Latest Version Update: August 15, 2021
Please read carefully: This document is designed to make users, clients, and partners (collectively, “User”) of Disease Management Strategy Group, Inc. (“DMSG”) services and web site aware of how your personal information will be collected, utilized, and protected.
For DMSG, it is a priority to ensure the privacy and security of User information. Therefore, this document aims to provide its User with due transparency about how their data is used by DMSG.
To facilitate the reading and understanding of the provisions contained in this Privacy and Data Protection Policy (the “Policy”), we present the following summary of the topics covered:
WHO HANDLES AND CONTROLS YOUR PERSONAL DATA?
DISEASE MANAGEMENT STRATEGY GROUP, INC. (DMSG)
EIN: 45-5371719
Address: 5500 Military Trail, Suite 22-299, Jupiter, FL, US 33458
WHAT PERSONAL DATA WILL BE COLLECTED?
Data provided by the User during the purchase, licensing, delivery of consulting services or training in the use of the WELLCAST ROI software (“SOFTWARE”) and during access to our website.
HOW LONG WILL WE STORE YOUR DATA?
Your personal data will be automatically deleted by DMSG when they are no longer useful for the purposes that motivated their being supplied and are no longer necessary to fulfill any legal obligation.
WHAT DOES DMSG USE YOUR PERSONAL DATA?
DMSG uses your personal data for the purchase, delivery of consulting services, licensing and/or training of the SOFTWARE and, if necessary, to enter or maintain contact before, during or after its purchase, licensing, while delivering consulting services and/or training in the use of the SOFTWARE.
WITH WHOM WILL DMSG SHARE YOUR PERSONAL DATA?
DMSG employees and independent contractors who provide the company’s services.
HOW CAN I COMMUNICATE QUESTIONS REGARDING MY RIGHTS?
Your concerns regarding your privacy rights can be communicated via the following email address: info@dmsg360.com
Personal information – What data do we use?
DMSG respects your privacy. Any information you provide to us will be treated with the highest level of care and security and will only be used within the limits set forth in this document.
“Personal Information” is information that allows you to be identified directly or indirectly. Personal information is gathered to purchase, license, identify needs, for delivery of consulting services and training. We gather this data via our web site and through personal and digital contact. Examples of personal data gathered include your name, title, telephone, e-mail, employer, IP address, data you provide us, and other information not publicly available in public databases. It is important to clarify that the SOFTWARE does not utilize personal data to generate the ROI calculations, as the SOFTWARE only uses aggregate population data as input (e.g., aggregate risk factors, aggregate prevalence of behavioral and physical conditions, average wages, etc.).
If you do send us any personal information relating to other entities or individuals, you represent that you have the authority to do so, and that you have obtained the necessary consent and are authorized to divulge such data.
During the initial contact stage via our Call Center or through our website, we collect your name, company, telephone number, and/or e-mail, for example. This information is necessary for us to identify you and to provide services.
DMSG may collect information entered by you at the time of contact, such as, for example, data linked to your connection, such as: IP address, date, time, device used, among other data.
There are two types of personal data collected: (a) those provided by the User; and (b) those collected automatically by DMSG.
(a) Personal data provided by the user: DMSG collects personal data entered or forwarded by the User when filling out the contact form on its web site. Examples include name, telephone, company, and e-mail address.
Regardless of which personal data is provided by the User, we will only use data that is relevant and necessary to deliver services; and
(b) Data collected automatically: DMSG also collects data automatically, such as: characteristics of the access device, browser, IP (with date and time), IP origin, information about clicks, pages accessed within the website, search terms, among others. For such data collection, several standard technologies are used, such as cookies, pixel tags, beacons, and local shared objects, which are used with the purpose of improving your browsing experience, according to your habits and your preferences.
DMSG does not process or use individual personal data, such as racial or ethnic origin, religious convictions, political opinion, union, or organization affiliation, philosophical or political views, data referring to individual health or sexual life, nor genetic and biometric data.
How DMSG Uses Personal Data
DMSG uses the data collected in its website or digitally for the following purposes:
• To confirm or correct information we have about you.
• What you use the SOFTWARE and website for.
• To carry out research or to send you studies and surveys.
• To send you information that we believe will be of interest to you.
• To identify the appropriate professionals within our company that can best assist you.
• To contact you via telephone and/or the email address you provided. We may contact you in person, by voice message, by text messages (SMS), by email, WhatsApp, or any other means of communication that your device can receive or send information, notifications, and important content about services.
• In other ways permitted by law.
User information may also be collected by DMSG when there is a legal requirement for its collection.
DMSG may also use personal data, when necessary, for the fulfillment of a legal or regulatory obligation or the regular exercise of rights in judicial, administrative or arbitration proceedings.
Additionally, the information collected may, with your authorization, be used to send information that is of interest to you.
If you feel uncomfortable and no longer wish to receive any communications from DMSG, you may, at any time, contact us through info@dmsg360.com to cancel such communications.
How Personal Information Can Be Shared
DMSG is committed to providing the best service possible. To this end, your data may be shared with our partners and collaborators who are involved in your use of the SOFTWARE.
For the operationalization of its services, DMSG partners with several collaborators located in various countries.
We may share your information as follows:
• For collaborators and/or partners in the use of the SOFTWARE.
• To third parties, in the event of any reorganization, merger, sale, joint venture, assignment, transfer or transfer of all or part of our business, assets or capital (including those relating to bankruptcy or similar proceedings).
• As we deem necessary or appropriate: (a) under applicable laws, including laws in effect outside your country of residence; (b) to meet legal process requirements; (c) to comply with a court order, regulatory decision or decision of competent authorities, including authorities outside the country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety of DMSG, you or others; (g) to detect and prevent fraud; and (h) allow us to limit damages we may suffer.
• To manage our infrastructure and business operations and comply with internal policies and procedures, including those related to Information Technology systems, data hosting and website, data analysis, business continuity management and electronic document management.
• In other ways permitted by law.
Additionally, it is possible that some of the data transfer mentioned above might take place outside the US.
DMSG undertakes to do so only for countries that provide a degree of protection for your personal data, as provided for in the applicable legislation; or through the adoption of guarantees and safeguards such as specific clauses, standard clauses, global corporate norms, among others; as well as upon your specific consent.
How DMSG Collects Other Information
DMSG and its third-party service providers may collect Other Information in a variety of ways, including but not limited to:
• Via browser or device: Some information is collected by most browsers or automatically via internet access devices, such as computer type, screen resolution, operating system, and version, model and manufacturer of the computer, device, language, type, and version of the Internet browser you are using. We may use this information to ensure that the services function properly.
• Use of pixel tags and other similar technologies: Pixel tags (also known as web beacons and invisible GIFs) may be used in connection with some services to track actions of users of the services (including e-mail recipients), measure the success of our marketing campaigns and collect statistical data on usage of the services and response rates, and for other unspecified purposes. We may engage behavioral advertising partners to obtain reports on advertisements across the Internet. These pages use cookies, pixel tags and other technologies to collect information about your use, or about the use of other users of our website and third-party websites. DMSG is not responsible for pixel tags, cookies and other similar technologies used by third parties.
• When provided by you: Information such as your location, as well as other information, such as preferred means of communication, is collected when you voluntarily provide this information.
• Use of cookies: Information about your use of the services may be collected by third parties through cookies. Cookies are information stored directly on the computer you are using. Cookies allow the collection of information such as browser type, time spent in service channels, pages visited, language preferences, and other anonymous traffic data. DMSG and our service providers use information for security protection, to make browsing easier, display information more efficiently, and customize your experience using our service channels, as well as for online tracking. DMSG also collects statistical information about the use of our service channels to continually improve our design and functionality, to understand how the website is used, and to help you resolve service issues.
In general, the cookies used on the website can be divided into the following categories:
Necessary Cookies are essential for the DMSG’s website to load properly and allow you to navigate correctly, as well as to make use of all available functionality.
Performance Cookies help us understand how visitors interact with the DMSG’s pages, providing information about the areas visited, the time of visit to the website and any problems encountered, such as error messages.
Functional Cookies allow the website pages to remember your choices and to provide a personalized experience. They also allow Users to watch videos and use social tools, comment fields, among others.
Marketing Cookies are used to provide more relevant content and of interest to Users. They can be used to present advertising with greater targeting. They also allow the measurement of the effectiveness of an advertising campaign.
To use the cookie tool, DMSG will ask the User for his authorization, when first accessing the website.
DMSG emphasizes that the acceptance of cookies classified as necessary are essential to the normal functioning of the website and limiting or not accepting the use of this tool may lead to direct and immediate limitation of services available. The user will be provided with the necessary tool to revoke the authorization regarding the use of cookies.
Protection of Personal Information
Any information provided by the User will be collected and stored in accordance with the strictest security standards.
To this end, DMSG takes several precautions, in compliance with the guidelines on safety standards established in applicable laws and regulations.
i. DMSG uses the latest methods and equipment available on the market to encrypt and anonymize your personal data, when necessary. Encryption allows us to protect your data before it is transmitted over the Internet. Advanced encryption techniques make this information unreadable and prevent others from viewing it before it reaches our server.
ii. DMSG has protection against unauthorized access to its systems.
iii. DMSG only authorizes the access of specific people to the location where their personal information is stored, provided that this access is essential to the delivery of services.
iv. DMSG guarantees that those agents, internal employees, or external partners who process personal data must maintain the absolute confidentiality of the information accessed, as well as to adopt best practices for handling of this information, as determined in the external policies and procedures.
v. DMSG regularly backs up data entered in the SOFTWARE and its website. DMSG’s information systems are checked consistently to protect the information you provide. Sophisticated protection systems are used in our website and SOFTWARE.
In addition to its technical efforts, DMSG also adopts institutional measures aimed at protecting personal data, to ensure privacy of its SOFTWARE and website. These measures are continually updated.
Access to collected information is restricted to employees and authorized persons. Those who improperly use this information, in violation of this Privacy and Data Protection Policy, will be subject to applicable administrative, disciplinary, and legal sanctions.
DMSG adopts the appropriate technical and organizational measures to protect Personal Information in our organization. Unfortunately, no data transmission or storage system is guaranteed to be 100% secure, so DMSG cannot fully guarantee that all information it receives and/or sends is not subject to unauthorized access perpetrated through methods developed to obtain such information improperly, such as technical failures, viruses, or invasions of the DMSG’s systems database. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any of your accounts has been compromised), please notify us immediately at: info@dmsg360.com.
In the unlikely event of such episodes, DMSG guarantees its full effort to remedy the consequences of the event.
DMSG is not responsible for any other website that can be accessed from ours. There is no link between such addresses.
Users’ Rights
In compliance with applicable regulations regarding the processing of personal data, DMSG respects and guarantees to the User the ability to submit requests for the following:
i. Access to the data.
ii. Correction of incomplete, inaccurate, or outdated data.
iii. Anonymization, blocking or deletion of unnecessary, or excessive data in violation of the Law.
iv. Data portability to another service or service provider, upon express request by the User.
v. Deletion of data with the User’s consent.
vi. Obtaining information about the public or private entities with which DMSG has shared its data.
vii. Ability to not provide USER consent, after being informed about the consequences of doing so.
viii. Revocation of USER consent.
Some of the above rights may be exercised directly by the User, during the management of registration/contact information, while other rights will require sending a request to our Privacy Department / Data Protection Officer for further evaluation and adoption of the necessary measures.
Requests to exclude essential information for the management of your registration with DMSG will result in the termination of your relationship, with the consequent cancellation of the services provided.
Updates to this Site Privacy Policy
We may change this Site Privacy Policy at any time upon notice. Please refer to the “Last Updated” caption at the top of this page to verify the date of the most recent version. All changes will be effective upon posting of the revised Site Privacy Policies. We recommend that you check this policy every time you browse the DMSG website.
Legislation and Jurisdiction
This Policy will be interpreted according to the Laws of the State of Florida.
