What Information Is Collected and How
The information collected by FHI 360 from and about Site users may (“User Information”) include:
- Contact information, such as your name, postal address, email address, telephone number, social media account names or other online identifiers, etc.
- Other information about you and your activities and areas of interest, such as location information; the identity of your employer or organization; your gender, age and other demographic data.
- Information about your Site usage, such as time and date of visits, frequency of visits, pages viewed, resources downloaded and information about your Site usage and resource requests.
- Information about the devices and Internet connections you use to access or use the Site, such as device type, operating system, browser type, domain, IP address, and system settings for language, time zone, etc.
User Information is collected:
- Directly from you when you provide it through your use of the Site or your communications with the Site or BTE program staff; examples include activities such as signing up for a Site account, filling out surveys or questionnaires, submitting a search query on the Site, submitting questions via the form on the “Contact Us” page of the Site, and sending or receiving emails.
- Automatically as you navigate through the site, through your browser and the use of browser cookies, Flash cookies, pixel tags, web beacons and other tracking technologies, which allows us to store information about your connection and preferences and make your use of the site easier and more customized.
How User Information Can Be Used
FHI 360 can use User Information for any of the following purposes:
- Operating, administering, developing and improving the Site and the BTE Program, including, but not limited to, providing information, resources, services and other support to Site users, and facilitating effective operation of local BTE programs.
- Responding to Site user questions and feedback, resolving user technical issues, and communicating with users about the Site and the BTE program.
- Tracking and monitoring Site usage for purposes of quality control, technical maintenance, and improving design and functionality.
- For data analysis, research, auditing, compliance, reporting, or publication purposes, in connection with the BTE program or any other FHI 360 program, or for any other FHI 360 business purpose.
- For other purposes for which you give FHI 360 your consent, or as otherwise required or permitted by law.
When User Information Can Be Shared With Third Parties
Some User Information is considered “Personal Information” because it either specifically identifies you, or could be used either alone or in combination with other information FHI 360 has to identify or contact you. Contact information, such as name, phone number and email address, is a common example. FHI 360 will only disclose Personal Information to third parties as follows:
- To J&J, to the extent necessary to fulfill any reporting, communication, publication or similar obligations FHI 360 may owe to J&J under any agreements between them relating to the BTE program.
- To local BTE program staff or participants, to the extent necessary for you to participate as desired in the BTE program or for the productive and efficient administration and operation of the BTE program or local BTE program.
- To FHI 360 affiliates, contractors and services providers who provide business services to FHI 360 in connection with or relating to the Site or the BTE program, subject to an obligation to protect the Personal Information and use it only for the purpose of providing services to FHI 360.
- As needed in order for FHI 360 to perform internal corporate governance, operational or administrative functions, or for auditing or compliance purposes and program administration functions, for auditing or compliance purposes, or in order to combat fraud or criminal activity.
- To a buyer or other successor of FHI 360 in the event of a merger or acquisition of the company or substantially all of its assets.
- In response to a subpoena or similar legal process from law enforcement agencies, regulatory agencies or courts.
- As needed where FHI 360 believes it is necessary or appropriate to do so in order to protect the rights, property, or safety of FHI 360, J&J, local BTE programs, or their respective employees, customers and program participants, or in connection with legal proceedings involving or affecting FHI 360, J&J, or any local BTE program.
- To other parties and for other purposes for which you give us your consent, or as otherwise required or permitted by law.
These restrictions and limitations don’t apply to disclosure of User Information that does not qualify as Personal Information. FHI 360 can share that information with the parties identified above or with any other third party for any permissible purpose under this Policy.
Choices About Use and Disclosure of Your Information
If you object to FHI 360’s use or disclosure of your information as set forth in this policy, you should refrain from accessing or using the Site, or limit the information you provide (although some information is required for proper Site operation and this could render the Site inoperable interfere with Site functions). You can adjust security and privacy settings on your computer, mobile device, browsers, and other applications to manage how cookies and other tracking mechanisms are handled. Refer to the instructions provided by your device manufacturer or service provider for details.
You can ask to access, correct or delete any Personal Information you have provided to us by submitting a request via the addresses provided in the “Contact Information” section below. We will try to comply with your request as soon as reasonably practicable. We may decline to change any Personal Information if we believe doing so would violate applicable law.
Cross Border Transfer
Your Personal Information may be stored and processed in any country where FHI 360 has facilities or service providers, and by using our Site or providing consent to us (where required by law), you agree to the transfer of your Personal Information to countries outside your country of residence, including to the United States, which may provide for different data protection than the rules in your country.
California Privacy Rights
Under California Civil Code Section § 1798.83, California residents may request certain information about the types of information that companies with whom they have an established business relationship have disclosed to third parties for direct marketing purposes in the last calendar year, and the names and addresses of those third parties. To request this information, please contact us via the email or postal address in the “Contact Information” section below.
We use commercially reasonable organizational and technical measures to protect the Personal Information disclosed on or through the Site under our control from unauthorized access, use, or disclosure. While we consider these measures adequate, no data storage system or Internet data transmission method is 100% secure and there is still some with the Site has been compromised, please contact us immediately.
Minors and Sensitive Information
This Site is not intended for children under 13 years of age, and use of the Site by children under 13 is prohibited. By using the Site, you represent that you are at least 18 years old.
No one should disclose any sensitive Personal Information, such as information related to race, ethnicity, religion, health, or criminal background, on or through this Site, or otherwise send any such information to us.
Changes To This Policy