Privacy Policy

This Privacy Policy describes how the ACMA collects, uses, and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as “Personal Data”) and what choices you have around this activity. If you have any questions, please don't hesitate to contact us.

When we refer to “ACMA”, we mean Apotheker Group LLC or the Accreditation Council for Medical Affairs.

Table of Contents:

• Applicability of this Privacy Policy

  • This Privacy Policy applies to ACMA's online workplace productivity tools and platform, including the associated ACMA mobile and desktop applications (collectively, the “Services”), reportpharma.org, medicalaffairsspecialist.org, priorauthtraining.org, acmamarketplace.org, and any other ACMA websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with ACMA. If you do not agree with this Privacy Policy, then do not access or use the Services, Websites or any other aspect of ACMA's business. For the avoidance of doubt, this is the only privacy policy that applies to ACMA.

  • This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the ACMA platform (“Third-Party Services”), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of data such as messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Services (its “Workspace”) and any associated Customer Data.

  • California Notice of Collection of Personal Information: We collect the information described below under “Information We Collect and Receive” for the business and commercial purposes described below under “Information Use.” To learn more about exercising your California Privacy Rights please review the “California Privacy Rights” section below.

  Information We Collect and Receive

  • ACMA will collect and receive information through operating the Services and Websites, and through other interactions with ACMA. Such information will include Customer Data and other information and data (“Other Information”) in a variety of ways:

  • Customer Data. Customers or individuals granted access to an ACMA Workspace by a Customer (“Authorized Users”) routinely submit Customer Data (such as messages, files or other content submitted through Services accounts) to ACMA when using the Services.

  • Other Information. ACMA also collects, generates and/or receives the following categories of Other Information:

  Usage information:

  • Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way that an Authorized User uses the Services. For example, ACMA logs the people, features, content, and links you view or interact with, the types of files shared and what Third-Party Services are used (if any)

  • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, and your language preferences.

  • Device information. ACMA collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.

  • Location information. We receive information from you, our Customers and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localization or for security purposes.

  • Cookie information: ACMA uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out controls and other options, please visit our Cookie Policy.

  • Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services for its Workspace and ACMA can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations. ACMA may also develop and offer ACMA applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with ACMA. For example, if a cloud storage application you are using is enabled to permit files to be imported to a Workspace, we may receive the user name and email address of Authorized Users, along with additional information that the application makes available to ACMA to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to ACMA. When a Third-Party Service is enabled, ACMA is authorized to connect and access Other Information made available to ACMA in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including, by its Authorized User(s)). Examples of information which ACMA may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to ACMA usage activity. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services. For more information on ACMA's interaction with Third-Party Services, click here.

  • Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import (such as importing an address book to find coworkers and ACMA Connect contacts or calendar from a device or API), forward or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.

  • Third-Party data: ACMA may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

  • Audio and video metadata: ACMA may receive, capture, and store metadata derived from your use of certain features, and additional related data such as data regarding the date and time of your activity on an ACMA website.

  • Additional information provided to ACMA: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions you provide if you participate in a focus group, contest, activity or event, feedback you provide about our products or services, information you provide if you apply for a job with ACMA, enroll in a certification program or other educational program hosted by ACMA or a vendor, request support, interact with our social media accounts or otherwise communicate with ACMA.

  • Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

  How We Process Your Information and Our Legal Basis for Doing So

  • ACMA uses Other Information to operate our Services, Websites, and business. More specifically, ACMA uses Other Information for the following purposes:

    • Compliance With A Legal Obligation:

      ACMA processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement, or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.

      We use Workspace and account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, Audio and video metadata, and Additional information provided to ACMA for compliance with a legal obligation.

    • Legitimate Interests:

      We rely on our legitimate interests or the legitimate interests of a third party where they are not outweighed by your interests or fundamental rights and freedoms legitimate interests.

      We use Workspace and account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, Audio and video metadata, and Additional information provided to ACMA for the following legitimate interests:

      • To provide, update, maintain and protect our Services, Websites, and business. It is in our and your interests to provide, update, maintain and protect our Services, Websites, and business.

      • To develop and provide search, learning, and productivity tools and additional features. ACMA tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may:

        • Improve search functionality by using Other Information to help determine and rank the relevance of content, channels, or expertise to an Authorized User;

        • Make Services or Third-Party Service suggestions based on historical use and predictive models;

        • Identify organizational trends and insights;

        • Customize a Services experience; or

        • Create new productivity features and products.

      • It is in our interest and in the interest of Customers and Authorized Users to continuously improve and develop the customer support we provide.

      • To investigate and help prevent security issues and abuse. We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how ACMA is used or to prevent spam or abuse.

      • To aggregate or de-identify information. In some cases, we aggregate or de-identify information we have associated with you and use the resulting information, for example, to improve the Services.

      • It is in our interest to research and improve the Services; It is in the interests of Customers and Authorized Users to practice data minimization and privacy by design in respect of their information.

      • Share information with others including law enforcement and to respond to legal requests. It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of ACMA, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.

      • Transfer, store or process your information outside the European Economic Area. As the Websites and Services operate globally, with Customers around the world, we need to share information we collect globally. We may carry out necessary transfers outside the European Economic Area, and the United States, including to Australia, Canada, Japan, India, South Korea, the Middle East/North Africa Region, and South America, to provide, update, maintain and protect our Services, Websites, and business.

      • For more information, review the “International Data Transfers” section below.

      • In our and your interests to provide, update, maintain and protect our Services, Websites, and business. Third-Party Services Information, Third-Party data, and Additional information provided to ACMA for the following legitimate interests:

      • To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Other Information to respond. It is in our, our Customers' and Authorized Users' interests to facilitate communication (for example to answer questions from Customers).

      • To send service emails and other communications. For example, we may:

        • Send you service, technical and other administrative emails, messages, and other types of communications; or

        • Contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services, and you may not opt out of them. It is in our Customers' and Authorized Users' interests to address service-related issues.

      • For billing, account management, and other administrative matters. ACMA may need to contact you for invoicing, account management, and similar reasons, and we use account data to administer accounts and keep track of billing and payments.

      • To send marketing emails and other communications. We sometimes send emails about new product features, promotional communications, or other news about ACMA. These are marketing messages, so you can control whether you receive them. If you have additional questions about a message you have received from ACMA, please get in touch through the contact mechanisms described below. It is in our interest to promote the Websites and Services and send our direct marketing.

  How We Share and Disclose Information

  • This section describes how ACMA may share and disclose Information, as described in the section entitled 'Information We Collect and Receive' above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. ACMA does not control how a Customer or any third party chooses to share or disclose Information.

  • The Customer's Instructions. ACMA may share and disclose Information in accordance with a Customer's instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer's use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer's request may incur additional fees.

  • To enable ACMA to follow our Customers' instructions, ACMA provides several administrator controls to allow Customers to manage their account information. For example, we follow our Customers' instructions to enable or disable Authorized Users use of various features of the Services. We also follow Customer and Authorized User instructions on how an Authorized User's profile may be displayed or when shared through an ACMA Website or platform such as ACMA Insights or our Learning management system (LMS) or other features.

  • Customers may also provide their Authorized Users with the ability to adjust the audience and visibility of certain Customer Data.

  • Displaying the Services. When an Authorized User submits Information, it may be displayed or discoverable to other Authorized Users.

  • Customer access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information.

  • Third-Party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist ACMA with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common customers. In this respect, depending on the Third-Party service provided, ACMA may share your Information. Additional information about the subprocessors we use to support delivery of our Services is set forth at ACMA Subprocessors.

  • Third-Party Services. A Customer may enable, or permit Authorized Users to enable, Third-Party Services. We require each Third-Party Service provider to disclose all permissions for information accessible through the Services, but we do not guarantee that they do so. When Third-Party Services are enabled by a Customer or an Authorized User, ACMA may share Information with Third-Party Services. Third-Party Services are not owned or controlled by ACMA and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions.

  • Forums. The Information you choose to provide in a community forum including personal data will be publicly available.

  • Organizers and sponsors of Events/Webinars. If you attend an event or webinar organized by ACMA, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors' privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.

  • Professional advisers. We may share your Information with professional advisers acting as service providers, processors, controllers, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.

  • Corporate Affiliates. ACMA may share Information with our corporate affiliates, parents and/or subsidiaries.

  • During a Change to ACMA's Business. If ACMA engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of ACMA's assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive' section may be shared or transferred, subject to standard confidentiality arrangements.

  • Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.

  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of ACMA, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.

  • With Consent. ACMA may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy.

  Data Retention

  • ACMA will retain Customer Data in accordance with a Customer's instructions (including to perform any applicable terms in the Customer Agreement and through Customer's use of Services functionality) and as required by applicable law. Customers may customize its retention settings and, depending on the Services plan, apply those customized settings at the Workspace level, channel level or other level. The Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information. ACMA may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for ACMA to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

  Security

  • ACMA takes security of data very seriously. ACMA works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, ACMA cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don't control or endorse what is on third-party sites.

  Age Limitations

  • ACMA does not allow use of our Services and Websites by anyone younger than 18 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

  Changes to this Privacy Policy

  • ACMA may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, ACMA will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

  International Data Transfers

  • ACMA may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, ACMA will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with ACMA's obligations.

  • In particular, we offer the following safeguards if ACMA transfers Personal Data from jurisdictions with differing data protection laws:

  • European Commission's Standard Contractual Clauses. ACMA uses Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK where appropriate) for transfers to, among others, Australia, Canada, India, Japan, South Korea, and the United States. ACMA will transfer your Personal Data to facilitate the provision of the Services. A copy of our standard data processing addendum, incorporating the Standard Contractual Clauses, is available here, and a copy of the executed version of the Standard Contractual Clauses may be obtained by contacting us as described in the “Contacting ACMA” section below.

  Data Protection Officer

  • To communicate with our Data Team, please email info@acmainfo.org.

  Your Rights

  • Individuals in the European Economic Area, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct this information.

  • To the extent that ACMA's processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), ACMA primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us at info@acmainfo.org

  • In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. ACMA may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to ACMA's use of your Personal Data for this purpose at any time.

  Data Protection Officer

  • To communicate with our Data Team, please email info@acmainfo.org.

  California Privacy Rights

  • This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA,” as amended by the California Privacy Rights Act or “CPRA”.

  • California law requires that we detail the categories of personal information that we collect and disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in earlier sections of Privacy Policy.

  • In addition to the information provided above in the ‘Information We Collect And Receive' section, we collect the following categories of personal information from you, your employer, data analytics providers, data brokers, and Third-Party Services for our business purposes:

    • Identifiers/contact information;

    • Commercial information;

    • Internet or electronic network activity information;

    • Financial information;

    • Geolocation information;

    • Professional or employment-related information;

    • Audio and visual data;

    • In limited circumstances where allowed by law, information that may be protected under California or United States law; and

    • Inferences drawn from any of the above categories.

  • We collect this information for the business and commercial purposes described in the ‘How We Process your Information and our Legal Bases for Doing So' section above. We share this information as described in the ‘How We Share and Disclose Information' section above. ACMA does not sell the personal information we collect (and will not sell it without providing a right to opt out). We may also share personal information (in the form of identifiers and internet activity information) with third-party advertisers for purposes of targeting advertisements on non-ACMA websites, applications, and services.

  • In addition, we may allow third parties to collect personal information from our sites or services if those third parties are authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you use our sites or services to interact with third parties or direct us to disclose your personal information to third parties.

  • Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt-out of any “sales,” to know and opt out of sharing of personal information for delivering advertisements on non-ACMA websites, and to not be discriminated against for exercising these rights.

  • California consumers may make a request pursuant to their rights under the CCPA by contacting us at info@acmainfo.org. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents must submit proof of authorization.

  Data Protection Authority

  • Subject to applicable law, you also have the right to (i) restrict ACMA's use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner's Office

  Contacting the ACMA

  • Please also feel free to contact the ACMA if you have any questions about this Privacy Policy or ACMA's practices, or if you are seeking to exercise any of your statutory rights. The ACMA will respond within a reasonable timeframe. You may contact us at info@acmainfo.org or at our mailing address below:

  • For Customers and Authorized Users who use Workspaces established for Customers in the US and Canada:

  Apotheker Group, LLC

  700 Kinderkamack Road, Suite 204 Oradell, NJ 07649, United States