I. Summary of our processing activities:

The material in this app is available to subscribers. The following summary offers an overview of the data processing activities that are undertaken in this app.

• If you register to access our app or subscribe to our e-newsletters, your personal data will be processed in the scope of such services (see IV and V).
• Furthermore, your personal data will be used for statistical analysis that helps us to improve our app (see VII).
• Additionally, we improve your app experience with third party content (see VIII).
• Your personal data may be disclosed to third parties (see IX) that might be located outside your country of residence; potentially, different data protection standards may apply (see X).
• We have implemented appropriate safeguards to secure your personal data (see XI) and retain your personal data only as long as necessary (see XII).
• Under the laws and regulations applicable to you, you may be entitled to exercise certain rights with regard to the processing of your personal data (see XIII).

II. Definitions:

• Personal data: means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
• Processing: means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.

III. Informational use of the app:

When you use our app for informational reasons, we may automatically collect additional information about you such as:

• your IP address;
• your device type, name and IDs;
• the date and time of your requests;
• the content of your requests;
• information on your browser version;
• information on your operating system, including language settings.

We use such information internally at NYU Langone Health to assist us in providing an effective service, and to collect broad demographic information for anonymized, aggregated access and use.

If you are identified by IP or as coming from an organization such as a medical center, university, or physician group, we may also collect the identity of that organization to create usage reports.

The personal data automatically collected is necessary for us to provide the app, and for our legitimate interest to guarantee the app’s stability and security.

IV. Registration for our services:

Access to subscription content is provided via a personal account requiring a unique passcode provided by us. A personal account is required to view our app content, or to receive personal services such as newsletters and alerts.

If you create a personal login with us, we will store and process the following:

• Information (such as your email address) that is provided by registration;
• Information in connection with an account sign-in facility (e.g. log-in and password details);
• Communications sent by you (e.g. via e-mail or app communication forms).

The information that is required to access the app is labelled accordingly. All further information is provided voluntarily.

We will process the personal data you provide to:

• Identify you at sign-in;
• Provide you with the services and information offered through the app or which you request;
• Administer your account;
• Communicate with you;
• Market and profile;
• Provide access (where appropriate) to other NYU Langone Health content

We may use the personal data and contact data you provide to inform you about our additional products and services. You can object to the use of your personal data for such marketing at any time. You may opt-out of direct marketing via opt-out links in any marketing communication. You can also inform us about your objection by contacting our Data Protection Officer, using the contact information provided above.

Registration data will be maintained until such time as an account deletion request is made. If such a request is received, we will erase your data within 30 days. However, please be aware that statutory storage obligations or other legal requirements may result in longer retention of your personal data.

V. Specific registration requirements:

Newsletters

You can use your email address to consent to subscribe to our e-newsletters. These provide you with the latest news about our products and services. Your email address will be retained as long as you subscribe to our newsletters. You can unsubscribe from this service by opting out via the link provided in each newsletter.

VI. Automated decision making:

We do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you, however we may use your personal data to offer you other NYU Langone Health and Transplant Institute content and services which we believe may be of interest.

VII. Analytics:

For statistical analyses we use web analytics services such as Adobe Analytics, Google Analytics, Webtrekk, and Webtrends to collect information about the use of this app.

General tracking information

The tools collect information such as:

• Device and browser information (operating system information, Mobile device identifier, mobile operating system, etc.)
• IP address
• Page accessed, URL click stream (the chronological order of our internet sites you visited)
• Geographic location
• Time of visit
• Referring site, application, or service

We use the information we get from the providers only to determine the most useful information you are looking for, and to improve and optimize this app. We do not combine the information collected through the use of the tools with personal data.

Depending on the provider the information generated about your use of the app may be transferred to and processed in third countries. For further information about the potential risks of a cross border data transfer please refer to section XI. The tools collect only the IP address assigned to you on the date you visit this site, rather than your name or any other identifying information. The provider will use this information in order to evaluate your use of the app, to compile reports on app activities and to provide other services relating to app and internet use to us.

VIII. Third party content and social media plug-ins:

This app may contain links to other websites and apps, including third-party’s websites and apps. We are not responsible for the content and the data collection on respective third party sites; please check the privacy policy of respective sites for information of respective sites’ data processing activities.

IX. Information sharing:

We may disclose your personal data to contractors who assist us in providing the services we offer through the app. Such a transfer will be based on data processing agreements. Therefore, our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually bound to process your personal data only on our behalf and in compliance with our requests. Some of the recipients may reside outside the United States. For further information about cross border transfer in general and transfers outside of the United States see XI.

We may disclose anonymous aggregate statistics about users of the app in order to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personal data.

Some of the recipients described in this section X may reside outside the United States. For further information about cross-border transfer in general and transfers outside of the United States see XI.

We may disclose your personal data to contractors who assist us in providing the services we offer through the app. Such a transfer will be based on data processing agreements. Therefore, our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually bound to process your personal data only on our behalf and in compliance with our requests.

In the event that we undergo reorganization, any personal data we hold about you may be transferred to in compliance with applicable law.

We may disclose your personal data if legally required by law or by a court order.

X. Cross border data transfers:

Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries which may have different data protection standards from your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavor to take reasonable measures to maintain an adequate level of data protection when sharing your personal data with such countries.

XI. Security:

We have taken all reasonable security measures to protect against the loss, misuse and alteration of personal data under our control.

Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized personnel have access to personal data. While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our app or the NYU Langone Health website while it is in transit over the internet. Any such submission is at your own risk.

XII. Data retention:

We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.

XIII. Your rights to your personal data:

Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:

1. require (i) information as to whether your personal data is retained and (ii) access to and/or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods;
2. request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
3. refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;
4. object, on grounds relating to your particular situation, that your personal data shall be subject to a processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing;
5. take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators;
6. require (i) to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller; and/or
7. not to be subject to any automated decision making, including profiling (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or affects you with similar significance.

You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us using the contact details set out below.

XIV. Questions or Concerns-Data Protection Officer Contact:

Please submit any questions, concerns or comments you have about this privacy policy or your personal data and this app by email to our Data Protection Officer (peter.christensen@nyu.edu).

By registering for a user account and continuing to use this application, you are agreeing to the terms of this Privacy Policy. If you do not agree to its terms and wish to withdraw your consent for any of your personal information to be used for the purposes described below, please inform us about your objection by contacting our Data Protection Officer at:

XV. Amendments to this policy:

We reserve the right to change this policy, and other applicable NYU Langone Health policies and terms and conditions. This policy was last updated on October 24, 2018.