We take your data privacy and information security very seriously, please take a moment to understand how we protect you and your patients online.
CMRAD collects three categories of data in order to provide the best possible radiology service and develop improved methods to secure accurate diagnosis fast.
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Your user profile data
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Pseudonymized patient data in the form of DICOM images
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Technical browsing data including the use of cookies
Exactly how we collect this information, why its required to provide you with this service, how its kept safe and what we do with it can be found in detail in our Privacy Policy below and our Security White Paper.
By using the CMRAD platform, you accept and acknowledge this policy.
Purpose
This is our current Privacy Policy and was Last Revised on the 10/04/2018. For further information on our policies please Contact Us.
PLEASE READ THIS PRIVACY POLICY CAREFULLY AND RETAIN A COPY FOR YOUR RECORDS. THIS POLICY FORMS PART OF CMRAD’S TERMS AND CONDITIONS.
Collective Minds Radiology AB, registered in Sweden with company number (organisationsnummer) 559120-7187, (Collective Minds Radiology, CMRAD, we, us), respect the privacy of every person and is committed to protecting all of your personal data, including sensitive personal health information (Personal Data).
This policy (together with our Terms and Conditions of Use as set out here and as updated from time to time (Terms and Conditions)) applies to your use of:
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the website at cmrad.com (Website); and
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the CMRAD mobile application software (App), available to download or stream to your mobile telephone or handheld device (Device),
together, the Platform, and any of the services accessible via the Platform (Services).
The data controller is Collective Minds Radiology AB of Torgnyvägen 24, 187 76 Täby, Sweden. Our Data Protection Officer can be contacted by email at dpo@cmrad.com.
The policy will serve as a summary of your privacy rights. The law (the EU wide General Data Protection Regulation (“GDPR”)) requires that your Personal Data is kept private unless there is a legal obligation or requirement for disclosure by us to authorised parties, in which case we will make such disclosure(s) as legally obliged. This is an important notice about our privacy practices and the terms of this policy while it is in effect. Your use of the Platform and the Services indicates your acceptance of the terms of this policy.
Introduction
Collective Minds Radiology is a web based platform that enables fast, simple and accurate consultation between radiologists, clinicians, doctors and other specialists (Customer, Customers, you, your, yourself, User) to diagnose radiological findings.
The platform function around Cases depending on the clinical and educational value. Add this value in a cumulative fashion and allow each individual user to build their own user defined library of cases and knowledge. All users are verified prior to registration to ensure authenticity.
CMRAD collects, processes and stores three distinct sets of personal data.
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Registration data necessary to manage the users on the platform and provide the service to the same.
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Pseudonymized patient data contained in the DICOM images and embedded metadata tags. This is the main purpose of the platform and its objective is to improve accuracy and speed to diagnosis, to the benefit of the individual patient and society as a whole, through the methodic processing of large data sets.
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Technical information about the nature of the user’s visit to our platform in order to correctly provide the service, run the systems, detect issues and misuse, analyse user behaviour and continuously improve the service.
Lawfulness of our processing
It’s lawful for us to process personal information about you.
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We process personal information about you, the user, to make available the Service on the CMRAD platform. We need that personal information to carry out our obligations towards yourself.
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We process pseudonymized patient personal information (related to a large set of anonymous patient health and medical records), in accordance with this Privacy Policy.
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We also use some personal information about you to contact you about our other services. We ask for your consent to this when you first register to use the Service.
Information you provide
Before you are able to log in to the Platform you will be asked to create an online account (Account). To create an Account, you must provide Personal Data that will be shared with other Users and members of the Collective Minds Radiology team (from time to time, as required). After you create your Account you can use the same details to log in to the Platform and use the Services.
In order to download or register the App, search for the App or any Service, report a problem with the App or Website or use the Services, you may be asked to provide personal details such as your name, address, age, e-mail address and phone number, the Device's phone number, username, password and other registration information.
Collective Minds Radiology creates a record of the Users, Cases, and Services you receive via the Platform.
The platform also collects or creates information through the above process in the form of pseudomized electronic medical images (DICOM) and associated metadata that may be uploaded by you or created as a result of your use of the Services. It’s at the time of case creation on the CMRAD platform where the user is asked to confirm the patient consent to uploading of the data exists according to local legislation. Hence the CMRAD platform does not allow cases to be created nor pseudonymized patient data to be stored on the platform without the prior confirmation of patient consent. This also means that it’s the user creating the case who stands responsible to ensure the patient consent exist.
Collective Minds Radiology does not seek direct patient consent. Our viewpoint is that the patient is seeking diagnosis from the source clinic and the CMRAD platform is simply one of the tools available to successfully arrive at a correct diagnosis. However, as this document describes, we have gone to great lengths in order to protect the patient personal data through the pseudonymization process.
It’s very important that you as a user do not include personal data about your patients when describing or discussing a particular case. Therefore CMRAD also performs periodic checks on the case data ensuring that this does not happen and rectifying any such usage.
Anonymization and Pseudonymization
All patient health data (DICOM images) are anonymized at its source within the clinic’s private network. The objective of the anonymization is to remove any data which can be traced back to an individual person. Nevertheless, a unique identifier is kept within each case to enable linking back to the original patient. This linking is only to be possible at the source clinic. This concept is called pseudonymization and enables a clinic to fulfill their data privacy policy obligations towards each patient. In this same process, CMRAD will retain a record from which clinic a particular image set was sent. This is not publicly available data on the platform, but the link needs to be retained in order to enable any future finding and deletion of such data upon a patient’s request.
Should a request to identify, produce or remove any patient specific data from the CMRAD platform, the source clinic provides the pseudonymization key and the date and time of upload in order to establish the link between the patient and the pseudonymized data. This process cannot take place without the source clinic providing the pseudonymization key and date/time stamp and hence Collective Minds Radiology has no ability to identify the patient.
The process of pseudonymization removes all attributes such as name, birthdate, phone number, etc. from the DICOM images. The process goes much deeper though and removes any metadata tag which could indirectly enable the tracing back to the original patient. For this purpose we use the anonymization method described in the DICOM standard 2017c. The specific tags which are removed or replaced can be found in Table E.1-1 from PS 3.15 of the DICOM standard 2017c. In order to correctly provide our service, the following tags are however retained as these play a vital role in the diagnosis work of our users and do not directly identify the patient.
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Patient’s Age
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Patient’s Sex
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Patient’s Weight
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Patient’s Size
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Acquisition Date
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Study Description
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Series Description
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Contrast Bolus Agent
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Content Sequence
As a secondary DICOM image upload method, we also let our users upload directly from their PCs to our platform. In this case, the pseudonymization happens on our platform prior to the data is stored.
Storage of pseudonymized patient data
The core of our service is to help radiologists (our users) to find a diagnosis to a radiological finding in radiology images.
We store pseudonymized images together with descriptions of radiology findings within these images (called Cases). A stored case is shared with other users with the purpose of solving a specific radiological finding. The description of the radiological finding is done by the user uploading the images with the support of other users.
Once a case is considered solved, the case is stored for educational purposes, comparison between cases and for training artificial intelligence software.
Educational purposes can be users reviewing historical cases on the service to enhance their own knowledge. Or cases downloaded to be used for other educational purposes, such as lecture material.
Future comparison can be a case uploaded and being compared to historical cases by looking for similarities in these cases. The purpose of this comparison is to help solve the uploaded case.
Training artificial intelligence software can include a larger subset of similar cases being reviewed by a software to create automatic classifications of images and cases.
As soon as a case is considered not to be meaningful for educational purposes, comparison or training of artificial intelligence software, it will be removed from our database.
Information that may be collected
Each time you use the App or the Website we may automatically collect the following technical browsing data:
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technical information, including the type of device (mobile or tablet) you are using, the temporary or persistent unique device identifiers (UDIDs) placed by us or our service providers, the unique identifier assigned by Collective Minds Radiology to your Device, the I.P. address of your Device, your mobile operating system, the type of mobile internet browsers you use and data about the way you use our Platform (Device Information);
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information about your visit, including the full uniform resource locators (URL) clickstream to, through and from the Website (including date and time); Services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), consultation length(s), recurrence of visits and other interaction information, methods used to browse away from the page and any phone number used to call our customer service number (Website Information);
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when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us (Unique Application Numbers);
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details of your use of the Platform including, but not limited to, traffic data, weblogs and other communication data (Log Information); and
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if you contact us, we may keep a record of that Correspondence.
Third Party Information
We are working closely with third parties (including, for example, clinics, analytics providers, search information providers) and may receive information about you from them.
We may associate any category of information with any other category of information and will treat the combined information as Personal Data in accordance with this policy for as long as it is combined.
How we use your data
We need the personal information we collect in order to provide you with the Services and to send you essential information about the Services (where you ask us to send you such information) and to help us with the operation of the Platform. We could give lots of examples; here are some typical examples:
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to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and Services that you request from us;
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to notify you about changes to the Platform and/or Services;
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to ensure that content from the Platform is presented in the most effective manner for you and your computer or Device;
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to undertake planning, Service evolution, new product development, Service delivery, marketing, internal and external performance indicators and a range of other business intelligence functions;
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to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
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to allow you to participate in interactive features of the Services;
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to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
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to make suggestions and recommendations to you and other users of the Platform about goods or services that may interest you or them; and
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to respond to any queries you raise with us and to provide customer support.
In addition to the above, Collective Minds Radiology will use the email address and mobile number you provide when you register to send you a text message requesting that you validate your Account. Your email address, mobile telephone number and other contact information that you provide via your Account may also be used by Collective Minds Radiology to enable your use of the Services. Collective Minds Radiology will use your email address and mobile number as the joint primary means to reset your username and password.
You have the right to ask us to restrict processing of your personal data and a right to object to our processing of your personal data in this way, but if you do either of these, it may impact on your use of the Services and/or we may not be able to provide you with information about the Services that you have requested us to provide to you.
Who do we share your personal data with?
Personal information
We never commercially exploit or distribute to any third party any information which is personal information. We may pass personal information to people who process data for us in accordance with this Privacy Policy, for example, companies which provide data storage, data analytics, advertising, IT support and other services. We have contracts with these third parties and we vet them to ensure they are contractually bound to do what we say they can do with this information.
For example, we may disclose your personal information to the following third party data processors:
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We may disclose or otherwise make available Personal Data about you to service providers that assist the function of the Platform. These service providers may collect device-specific data, such as a UDID, when you use our Platform. This data will not be associated in any way with your Account or any Personal Data that identifies who you are; we use this UDID to improve our Platform.
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Your email address and mobile number may be shared with third parties working with Collective Minds Radiology in the delivery and development of the Services and the Platform, to track usage, and these details may be used to advertise new Collective Minds Radiology services to you from time to time.
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You should also know that we work with third party analytics companies to discover how we can improve, update and change the Platform. Such third parties may therefore gain access to your Personal Data (but not any medical records). If you do not consent to such use of Personal Data, please do not use the Platform and remove the Platform from your Device by uninstalling the App.
In addition to the above, we may share your personal data with the following third parties:
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In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective buyer or seller.
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If CMRAD or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
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If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
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In order to:
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enforce or apply the Terms and Conditions or to investigate potential breaches; or
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protect the rights, property or safety of CMRAD, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How information about you may be used by Collective Minds Radiology
Use and Disclosure of Personal Data
Collective Minds Radiology may also use aggregated, anonymised data sets of unidentifiable, non-personal information for: (i) statistical analysis, improvement of the Services and customisation of UX-design and content layout or creation; or (ii) sharing with government agencies or regulators that oversee and monitor health care providers in both the public and private sectors.
Cookies
A cookie is a small text file that may be placed on your computer or Device when you visit the Platform. When you next visit the Platform the cookie allows us to distinguish you from other users. There are two categories of cookies: (a) ‘persistent cookies’ that remain on your computer or Device until deleted manually or automatically; and (b) ‘session cookies’ which remain on your computer or Device until you close your browser, when they are automatically deleted.
The cookies Collective Minds Radiology uses:
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Essential cookies are required for the operation of the Platform and without them the Platform can’t operate properly.
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Performance cookies allow us to see and count the number of visitors to the Platform and what they do during their visit. We use the information from these cookies to improve the Platform’s performance. The data from these cookies doesn’t allow us to identify you.
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Experience cookies allow the Platform to remember your choices, which means we can personalise your experience of the Platform. Data collection by experience cookies is used by our analytics systems (including third party systems) to monitor and enhance the Platform’s user-friendliness.
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Marketing cookies track and record your visits to the Platform, including but not limited to the actual pages you visit and the links you have clicked or followed. We use this data to make the content of the Platform more relevant to/for you based on what we know about you. We do share information about your activity on the Platform that is stored by these cookies with our agents, agencies and other third party ad networks and this information can be used to advertise products to you on other sites. Any data we share is anonymous and cannot be used to identify you.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can REFUSE cookies, by activating settings of your chosen browser(s). If you alter your browser settings to refuse cookies your access to the Platform will be restricted.
Security
The importance of security for all your Personal Data is of great concern to us. At Collective Minds Radiology, we have gone to great lengths to manage the security and integrity of the Platform and to ensure that we use best–in-class services when providing secure transmission of information from your computer or Device.
Personal Data collected via the Platform is stored in secure environments that are not available or accessible to the public; only those duly authorised people, officers, employees or agents of Collective Minds Radiology who need access to your information in order to do their jobs are allowed access. Anyone who violates our privacy or security policies is subject to disciplinary action, including possible termination of their contract with Collective Minds Radiology and civil and/or criminal prosecution.
Collective Minds Radiology uses the latest technologies to ensure utmost security, including utilising several layers of firewall security and encryption of personal data to ensure the highest level of security.
Collective Minds Radiology is the sole owner of any data collected via the Platform.
Please see the CMRAD Security White Paper for further information.
The Platform is hosted in Amazon Web Services (AWS) who in turn guarantee the compliance with GDPR. https://aws.amazon.com/compliance/gdpr-center/
Data Storage
The data that we collect from you may be shared with our third party processors (who provide analytics, payment processing, information and/or other support services) which are located and/or store data in the EU. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
Certain features of the Platform link to social networking. Ensure when using these features that you do not submit any Personal Data that you do not want to be seen, collected or used by third parties.
Security when using the Platform
When using the Platform, all your Personal Data are transmitted through the internet using Secure Socket Layers (SSL) technology. SSL technology causes your browser to encrypt your entered information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent a third party from capturing and viewing your Personal Data. Collective Minds Radiology also takes the following measures to protect your Personal Data online:
Two-Step Process:
You are required to go through a two-step verification process to create and restore your Account. Online access to your Account is protected with a password that you create. We strongly recommend that you do not disclose your password to anyone. Collective Minds Radiology will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls, email or text messages). You will only ever be able to reset your password using a two-step process.
Information:
Since any information you provide to us on the Platform will be transmitted using a secure connection, if your web browser cannot support the required level of security you will not be able to use the Platform properly. The most recent versions of Google Chrome, Safari and Firefox can support a secure connection and can be downloaded for free from their respective websites. Should you choose to download and/or install any such package such actions are at your own risk.
No data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect your Personal Data from unauthorised access, use or disclosure, Collective Minds Radiology cannot ensure or warrant the security of any information you transmit to us via the Platform. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights
You have the following legal rights in respect of your personal information or the pseudonymized personal data of a patient at your clinic by providing us the pseudonymization key:
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A right to request from us access to your/your patient’s personal data;
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A right to request rectification of your/your patient’s personal data;
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A right to request erasure of your/your patient’s personal data;
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A right to ask us to restrict processing of your/your patient’s personal data and a right to object to our processing of your personal data (but if you do either of these, it may impact on your use of the Services and/or Platform and/or we may not be able to provide you with information about the Service that you have requested us to provide to you);
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A right to ask us for a copy of any personal data you have provided about yourself or your patient and to have a copy of it from us; and
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A right to lodge a complaint about how we treat your personal data with the Swedish Information Commissioner’s Office (Datainspektionen).
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If you wish to discuss or make a request in respect of any of the above rights, please refer to the relevant sections below or Contact Us.
How long do we keep personal information
Once a case has been finalised and a suggested diagnosis has been established, the CMRAD platform continues to provide educational services based on these historic cases. The objective here is to help establish diagnosis in other cases, train radiologists to become even more efficient and develop radiology services to become more precise than today. Once a case and all its supporting data has fulfilled this purpose, it will be deleted.
In practice, this means that personal data gathered during the process of collaboration around medical imaging will be retained maximally for 30 years. Personal data about registered users who have not used our Services will be deleted after 5 years of inactivity on the Platform.
If you agree to be added to our mailing list, we will keep your personal information for that purpose unless and until you tell us that you want to unsubscribe or be removed from the list. If you advise that you do not want to be added to our mailing list or you ask to be removed, we will delete your personal data (aside from keeping a record that you have asked us not to send you marketing information).
Other provisions
Other Links
The Platform may contain links to let you to visit other websites or mobile applications easily. If you click on a link to a third party site or app, you will leave the Platform and go to the site or app you selected. Because Collective Minds Radiology cannot control the activities of third parties, we cannot accept responsibility for the content of any such sites or apps or for any use of your Personal Data by such third parties and we cannot guarantee that they will adhere to the same privacy practices as Collective Minds Radiology. If you visit a third party website that is linked to our site, you should read that site's privacy policy before providing any personal information.
Notices, Amendments and Updates
Collective Minds Radiology may revise this policy to reflect any changes in its privacy practices. We reserve the right to make any revised policy effective for Personal Data we already have about you as well as any information we receive in the future. We will post a copy of the updated policy on our Platform prior to any change becoming effective. The effective date of this policy is displayed directly under the title of the document. If we make any material changes we will notify you by means of a notice on the Platform prior to the change becoming effective.
Social Media Sharing
Our Platform includes some social media features. These features may collect your IP address, which page you are visiting on our Platform and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Platform. Your interactions with these features are governed by the privacy policy of the company providing it.
Accessing Information Held By Us
If you would like a copy of all of the Personal Data, we hold about you please Contact Us. We do charge for providing information because we have to gather, collate and process this data to make it available to you in its entirety: a fee of 10€ must be paid prior to releasing data and details of how this should be paid will be provided in our response to your request.
Incidents and complaints
Given the importance of the Data Privacy topic, we continuously monitor the platform for unwanted behavior from our users and other forms of intrusions. The techniques applied for this monitoring are explained in the CMRAD Security White Paper.
Nevertheless, should you wish to report a Data Privacy incident or raise a concern or complaint, we ask you to contact our Data Protection Officer by email at dpo@cmrad.com.
All Data Privacy incidents discovered by us or reported to us, we will be investigated. Depending on the findings these investigations, we will take appropriate remedial actions and where relevant report to the correct governing bodies of GDPR within 72 hours.
Acceptance
By using the Platform and/or the Services you acknowledge your acceptance of our privacy policy, as updated from time to time. If you do not agree with this policy you should not use the Platform or the Services. It is recommended that you read this privacy policy each time you consider or choose to use the Platform or the Services to ensure that you have not missed any changes to this Privacy Policy.
Your continued use of the Platform following any changes to the privacy policy (which will be notified to you as described above) signifies your acceptance of those changes.
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