Last updated: June 25, 2022
1. What information does eNavvi collect?
Information you provide us.
When you create a new account in our mobile application, we may ask for your first and last name, email, creation of a password, occupation, country of practice and if your country of residence is the United States, we may ask for your zip code. We will then present you with a list of Health Care Providers (“HCPs”) with your same name/zip code combination and available National Provider Identification (“NPI”) numbers, based on data from the National Plan & Provider Enumeration System (“NPPES”) registry. You will be asked to select the correct NPI profile that represents you. Once you claim your profile, we will ask about your specialty and any applicable sub-specialty to designate in your account;
When you create a new account or update an existing account on eNavvi, we ask for your full name, email address(es), creation of password, country of residence, work zip code, occupation and specialty/subspecialty information (as applicable). You may also provide information related to the medical school you attended including the country, state, name, graduation year, former last name (as applicable) and date of birth. We may also ask you to provide other pieces of information, including, but not limited to, information related to your residency (including year(s) attended), information related to your practice, information related to your hospital affiliation and your billing address. This process may also include a series of security related questions;
We will collect date of birth when you participate in Continuing Medical Education (“CME”) programs offered through our Services;
We may ask you for other types of information like demographic information, for example, when you participate in a survey or product test or when you enter a contest or other promotional event;
We may also collect and track information related to your current and historic subscription status, search queries, discount codes used, and other interactions with the Services which may inherently be associated with other identifiable characteristics of you. For example, we may collect a discount code that is directly tied to your employer;
Through your interaction and use of eNavvi.com and/or request for information related to our Services, we may also collect the following information from you: first and last name, email address(es), phone, address including a zip code, employer/organization name, employment title, school affiliation information (as applicable), information you provide related to your interest in eNavvi and our Services (for example, nature of your request (for example, what product(s) you are interested in and why you are interested in eNavvi), number of licenses you are interested in, product interest, etc.), school affiliation information, and the text you enter into free text fields;
We may also collect any information you provide to us through use of the Services. For example, if you use the ‘Feedback’ functionality within the Services, we will collect the rating you provide as well as any information you enter the free text field;
We do not collect or process any sensitive data such as: race or ethnic origin; political opinions; religious or philosophical beliefs; genetic or biometric data; health or mortality; or sexual orientation.
Information we may automatically collect.
When you visit our website eNavvi.com use our Services or interact with communications we may send to you in connection with your use of our Services (for example, emails or newsletters), some information is automatically collected. For example, when you visit or use our Services your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, geo-location and the website you visited before our site are collected and logged automatically.
We also collect information in connection with your use of the Services and your interaction with the Services or your interaction with communications sent to you in connection with your use of our Services (including, but not limited to, your clicks and searches through your use of the Services, advertisements, your interaction with the content made available through the Services, messages and communications (e.g. emails or newsletters) surfaced through or in connection with your use of the Services (whether sponsored or not sponsored), emails, newsletters, push notifications, In App messages or other messaging from us (“User Behavior Information”).
We may combine this automatically collected information with other information we collect about you through your use of the Services or received from other 3rd party sources (for example, your NPI available data from the National Plan & Provider Enumeration System (“NPPES”). Your use of our Services or our website are treated as your consent to the automatic collection of the data described herein.
Additionally, when you use our Services or interact with communications sent to you in connection with our Services, we may automatically collect data about your device such as your device ID, type of device you use, operating system version and information related to your use of the Services.
Information we receive from third parties.
2. How does eNavvi use the information we collect?
We use information collected (including User Behavior Information) through our Services for purposes described in this policy or for those purposes disclosed to you in our Services. For example, we may use your information to:
Operate and improve our Services;
Share information you provide to us and/or User Behavior Information with clients and prospective clients (for example, pharmaceutical companies and other advertising clients) about your use or interaction with the Services, interaction with promotional and non-promotional content contained within the Services as well as interaction with communications you receive in connection with the Services (for example, emails and newsletters);
To provide you access to CME content through the Services;
Share User Behavior Information insights with existing or prospective clients;
Respond to your comments and questions and provide customer service;
Provide, deliver and improve upon products and services you request;
Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Better understand you so that we may tailor messaging and services to you based on your interests, preferences, needs and specialties;
Communicate with you via email, alerts (push notifications and/or in app alerts) and other messaging outlets about commercial, non-commercial, sponsored and non-sponsored information, FDA and product safety alerts, new drugs and pharmaceutical studies and related information. By accepting the terms of this policy, you are opting in to receiving such communications from us;
Send you information via email about products and services offered by us, our affiliates, and our partners. By accepting the terms of this policy, you are opting in to receive such emails from us.
Send you invitations, by email or other means, to participate in market research survey opportunities. By accepting the terms of this policy, you are opting in to receive such invitations from us;
Link or combine your information with other information we collect through our Services information collected through your interaction with communications received in connection with the Services, with information receive from third parties.
3.How does eNavvi protect your information?
We take appropriate measures to protect the information that we receive about you from unauthorized access, disclosure, alteration, or destruction. When we collect certain sensitive information (such as geolocation), we encrypt the transmission of that information using secure socket layer technology (SSL). No method of transmission over the Internet or electronic storage is 100% secure; as a result, we cannot guarantee absolute security. If you have any questions about security, you can contact us at help@eNavvi.com.
4. Will eNavvi share the information it collects with others?
With your consent;
With our third-party vendors, consultants, agents, and other service providers with whom we contract to help us provide or improve our Services. For example, we may work with companies to host and maintain our data, provide messaging services, analyze our data or provide marketing assistance;
To provide our commercial clients and prospective commercial clients, such as pharmaceutical companies and their advertising agencies, with your information for audience or user matching purposes;
To provide our commercial clients and prospective commercial clients (for example, pharmaceutical companies and their advertising agencies) with your information when you engage with promotional and nonpromotional content (including related communications) through or in connection with our Services and information about the type of engagement (e.g., whether you viewed, interacted with or requested information about such promotional content);
In connection with providing you access to CME content through the Services, your information and/or User Behavior Information will be shared with relevant Accrediting Organizations, Accredited Education Providers, Medical Education Companies and Medical Education Sponsors (collectively referred to as “Continuing Medical Education Partners”) who have funded, created, or distributed the CME content through the Services. An Accrediting Organization is a body that provides the criteria, policies, and standards to Accredited Education Providers. An Accredited Education Provider is an entity that has created medical education materials and has been given accreditation by an Accrediting Organization. A Medical Education Company participates in the coordination and distribution of accredited medical education content. A Medical Education Sponsor is a company or organization that provides funding to create medical education content;
In connection with or during negotiation of any merger, financing, acquisition or bankruptcy transaction or proceeding involving sale or transfer of all or a portion of our business or assets to another company;
Share aggregated information such as statistics about our customers, sales, product usage or traffic patterns, and related website or Services information as well as User Behavior Information with clients, prospective clients or third-party vendors who need access to the information in order to provide the Services;
When you engage in market research activities, we will share your information with the market research clients;
If you post a comment or message in our blog or other public forums hosted by us, it will be shared publicly. We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.
We do not sell or disclose the information of minors under the age of sixteen without affirmative authorization.
5. Your choices about the information we collect.
You have the option of correcting, updating, deleting and/or changing information by emailing help@eNavvi.com or by updating your profile. If you would like to update your password or change or update your credit card information, please email help@eNavvi.com for instructions on how to make such password or credit card changes or updates. We will retain information we collect for as long as your account is active or as needed to provide you Services, subject to legal obligations, in order to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at help@eNavvi.com.You may opt out of any promotional emails at any time by following the unsubscribe instructions in the promotional emails you receive from us or by sending an email to help@eNavvi.com.
If you have questions or concerns about market research programs we may conduct you can send an email to help@eNavvi.com.
6. How are "tracking technologies" used in/on our Services?
Technologies such as cookies, beacons, tags, and scripts are used by eNavvi and our marketing partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements on both the native iOS and Android apps, as well as eNavvi.com, and to gather information about our user base. For example, we may receive reports based on the use of these technologies on an individual as well as aggregated basis. In doing so, we may collect personally identifiable and non-personally identifiable information (including, but not limited to, domain type, browser type and version, service provider and IP address, referring/exit pages, operating system, date/time stamp, email address, and click-stream data). We may also compile statistics about how our visitors collectively interact with the Services. We may also supplement this information we collect with other publicly available or commercial sources to build out user profiles for improved targeting and to share with our advertisers for their services.
Cookies are bits of electronic information that a website may transfer to a visitor’s computer to identify specific information about that visitor’s use of that website. Session cookies or transient cookies are cookies that are stored in temporary memory and are not retained when the browser is closed. Session cookies do not collect information from your computer and typically will store information in the form of a session identification that does not personally identify you.
Persistent cookies assign a unique identification to your computer and are typically stored on your computer’s hard drive and are used to help track clicks as you use or access the Services. Persistent cookies remain on your computer until affirmatively deleted by you.
We may also use web beacons or clear.gifs. Web beacons or clear.gifs, and similar technologies are pieces of code placed on a web page to collect data on the users of a specific web page.Server Logs and Widgets:
We may use web server logs. A web server log is a record of activity created by a computer that delivers certain webpages to your browser. Certain activities that you perform utilizing the Services may record information in server logs. For example, the server log may record the search term(s) you use, or the link you clicked on to bring you to the Services. The server log may also record information about your browser, such as your IP address and the cookies set on your browser.
We may also use widgets. A widget is generally an application that can be embedded in a webpage, and which can provide real-time information to the webpage. Widgets are often provided by third parties to enable collection of data about website usage.
We may use mobile analytics software to allow us to better understand the functionality of our Services. This software may record information such as, but not limited to, how often you use the application, the events that occur within the application, usage information, performance data, and where the application was downloaded from.
We or third parties with whom we may partner to provide certain features within our Services or to display advertising based upon your browsing activity use LSOs (Local Shared Objects), which are similar to cookies, to collect and store information. Various browsers may offer their own management tools for removing LSOs.
We may partner with third parties to either display advertising on our website and mobile applications or to manage our advertising on other sites. Our third-party partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you targeted advertising based upon your browsing activities and interests.
Our Services do not respond to browser “Do Not Track” signals. By using or accessing the Services and/or by contacting us and/or by providing any of your information, you give us your consent to track your activities using the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send you.
7. California Privacy Rights Notice
Effective Date: January 1st, 2022
Where noted in this Notice, the CCPA temporarily exempts Personal Information reflecting a written or verbal business-to-business communication ("B2B Personal Information") from some its requirements.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("Personal Information"). Personal Information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
We collected the following categories of Personal Information from you within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other Personal Information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of Personal Information listed above from the following categories of sources:
Directly from you. For example, from your use of the Services.
Indirectly from you. For example, from observing your actions on our website your interaction with our Services.
Use of Personal Information
We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information. For example, responding to questions about services; processing payment or provision of services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your experience through our Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message with your consent, where required by law.
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
To provide our paying commercial clients or prospective commercial clients (for example, pharmaceutical companies) with information about your use of the Services and Usage Behavior Information.
To provide our Continuing Medical Education Partners with information about your use of the Services, Usage Behavior Information, and information as required for your CME credit(s), Continuing Medical Education Partner’s reporting obligations to the relevant accreditation bodies, and/or for their internal recordkeeping and regulatory purposes.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose or sell your Personal Information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights, below).
We share your Personal Information with the following categories of third parties:
Clients that pay for use of the information including pharmaceutical companies.
Continuing Medical Education Partners.
Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other Personal Information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
Third Party Partners
Sales of Personal Information In the preceding twelve (12) months, Company has sold the following categories of Personal Information:
B. California Customer Records Personal Information categories.
D. Commercial information.
F. Internet or other similar network activity.
I. Professional or employment-related information.
K. Inferences drawn from other Personal Information.
We sell your Personal Information to the following categories of third parties:
Commercial clients (including prospective commercial clients). For example, pharmaceutical companies, media agencies that represent such pharmaceutical clients and medical societies as well as Continuing Medical Education Partners.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or selling that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
sales, identifying the Personal Information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B Personal Information. Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies, including B2B Personal Information.We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B Personal Information. Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email.
Contact us at help@eNavvi.com
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact the email address referenced above.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include:
Name, address, usernames (where applicable) and email address. We may use this information to surface a series of security questions to you to verify your identity.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Please also note that any support issues related to your use of eNavvi must be sent to help@eNavvi.com.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us through email help@eNavvi.com:
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into Personal Information sales at any time by:
Emailing us at Help@eNavvi.com
We will only use Personal Information provided in an opt-out request to review and comply with the request.
For Access, Data Portability, Deletion, or Sale Opt Out rights, we cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Any disclosures we provide will cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to help@eNavvi.com.
8.Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
9.Contact Information and Feedback
If you have general questions about your eNavvi account, including application issues, questions over payment, or technical questions, please email help@eNavvi.com.
If you have any questions or comments about this privacy notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
LAST UPDATED: 6/25/2022