NAS Recruitment Innovation Business Associate Privacy Policy

Introduction

This Business Associate Privacy Policy (the “Policy”) describes how NAS Recruitment Innovation (“NAS”, “We”, Us”) uses Personal information relating to the personnel or representatives (“Representatives”) of our clients, suppliers and other entities with whom we have entered, or may enter, business transactions (“Business Associates”). This Policy describes how we may obtain Representatives’ personal information, the types of personal information we may obtain, how we use, share and protect the personal information, the rights of Representatives with respect to their personal information, and how to contact us about our privacy practices.

Changes and updates to the Privacy Policy

We reserve the right to amend the Privacy Policy and Terms of Use at any time, without notice to you other than the posting of the amended Privacy Policy and Terms of Use at this Site.

We may e-mail periodic reminders of our policy and terms and will e-mail Representatives of material changes to it, but you should check our Site frequently to see the current Privacy Policy and Terms of Use that are in effect and any changes that may have been made to them.

This Policy was last revised on June 28, 2024.

About NAS Recruitment Innovation

NAS Recruitment Innovation (NAS) is part of the M3 Group and builds and hosts individually branded career-related websites on behalf of hiring organizations that combine proprietary SaaS job search functionality (ACTIVATE) with career site content and Media strategy and support.

About the M3 Group

The M3 Group, named to represent Medicine, Media, and Metamorphosis, was founded with the goal of changing the world of medicine through full use of the power of the Internet.

The M3 Group is comprised of affiliated companies owned by M3, Inc., a publicly traded company on the Tokyo Stock Exchange (jp:2413) with subsidiaries in major markets including USA, Europe, Japan, South Korea, and China. The M3 Group provides services to healthcare and the life science industry, including market research, medical education, ethical drug promotion, clinical development, job recruitment, and clinic appointment services.

The types of personal information we may obtain and process

NAS obtains personal information of Representatives that is disclosed or otherwise processed by NAS upon entering and performing agreements, communicating with Business Associates in relation to agreements and making and receiving payments under agreements. We also may obtain Representatives’ personal information from public sources in anticipation of a prospective business relationship.

We use a variety of public sources to collate information about potential Business Associates we believe may be suitable for our services. We may also receive a referral from one of your colleagues and process that information in a similar way. Personal information is any information that allows an individual (in this case, the Representative) to be identified.
We may process the following types of personal information about Representatives:

Names, postal or e-mail addresses, and phone numbers
Employment information (e.g., job titles) relating to Representatives
Communication preferences

As a matter of practice, we will not collect any sensitive (special category) personal information relating to Representatives. To the extent that there is a need for us to process sensitive personal information, we will obtain the Representative’s prior written consent.

Purpose and legal basis for processing your personal information

This data is used to manage our contact with you, so that, for example, multiple attempts to contact you regarding the same services are eliminated or you are not re-contacted after informing us you are not interested in our services. We also use it as we generate lists of potential Business Associates to contact.

We process personal information based on our legitimate interest (i.e. we have a valid business reason) and we have carefully balanced your individual rights against this need.

We will only process your personal information for the purpose it was first collected. If we process the personal information for a new purpose, we will ensure it is either compatible with your original purpose or gain your consent.

How we use the Personal information we obtain

We may use the personal information we obtain about Representatives to:

Manage our existing and prospective Business Associates relationships;
Communicate with Representatives for marketing, newsletters and company updates (for example, services we offer or intend to offer in connection with our services);
Perform accounting, auditing, billing, and collection activities;
Safeguard and defend NAS interests; and
Comply with applicable legal requirements, industry standards and our policies.

How we may share Personal information:

NAS does not sell, rent, or trade Representatives’ personal information. We may share your personal information only with:

Affiliates of NAS to whom it is reasonably necessary or desirable for NAS to disclose the personal information;
Service providers / business support partners that NAS has retained to perform services on its behalf, such as, but not limited to, IT service providers, consultants, advisors, and/or vendors; and
Law enforcement and other government authorities if required by law or reasonably necessary to protect the rights, property, and safety of others or us. This includes lawful requests by public authorities, including to meet national security or law enforcement requirements.

Links to other websites

Our website may contain links to other websites. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting other websites and these other websites are not governed by this privacy policy. You should exercise caution and look at the privacy statement applicable to the website in question.

International Data Transfers

NAS endeavours to apply suitable safeguards to protect the privacy and security of your personal information and to use it only in ways that are consistent with your relationship with NAS and the practices described in this Privacy Policy.

NAS has its headquarters in the USA and personal information we collect from you may be processed in the USA.

NAS may need to share, transfer, store, or otherwise process your Personal Data in locations outside of the jurisdiction in which you reside or are located. When we transfer Personal Data, we do so in accordance with applicable laws.

How we protect Personal information

We maintain appropriate technical and organizational security safeguards designed to protect Representatives’ personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use. We update and test our security technology on an ongoing basis. We limit access to your personal information to those employees who need access to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your personal information.

How long we retain Personal information

We store Representatives’ personal information for as long as necessary to fulfil the purposes for which we collect the data (see “How We Use the Personal information We Obtain”), except if required otherwise by law.

Where Personal Information is used for more than one purpose, we will retain the Personal Information until the purpose with the longest retention period expires.

Your Rights

Under data protection laws, you may be able to exercise certain rights including:

Access: The right to request access to your Personal information that is processed by NAS;
Correct: The right to request personal information to be updated and corrected, or completed if incomplete;
Erase: The right to request your personal information to be deleted. Where we have legal requirements to retain information, we will confirm this.
Object or Restrict: The right to object to or restrict our processing of your Personal Data, which includes opting out from marketing communications or restricting the processing of personal information to only certain activities.
Data Portability: The right to data portability which means you request to have your Personal Data transmitted from us to another controller;
Withdraw Consent: When Personal Data processing is based on your consent, you have the right to withdraw consent at any time; and
Automated decision making: To opt out of processing of personal information used for solely automated decision making.

To exercise your rights, you can write the Data Protection Officer at dataprotection@nasrecruitment.com

Cookies and Tracking Technologies

You may disable certain cookies and tracking technologies at any time by adjusting your browser settings or by using the cookies pop up on the Site. Please be aware, however, that if you disable cookies, you may not be able to take full advantage of all our Site features.

Contact Information

NAS is headquartered in Ohio in the USA. NAS has appointed an internal data protection officer for you to contact if you have any questions, requests, concerns or complaints please send an email to dataprotection@nasrecruitment.com or alternative contact details are:

Address: NAS Recruitment Innovation
6133 Rockside Road, Suite 302
Independence, OH 44131
United States

Supplementary California Privacy Policy

This notice supplements the information contained in the main NAS Privacy set forth above and applies solely to residents of the State of California to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

Our California Privacy Policy is intended to fulfil CCPA’s objectives of providing California consumers with a comprehensive disclosure of the collection, sharing, disclosure, and sale of their personal information (as CCPA defines those terms), and of the rights that California consumers have regarding their personal information (“California Privacy Rights”).

California Privacy Rights Under CCPA

a. Right to know about Personal Information collected, disclosed or sold (“Right to Know”)
CCPA provides you the right to request that we disclose to you any or all of the following about your personal information for the 12-month period preceding your request:

the specific pieces of personal information that we have collected about you;
the categories of personal information we have collected about you;
the categories of sources from which we have collected your personal information;
the categories of personal information that we have sold or disclosed for a business purpose about you;
the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
the business purpose for collecting or selling your personal information.

b. Right to have Personal Information deleted (“Right to Delete”)

You have the right to request the deletion of your personal information that we collect or maintain.

If you exercise your Right to Delete, we will, in the manner specified by CCPA, permanently delete your personal information from our records, unless one of the CCPA exceptions applies to your deletion request applies.

Also, to the extent required by CCPA, we will direct deletion of your personal information by third parties with whom we have shared the personal information that you have requested that we delete.

Exceptions to your Right To Delete include, but are not limited to, instances when the personal information is necessary to complete a transaction or provide the service requested by you for which the subject personal information was collected or provided, detect security incidents or protect against deceptive, fraudulent, or illegal activity, or to comply with a legal obligation under CCPA, the California Electronic Communications Privacy Act, or other California or US federal law.

c. Right to Opt-Out of the Sale of Personal Information (“Right to Opt-Out”)

Under CCPA, you also have the right to opt-out of the “sale” (as defined by CCPA) by a CCPA-subject business of your personal information to third parties. You may exercise this right by contacted us via email dataprotection@nasrecruitment.com

Right to Not Be Discriminated Against for Exercising Your California Privacy Rights (“Right to Non-Discrimination”)

You have the right to not receive discriminatory treatment if and when you exercise any of your California Privacy Rights under CCPA. This would include, as examples, imposing a penalty fee or denying services to you because you exercised a CCPA right. We will never penalize or otherwise subject you to discriminatory treatment for exercising any of your California Privacy Rights.

Information we may collect
We may collected personal information as described in Section 4 of the main policy (“The types of personal information we may obtain and process”)

Use and disclosure of Personal Information
We may use and disclose your personal information as described in section 6 (“How we use the Personal Information we obtain”) and clause 7 (“How we may share Personal information”)

Personal information we have collected over the past twelve months

*Third Parties refers to the following persons or entities with whom we may obtain from or share personal information for business purposes:

a. Business Support Consultants (examples include our consultants, advisors, and/or vendors who help us by (as examples only): (a) preventing fraud or violations of our Terms of Service; (b) analyzing site user data and behavior, and tracking page performance; (c) identifying site issues and repair errors that impair intended functionality; (d) providing marketing and survey panel recruitment assistance, such as moderators and translators; (e) providing customer service to our Site users; (f) providing CCPA-required and other verifications of consumers or consumer consent; and/or (g) providing data storage and/or data processing services.

b. Business Partners (examples include NAS Affiliate companies, clients, prospective clients and their representatives who may engage us to provide Services);
c. Public Authorities (examples include law enforcement and other government authorities if required by law or reasonably necessary to protect the rights, property, and safety of others or ourselves)

d. Public records (examples include publicly accessible websites)

** Business Purposes for Collecting Personal Information: NAS will only collect and use your personal information for the following business purposes listed below:

I. Providing you with the services and support that you may request, and processing and validating your transactions;
II. Communicating with you about your account or transactions, changes to our policies and other administrative matters, or responding to your questions and comments;
III. Understanding better your interests in order to provide you with customized job opportunities and other content;
IV. Administering and improving all of our products, services and operations;
V. Ensuring compliance with our policies and Website Terms and Condition, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others;
VI. Complying with our legal and regulatory requirements; and
VII. Providing you with information regarding NAS Services.

Collection of Personal Information of Minor Children
NAS Does not Collect, Use, Disclose or Sell Personal Information of Minor Children and does not offer Services designed for, intended to attract, or directed towards children under the age of 18. If we become aware of personal information unknowingly collected about minors under the age of 18, we will immediately and permanently delete it.

Exercising Your California Privacy Rights
In order to exercise any of your rights, or if you have questions or concerns about your rights under our California Privacy Policy, or any of the provisions or practices described in this Privacy Policy, please contact us via the telephone number, e-mail address, or mail/courier address provided above.

By Webform: please complete the form below which you may either send electronically, or print out and mail to us at our address below:
NAS CCPA Request form.doc
By E-mail: dataprotection@nasrecruitment.com (please put “California Privacy Request” in the subject line)
By Mail or Courier:
NAS Recruitment Innovation
6133 Rockside Road, Suite 302
Independence, OH 44131
United States

Only you, or a person (or a business entity registered with the California Secretary of State) whom you have authorized to act on your behalf may make a consumer request about your personal information. Consistent with CCPA’s provisions, we may require either (or both) that you provide your authorized agent with written permission to act for you and verify your own identity to us (or provide a power of attorney signed by you stating your authorized agent’s power to act for you).¹

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¹For information on preparing a Power of Attorney, see Cal. Probate Code §§ 4000-4465 (“Powers of Attorney”), here: http://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCode=PROB&division=4.5.&title=&part=&chapter=&article=