Effective date: June 29, 2018
At Cohen Veterans Bioscience (“us”, “we”, or “our”), we value your trust and we understand the importance of protecting your privacy. We are committed to protecting your information. This Privacy Statement describes what information we collect about you, including when and how we collect it; how we use it; with whom we may share it; and what choices you have regarding your use. This Privacy Statement is applicable to all Cohen Veterans Bioscience websites and event registrations and other services (collectively, the “Services”) where we post or link to this Privacy Statement, as well as information we automatically collect from your online visits (e.g. data collected via cookies). Cohen Veterans Bioscience operates the https://cohenveteransbioscience.org website and other related websites (the “Service”).
This Privacy Statement informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. This Privacy Statement does not apply to the privacy practices of any other third party websites that may be accessible from our website.
For purposes of this Privacy Statement, personal data or personal information means any information that, by itself, can identify you or can be combined with other information to identify you.
This Privacy Statement describes our privacy practices and will cover the following topics:
- What types of personal information we collect about and from you
- How we collect personal information about you
- How we may use your personal information and what choices you have about how we treat your information
- With whom we may share your personal information
- Other information collected
- Our data security protections and how we protect your privacy
- Your privacy options and access rights
- Notices and Disclosures
- How to contact us
- Updates to this privacy statement
“Services” encompasses the https://cohenveteransbioscience.org and all related websites owned and operated by Cohen Veterans Bioscience.
- Personal Data
For the purposes of this Privacy Statement, “Personal Information” or Personal Data means any information that, by itself, can identify you or can be combined with other information to identify you.
- Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or tablet or mobile device). Cohen Veterans Bioscience uses “cookies” on its websites to enable you to sign in to our services and personalize your online experience. This small data file is stored on your hard drive. By using cookies, the information you previously provided can be retrieved on your next visit to our website(s) so that your use of the website is more efficient.
- Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
- Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively. In some cases and for some data we may act as a Service Provider as well.
- Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). The type of information we collect on you will depend on how you choose to interact with us. Personally identifiable information may include contact information and demographic information, and may include, but is not limited to:
- Email addresses
- First name and last names
- Phone numbers
- Mailing address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
- Company or Organization including location
- Emergency contact info
- Preferred formatting data
We may also collect information about your personal or professional areas of interest.
We may use your Personal Data to register you for an event or to contact you with newsletters, education materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Research Participation Data
If you inquire about or enroll in a research study, we may collect information from you related to the study or studies, which may include health information. Research participant data will always be maintained in a secure, fully compliant, restricted environment that is accessed only for research purposes.
We may also collect information about how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Browser and Device Data
Certain device data may be automatically collected by your browser or device such as your MAC address, computer type, screen resolution, operating system and version, device manufacturer and model, internet browser and version. This information, when available, is used to ensure proper operation and function of our Services.
Tracking & Cookies Data
Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use the IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used, such as beacons, internet tags, and scripts, to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Cookies are typically either session-based (which disappear after you close your browser) or persistent (which remain on your computer after you close your browser or turn off your computer). Cohen Veterans Bioscience may use any of the following types or categories of cookies:
- Required Cookies are essential to core website functionality.
- Performance cookies are collect information about website visits to improve performance, but do not collect personal information.
- Functional or Preference cookies are used to keep track of your preferences and various settings and track your preferences, such as your preferred language or display settings, and customize the website to you. Some of these cookies may be required.
- Analytics Cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our websites and our communications campaigns.
- Security Cookies are for security purposes.
You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.
If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. This web site may be partially or completely inaccessible or not function properly.
Some of our websites web pages may now or in the future use web beacons in conjunction with cookies to compile aggregate statistics about website usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of the Website. Some web beacons may be unusable if you elect to reject their associated cookies.
Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera Mobile
For other browsers, please consult the documentation that your browser manufacturer provides.
Information from other sources
We may also obtain information about you from other sources and combine that with information we collect through our Services. For example, we may aggregate your personal information with information that you make publicly available to better communicate with you but only in a way that you prefer and consent too.
We may collect information about you from event registration, fundraising and other public sources.
Based on how you connect with us over social media, your social media account may collect information about you. Your interactions with social media companies are governed by their privacy policies.
We respect your right to make choices about the ways we collect, use, and disclose your Personal Information. Discussed above are choices you have about delivery of cookies to your computer through our websites. In addition, we generally will ask you to indicate your choices at the time we collect your Personal Information. For example, we provide you with an opportunity to “opt out” of receiving certain communications from us. In addition, we will include an “unsubscribe” link in each email we send you, so that you can inform us that you do not wish to receive such communications from us in the future.
You may change previously expressed preferences regarding how we use your Personal Information. If at any time you wish to be taken off our mailing lists, please contact us using the information provided above . Once we have the information we need, we will remove you from our mailing lists as you have requested. Please give us a reasonable amount of time to honor your request.
Use of your Data
This section covers how we may use your personal information. Cohen Veterans Bioscience will use your personal information to respond to your inquiries and to provide you with the information, resources and support services you request. We will use your information to better understand the community we serve and to evaluate and improve our communication programs. Specifically we will use your information to:
- To notify you about changes to our Service.
- To provide security and fraud protection for our Services.
- To allow you to participate in interactive features of our Service when you choose to do so.
- To provide you customer support.
- To gather analysis or valuable information so that we can improve our service, mission delivery and support.
- To monitor the usage of our Service including usage trends, audits, performance monitoring and delivery.
- To detect, prevent and address technical issues.
- To provide you with news, and general information about services and events which we offer or that you have enquired about unless you have opted not to receive such information.
We may disclose your personal information to reputable vendors. They will always be restricted from using any information for any purpose other than helping us provide services.
Legal or lawful Basis for Processing Personal Data (Including Under General Data Protection Regulation GDPR)
If you are in the European Union, that is you are from the European Economic Area (EEA), we will collect and use your personal data only if we have one or more legal or lawful bases for doing so under the GDPR. The legal bases depend on your interaction with us and our sites. This means we collect and use your personal data only where: you have given your consent for one or more specific purposes (1) It is necessary to perform a contract we are about to enter into or have entered into with you (2) It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (3) it is necessary to protect the vital interests of you or another natural person (4) or it is necessary to comply with a legal obligation.
Where we are relying on your consent as the legal basis, we will notify you and seek additional consent before using your personal data for a new purpose that is inconsistent with the original purpose for which we collected it. You have the right to withdraw or decline your consent at any time. Where we rely on legitimate interest you have the right to object.
Cohen Veterans Bioscience legitimate interest is in providing its websites and making the Services available to you, provided our interest is not outweighed by the risk of harm to your rights and freedoms. Cohen Veterans Bioscience may process your Personal Data because:
- We need to execute and perform a legally binding contract with you
- You have given us permission consent to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- To comply with law
Your Personal Information may be shared with third part service providers that provide operational services on our behalf (such as web site hosting, information technology and infrastructure, data analytics, email delivery, auditing or other services) or assist us in providing you with support an resources.
We may provide your information to our affiliated organizations that share a common mission.
Retention of Data
Cohen Veterans Bioscience will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Countries where we process data may have laws which are different and potentially not as protective, as the laws of your own country.
If you are located outside United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to the United States and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Cohen Veterans Bioscience may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Cohen Veterans Bioscience may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Cohen Veterans Bioscience
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Except as described above, Cohen Veterans Bioscience will not disclose your personal information to third parties for their own marketing purposes without your consent.
Security of Data
Cohen Veterans Bioscience takes all reasonable steps to protect your information from loss, misuse, unauthorized access or disclosure, alteration or destruction, including through the use of encryption when collecting or transferring sensitive data. The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We work hard to protect your personal information. We use both technical and procedural methods to maintain the integrity and security of our databases. Our websites contain links to other websites operated by third parties. They may be of interest to you. We cannot control these third party sites. They may collect personal information from you. When you follow a link and leave our websites, you do so at your own risk.
“Do Not Track” Signals
Do Not Track (DNT) is a preference you can set in some web browsers to inform websites that you do not want to be tracked. You can enable or disable this feature, Do Not Track (DNT), by visiting the preferences or settings page of your web browser. Web browsers incorporate and activate this functionality in different ways, and user intent is not always clear.
Certain browsers like Internet Explorer, Firefox and Safari offer a “Do Not Track” or “DNT” option that sends a signal to websites visited by the user about the user’s browser DNT preference setting.
Uniform standards for “Do Not Track” have not been established, Cohen Veterans Bioscience websites and our Service does not process or respond to “Do Not Track” signals.
There currently is disagreement, including among participants in leading Internet standards-setting organizations, concerning what, if anything, websites should do when they receive such signals.
Our websites currently do not take action in response to these signals, but, if and when a standard is established and accepted, we may reassess how to respond to these signals.
Your Data Protection Rights including Rights Under the General Data Protection Regulation (GDPR)
Pursuant to the EU General Data Protection Regulation, natural persons (called data subjects) located in the European Economic Area (EEA) are afforded certain rights regarding their personal data, including the right access, correct, delete, restrict or object to our use of, and receive a portable copy in a usable electronic format of your personal data. You also may have the right withdraw any consent that you have previously provided to us and to lodge a complaint with your local data protection or privacy regulator.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
The scope of these GDPR data protection rights include:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Cohen Veterans Bioscience relied on your consent to process your personal information.
To the extent provided by applicable laws (including the GDPR), you also may have the right to have the data or content deactivated, blocked, anonymized, or deleted, as appropriate, request and receive a copy of the personal data you have provided us and to transmit this data to a third party, and lodge a complaint with the applicable data protection authority. To exercise any of these rights that you are not able to do directly, please contact us.
If you would like to exercise any of the above rights, and the law of your jurisdiction requires us to honor that request, please send your request in writing to the address below. To assist us in processing your request in timely manner, please make your request in English if you are able to do so. Your request should include any information relevant to your request, including, without limitation: (i) your name, email and postal address; (ii) the specific right you are asserting (e.g., removal); and (iii) if you are requesting removal, a brief explanation of why you believe such information should be removed.
Please note that we may ask you to verify your identity before responding to such requests.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Links to Other Sites and third party websites
This Privacy Statement does not apply to, and Cohen Veterans Bioscience is not responsible for, the privacy practices or the content of such third-party websites, including business partner websites. Their use of personal information will be governed by their own privacy policies.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Minors and Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. We will not knowingly collect information from website visitors in this age group. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our Services .
Your continued use of this website and the continued use of the our Services following these changes means that you accept such changes and any revised Privacy Statement.
- By email: firstname.lastname@example.org
- By visiting this page on our website: https://www.cohenveteransbioscience.org/contact-us/
- By mail:
- Cohen Veterans Bioscience
1 Broadway, 14th Floor
Cambridge, MA 02142
Attention: Chief Privacy Officer
- Cohen Veterans Bioscience
Security Breach or Fraud Notification.
If you witness or become aware of any suspected privacy or security breach of data (i.e., mishandling, theft, loss, or improper disclosure of personal information) or potentially fraudulent activity, please report within 24 hours.