Last Updated: June 2023
This Privacy Notice ("Privacy Notice") sets out how Matthews Media Group (herein referred to as "MMG" , "we", "us" or "our") processes your personal data in connection with our business, including the provision of our website ("Site") and the services we offer ("Services").
In particular, this Privacy Notice explains our approach to any personal data that we might collect from you (i) when you use our Site or Services (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal data we collect, why we collected it and your rights in respect of our processing of your personal data).
This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Terms of Use.
Finally, this Privacy Notice is only intended to meet the requirements of:
For ease of reference, in this Privacy Notice we use the term “GDPR” to collectively refer to the EU GDPR, UK GDPR and Swiss Data Protection Laws.
Where other privacy laws (other than the GDPR) apply, please see our General Privacy Notice.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control).
Further, this Privacy Notice is not intended to cover the processing of workplace personal data.
This Privacy Notice only applies where the GDPR applies. Where other privacy laws apply, please see our General Privacy Notice.
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the 'Last Updated' date at the top of the page.
The Site and Services are made available by MMG.
MMG is USA corporation with the registered company name of Matthews Media Group Inc, with its registered office at 7361 Calhoun Place, Suite 140, Rockville, MD 20855.
For the purpose of Article 27 UK GDPR, our UK representative is DAS Europe Ltd, an English company with its registered office at 90-100 Southwark St, London SE1 0SW.
For the purpose of Article 27 EU GDPR, our EU representative is Diversified Agency Services B.V, a Netherlands company, with its registered office at Generaal Vetterstraat 82 (1059 BW) Amsterdam.
For the purpose of this Privacy Notice and the GDPR, unless we state otherwise, we shall be considered a data controller of your personal data in connection with use cases identified in this Privacy Notice. Please note that in many cases where we process data in relation to Services that we provide, we may carry out the activities referred to in this Privacy Notice in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Privacy Notice.
If you have any questions about this Privacy Notice or want to exercise 'your rights as a data subject' set out in this Privacy Notice, you can contact us using the following methods:
| Send us an email at: privacy@mmgct.com | |
| Post |
Write to us at:
Attn: Catherine Clarke, SVP Finance MMG 7361 Calhoun Place Suite 140 Rockville, MD 20855 USA |
| Telephone | (301) 984-7191 |
When we talk about personal data, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Categories of personal data we may collect and process about you include:
| Identity Data | First name; last name. |
|---|---|
| Contact Data | Delivery address; billing address; email address; telephone number; social media handle. |
| Applicant Data | Date of birth; gender; country; nationality; resumes; work experience; dietary requirements any other personal data that you may provide in advance of/during your supply of services to us. |
| Image Data | Photos; video recordings. |
| Financial Data | Bank account details; partial payment card details. |
| Transaction Data | Details about payments made between you and us; details of services purchased from us. |
| Profile Data | Interests and preferences; contact/marketing preferences; feedback and survey responses. |
| Health Data | Data relating to health and health interests; other information pertinent to the needs of the clinical trials conducted on behalf of our clients. |
| Behavioral Data | Data relating to your browsing activity, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any services you viewed or purchased through the Site. |
| Technical Data | IP address; browser type and operating system; geolocation, to ensure we're showing you the correct notices and information; any other unique numbers assigned to a device. |
| Publicly Available Data | Information about articles (or similar) that you may have published; information about your interests or affiliations or publicly stated positions on political matter, corporate matters and similar. |
For more information about the personal data we collect please refer to section 'How we use Personal Data' below.
We may collect and receive your personal data using different methods:
| Personal data you provide to us | You may give us your personal data directly, for example, when you when you participate in our surveys, questionnaires, or screeners, obtain services via our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us. |
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| Personal data we collect using cookies and other similar technologies | When you access and use our Site, we may collect certain Behavioral Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the 'Website insight and analysis' section below). |
| Personal data received from third parties | We may receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide our Site and our Services. |
| Publicly available personal data | From time to time, we may collect personal data about you (Identity Data, Contact Data, or Publicly Available Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms). |
We collect and process personal data from the following people:
| Site visitors | We will collect and process your personal data in connection with your interaction with us and our Site. |
|---|---|
| People who contact us with enquiries | If you contact us with an enquiry through our Site, submit a complaint or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Site. |
| Client personnel | We may collect and process your personal data in connection with the supply of services to you and/or your organization. |
| Partner/supplier personnel | If you (or your organization) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data. |
| Visitors to our offices or other locations | If you attend one of our physical offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when signing in as a guest, or when you register for and access our guest Wi-Fi network at our premises. CCTV footage may also be collected for security purposes. |
| Questionnaire / Screener participants | If you participate in our questionnaires/surveys, we will process personal information about you in connection with your participation. For example, we may process your contact information in order to you refer you to clinical site conducting a clinical trial for which you have indicated an interest. |
| Job applicants | If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application. |
| Members of the public | We may process your data in connection with the provision of the Services to our clients. |
A: OPERATION OF SITE, PROVISION OF SERVICES AND MARKETING
I. Operation of the Site
If you browse our Site
When you browse our Site, we may collect and process Behavioral Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site.
Website insight and analysis
We and our third-party partners might use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as "Cookies") to collect data from the devices that you use to access our Site. The data that is collected could include Behavioral Data and Technical Data, and certain Profile Data. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use this data to analyze how you use our Site and our Services and the effectiveness of our Site and Services, including:
Our legal basis for processing
Where your data is collected through the use of cookies that are not strictly necessary, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of performance cookies to analyze how you use our Site, it is in our legitimate interest to use your personal data in such a way to improve our Site and Services.
If you use the interactive features on our Site
We will collect and use personal data about you when you use certain features on our Site. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data, Registration Data, Profile Data and certain Behavioural Data and Technical Data when you use the Enquiry Form or Chat function to get in touch with us or other account holders, or so that you can be searched for by other account holders.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Site in a secure and effective way and make improvements to our Site.
If you link to social media sites and interact with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any 'like' or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the ' Website insight and analysis' section below.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy notice of the relevant social media platform.
Our legal basis for processing
It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Site in an effective way and to promote our Site via social media.
II. Provision of our Services
Clinical Trial Recruitment
Acting on behalf of our clients, we collect personal information (including the types of personal information we set out in Section 6 ' Types of personal information we collect/process about you') to determine if there are clinical studies or health-related news and information that match your areas of medical interest. You provide this information to us when you complete our questionnaires/screeners, and you are asked to give your consent when we collect this information. Where you have been identified as potentially eligible for a clinical trial, your contact information is shared with the clinical site conducting the clinical trial for which you have indicated an interest.
Our legal basis for processing
Our legal basis for processing data for clinical trial recruitment is consent. You provide this information to us when you complete our questionnaires/screeners. You will be asked to give your consent when we collect this information.
Clinical Trial Management
Acting on behalf of our clients, we collect and store contact information of research centre staff and other study personnel so that we may contact them for the purposes of providing recruitment and retention support, and for shipping materials to them.
Our legal basis for processing
Our legal basis for processing: it is in our legitimate interests (and those of our clients) to process personal data in this way to ensure that we provide the services requested by our clients.
Social media
We may collect or process individuals' personal data (including Contact Data, Identity Data and some Profile and Publicly Available Data) who engage with us through our social media channels (including by visiting our social media pages or otherwise communicating with us via social media).
Our legal basis for processing
It is in our legitimate interests to process personal data in this way so that we can market ourselves and engage with the public.
III. Marketing and Media Enquiries
Marketing
We may use your Identity Data, Contact Data and Profile Data to send you (or the organization you represent) marketing communications by email or via phone. Our marketing will include press releases and information about us
Our legal basis for processing
It is in our legitimate interest to use your personal data in this way to ensure the promotion of our services is tailored and/or appealing to you and/or the organization you work for although sometimes we may also obtain your consent.
B: BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL
Receipt of services
If we have engaged an organization to provide us or our client with services (for example, IT support or financial advice), we will collect and process your personal data (including Contact and Identity Data) if you are a contact within the relevant organization in order to manage our relationship or our clients with the organization, to receive services from the organization and, where relevant, to provide our services to others including our clients.
Our legal basis for processing
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the organization, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with the organization and are able to provide our services to others in an effective way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Business administration, finance, and legal compliance
We may use an individual's personal data (including Identity Data, Contact Data, Financial Data, Transaction Data, Publicly Available Data) for the following business administration and legal compliance purposes:
Our legal basis for processing
Where we use personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we will rely on our obligation to comply with law (including any court order) to process such personal data.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with the individual's explicit consent.
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data that we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
Further (again subject to the above) we may share your personal data with third parties as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
| Our Clients | We may share personal data with our clients for the purposes of providing them with Services. |
| Our specialist suppliers/partners | We use various specialist suppliers including external subject matter experts and/or partners in order to provide our services. |
| Research Centres & Clinical Sites | We may share personal information with research centres and clinical sites in connection with the screening services we provide to our clients |
| Third-party IT suppliers | We may share personal data with third parties who support us in providing our Site and help provide, run, and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We may also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice. |
| Payment providers and banks | We may share personal data with third parties who assist us with our invoicing and/or making/receiving payments. |
| Third-party post/email marketing and CRM specialists | We may share personal data with specialist suppliers who assist us in managing our marketing database and sending out email marketing communications. |
| Recruitment agencies and related organizations | We may share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies for recruitment purposes |
| Auditors, lawyers, accountants and other professional advisers | We may share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in. |
| Law enforcement or other government and regulatory agencies and bodies | We may share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation. |
| Other third parties | Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. |
Transfers by us – where we disclose personal data
We may transmit personal data to certain third parties (as listed in the 'Sharing your personal data' section) that are located in countries that do not protect personal data to the same standard as the GDPR, including to Omnicom Group entities, networks or partner agencies.
These countries may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data.
However, when transferring your personal data, we will ensure that, where required by the GDPR, at least one of the following applies: (1) we will only transfer your personal data to countries or organisations that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission; or (2) we may use specific contracts approved by the UK Government or the European Commission referred to as the “Standard Contractual Clauses” or “SSCs” which give personal data the same protection it has in the UK and EU.
To find out more about the SCCs we use, please see: Standard contractual clauses for international transfers | European Commission (europa.eu) or please email us at: privacy@mmgct.com.
In addition, where we disclose personal data that we process in connection with our participation in the EU-U.S. Data Privacy Framework the UK Extension to that framework and/or Swiss-U.S. Data Privacy Framework, we remain liable under those frameworks in relation to our onward transfer of personal data to these countries, unless we can show that we are not responsible for the event giving rise to the damage.
Transfers to us – where we receive personal data
As Matthews Media Group Inc. is located in the United States, any data that you provide directly to us, or that is received from third parties, may be stored in the USA. In addition, it may be transferred by us to other countries (as described above).
Matthews Media Group Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Matthews Media Group Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Matthews Media Group Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/ .
Where our use of your personal data requires your consent, you can provide such consent:
Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services.
You have the following rights in relation to the personal data we hold about you under certain circumstances:
Data Subject Rights
Data subjects may exercise these rights verbally or in writing using our contact information provided in the ' How to contact us' section. We will endeavour to promptly respond to your requests. Where you ask us to provide a copy of your personal data we are legally obliged to respond within one month of such request. If your request is denied, we will inform you about the reasons for denial.
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
Lodging complaints
In addition, you may have the right to lodge certain complaints in relation to our processing of your personal data with regulators in your jurisdiction.
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, we encourage you to first contact us using our contact information provided in the 'how to contact us' section.
If the GDPR applies, you can report your concerns to the following organisations:
| European Economic Area | You can find a list of supervisory authorities and their contact details for the EEA at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm |
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| United Kingdom | The Information Commissioner’s Office ("ICO") is the supervisory authority in the United Kingdom. Contact details for the ICO can be found at https://ico.org.uk . |
| United States of America |
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Matthews Media Group
Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.{' '}
If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. Following the dispute resolution process, JAMS or you may refer the matter to the U.S. Federal Trade Commission, which has investigatory and enforcement powers over us. Under certain circumstances, you also may be able to invoke binding arbitration to address complaints about our compliance with DPF Principles. |
To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled 'how to contact us' above.
This Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal data with such third party.
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website's or third-party service provider's own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
We retain personal data only for as long as is necessary for the purposes described in this Privacy Notice, after which it is deleted from our systems.
If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate, we may keep your information for a short period.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.
Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, due to the nature of our organization and the Services we provide, we may from time-to-time collect and process personal data relating to minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
For clinical studies conducted within the United States, we do not allow persons younger than 18 to provide information about themselves. We require a parent or a caregiver to answer screening questions for them and act as the primary contact. We collect parent/caregiver contact information in addition to the name of the person younger than 18. This information is also held in accordance with this privacy policy.
Trials conducted outside of the United States in the field of paediatrics will be managed in accordance with those laws and policies of the specific country involved and with approval from the relevant review board.
