Primo 121 Privacy Policy

Your Privacy Matters

Primo121’s mission is to connect primary care professionals to allow them to be more productive and successful. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy Policy applies when you use our Services (described below).

Table of Contents:

• Introduction
• Data We Collect
• How We Use Your Data
• How We Share Information
• Your Choices & Obligations
• Other Important Information

We are a social network and online platform for primary care professionals. People use our Services to connect with others, find and be found for business opportunities, and find information. Our Privacy Policy applies to any Member or Visitor to our Services

Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and develop skills, and find business and career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”).

We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

 

Data Controllers and Contracting Parties

Primo121 is open to UK professionals currently. Primo121 will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

Primo121 (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

1. Data We Collect

1.1 Data You Provide To Us

You provide data to create an account with us.

Registration

To create an account you need to provide data including your name, email address and/or mobile number, and a password. Access is via an nhs.net email account to help ensure members are linked to the NHS, and protect the site from individuals for whom this site is not designed for.

You create your profile (a complete profile helps you get the most from our Services).

Profile

You have choices about the information on your profile, such as your area of work, skills, photo and clinical interests. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.2 Data From Others

Others may post or write about you.

Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. We also may collect public information about you, such as professional-related news and accomplishments, and make it available as part of our Services, including, as permitted by your settings, in notifications to others of mentions in the news.

1.3 Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, or share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies and Similar Technologies

We can collect data through cookies and similar technologies.

You can opt out from our use of data from cookies and similar technologies that track your behaviour on the sites of others for ad targeting and other ad-related purposes.

1.5 Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services.

1.7 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.

2.1 Services

Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive.

We use your data to authorize access to our Services and honour your settings.

Stay Connected

Our Services allow you to stay in touch and up to date with other professional contacts.

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your network and basic profile information (e.g., name, profile photo, job title, region).

Visitors have choices about how we use their data.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain members on our site, or suggest related learning content to help you towards that new skill. We use your content, activity and other data, including your name and photo, to provide notices to your network and others.

 

2.2 Communications

We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.

You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

2.3 Advertising

We may serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

• Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
• Member-provided information (e.g., profile, contact information, title and industry);
• Data from your use of our
• Information inferred from data described above

 

Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you.

2.4Marketing

We promote our Services to you and others.

In addition to advertising our Services, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services.

2.5 Developing Services and Research

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other.

Other Research

We seek to help Members of the workforce and to be more productive and successful. We use the personal data available to us to research social, economic and workplace trends. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish insights, presented as aggregated data rather than personal data.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.6 Customer Support

We use data to help you and fix problems.

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

2.7 Insights That Do Not Identify You

We use data to generate insights that do not identify you.

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.

2.9 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members,Visitors or others.

3. How We Share Information

3.1 Our Services

Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.

Profile

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines).

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

• When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
• In a network, posts are visible to others in the network. Your membership in networks is public and part of your profile.
• Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
• We let senders know when you act on their message, subject to your settings where applicable.
• When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

3.2 Communication Archival

Regulated Members may need to store communications outside of our Service.

Some Members (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by and to those Members outside of our Services.

3.3 Others’ Services

You may be able to link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile may also appear on the services of others.

Subject to your settings, other services may look up your profile. If you opt to link your account with other services, personal data will become available to them. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.

“Old” profile information remains on these services until they update their data cache with changes you made to your profile.

3.4 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.5 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Primo121, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.6 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

For personal data that we have about you, you can:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

4.3 Account Closure

We keep some of your data even after you close your account.

If you choose to close your account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, or prevent fraud and abuse. We will retain de-personalized information after your account has been closed.

Information you have shared with others will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches.

We implement security safeguards designed to protect your data. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you and “legitimate interests”.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer.

5.3. Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

5.5. Contact Information

You can contact us to resolve any complaints.