This Privacy Policy describes how we use, disclose and protect the information we collect about you when you visit our website at https://phsu-mcc.moffitt.org/cancercientouno/ or in other circumstances when we present you with this Privacy Policy (collectively, the “Cancer Cientouno training program”) and its subsidiaries (collectively, “we” or “us”) This Policy also contains information about your privacy rights and how you can exercise them. The U54 Ponce Health Sciences University-Moffitt Cancer Center (PHSU-MCC) Partnership is the data controller of the information we collect under this Privacy Policy.
Please read our Privacy Policy and our website to understand both our commitment to you and your privacy, and how you can help us to honor that commitment.
Personal Information We Process
“Personal Identifiable Information” refers to any information that relates to you directly or indirectly, in particular by reference to an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity. We process the following categories of Personal Information:
- Contact information, such as your name, phone number, address. and email address which is collected on our registration form;
- Technical information, such as your IP address, browser, operating system, device type and ID, and data collected about your interaction with the website (such as the tabs you visited);
- Education and training information, such as your schooling and other information included on our registration form;
- Research study participant information, such as sociodemographic information;
- Any other information that you provide to us that can be used to identify you.
We collect Personal Information about you in the following ways:
- When you submit information voluntarily. There are certain areas of the website where you can voluntarily submit Personal Information to us, such as when you register for the training program or otherwise contact us directly;
- Through data collection technology. We use cookies and other data collection technology to collect and store your Personal information when you interact with the Services;
In addition to Personal Information, we may collect other information that alone cannot be generally used to identify you. For example, when you visit our website, we may collect your browser type, device type, and operating system information. If any of this information can be used to identify you because, for example, we link it to your Personal Information, we will treat such information as Personal Information.
Our Use of Your Personal Information
The chart below describes the Personal Information that we collect, the likely sources of the Personal Information, how we may use and disclose it, for what purposes, and pursuant to what legal basis under the European Union’s General Data Protection Regulation (“GDPR”). Please also review our NPP for more information for how we use and disclose Protection Health Information to provide health care items and services and conduct other activities subject to HIPAA.
Use of your Personal Information | Categories of Personal Information We Process | Source | Legal Basis under GDPR |
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Contact you regarding important administrative announcements | Contact information | You | Legitimate interest: To provide you with important information about your progress or status as a participant in the Cancer Cientouno training program |
Respond to inquiries and fulfill requests | Contact information and other information you provide, such as your requests | You | Legitimate interest: To provide you with information you need and other services you request and to efficiently communicate with you |
Conduct questionnaires and surveys | Contact information and other information you provide, such as your survey answers | You | Legitimate interest: To evaluate and take action with regard to your survey responses and feedback and comments about the Cancer Cientouno training program |
Register you for the Cancer Cientouno training program to get access to training program-related materials | Contact information other information you provide, such as your preferences on how to be contacted | You | Legitimate interest: To enable your participation in the Cancer Cientouno training program. Informed consent: As may be described on the registration page for the Cancer Cientouno training program |
Perform website analytics and develop and improve our features, content, and services | Technical information and other information we collect, such as demographics, behavior, and program progress tracking | First and third-party analytics cookies | Legitimate interest: To understand more about our visitors (what pages you view, how long you visit, your devices, etc.) in order to improve our services |
| Administration and Internal Operations |
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Verify your identity | Contact information, other demographic information, and Personal Identifiable Information | You | Legitimate interest: To provide you with access to your account and information, and to prevent fraud |
We may also aggregate or de-identify your Personal Information so that it can no longer be used to identify you. This aggregate or de-identified information may be used for any purpose permitted by law.
Other Uses: In the event of any other purposes for which we wish to use your Personal Information that are not listed above, or any other changes we propose to make to the existing purposes, we will notify you by amending this Privacy Policy in accordance with the Section titled “Changes to this Privacy Policy” below.
Cookies and other Data Collection Technology
We use Cookies, Web Beacons (also known as pixel tags and clear GIFs) and other similar technology (together, “Data Collection Technology”) on our website. “Cookies” are small text files placed on your computer’s hard drive that allow us to know how often you visit our Services and the activities you conduct while on our Services. A “Web Beacon” (also called a “pixel tag” or “clear GIF”) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about Cookies and Web Beacons, visit www.allaboutcookies.org.
Data Collection Technology helps us dynamically generate content on our web pages that is specifically designed for you and allows us to statistically monitor how many people are using our website and for what purpose. For example, we use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing Cookies on your device. The information that the Cookies collect, such as the number of visitors to the website, the pages visited and the length of time spent on the website, is aggregated. We also may use Data Collection Technology to collect information from the computer or device that you use to access our online services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.
Your Control of Cookies: Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, you may not be able to fully utilize all features of this Site. You have the ability to delete cookie files from your hard drive at any time.
Our Policy on Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. To the extent we are able, we honor the DNT signals we receive from your browsers.
Our Disclosure of Personal Information to Third Parties
We will disclose your Personal Information within Moffitt, at your direction, as disclosed to you at the time of collection, or in the following circumstances:
- As Required By Law: We may disclose your Personal Information if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to protect the legitimate rights, privacy, property, interests or safety of the U54 PHSU-MCC Partnership, our business partners, personnel, or the general public; (iv) to pursue available remedies or limit damages; (v) to enforce our Terms & Conditions; or (vi) to respond to an emergency.
International Transfer of Personal Information
The U54 PHSU-MCC Partnership is committed to complying with this Privacy Policy and data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Information. The U54 PHSU-MCC Partnership is located in the United States, and we recognize that the laws in the United States may be different and, in some cases, not as protective as the laws other countries, including those located in the European Economic Area. By providing us with your Personal Information and using this website, you acknowledge that your Personal Information will be transferred and processed in the United States. If you would like to know more about how we protect your Personal Information, you can contact us using the information in the section “Contact Us” at the end of this Privacy Policy.
Security of Your Personal Information
We have made efforts to provide a reasonable level of security for your Personal Information. All members of the Moffitt Cancer Center-Ponce Health Sciences University U54 Partnership Outreach Core team are trained in ethical conduct, confidentiality, and identity protection. The U54 Partnership Outreach Core team has partnered with CS Consulting LLC to support the administrative side of the website and therefore has administrative access. Any publications or presentations containing research results will not include any information that can be traced back to individual participants. Participant registration data is used to understand who the training program has reached. Contact information is collected to send participants a certificate upon program completion and a 6-month follow-up to learn how participants have used the information learned in the program. There will also be data collected on website usage (e.g., progress status, completion status, date of completion, date course started, total time spent on course, date of last log in, IP address, browser) for evaluation purposes.
Participant data will not be shared with other entities who are not involved in the project. The administrative side of the website and the Moffitt Cancer Center network is password protected with daily back up for increased security. The website and project database will be protected and accessed only by authorized individuals including research team members and partners. Participant data will be kept on password-protected computers that will be backed up daily on a secure server.
While the U54 PHSU-MCC Partnership has taken reasonable steps to protect any information that you may submit from unauthorized interception and use, the risk of unauthorized interception and use of electronically transmitted information cannot be entirely eliminated, and no method of electronic communication is entirely secure. Therefore, there is always a risk of unauthorized interception and use of any information that you submit to the U54 PHSU-MCC Partnership through this website.
Retention of Personal Information
We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements.
Your Rights
You have the right to request access and modifications to the Personal Information we maintain about you. We will respond to your inquiry within a reasonable timeframe.
If you wish to exercise any of your rights (including the rights of individuals in the European Economic Area discussed below), please contact us using the information in the “Contact Us” section at the end of this Privacy Policy.
Special Rights of Individuals in the European Economic Area
If you are located in the European Economic Area and we maintain your Personal Information, you have the following additional rights (under the GDPR) with regard to your Personal Information:
- Right to access and receive: You may request a copy of or access to the Personal Information we hold about you. You may also request that we transfer your Personal Information to a third party in a machine-readable format.
- Right to correct: You may ask us to update or correct inaccurate or incomplete Personal Information we hold about you.
- Right to limit or restrict: You may have the right to request that we stop using all or some of your Personal Information or to limit our use of it.
- Right to withdraw consent: You have the right to withdraw any consent you have previously given to the U54 PHSU-MCC Partnership at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Information prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Information if it has been fully anonymized and cannot be used to personally identify you.
- Right to complain: You have the right to lodge a complaint with your Supervisory Authority if you are unhappy with how we process your Personal Information. You can find contact information for your Supervisory Authority on the European Commission Data Protection Authorities webpage or through other publicly available sources.
Special Notice to California Residents
California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information in the “Contact Us” section below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.
Children’s Privacy
The website is intended for adults aged 18 and older, and the U54 PHSU-MCC Partnership Moffitt does not knowingly collect Personal Information through the Services from any person known to be under the age of 18.
Third-Party Websites and Services
When using the website, you may come across links or references to third-party websites and services that we do not operate or control. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices, policies, and terms of use. This Privacy Policy does not apply to any Personal Information that you provide to a third-party website or service. We recommend that you read the privacy policy that applies to that third-party website or service. A link or reference to a third-party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.
Changes to this Privacy Policy
The U54 PHSU-MCC Partnership reserves the right to modify this Privacy Policy at any time. We will notify you via your preferred method of contact or any other reasonable means (e.g., by emailing you using the email address we have on file) prior to when any material changes to the Privacy Policy take effect. Any modified Privacy Policy will supersede the current Privacy Policy.
Contact Us
We welcome your questions and comments about this Privacy Policy or how we process your Personal Information. Please contact us using the information below and we will respond to you as soon as reasonably possible.
The U54 PHSU-MCC Partnership psm-mcc.partnership@moffitt.org