PRIVACY NOTICE FOR VIRGINIA RESIDENTS
Last updated [08/05/2024]
This Privacy Notice for Virginia Residents (this “Privacy Notice”) is intended to supplement our Privacy Policy and applies only to Virginia residents. Any terms defined in the MJH Privacy Policy have the same meaning when used in this Privacy Notice.
Application
Pursuant to the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents have the right to be informed about the data we collect about them. This Privacy Notice applies solely to natural persons who are Virginia residents, as defined in the VCDPA. Please note that this Privacy Notice does not apply to Virginia residents who are acting as employees or job applicants. Any terms defined in the VCDPA have the same meaning when used in this Privacy Notice.
Categories of Personal Data We Collect
The VCDPA defines “Personal Data” as “any information that is linked or reasonably linkable to an identified or identifiable natural person.” Personal Data does not include de-identified data or publicly available data. Below are the categories of Personal Data that we may have collected, used, and disclosed for a business purpose, as permitted by law, in the last twelve (12) months, depending on the Services you receive:
|
Category |
Examples May Include |
Collected |
|
A. Identifiers |
your name, postal address, unique personal identifier, online identifier, email address, and telephone number |
Yes |
|
B. Customer Records Personal Information Categories |
Name, signature, address, telephone number, education, employment |
Yes |
|
C. Protected Classification Characteristics |
gender, age |
Yes |
|
D. Commercial Information |
products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
Yes |
|
E. Biometric information |
Not applicable |
No |
|
F. Internet or other electronic network activity information |
Browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement |
Yes |
|
G. Geolocation data |
City and state location of your device |
Yes |
|
H. Sensory Data |
Audio, electronic, visual, thermal, olfactory, or similar information |
No |
|
I. Professional or Employment-related Information |
employer, job title, occupation, practice type/specialty, year of school graduation, professional provider number |
Yes |
|
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades or transcripts |
Yes |
|
K. Inferences drawn from other personal information collected |
Inferences drawn from the information we collect when you visit our Sites, reflecting your preferences, predispositions, etc. |
Yes |
|
L. Sensitive Personal Information |
1. Personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; 2. The processing of genetic or biometric data for the purpose of uniquely identifying a natural person; 3. The personal data collected from a known child; or 4. Precise geolocation data.” |
No |
Sources from which We Collect Personal Data
The following are categories of sources from which we may receive your Personal Data:
- directly from you when you inquire about our services via our Site, by telephone, or in person;
- directly from you when you complete the registration process required by certain services that we offer;
- from public online forums where you share information with other users;
- from market research studies and surveys sponsored by us or other third parties;
- directly from you when you participate in Continuing Medical Education (CME) or a Continuing Education (CE) activity through the Site;
- from information collected through third party advertisements;
- from information collected through the use of cookies, web beacons, and other tracking technologies within our Site and third party advertisements on our Site; and
- from third parties that assist us in providing relevant services.
Business or Commercial Purposes for which We Collect Personal Data
We may collect the Personal Data listed above for the following business or commercial purposes:
- To respond to your questions;
- To confirm or fulfill purchase and/or registration requests;
- To provide to you the services, subscriptions, or information you requested;
- To send you information about third party services through pop-ups, banners and emails;
- To target advertising and marketing communication to your interests and geographic location;
- To conduct and administer tests, surveys, sweepstakes, competitions and/or similar promotions;
- To contact you regarding CME/CE activities, news, or other resources and to advise you of products or services that may be available;
- To display content we think may be of interest to you and customize your visit to the Site and with communications;
- To notify you about website maintenance, updates, and new features;
- To contact you as needed to inform you of updates to or to address a suspected violation of our Terms of Use, Privacy Policy, or any other rules or policies applicable to the Site;
- To send and manage educational outcomes measurement surveys;
- To get your feedback to assess user-satisfaction or other needs and interests;
- To perform information analysis, compliance audits, and data metrics;
- To evaluate the use and the effectiveness of the Services that we offer which can include the effectiveness of content, advertising or programs;
- To help us create new tools, features, and services and improve our Sites, content, and Services;
- To perform security and integrity tasks, including detecting security incidents and protecting against malicious or illegal activity;
- To provide required reporting on CME/CE activity to the appropriate monitoring bodies and involved CME/CE providers;
- To study our CME/CE activities for effectiveness and understand educational needs;
- To maintain archival records of your participation for historical and research purposes, subject to retention limits imposed by applicable laws;
- To comply with applicable laws, rules, or regulations in operating our business; and
- Otherwise in rendering, administering, and improving the Site, our Services, and our business.
Disclosure of Personal Data for Our Business or Commercial Purposes
We have disclosed the following categories of Personal Data for business or commercial purposes in the preceding twelve (12) months to the following categories of third parties:
|
Categories of Third Parties to Whom Personal Data Was Disclosed for a Business or Commercial Purpose |
Categories of Personal Data Disclosed for a Commercial Purpose |
Business or Commercial Purpose for Disclosing Personal Data |
|
Service providers or contractors |
Identifiers, Professional or Employment-related Information, Geolocation data |
To help facilitate, manage, and/or analyze our Services (including web servers, cloud storage systems and service providers, support teams, web analysis, and others) |
|
Subsidiaries and affiliates |
Identifiers, Professional or Employment-related Information, Geolocation data |
To operate our business and provide Services |
|
Third parties authorized by law to receive Personal Data |
Identifiers, Professional or Employment-related Information, Sensory Data, Protected Classification Characteristics, Sensitive Personal Information |
To comply with applicable legal requirements |
|
Third parties involved in business transfers |
Identifiers, Professional or Employment-related Information, Geolocation data |
For example, for a corporate merger, acquisition, consolidation, the sale of substantially all of our assets, or other fundamental corporate change, whatever form it may take |
|
Market research sponsors |
Identifiers, Professional or Employment-related Information, Geolocation data, Non-public education information |
When you consent to participate in a market study or survey |
|
Current or prospective advertisers, sponsors, and other business partners |
Identifiers, Professional or Employment-related Information, Geolocation data, Non-public education information |
For marketing purposes |
|
Accreditors of our continuing education programs |
Identifiers, Professional or Employment-related Information, Geolocation data, Non-public education information |
To maintain our continuing education programs |
|
Third parties to whom you or your agents request or authorize us to disclose your Personal Data in connection with products or services we provide to you. |
All categories of Personal Data listed above, depending upon the request and/or authorization |
To operate our business and provide Services |
Sale of Personal Data & Processing for Targeted Advertising
Subject to certain limited exceptions, the VCDPA defines the “sale of personal data” as “the exchange of personal data for monetary consideration” by MJH to a third party.
In the preceding twelve (12) months, we have “sold” Personal Data to third parties and/or processed Personal Data for targeted advertising, as set forth below.
You have the right to opt out of the sale or sharing of your Personal Data. You may exercise this right by visiting the Do Not Sell or Share My Personal Information Opt-out form available here.
|
Categories of Personal Data “Sold” or Processed for Targeted Advertising |
Business or Commercial Purpose for Selling or Processing for Targeted Advertising |
Categories of Third Parties to Whom Personal Data Was Sold or Processed for Targeted Advertising |
|
Identifiers |
List matching, contract fulfillment, system requirements |
Data brokers, clients |
|
Internet or other electronic network activity information |
List matching, contract fulfillment, system requirements |
Data brokers, clients |
|
Geolocation data |
List matching, contract fulfillment, system requirements |
Data brokers, clients |
|
Professional or Employment-related Information |
List matching, contract fulfillment, system requirements |
Data brokers, clients |
|
Inferences drawn from other personal information collected |
Contract fulfillment, system requirements |
Data brokers, clients |
|
Non-public education information |
Contract fulfillment |
Clients |
Consumers under 16 Years of Age
MJH does not intentionally collect, sell, or process for targeted advertising the Personal Data of consumers under 16 years of age.
Data Retention
We retain Personal Data about you necessary to fulfill the purpose for which that information was collected, consistent with applicable laws. When we destroy your Personal Data, we do so in a secure manner in compliance with applicable laws, such that the Personal Data may not be reconstructed.
My Rights under the VCDPA
If you are a Virginia resident, you may exercise certain privacy rights related to the Personal Data we collect about you. You may exercise these rights free of charge, except as otherwise permitted under applicable law.
- Right to Confirm Processing and Access Personal Data
You have the right to request that we confirm whether we are actually processing your Personal Data and to access such Personal Data. You have the right to submit such a request, free of charge, up to twice annually, except as otherwise permitted under applicable law.
- Right to Obtain Copy of Personal Data
You have the right to obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another business without hindrance, where the processing is carried out by automated means. You have the right to submit such a request, free of charge, up to twice annually, except as otherwise permitted under applicable law.
- Right to Deletion of Personal Data
You have the right to request that we delete your Personal Data, subject to certain limited exceptions. For example, we may deny your request to delete Personal Data that we are required to maintain to fulfill a legal obligation.
- Right to Correct Inaccurate Personal Data
You have the right to request that we correct inaccurate Personal Data that we maintain about you.
- Right to Opt-out of Targeted Advertising or Sale of Personal Data
You have the right to opt-out of the processing of Personal Data for the purposes of: (1) targeted advertising or the (2) sale of Personal Data. You may submit such a request here.
- Right to Appeal
If we deny your request to access, delete, correct, or opt-out, you have the right to appeal such decision by submitting your request to appeal by contacting us as set forth below. Within sixty (60) days of our receipt of your appeal request, we will inform you of any action taken or not taken in response to the appeal, including an explanation of the reasons for the decisions.
If your appeal is denied, you have the right to submit a complaint to the Virginia Attorney General. To file a complaint with the Virginia Attorney General, please visit: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
- Right to Non-Discrimination
We will not discriminate or retaliate against you for exercising your consumer rights under the VCDPA, including by (a) denying you goods or services; (b) charging (or suggesting that we will charge) different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or (c) providing you a different level or quality of goods or services (or suggesting that we will do so). We may, however, offer a different price, rate, level, or quality of goods or services if that price or difference is reasonably related to the value provided to us by your data.
How to Submit a Request
You may submit your request to access, delete, or correct Personal Data collected about you, or to appeal a denial of your request, by contacting us at 1 (800) 598-6115, by email at Info@MJHPrivacy.com, or by visiting https://www.mjhlifesciences.com/contact/.
You may submit your request to opt-out of the processing of Personal Data for the purposes of: (1) targeted advertising or (2) sale of Personal Data here.
Verification of Identity and Processing of Requests
As required or permitted under applicable law, we may take steps to verify your identity before processing your request as set forth above. In order for your request to be processed, you must provide us with enough information to reasonably verify you are the person about whom we collected Personal Data or an authorized representative of that person. We will confirm receipt of your request within 10 business days and provide information about how we will process your request. We will review each request carefully and respond to most requests within 45 calendar days if we are able to verify your identity based on the information you have provided; however, we may extend this time period once by an additional 45 calendar days when reasonably necessary, provided that we provide you with notice of this extension.
Agent Authorization
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as set forth in this Notice. Even if you choose to use an agent, as permitted by law, we may require you to confirm that you have authorized the agent to act on your behalf or require you to verify your own identity.
Questions or Concerns?
If you have any questions, you may contact us at 1 (800) 598-6115, by email at Info@MJHPrivacy.com, or by visiting https://www.mjhlifesciences.com/contact/.