The protection of personal data is highly important to Boston Healthcare Associates, Inc. (“Company”). This Privacy Statement serves to inform visitors to the website of Boston Healthcare Associates, Inc. (“User(s)”) about the processing of personal data (hereinafter also “Data”) that takes place on the websites of Boston Healthcare Associates, Inc., subject to the applicable data protection laws, in particular Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”).

1. Controller of data processing

Boston Healthcare Associates, Inc. is the controller of the lawful processing of Users’ personal data. Its representative in the European Union is Dr. Jörg Burkowitz:
Leipziger Platz 11
D-10117 Berlin, Germany
phone + 49 (0) 30-30 88 12 6-0
fax + 49 (0) 30-30 88 12 6-20

2. Data processed and purposes of processing

2.1  Usage data

When the website of Boston Healthcare Associates, Inc. is accessed, the servers of Boston Healthcare Associates, Inc. automatically store certain data of the accessing system. This includes the type of browser used, the browser version, the operating system used, the website from which the website of Boston Healthcare Associates, Inc. is accessed, the controlled subpages of the website of Boston Healthcare Associates, Inc., the date and time of access, the internet protocol address (IP address), the internet service provider and data comparable with such data.

Boston Healthcare Associates, Inc. uses this data to make the websites available, to detect and remove possibly occurring technical problems and to prevent and, if need be, prosecute any abuse of the services of Boston Healthcare Associates, Inc. Boston Healthcare Associates, Inc. also uses this data in anonymized form, i.e. without being able to identify the user, for statistical purposes and in order to improve the websites. The legal basis for processing personal usage data is Article 6(1), first subparagraph, point (f) GDPR.

2.2 Registration data

The User must provide contact details to be able to access certain functions on the websites of Boston Healthcare Associates, Inc. Depending on the function desired, certain information is required for registration (e.g. name of User, e-mail address). We need this information to provide the User with the requested resources (i.e presentations, white papers).  More details on registering and using the functions offered on the websites of Boston Healthcare Associates, Inc. are provided in the Terms of Use. The legal basis for processing the data outlined above is Article 6(1), first subparagraph, point (b) GDPR.

2.3 Use of cookies

The websites of Boston Healthcare Associates, Inc. use cookies. Cookies are small text files that are stored on the User’s data carrier and exchange certain settings and data with the system of Boston Healthcare Associates, Inc. via the browser. A cookie normally contains the name of the domain from which the cookie data are sent and information on the age of the cookie and an alphanumerical identifier. Cookies enable Boston Healthcare Associates, Inc. to design the website attractively to the User and also facilitate use by, for example, storing certain input such that it need not be entered repeatedly. The information stored in the cookies is not used to identify the User and is not combined with other personal data stored about the User. The legal basis for processing personal data is Article 6(1), first subparagraph, point (f) GDPR.

Users may deactivate or restrict the transfer of cookies by changing the settings on the internet browser. Cookies already stored may be erased at any time. This may also be done by automatic means. Should cookies for the websites of Boston Healthcare Associates, Inc. be deactivated, it may be the case that not all functions of the websites can be fully used.

2.4 Google Analytics

The websites of Boston Healthcare Associates, Inc. also use functions of the web analysis service Google Analytics provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”). Google Analytics likewise uses cookies. The information generated by the cookie about the use of this website is as a rule transmitted to a Google server in the USA where it is stored.

The websites of Boston Healthcare Associates, Inc. use Google Analytics with the additional component “anonymize IP”. This means that the IP address of the User collected by the Google Analytics cookie will be shortened by Google beforehand within Member States of the European Union or in other signatory states of the Treaty on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. Google is certified under the EU-US Privacy Shield Program. You can find more information here.

Google uses the information generated by the Google Analytics cookie on behalf of Boston Healthcare Associates, Inc. in order to evaluate the use of the website, prepare reports on the website activities and to provide Boston Healthcare Associates, Inc. with additional services associated with the use of the website and the internet. The IP address transmitted by the browser of the accessing system as part of Google Analytics will not be combined with other Google data. More detailed information on the conditions of use and data protection is available at http://www.google.com/analytics/terms/de.html or at http://www.google.com/intl/de/analytics/privacyoverview.html. The legal basis for processing personal data by using cookies is Article 6(1), first subparagraph, point (f) GDPR.

The User can prevent Google from collecting the data generated by the cookie and pertaining to the use of the website or from processing this data by downloading and installing the browser plugin available via the following link (http://tools.google.com/dlpage/gaoptout?hl=de). Boston Healthcare Associates, Inc. does however point out that in this case it may be that not all functions of the website can be fully used. The User may deactivate or restrict the transfer of cookies by changing the settings on the browser. Cookies already stored may be erased at any time. This may also be done by automatic means. Should cookies for the websites of Boston Healthcare Associates, Inc. be deactivated, it may be the case that not all functions of the website can be fully used. Should Users only wish to accept cookies from Boston Healthcare Associates, Inc. but not cookies from the service providers and partners of Boston Healthcare Associates, Inc., they may select the “block cookies from third party providers” (or similar) settings on their browsers.

2.5 Data transferred in the course of making contact

Boston Healthcare Associates, Inc. websites provide Users with the option to make contact with Boston Healthcare Associates, Inc. [and, for example, to send Boston Healthcare Associates, Inc. applications online]. The personal data transferred to Boston Healthcare Associates, Inc. in this connection are exclusively used in order to handle the respective inquiries. The legal basis for processing the data outlined above, depending on the content of the respective contact-making, is Article 6(1) subparagraph 1 point (b) respectively (f) GDPR.

2.6 Newsletter

Boston Healthcare Associates, Inc.’s websites provide Users with the option to subscribe to a newsletter and to consent to the processing of personal data necessary for this. In order to register for the newsletter the User must provide his e-mail address. Additional information can be provided on a voluntary basis. These data are exclusively used in order to send the newsletter and are not transferred to third parties. The date and time of registration and the e-mail verification are also collected at registration. These data are exclusively processed for the purpose of identifying the possible abuse of an e-mail address. The legal basis for processing the data outlined above is Article 6(1) subparagraph 1 point (a) GDPR. The User has the right to withdraw his consent at any time without prejudice to the lawfulness of the processing carried out based on the consent prior to his withdrawal.

3. Transfer of data to externals

Boston Healthcare Associates, Inc. receives assistance from outside service providers for certain technical data analysis, processing or storage processes (e.g. to obtain aggregated, non-personal statistics from databases or for the storage of backup copies). These service providers are carefully selected and meet high data protection and data security standards. They are obligated to maintain strict confidentiality and process personal data only when commissioned to do so by Boston Healthcare Associates, Inc. and according to Boston Healthcare Associates, Inc.’s instructions. The legal basis for the involvement of such service providers is Article 28 GDPR.

Boston Healthcare Associates, Inc. cooperates with companies and other entities, which provide specialized expertise with regard to special areas (e.g. tax consultants, legal counsel, accounting firms, logistics companies). These entities are either legally or contractually obliged to maintain confidentiality. If a transmission of personal data to these entities is necessary, the legal basis is, depending on the respective kind of cooperation, Article 6(1) first subparagraph 1 point (b) or, (f) GDPR.

Except in the cases set out in this Privacy Statement, Boston Healthcare Associates, Inc. only transfers data to third parties without the User’s explicit consent if so obliged by law or by administrative or judicial directive.

4. Storage period

Usage data will be stored for a period of 731 days. The data outlined above will otherwise be erased once it is no longer required for the described purposes, provided statutory provisions do not stipulate a longer retention period.

5. Rights of the Users

Users requesting detailed information on the processing of personal data concerning them may contact Boston Healthcare Associates, Inc. at any time. They may also ask to receive in structured, commonly used and machine-readable format the data which they have provided to Boston Healthcare Associates, Inc. or for such data to be transferred to a third party. Should the Users establish that the data stored about them is incorrect or incomplete, they may at any time require the immediate rectification or completion of such data. Subject to the preconditions set out in Articles 17 and 18 GDPR, the User may also require the erasure or restriction of processing of personal data. Users also have the right to lodge a complaint with the competent supervisory authority for Boston Healthcare Associates, Inc.

6. Contact information

The User may contact Boston Healthcare Associates, Inc. at any time regarding questions concerning Boston Healthcare Associates, Inc.’s processing of personal data and the exercise of rights to which the User is entitled against such processing. To do so it is sufficient to contact Boston Healthcare Associates, Inc.:

Boston Healthcare Associates, Inc.
Global Head Office
33 Arch Street, 17th Floor
Boston, MA 02110

Data Protection Information for Interviewees
As of: October 2018

The protection of personal data has a high priority for Boston Healthcare Associates, Inc., 75 Federal Street, Suite 900, Boston, MA, 02110, USA, German office at Leipziger Platz 11, 10117 Berlin (referred to herein as „BHA“, “we” or “us”). We take our position as controller of your personal data very seriously.

This notice is to inform you, medical doctors and other professionals who are interviewed by BHA or third parties on BHA’s behalf, of what personal data of yours BHA processes and for what purposes. This document also contains information on your rights in relation to the processing of your data.

BHA processes your data pursuant to the provisions of Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”) and in accordance with nationally applicable data protection laws. Special legal concepts referring to data protection and which are not separately defined here can be checked there, in particular in Article 4 GDPR.

Should you still have questions or concerns after reading this data protection information, please feel free to contact our data protection officer at the BHA Berlin office, Dr. Joerg Burkowitz, jburkowitz@bostonhealthcae.com.

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