Privacy and Security Policy

Privacy and Security

PathPresenter (“PathPresenter”) is committed to protecting your personal information. This statement explains our practices for this Web site.

What Personal Information We Gather

We gather personal information that we need to know when you ask us to do something for you. For example, if you ask us to send you our newsletter, we need to know and store your email address. We will always ask for your permission and tell you how we’re going to use your personal information first. You can always choose not to provide it.

How We Use It

We only use the personal information we gather for purposes that you have agreed to, for example, to send you a newsletter. We do not collect personal information about any of our site’s visitors unless the visitor authorizes us to do so.

Legal Basis for Processing Personal Information

PathPresenter processes personal information based on applicable data protection laws and relies on different legal bases depending on the nature and purpose of the processing.

Consent

Where required, PathPresenter relies on consent for specific processing activities, such as when you choose to subscribe to newsletters or receive certain communications. You may withdraw your consent at any time by contacting us.

Contractual Necessity

PathPresenter may process personal information where processing is necessary to provide requested products and services, manage customer relationships, support users, and fulfill contractual obligations.

Legal Obligations

PathPresenter may process or disclose personal information where required to comply with applicable laws, regulations, legal processes, or lawful requests from authorities.

Legitimate Interests

PathPresenter may rely on legitimate interests where processing is necessary for purposes that support the operation, security, and improvement of our business and services, and where those interests are not overridden by an individual’s privacy rights.

Examples of legitimate interests include:

• maintaining and improving the security, reliability, and performance of our systems and services;
• managing customer relationships and responding to inquiries;
• preventing fraud, misuse, security threats, and unauthorized access;
• managing business operations and service providers that support PathPresenter’s services; and
• protecting PathPresenter’s legal rights and business interests.

Before relying on legitimate interests, PathPresenter considers the impact of the processing on individuals and ensures that appropriate safeguards are implemented.

Who Has Access to It

Only people within PathPresenter who need to access your personal information can access it; for example, the people who send a newsletter need to know your email address.

How We Share It

We do not sell or provide your personal information to any third parties.

We might share your personal information under the following circumstances:

• We have your consent.
• We are required to share customer information by law, to protect the interests of the company or in the discharge of public duty.
• We need to share your personal information with a business partner in order to provide a service you have requested. Our business partner’s use of your information is restricted to the delivery of the service you have requested.

How You Change or Remove It

You have the ability to change your personal information that we retain. We try to keep your personal information accurate and up to date. If you’d like to change or remove your personal information, please contact us at privacy@pathpresenter.com

Data Controller

PathPresenter Inc. is the data controller for personal data processed through our website, customer interactions, account management activities, and other business operations.

For questions regarding the processing of personal data or this Privacy Policy, please contact: Email: privacy@pathpresenter.com

Data Protection Officer

PathPresenter has appointed a Data Protection Officer to oversee data protection compliance and act as a point of contact for privacy-related matters.

Data Protection Officer: Brian Matcheski
Email: brian@pathpresenter.com

EU and UK Representatives

Where required under applicable data protection laws, PathPresenter has appointed representatives in the European Union and the United Kingdom to act as points of contact for data protection matters.

European Union Representative

Under Article 27 of the General Data Protection Regulation (GDPR), PathPresenter has appointed an EU Representative:

• Instant EU GDPR Representative Ltd.
  Adam Brogden | Email: contact@gdprlocal.com | T: +35 3155 49700
• Office 2, 12A Lower Main Street, Lucan, Co. Dublin, |K78 X5P8, Ireland

United Kingdom Representative

Under the UK General Data Protection Regulation (UK GDPR), PathPresenter has appointed a UK Representative:

• GDPR Local Ltd.
  Adam Brogden | Email: contact@gdprlocal.com | T: +44 1772 217800
  1st Floor Front Suite, 27-29 North Street, Brighton, England

Our Data Protection Responsibilities

PathPresenter is committed to protecting personal data and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR), where applicable. Depending on the nature of the processing activity, PathPresenter may act as either a data controller or a data processor.

PathPresenter as a Data Controller

PathPresenter acts as a data controller when it determines the purposes and means of processing personal data for its own business activities. This may include processing related to:

• managing customer and user accounts;
• responding to inquiries and providing customer support;
• managing business relationships;
• operating and improving our website, products, and services;
• fulfilling legal, regulatory, security, and contractual obligations.

When acting as a controller, PathPresenter is responsible for ensuring that personal data is processed lawfully, fairly, and transparently. PathPresenter maintains appropriate technical and organizational measures to protect personal data, provides transparency regarding its processing activities, supports applicable data subject rights, and maintains appropriate records and documentation as required by applicable data protection laws.

PathPresenter as a Data Processor

For customer clinical data processed through the PathPresenter Clinical Viewer, PathPresenter generally acts as a data processor on behalf of healthcare organizations and other customers who act as the data controllers.

In this role, PathPresenter processes personal data only in accordance with documented instructions from the customer, including applicable agreements governing the use of the PathPresenter platform. Customers remain responsible for determining the purposes for which clinical data is processed, including decisions regarding patient care, access permissions, retention requirements, and applicable legal bases.

As a processor, PathPresenter is responsible for:

• processing personal data only as instructed by the customer;
• implementing appropriate technical and organizational safeguards to protect personal data;
• maintaining confidentiality and limiting access to authorized personnel;
• supporting customers in meeting applicable data protection obligations;
• maintaining appropriate records of processing activities where required;
• notifying customers of applicable personal data breaches in accordance with contractual and legal requirements; and
• ensuring that approved subprocessors are appropriately managed.

PathPresenter does not determine the purposes of clinical data processing performed by healthcare organizations and does not use customer clinical data for independent purposes unrelated to providing the contracted services.

Shared Commitment to Data Protection

PathPresenter regularly reviews its privacy and security practices to ensure appropriate protection of personal data and to support compliance with applicable data protection requirements.

Security

We use security measures to safeguard your personal information.

All the personal information you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access.

We control access so that only people who need to access the information can. All staff of PathPresenter are required to adhere to a confidentiality agreement.

Credit Cards

We do accept credit card payments for registrations. If someone uses your credit card to make an unauthorized purchase, check with the institution that issued your card to find out what the exact liability is.

Email

If you send us an email, we may save it if we think we’ll need it to communicate with you. We never sell or share email addresses. Remember, email is not a secure way to send personal information because it is not encrypted. Please don’t send any personal information to us using email.

Cookies

Our Web site stores information in a small text file, called a cookie, on your computer. We use what is called a “persistent cookie,” which is stored as a file on your computer and remains there when you close your Web browser. The cookie can only be read by the Web site that created it when you visit that site again.

Our Use of Cookies

PathPresenter stores a unique number (not any personal information) in the cookie that we place on your computer. We use this cookie to determine if you have visited the site before, and to ensure you are only prompted once to fill in certain forms such as our newsletter form. The information we store in the cookie does not include data such as your name, company, email address, telephone number, state/province, country.

Note: If you do not allow cookies to be saved on your computer, you will not be able to download information from this site.

Security Concerns

Once the cookie is saved on your computer, our Web site is the only site that can access and read the information that you provide. PathPresenter will not provide this information to any third parties or use it for sending unsolicited email.

Java and Javascript

Java is a language that allows different kinds of computers to talk to each other. We use Java technology to provide functionality such as navigation menus and forms. You will still be able to use this Web site if you have Java or Javascript disabled, but some functionality may not be available.

Changes to this Statement

We may amend this privacy and security statement. If we make any substantial changes in the way we use your personal information, we will notify you by posting a prominent announcement on this Web site.