Last Updated: 11/02/2020 (November 2, 2020)
This Privacy Notice is intended to make you aware of the types of information we gather from people visiting Clarion Healthcare’s corporate website, https://clarionhealthcare.com/ (the “Website”) and how we use, transfer, secure and otherwise deal with such information.
As used in this Privacy Notice, “Clarion,” “we,” “us” and “our” refer to Clarion Healthcare, LLC, and our subsidiaries, joint ventures, and other companies under common control with us from time to time (“Affiliates”), and “you” or “users” refer to people who visit the Website.
By accessing the Website, you agree to be bound by this Privacy Notice. If you do not agree to the terms of this Privacy Notice, then please do not use the Website.
- THE INFORMATION WE COLLECT
We gather and use the following types of information about users:
1.1 Personal Information: Information that is about, or relates to, an identified or identifiable individual, or that can be linked to that individual (such as name and contact information).
1.2 Aggregate Information: Combined information that cannot be used to identify an individual (such as the total number of visits to the Website in one day). Please note that we may convert Personal Information into Aggregate Information via one or more processes at our discretion.
- CATEGORIES OF PERSONAL INFORMATION COLLECTED AND HOW USED
2.1 Personal Information You Provide Us
2.1.1 When you use the Website, Clarion will collect the Personal Information you provide Clarion, if any, such as your name, home address, personal telephone number, personal e-mail address, company name, company mailing address, company e-mail address and company telephone number. We also may collect Personal Information that you provide us when you sign up for an investor presentation or when you contact us via e-mail for information or assistance, including the content of your e-mail.
2.1.2 In the course of applying for a job with Clarion through the Website, you may provide certain Personal Information to Clarion. Such Personal Information could include your name, e-mail address, phone number, date of birth, social security number, bank information and government identification numbers, among other identifiers.
2.2 Personal Information Collected Automatically
2.3 How Your Personal Information Is Used
2.3.1 We may use the Personal Information you provide us to contact you, provide support, operate and improve the Website, and respond to your comments and questions.
2.3.2 If you apply for employment with Clarion through the Website, we may use the Personal Information you provide us to process your job application and contact you.
2.3.3 Personal Information collected automatically is used for the purpose of improving our Website and services, and to offer more relevant information and content to you.
- DISCLOSURE OF PERSONAL INFORMATION
3.1 We may share your Personal Information with third party service providers, including cloud services providers, to help us with our business activities such as maintaining the Website or sending e-mail alerts or other similar information for which you have subscribed . We include provisions within our contracts with these businesses to ensure that they: (i) use your Personal Information only as necessary to provide these services to us; and (ii) establish safeguards to protect the confidentiality of the information that we provide them.
3.2 We may share some or all of your Personal Information with our Affiliates, in which case we will require our Affiliates to honor this Privacy Notice.
3.3 We may share some or all of your Personal Information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Notice.
3.4 We may also disclose Personal Information if Clarion believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Clarion; (iii) to protect or defend the rights or property of Clarion or users of the Website or services; (iv) to investigate or assist in preventing any violation or potential violation of the law, or this Privacy Notice; or (v) consistent with the contractual obligations of Clarion
4. CATEGORIES OF AGGREGATE INFORMATION COLLECTED AND HOW USED
Aggregate Information may be collected when you visit use the Website, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without restriction.
- OUR WEBSITE IS NOT AVAILABLE TO THOSE UNDER 18
Access to and use of the Website are not intended for use by anyone younger than the age of 18 and we do not knowingly collect Personal Information from individuals younger than the age of 18. If you have reason to believe that an individual under the age of 18 has provided Personal Information to us, please contact us. We will take reasonable steps to investigate and if it is confirmed that we possess Personal Information of an individual under 18 years of age, we will delete the Personal Information. We may require additional information to confirm that the request is a bona fide request from an appropriate person concerning an individual under the age of 18, as allowed by applicable law.
6.1 Cookies are small files that are placed on your device by a website you visit. From this we can, for example, recognize whether there has already been a connection between your device and the Website, or which language or other settings you prefer. Cookies may also contain Personal Information, and any Personal Information that they contain is subject to this Privacy Notice. Our Cookies Notice https://clarionhealthcare.com/cookie-policy provides information about the cookies (and any similar tracking technologies) that our Website uses. Our Cookies Notice also provides information about managing your consent to cookies when required by applicable law.
6.2 Some web browsers may be configured to send ‘Do Not Track’ signals to the websites that you visit. There is no consensus among industry participants as to what ‘Do Not Track’ means in this context. We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. To find out more about ‘Do Not Track’, please visit www.allaboutdnt.com.
7. EUROPEAN USERS
7.1 This section applies to all Personal Information collected by Clarion via the Website from the European Economic Area and the United Kingdom (“personal data”). The processing of personal data is governed by the EU’s General Data Protection Regulation (“GDPR”) (as applicable). The GDPR requires us to provide certain information concerning our processing of personal data.
|Data controller||Clarion Healthcare, LLC
See address and contact information in the “Contact Us” section
|Purposes of the processing||The purposes of the processing are described in Sections 2 and 3 of this Privacy Notice.|
|Lawful basis for the processing||Generally, we process personal data on the basis that the processing is necessary for purposes of our legitimate interest in conducting our business in a manner typical for a healthcare consultancy, having taken into account any risks to your fundamental rights and freedoms (including your right to privacy).
We also may process personal data on other bases permitted by the GDPR and other applicable laws, such as when the processing is necessary for us to comply with our legal obligations.
|The legitimate interests of the controller or third party, where applicable||Our specific legitimate interests, such as improving the Website, providing you with support, service or products, processing and responding to any employment application, are described in Sections 2 and 3 of this Privacy Notice.|
|The categories of personal data concerned||The categories of personal data that we process are described in Sections 2 and 4 of this Privacy Notice.|
|The recipients or categories of recipients of the personal data||The potential recipients of the personal data that we collect via the Website are described in Sections 2 and 3 of this Privacy Notice.|
|Information regarding the transfers of personal data outside of the European Economic Area (EEA)||Clarion, LLC. is headquartered in the USA and the Website is hosted in the USA.
When you provide your personal data to us via the Website or by contacting us by e-mail, you are providing your personal data directly to the USA. Personal data submitted through the Careers portion of the Website is transferred to Lever, a Clarion service provider that has entered into a data processing agreement with us that requires it to handle your personal data in accordance with all applicable provisions of the GDPR. When you e-mail us, or when you register to receive e-mail alerts from Clarion through the Website, the fact that you have chosen to e-mail us and/or to provide us with your e-mail address knowing that we are located in the USA will be understood to constitute your express consent to the transfer of your e-mail address and any other personal data in your e-mail to the USA.
US privacy laws differ from the privacy laws of the EEA and the United Kingdom and may offer a lower level of privacy protection. However, regardless of the differences in US privacy laws, we safeguard your personal data as described in this Privacy Notice. If we transfer your personal data to a third party, we require the third party to commit contractually to process your personal data only in ways that are consistent with this Privacy Notice.
|The period for which the personal data will be stored, or the criteria for determining the retention period||How long we retain personal data varies according to the type of data in question and the purpose for which it is used. We delete personal data within a reasonable period after we no longer need to use it for the purpose for which it was collected or for any subsequent purpose that is compatible with the original purpose. This does not affect your right to request that we delete your personal data before the end of its retention period. We may archive personal data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.|
|Your rights to access, correct, restrict or delete your personal data and object to processing||You have the right to request access to your personal data, to have your personal data corrected, restricted or deleted, and to object to our processing of your personal data. Your rights may be subject to various limitations under the GDPR. If you wish to exercise any of these rights, or if you have any concerns about our processing of your personal data, please contact us in any of the ways listed in the section “Contact Us”. The GDPR’s data portability rights are not relevant to the kinds of processing that we do.|
|The right to lodge a complaint with a supervisory authority||You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. The data protection authority for the United Kingdom is the Information Commissioner’s office (www. ico.org.uk).|
|Statutory or contractual requirement or other obligation to provide any personal data||Users of the Website are under no statutory or contractual requirement or other obligation to provide personal data to us via the Website.|
7.2 With respect to European users, this Privacy Notice only applies to personal data collected via the Website. If you have provided personal data to us through some other means besides the Website (for example, in connection with a research project run by Clarion in Europe), you will have received a separate notice concerning your personal data. Please refer to that notice first if you have any concerns about our processing of your personal data, as that notice will contain important information and a designated contact person for concerns – but you can always contact us (see the “Contact Us” section of this Privacy Notice).
Clarion is committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while Clarion uses reasonable efforts to protect your Personal Information, Clarion cannot guarantee its absolute security.
- YOUR CHOICES REGARDING YOUR INFORMATION
All users may review, update, correct or delete their Personal Information by contacting us as described in the “Contact Us” section of this Privacy Notice, where the right to do so is provided by applicable law, including as described elsewhere in this Privacy Notice. We will use commercially reasonable efforts to honor your request, and in all events, we will comply with applicable laws relating to your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
- THIRD-PARTY PAGES AND WEBSITES
As a convenience to our visitors, the Website may contain links to a number of websites that we believe may offer useful information. The privacy policies and procedures described herein do not apply to such websites or their content, or to any collection of your Personal Information after you click on links to such third-party websites.
- CONTACT US
If you have any questions regarding this Privacy Notice, or to exercise your rights as described above, please contact us using any of the following methods:
Mail: Clarion Healthcare, LLC
One Financial Center, Suite 1610
Boston, MA 02111
- CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice may be amended from time to time. Each time you use the Website, the current version of this Privacy Notice will apply. We will notify you of any changes to our Privacy Notice by posting a new Privacy Notice on this page as indicated by changing the “Last Updated” date below. In addition, if we change this Privacy Notice in a significant way, we will include a prominent statement on our home page to bring this to our users’ attention. You should consult this Privacy Notice regularly for any changes.