note also that HPM does not possess a data based key to re-identify patient data.
Information to/from third parties
We reserve the right to instruct trusted third parties to process Your information in order to verify HPM user identities and ensure that members are medical professionals and to protect the integrity of HPM by preventing fraud.
We may obtain data from our affiliates or our advertising partners, customers and other third parties, which help us (or them) deliver sponsored content onto HPM, understand online activity, and generally improve Your HPM experience. Such third parties may share information about You which includes a browser cookie ID, website URL visited, mobile device ID, or cryptographic hash of a common account identifier (e.g. usernames or email address), which enables HPM to provide ads on the Site and monitor Your preferences and Your interest in them. However, You can choose to block certain ads by enabling an ad blocker to Your web browser so that Your information will not be matched to information shared by ad partners for this purpose. HPM also makes use of Google Analytics, a web analytics service provided by Google, Inc. (“Google”), which uses cookies to analyse how users use the website. The information generated by the cookie about Your use of the website will generally be transmitted to and stored by Google on servers in the United States. At the request of HPM, Google will use this information for the purpose of measuring Your activity on HPM’s website, compiling statistical reports on overall website activity for HPM on an anonymous basis and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other information held by Google. In addition, you can prevent the collection of the information generated by the Google cookie, as well as the processing of this data by Google, by downloading and installing a browser plug-in available here.
Cookie information
A cookie is a small piece of data that is sent to Your browser from a Web server and stored on Your computer’s hard drive. A cookie cannot be used to read data off Your hard disk, nor can it read cookie files created by other sites. We use cookies to improve Your experience on the site; for example, by setting a cookie on Your browser, You would not have to log in a password more than once, thereby saving time. You can choose whether to accept cookies or not by changing the settings of Your browser. You can reset Your browser to refuse all cookies or allow Your browser to show You when a cookie is being set. If You reject the cookies on the Site, You may still be able to use the Site, but Your use may be limited in some areas or limited to certain functions of the Site.
The HPM Site uses session cookies and persistent cookies to better understand how you interact with the Site, to monitor aggregate usage by and web traffic, to enable You to access surveys and to make improvements the Site. You can learn more about the use of cookies in our Cookie Policy.
Log information
When you use our Site, we may use information such as Your IP address, browser type, operating system, referring web page, pages previously visited, location (see below), mobile carrier, device and/or application identifiers, search terms, and cookie information to align our services with changes in Your device usage patterns, to administer the Site and to gather certain demographic information for aggregate use. We may also receive log information when You view or interact with links on the HPM site, including sites operated by third parties.
Location information
We may receive information concerning your location if, for example, You choose to post content which reveals this information. We may also determine Your location using information from Your device, such as GPS data, information about wireless networks or cell towers near Your device, or IP address. Subject to your explicit consent, we may use this to improve and customise our service to You, for example by making you aware of content, people and ads more relevant to Your location. You can choose to turn off location services on Your device if you prefer, however if You do so You will not benefit from such tailored content.
2.How and why we share your information
We will only process the information we collect about You in accordance with this Privacy Policy or where You have otherwise authorised us to do so by granting us your explicit consent.
We may direct You to pages which contain commercial content or You may be presented with the opportunity to engage with sponsored content, such as at the conclusion of a Real-Time survey or via HPM Conversations, HPM Promo and HPM Ratings, which are further described in the Terms of Service. We may then provide our partners with engagement effectiveness metrics that include the sharing of some minimal personal data for performance assessment purposes. To the extent required by law, we will collect your explicit consent prior to providing such identifiable information.
We engage partners to perform certain functions on our behalf and help us provide our services. We may share Your information with such partners, who are carefully selected by us, where we impose legal obligations on them which are consistent with this Privacy Policy, and on the condition that they act only on our instructions and keep Your information secure. We may also share Your information with other entities within the HPM group and we have implemented technical and contractual measures to help ensure that Your information is secure through-out the HPM group.
Subject to implementing relevant safeguards under Art. 46 GDPR, the data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our partners. We will take all steps necessary to ensure that Your information is subject to the required technical and organisational measures as required under law and are treated in accordance with this Privacy Policy.
Users of the Site are prohibited from revealing any information that might identify another user; and doing so will constitute grounds for immediate termination of that members’ account. However, if You have chosen to reveal personal data on the Site it is possible that other users may make reference to it. As such, please consider carefully what information You choose to make public on the Site.
Sale of assets, merger, acquisition, bankruptcy
Information collected from You, or received by us from others about you may be transferred to a third party to the extent permitted by law, as a result of a sale or acquisition, merger or bankruptcy involving HPM. This Privacy Policy will apply to Your information as transferred to the new entity. We will still inform You beforehand and provide you with a possibility to object within a reasonable timeframe.
Legal requests
HPM takes Your right to privacy very seriously and has taken measures to safeguard Your personal data. HPM will only disclose Your personal data other than as set out above in the event we are required to do so by law, rule, regulation, law enforcement, governmental official, legal authority or similar requirements.
3.How we secure your information
We are committed to protecting the security of Your information. We use a variety of industry-standard security technologies and procedures designed to help protect Your information from unauthorized access, use, or disclosure. Despite these measures, You should know that we cannot fully eliminate security risks associated with information and transmission of data over the internet, it can never be completely secure. In the event of a data security breach, we will take all essential actions as required under applicable laws.
The Site may contain links to other sites. The linked sites are not necessarily under the control of HPM. Please be aware that HPM is not responsible for the privacy practices of such other sites. HPM encourages You to be aware when You leave this Site and to read the privacy policies of each and every web site that collects personal information. If You decide to access any of the third-party sites linked to this Site, You do this entirely at Your own risk. Any links to any partner of the Site is responsibility of that partner and HPM shall not be responsible for notification of any change in name, or location of any information on the Site.
4.Your rights
You also have a legal right under the GDPR and other relevant data protection laws to:
(i) access the information we hold about you and (ii) to a copy of any information about You held by us. Upon request, we will provide You with access to and a copy of this information. You also have a right to (iii) correct any errors in this information, (iv) request its deletion or (v) to object to any processing operations (provided we are not under legal obligations to retain certain information) and (vi) to revoke any given consent at any time.
We reserve the right to decline requests that are (i) unreasonably repetitive, (ii) that jeopardise the privacy of others, (iii) the validation facility, (iv) the interests of justice, (v) or where we are otherwise required to retain Your personal data by law.
You can exercise Your rights to access, edit and delete your information in accordance with the GDPR, CCPA, Nevada Privacy Law SB-220 or other relevant local privacy laws at your location – at any time by Contacting Us at admin@healthpromatch.com. Lastly, if you are a European Union resident, you also have the right to submit a complaint to the relevant data protection authority in your European Union member state.
Update and deletion of Personal Information
If Your personal information changes (such as Your address), You can update Your profile on the Profile page of the Site. HPM will correct, update or remove Your personal data as directed or You can do so Yourself via the self-service Profile page mentioned above.
If You no longer desire to use the Site, you may permanently delete your HPM account. The time to deactivate Your account will vary according to your prior history with HPM. In the simplest cases, deactivation will be prompt following the receipt of a “cooling off” communication reminding you of the results of deactivation. For some accounts the process will be longer as we complete certain administrative task relating to Your past activity and any incentives You may have earned. However, HPM will aim to complete account deactivations within 28 days from the original request. This does not affect any information use choices You make, which will be honoured promptly.
You can request Your personal details to be removed from the Panel active database and to have your participation in the Panel terminated by:
- Contacting Us, choosing “I want to delete my information” as the inquiry subject;
or - sending Us an e-mail at admin@healthpromatch.com from the e-mail address you registered with and with the words “” in the subject line.
Failure to follow the stated procedure correctly may result in delay in the removal of Your information from the Panel databases. Your removal request will be dealt with promptly. If You choose to remain a HPM member, we will retain Your personal information for as long as necessary for the purpose for which it was collected and processed, such as with respect to Your HPM membership.
Lawful Bases to Process Your Information under the GDPR
HPM is the data controller of Your information and when we collect and process Your information, we rely on Your consent or our legitimate business interests as the legal basis to do so. The GDPR provides for six legal bases that permit an organisation like HPM to lawfully process Your information. There are:
- You have given consent to the processing of Your information for one or more specific purposes. For example: clicking “I agree” to a cookie alert while browsing a page on the internet or consenting to a specific information processing request contained within an online survey.
- Processing is necessary for compliance with a legal obligation to which HPM is subject. For example: accurately reporting taxes, complying with financial transparency laws [e.g. Loi Bertrand and Loi Anti-Cadeaux in France] or reporting pharmacovigilance adverse events information.
- Processing is necessary in order to protect the vital interests of You or of another natural person. For example: reporting Your information as part of a potentially life-saving or life-threatening event, via HPM’s obligation to report adverse events.
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in HPM. This legal base will probably not be used by HPM.
- Processing is necessary for the purposes of the legitimate business interests pursued by HPM or by a related third party, except where such interests are overridden by Your interests or fundamental rights and freedoms. For example: Your information is an important element in HPM’s provision of a global social network, free at the point of access. As a result HPM is able to provide its social platform based tools and products, such as HPM Drug Ratings™ tool that is based upon the drug ratings You provide and then You have the right to use the HPM Ratings results via the Site. The HPM Community team also uses Your information to help administer this Site and HPM’s market research and social network activity that are in part generated form this Site.
Notification of Changes
We may update this Privacy Policy at any time, with or without advance notice. In the
event of any change in the way we treat Your personal data, or in the Privacy Policy
document itself, we will display a notice on the HPM website or send You an email, so that You may review the changed terms prior to continuing to use the Site. As always, if You object to any of the changes to our terms, and You no longer wish to use the Site, You may contact HPM Support to deactivate Your account. Unless stated otherwise, our current Privacy Policy applies to all information that HPM has about You and Your account.
Site and Service Updates
As necessary, HPM may send You Site and service announcement updates. You are not able to unsubscribe from service announcements, which contain important information about the Site, unless you delete your account. HPM primarily communicates via e-mail with You to provide requested services and to resolve issues relating to Your accounts.
5.Contact us
Should You have questions about this policy or HPM’s information collection, use and disclosure practices, feel free to Contact Us. You may also contact us by a written request at
EHE Inc,
Flat 9
24 Second Avenue, Hove, BN32LN
East Sussex, United Kingdom.
We will use all reasonable efforts to respond promptly to requests, questions or concerns You may have regarding our use of personal information about You. Except where required by law, HPM cannot ensure a response to questions or comments regarding topics unrelated to this policy or HPM’s privacy practices.