Privacy Policy - Allymar Health AI

Allymar Health Privacy Statement

Unless stated otherwise, this privacy statement applies to all of Allymar’s externally facing services, tools, websites and other data processing activities where Allymar is acting as a data controller (or any local equivalent).

This page and its sub-pages tell you everything you need to know about how CPF MIB, LLC d/b/a Allymar Health Solutions and/or its affiliates, subsidiaries and newly acquired companies ("Allymar"; "we") protect the personal data we process and control relating to you (“your personal data”; "your data") and which rights you have in relation to the processing of your personal data.

Below, we first give a general description of how Allymar protects your personal data. Further below, we also include specific information on the following:

How do we use personal data when you visit Allymar’s website?
How do we use cookies (and other tracking technologies)?
How do we use personal data when you visit our offices?
How do we use personal data for marketing purposes?

1. How does Allymar protect your personal data?

Allymar attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with Allymar, your personal data are in good hands.

Allymar protects your personal data in accordance with applicable laws and our data privacy policies. In addition, Allymar maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The following sections provide further details as to how Allymar processes your personal data:

Which categories of personal data do we collect and how do we process such personal data?
For which purposes and on which legal basis do we use your personal data?
Will we share your personal data with third parties?
What about sensitive data?
What about data security?
Where will your personal data be processed?
How long will your personal data be retained by us?
Which rights do you have with respect to the processing of your personal data?

Which categories of personal data do we collect and how do we process such personal data?

We collect personal data of our employees, potential employees, clients and their current/former/prospective employees/directors, suppliers, business contacts, shareholders and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.

The personal data we collect includes the categories of personal data described in the sections “How do we use personal data when you visit Allymar’s website?”, “How do we use cookies (and other tracking technologies)?”, “How do we use personal data when you visit our offices?” and “How do we use personal data for marketing purposes?”, as well as any other categories of personal data referred to in this privacy statement or in other statements you have received.

Below is also a chart describing the categories of personal data we collect:

Category of personal information	Types of personal information captured by category
Personal details, contact details, and identifiers.	Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address) and occasionally, when necessary for specific purposes, gender, date of birth, age, place of birth.
Commercial information.	History and records of the products and services you have obtained from Allymar. Correspondence between you and us when it is sent to a dedicated mailbox or via other electronic communication means (including communication channels supported by AI that – for example - generates content to assist our personnel when interacting with you), for the purpose of processing account receivable payments and commercial follow-up.
Marketing and research information	1. Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address 2. Demographic data - (e.g. income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers) 3. Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system. 4. Social media content – blogs, posts and anything posted by an individual online or which mentioned/references an individual 5. Analytics and profiles of the individuals based on the data collected on them 6. Voice-enabled services (Speech-to-Text engines for search requests) without being recorded or stored by the mobile device.
Sensitive data and biometric information.	Allymar may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status/access requirements and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication.
Audiovisual materials, including transcriptions.	Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security/monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions), voice search functionality to enable a voice command feature that allows you to ask a question and see results (functionality enabled for mobile applications only), and/or audio video recording and transcription during meetings.
Position and professional or employment-related information.	Professional or employment-related information, such as description of current position, job title, employer, location, and Allymar contact(s).
System and application access data and Internet and electronic network activity information.	Where you are provided with access to Allymar’s systems, Allymar may collect information required to access such Allymar systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using Allymar systems.
Cookies and geolocation data	As described below, we also may collect geolocation data in some circumstances. Please see our Cookies Policy for more details regarding our use of cookies.

We also may derive inferences about you based on the information described above and also collect other information about you as described in this privacy statement. If you provide us with personal information of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with Allymar.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, clients and vendors. Except where certain information is required by law or by Allymar policies (including management of an employment relationship with Allymar), your decision to provide any personal data to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

For which purposes and on which legal basis do we use your personal data?

Allymar uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which Allymar uses your personal data and (ii) an overview of the legal basis for each such purpose.

Purpose	Legal basis
Managing our contractual and/or employment relationship with you.	Necessary for the performance of a contract to which you are a party.
Facilitating communication with you, which may include AI-powered support capabilities (including facilitating meetings, meeting recaps, email suggested content, communication in case of emergencies, and to provide you with requested information).	Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations including or being part of the provision of our services to our clients and their employees/contractors and their customers, for example in collecting their data as part of surveys/assessments/psychometrics, data analytics, Marketing research or other purposes.	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements.	Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).	Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Social listening (Identifying and assessing what is being said about Allymar and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)	Justified on the basis of our legitimate interest of protecting our assets and our brand on social media
Improving the security and functioning of our website, networks and information.	Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within Allymar and/or to provide a better user experience, including the use of AI (e.g., machine learning). This includes marketing analytics and analytics related to the organization of events/meetings. (more details on how we run analytics on our website can be found in our cookies policy).	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below).	Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Audio, video and transcription captured during live/recorded events and meetings (including virtual events/webinars) to inform interested stakeholders about the content of such events/meetings (including online publication of recordings for marketing purposes).	Based on your informed consent obtained prior to the event/meeting.
Specific Recruitment/Employment Purposes	Legal basis
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.	Justified on the basis of Allymar’s legitimate interests of ensuring that it recruits the appropriate employees.
Manage your application.	Justified on the basis of Allymar’s legitimate interests of ensuring that it recruits the appropriate employees.
Facilitate communication with you.	Justified on the basis of Allymar’s legitimate interests of ensuring proper communication within the organization and with you.
Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Allymar and how to attract and keep top talent.	Justified on the basis of Allymar’s legitimate interests of ensuring that it continually improves its recruitment processes.
In some cases, record your online interview for review by additional recruiters and hiring managers.	Justified on the basis of Allymar’s legitimate interests of ensuring that it recruits the appropriate employees.

Legitimate interest means that Allymar has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact Allymar’s Privacy Officer.

We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal information, only where such consent is required by mandatory law.

We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Will we share your personal data with third parties?

We may transfer personal data to our service providers and professional advisors, public and governmental authorities, Allymar companies/affiliates or third parties in connection with Allymar’s operation of its business, including any (potential) corporate or commercial transaction and including clients if the data has been processed to provide client services. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and Allymar’s internal policies.

For example, we may disclose personal information to third parties for other business purposes as follows:

We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
To protect and defend the legal rights, safety, and security of Allymar, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.

We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

What about sensitive data?

We do not generally seek to collect sensitive data as defined in the second paragraph through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

What about data security?

We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.

What are the sources we get your personal information from?

If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), Allymar employees, contractors, (prospective) members of board of directors, shareholders, Allymar’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, our clients, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).

In section 4, you can find more information on the sources of your personal information for marketing purposes.

How long will your personal data be retained by us?

We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
We will only keep the data while your account is active or for as long as needed to provide services to you.
We retain your data for as long as needed in order to comply with our global legal and contractual obligations.

Which rights do you have with respect to the processing of your personal data?

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
Object to the processing of your personal data: this right entitles you to request that Allymar no longer processes your personal data.
Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
Request the restriction of the processing of your personal data: this right entitles you to request that Allymar only processes your personal data in limited circumstances, including with your consent.
Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Allymar, or request Allymar to transmit such personal data to another data controller.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Allymar’s Data Privacy Officer. Please note that this will not affect Allymar’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to Allymar first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Allymar with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

2. How do we use personal data when you visit Allymar’s website?

In addition to the information set out above, the following sections describe how we use personal data when you visit Allymar’s website:

Which personal data do we gather?
Do we include (links to) websites and programs of third parties?
How do we use personal data that we collect from our websites?

Which personal data do we gather?

Allymar collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website's technology).

We may collect and process the following personal data:

Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.
If you contact us, we may keep a record of that correspondence.
We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Any postings, comments or other content that you upload or post to an Allymar website.
Our website or mobile applications can collect personal information about your computer or your mobile device, including (where available) your IP address, operating system, type of device, device identification number, mobile operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the section below for more information.

Do we include (links to) websites and programs of third parties?

Our websites may include:

Links to and from the sites of our partner networks, advertisers and affiliates
Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

How do we use personal data that we collect from our websites?

We use personal data for the purposes described in the section “For which purposes and on which legal basis do we use your personal data?” above, as well as to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected. For example:

Links to and from the sites of our partner networks, advertisers and affiliates.
Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section  below for more information.

3. How do we use cookies (and other tracking technologies)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

Please see our Cookies policy for more details.

4. How do we use personal data for marketing purposes?

In addition to the information set out above, the following sections describe how we use personal data for marketing purposes:

What are the sources of marketing data?
Do we send targeted e-mails?
Do we send push notifications?
Do we maintain Customer Relationship Management (CRM) databases?
Do we combine and analyze personal data?
Do we share personal data with third parties?
What are your rights regarding marketing communications?

What are the sources of marketing data?

The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.

Do we send targeted e-mails?

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Allymar, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from Allymar may include additional data privacy information, as required by applicable laws.

Do we maintain Customer Relationship Management (CRM) databases?

Like most companies, Allymar uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Allymar professionals based on their personal interactions with you.

Do we combine and analyze personal data?

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites such as our careers and corporate sites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn and Xing). We combine this data to better assess your experience with Allymar and to perform the other activities described throughout our privacy policy.

Do we share personal data with third parties?

In addition to the third parties mentioned in the section “Will we share your personal data with third parties?" above, we may share your personal data with marketing agencies.

What are your rights regarding marketing communications?

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

5. Contact us

Please contact us at PrivacyOfficer@allymarhealth.com regarding the information below if:

You have a general question about how Allymar protects your personal data.
You wish to exercise your rights in relation to your personal data rights (as set out in the sections “Which rights do you have with respect to the processing of your personal data?” and “Your rights regarding marketing communications”).
You wish to make a complaint about Allymar’s use of your data.

Allymar Privacy Statement for California Residents

This privacy statement is effective as of August 1, 2024. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal information or any changes in applicable laws. If you are not a California resident, this privacy statement does not apply to you. Please visit the Allymar Privacy Statement for more information.

This Allymar Privacy Statement for California Residents applies to California residents whose personal information is processed by CPF MIB, LLC d/b/a Allymar Health Solutions and/or its affiliates, subsidiaries and newly acquired companies ("Allymar"; "we") pursuant to the California Consumer Privacy Act (“CCPA”), including how we protect the personal information we process and control relating to you (“your personal information”; "your information") and which rights you have in relation to the processing of your personal information.

Below, we first give a general description of how Allymar protects your personal information. Further below, we also include specific information on the following:

How do we use personal data when you visit Allymar’s website?
How do we use cookies (and other tracking technologies)?
How do we use personal information when you visit our offices?
How do we use personal information for marketing purposes?

1. How does Allymar protect your personal information?

Allymar attaches great importance to your right to privacy and the protection of your personal information. We want you to feel secure that when you deal with Allymar, your personal information is in good hands.

Allymar protects your personal information in accordance with applicable laws and our data privacy policies. In addition, Allymar maintains the appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The following sections provide further details as to how Allymar processes your personal information:

Which categories of personal information do we collect and how do we process such personal information?
For which purposes and on which legal basis do we use your personal information?
Will we share your personal data with third parties?
What about sensitive data?
What about data security?
Where will your personal information be processed?
How long will your personal information be retained by us?
Which rights do you have with respect to the processing of your personal information?

Which categories of personal information do we collect and how do we process such personal information?

We collect personal information of our employees, potential employees, clients and their current/former/prospective employees/directors, suppliers, business contacts, shareholders and website users. If the information we collect is not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other information will be collected and how it will be used.

Specifically, the personal information we collect includes the categories of personal information described in the sections "How do we use personal data when you visit Allymar’s website?”, “How do we use cookies (and other tracking technologies)?”, “How do we use personal data when you visit our offices?” and “How do we use personal data for marketing purposes?”

The below table provides an overview of the categories of personal information that Allymar processes or may process in the context of the processing activities described in this privacy statement.

Category of personal information	Types of personal information captured by category
Personal details, contact details, and identifiers.	Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address) and occasionally, when necessary for specific purposes, gender, date of birth, age, place of birth.
Commercial information.	History and records of the products and services you have obtained from Allymar. Correspondence between you and us when it is sent to a dedicated mailbox or via other electronic communication means (including communication channels supported by AI that – for example - generates content to assist our personnel when interacting with you), for the purpose of processing account receivable payments and commercial follow-up.
Marketing and research information	1. Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address 2. Demographic data - (e.g. income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers) 3. Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system. 4. Social media content – blogs, posts and anything posted by an individual online or which mentioned/references an individual 5. Analytics and profiles of the individuals based on the data collected on them 6. Voice-enabled services (Speech-to-Text engines for search requests) without being recorded or stored by the mobile device.
Sensitive data and biometric information.	Allymar may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status/access requirements and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication.
Audiovisual materials, including transcriptions.	Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security/monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions), voice search functionality to enable a voice command feature that allows you to ask a question and see results (functionality enabled for mobile applications only), and/or audio video recording and transcription during meetings.
Position and professional or employment-related information.	Professional or employment-related information, such as description of current position, job title, employer, location, and Allymar contact(s).
System and application access data and Internet and electronic network activity information.	Where you are provided with access to Allymar’s systems, Allymar may collect information required to access such Allymar systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using Allymar systems.
Cookies and geolocation data	As described below, we also may collect geolocation data in some circumstances. Please see our Cookies Policy for more details regarding our use of cookies.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, clients and vendors. Except where certain information is required by law or by Allymar policies (including management of an employment relationship with Allymar), your decision to provide any personal data to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

For which purposes and on which legal basis do we use your personal information?

Allymar uses your personal information only where required for specific purposes. Please view the table below for (i) a list of the business purposes for which Allymar uses your personal information and (ii) an overview of the legal basis for each such business purpose.

Purpose	Legal basis
Managing our contractual and/or employment relationship with you.	Necessary for the performance of a contract to which you are a party.
Facilitating communication with you, which may include AI-powered support capabilities (including facilitating meetings, meeting recaps, email suggested content, communication in case of emergencies, and to provide you with requested information).	Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations including or being part of the provision of our services to our clients and their employees/contractors and their customers, for example in collecting their data as part of surveys/assessments/psychometrics, data analytics, Marketing research or other purposes.	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements.	Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).	Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Social listening (Identifying and assessing what is being said about Allymar and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)	Justified on the basis of our legitimate interest of protecting our assets and our brand on social media
Improving the security and functioning of our website, networks and information.	Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within Allymar and/or to provide a better user experience, including the use of AI (e.g., machine learning). This includes marketing analytics and analytics related to the organization of events/meetings. (more details on how we run analytics on our website can be found in our cookies policy).	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below).	Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Audio, video and transcription captured during live/recorded events and meetings (including virtual events/webinars) to inform interested stakeholders about the content of such events/meetings (including online publication of recordings for marketing purposes).	Based on your informed consent obtained prior to the event/meeting.
Specific Recruitment/Employment Purposes	Legal basis
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.	Justified on the basis of Allymar’s legitimate interests of ensuring that it recruits the appropriate employees.
Manage your application.	Justified on the basis of Allymar’s legitimate interests of ensuring that it recruits the appropriate employees.
Facilitate communication with you.	Justified on the basis of Allymar’s legitimate interests of ensuring proper communication within the organization and with you.
Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Allymar and how to attract and keep top talent.	Justified on the basis of Allymar’s legitimate interests of ensuring that it continually improves its recruitment processes.
In some cases, record your online interview for review by additional recruiters and hiring managers.	Justified on the basis of Allymar’s legitimate interests of ensuring that it recruits the appropriate employees.

We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check "I accept", "I agree" or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law.

We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Where we maintain or use deidentified information, we will continue to maintain and use that information only in a deidentified form and will not attempt to reidentify the information.

Will we share your personal information with third parties and service providers?

We may transfer personal information to our service providers and professional advisors, public and governmental authorities, Allymar companies/affiliates or third parties in connection with Allymar’s operation of its business, including any (potential) corporate or commercial transaction and including clients if the data has been processed to provide client services. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal information will be given adequate protection as required by relevant data privacy laws and Allymar’s internal policies.

For example, we may disclose personal information to third parties for other business purposes as follows:

We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
To protect and defend the legal rights, safety, and security of Allymar, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.

What about sensitive data?

We do not generally seek to collect sensitive data as defined in the second paragraph below through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal information identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health information, biometric or genetic data, sexual life or orientation, finances, geolocation, the contents of private communications, sensitive data related to a consumer’s government I.D. (i.e. social security number or driver’s license number), or criminal convictions and offences (including information about suspected criminal activities).

What about data security?

We maintain organizational, physical and technical security arrangements for all the personal information we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal information and the processing we undertake.

What are the sources we get your personal information from?

If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), Allymar employees, contractors, (prospective) members of board of directors, shareholders, Allymar’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, our clients, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).

In section 4, you can find more information on the sources of your personal information for marketing purposes.

How long will your personal information be retained by us?

We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
We will only keep the data while your account is active or for as long as needed to provide services to you.
We retain your data for as long as needed in order to comply with our legal and contractual obligations.

Which rights do you have with respect to the processing of your personal information?

You may be entitled, where provided for under applicable law, to:

Request access to the personal information we process about you: this right entitles you to know whether we hold personal information about you and, if we do, to obtain information on and a copy of the specific pieces and categories of personal information.
Request a rectification of your personal information: this right entitles you to have your personal information corrected if it is inaccurate or incomplete.
Object to the processing of your personal information: this right entitles you to request that Allymar no longer processes your personal information.
Request the erasure or deletion of your personal information: this right entitles you to request the erasure or deletion of your personal information, including where such personal information would no longer be necessary to achieve the purposes.
Request the restriction of the processing of your personal information: this right entitles you to request that Allymar only processes your personal information in limited circumstances, including with your consent.
Request portability of your personal information: this right entitles you to receive a copy (in a portable and, if technically feasible, readily usable format) of your personal information, or request Allymar to transmit such personal information to another data controller.

California law provides California residents with the right to receive a privacy notice with information about what we have collected, disclosed for business purposes, and sold during the preceding 12 months. This Allymar Privacy Statement for California Residents provides information about the categories of information that we have collected, the sources of that information, the purposes for which we have used the information, and the categories of third parties to whom we have disclosed the information for business purposes.

California law also affords California residents a right to opt out of the “sale” of your personal information. This right is applicable to the extent that Allymar is engaging in a “sale” of your personal information as that term is defined under applicable law. While Allymar generally is not in the business of selling information, there are limited circumstances where we share personal information with our clients, third-party partners, or others that we treat as a sale for which California residents have the right to opt out. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

If you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your personal information or otherwise permitted by law. Please contact us to opt out of the “sale” of your personal information. If at any time you would like to opt back in and allow Allymar to sell your personal information, please contact us.

To exercise any other rights available to you under California law, please contact us. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. Where necessary, this may include asking you for a copy of your valid government-issued identification, such as your valid passport or driver’s license (with the allowance of the redaction of your driver’s license number or social security number). If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf that we can confirm directly with the requestor. We reserve the right to deny requests from authorized agents in certain circumstances, such as where we have a reasonable belief that the request is fraudulent. For this reporting period, Allymar does not qualify for the CCPA 11 CCR § 999.317(g) reporting requirement.

Allymar may offer certain financial incentives for the collection, sale, or deletion of personal information. Where we would do so, we will provide California residents additional information where required by California law.

To the extent that the processing of your personal information is based on your consent, you have the right to withdraw such consent at any time by contacting us. Please note that this will not affect Allymar’s right to process personal information obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal information, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to Allymar first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Allymar with a competent court (either in the country/State where you live, the country where you work or the country where you deem that data privacy law has been infringed).

2. How do we use personal information when you visit Allymar’s website?

In addition to the information set out above, the following sections describe how we use personal information when you visit Allymar’s website:

Which personal information do we gather?
Do we include (links to) websites and programs of third parties?
How do we use personal information that we collect from our websites?

Which personal information do we gather?

Allymar collects personal information at its websites in two ways: (1) directly (for example, when you provide personal information to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website's technology).

We may collect and process the following personal information:

Personal information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of personal information may provide further information as to why your personal information is needed and how it will be used. It is completely up to you whether you want to provide it.
If you contact us, we may keep a record of that correspondence.
We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Any postings, comments or other content that you upload or post to an Allymar website.
Our website can collect personal information about your computer, including (where available) your IP address, operating system, type of device, device identification number, mobile operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, (geo) location data, weblogs and other communication data. Please see the Cookies section below for more information.

Do we include (links to) websites and programs of third parties?

Our websites may include:

Links to and from the sites of our partner networks, advertisers and affiliates.
Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal information collected through such programs for their own purposes.

How do we use personal information that we collect from our websites?

We use personal information for the purposes described in the section “For which purposes and on which legal basis do we use your personal information?” above, as well as to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected. For example:

Links to and from the sites of our partner networks, advertisers and affiliates.
Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal information collected through such programs for their own purposes.

3. How do we use cookies (and other tracking technologies)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.

Please see our Cookies policy for more details. By using our website, you agree that we and third parties can place cookies and other similar technologies on your device as explained in our Cookies policy.

4. How do we use personal information for marketing purposes?

In addition to the information set out above, the following sections describe how we use personal information for marketing purposes:

What are the sources of marketing data?
Do we send targeted e-mails?
Do we send push notifications?
Do we maintain Customer Relationship Management (CRM) databases?
Do we combine and analyze personal information?
Do we share personal information with third parties?
What are your rights regarding marketing communications?

What are the sources of marketing data?

The bulk of the personal information we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.

Do we send targeted e-mails?

Targeted e-mails from Allymar may include additional data privacy information, as required by applicable laws.

Do we maintain Customer Relationship Management (CRM) databases?

Like most companies, Allymar uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal information belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal information used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purposes), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Allymar professionals based on their personal interactions with you.

Do we combine and analyze personal information?

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites such as our careers and corporate sites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn and Xing)). We combine this data to better assess your experience with Allymar and to perform the other activities described throughout our privacy statement.

Do we share personal information with third parties?

In addition to the third parties mentioned in the section “Will we share your personal data with third parties?” above, we may share your personal information with marketing agencies.

What are your rights regarding marketing communications?

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal information, or by utilizing opt-out mechanisms in e-mails we send to you. In such cases, we will retain minimum personal information to note that you opted out in order to avoid contacting you again.

5. Contact us

Please contact us at PrivacyOfficer@allymarhealth.com  if:

You have a general question about how Allymar protects your personal information.
You wish to exercise your rights in relation to your personal information rights (as set out in the sections “Which rights do you have with respect to the processing of your personal information?” and “Your rights regarding marketing communications”).
You wish to make a complaint about Allymar’s use of your personal information.

This Allymar Privacy Supplement for Texas Residents (“Supplement”) is effective as of August 1, 2024

Please note that the Supplement will regularly be updated to reflect any changes in the way we handle your personal information or any changes in applicable laws. If you are not a Texas resident, this privacy statement does not apply to you.

This Supplement applies to Texas residents whose personal information is processed by Allymar PLC and/or its affiliates, subsidiaries and newly acquired companies ("Allymar" or "we") pursuant to the Texas Data Privacy and Security Act (“TDPSA”), detailing which rights you have in relation to the processing of your personal information.

Importantly, this Supplement is in addition to detailed explanation about how Allymar processes your information and what information we collect. Please visit the Allymar Privacy Statement to read more information.

Which additional rights do you have under the TDPSA with respect to the processing of your personal information?

In addition to the protections addressed in the Allymar Privacy Statement, the TDPSA provides Texas residents with the following rights:

The right to opt out of the “sale” of your personal information. This right is applicable to the extent that Allymar is engaging in a “sale” of your personal information as that term is defined under applicable law. While Allymar generally is not in the business of selling information, there are limited circumstances where we share personal information with our clients, third-party partners, or others that may be considered a “sale” under the TDPSA.
The right to opt out of targeted advertising.

If you choose to exercise these rights, we will not charge you different prices or provide different quality of services unless those differences are related to your personal information or otherwise permitted by law.

Please contact us to opt out of the “sale” of your personal information or to exercise any other rights available to you under Texas law, please contact Allymar’s Data Privacy Officer.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. Where necessary, this may include asking you for a copy of your valid government-issued identification, such as your valid passport or driver’s license (with the allowance of the redaction of your driver’s license number or social security number). If you would like to use an authorized agent to exercise your rights, we may request evidence that the agent has valid authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests from authorized agents in certain circumstances, such as where we have a reasonable belief that the request is fraudulent. If we refuse to take action on your privacy rights request, you may appeal our refusal within a reasonable period after you have received notice of the refusal.

Contact us

Please contact us at PrivacyOfficer@allymarhealth.com if:

You have a general question about how Allymar protects your personal information.
You wish to exercise your rights in relation to your personal information rights.
You wish to make a complaint/appeal a decision about Allymar’s use of your personal information.