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Your privacy is important to Charles River Analytics, Inc. (“Charles River”, “we,” or “us”). This Privacy Policy describes Charles River’s information practices in connection with the Application, including what type of information is gathered and tracked, how the information is used, and with whom the information is shared.
BY USING THE APPLICATION, YOU INDICATE YOUR UNDERSTANDING AND ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THESE TERMS, DO NOT USE THE APPLICATION.
Please carefully read this Privacy Policy as it may have changed since your last use of the Application. Continued use of the Application indicates your understanding and acceptance of any changes made to this Privacy Policy. This Privacy Policy does not cover the privacy practices of any third parties to which the Application may link.
This Privacy Policy applies to all information collected from End Users by Charles River (or carefully selected third parties acting on our behalf). This Privacy Policy does not cover the privacy policies of any third party to which the Application may link.
The Application is a virtual simulator for training, practicing, and assessing mass casualty and emergency medicine skills. When an End User opens or otherwise accesses the Application (thus commencing a Session), the End User will be presented with virtual scenarios and patients on which to practice trauma and mass casualty medicine skills. The Application processes the End User’s actions during the scenarios and generates data on training effectiveness, as well as performance data necessary to improve the application (the “End User Data”).
Note that End User Data is anonymized and does not contain Personal Information. The Application does not collect Personal Information, but we may collect Personal Information in other ways if you:
The types of Personal Information we collect may include (but are not limited to):
Charles River only uses End User Data to facilitate the transaction requested by the End Users and to monitor and enhance performance of the Application. Charles River only shares aggregated and anonymized End User Data with selected partners for research purposes and to enhance the reliability and performance of the Application. Please note that End User Data does not contain Personal Information, thus the section below titled “Sharing of Personal Information” does not apply to End User Data. End User Data is only shared as described in this paragraph.
Charles River will not sell, rent, or lease your information, including your Personal Information, to others. Charles River shares Personal Information with other companies working on our behalf. Except as described in this Privacy Policy, we will not disclose your Personal Information to third parties for their own marketing purposes unless you have provided consent.
Sharing with third-party providers: In some cases, we use third parties to collect, use, analyze, and otherwise process information, including Personal Information, on our behalf. This includes our use of certain products and services provided by third parties for the purposes of enabling certain features of the Application. We occasionally hire other third parties to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting our website, processing transactions, or performing statistical analysis of our products and services. Service providers will be permitted to obtain only the Personal Information they need to deliver the service. They are required to maintain adequate safeguards to protect the confidentiality of the information and are prohibited from using your information for any other purpose.
Compelled disclosures: We may access or disclose your information, including your Personal Information, if we believe such action is necessary to: (a) comply with the law or legal process served on Charles River; (b) protect and defend the rights or property of Charles River (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of users of Charles River services or members of the public.
Opting Out: Charles River provides a number of ways for you to “opt-out” of receiving additional information from us or having us provide your Personal Information to our partners. We may offer you these choices at the time you give us your Personal Information. If you do not wish to continue receiving certain marketing materials (e.g., email messages), you can opt-out of receiving these materials by following the instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, software updates, or other administrative and transactional notices.
How to update your information: To modify the contact information that you have provided to us, you can contact us at legal@cra.com or by mailing us at 625 Mount Auburn Street, Cambridge, MA 02138. Please note that we cannot modify all information provided to us, such as anonymized data. We will comply with requests to modify information to the extent that we are able to do so.
In order to protect your information, including your Personal Information, from improper disclosure, Charles River uses commercially reasonable efforts to maintain a secure operating environment to protect any information we collect. Browsers offer varying degrees of security, particularly in regard to encryption. Even the same version of a browser can come with different levels of encryption. Review your browser’s settings for more information. While we are committed to protecting your privacy, please be aware that no transaction over the internet can be completely secure.
Notice to Minors and their Parents or Legal Guardians: The Application is intended for adults. We do not knowingly or intentionally collect information from anyone under the age of 18. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION THROUGH THE APPLICATION. Charles River cannot control what users submit; In the event Charles River receives information from a minor, it is Charles River’s practice to immediately delete such information upon discovery that such information is in Charles River’s possession. If you know of a minor who has provided us with information, please contact us immediately.
Specific Provisions for California Residents: This section of the Privacy Policy applies only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete, and opt out, and requires businesses collecting or disclosing Personal Information to provide notices and means to exercise rights. For Purposes of this section, “Personal Information” has the definition set forth in the CCPA.
California Notice of Collection: In the past 12 months, we or our service providers have collected the following categories of information enumerated in the CCPA in connection with the Application:
We do not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA would be interpreted to include any of the activities described in the “Sharing of Personal Information” section above, we will comply with applicable law as to such activity.
Right to Know and Delete: If you are a California resident, you have the right to delete Personal Information we have collected from you and you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following:
To exercise any of these rights, please submit a request to us at legal@cra.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten days. We may require specific information from you to help us verify your identity and process your request. Please note that, in many instances, we do not collect types of information that enable us to identify you, or we do not retain such information. As such, if we do not have information that permits us to verify your identity, we may deny your requests to know or delete. A request for access can be made by you only twice within a 12 month period.
Right to Opt Out: Under the CCPA, you have the right to opt out of the sale of your Personal Information to third parties at any time. Charles River does not “sell” your Personal Information as it is currently defined under the CCPA. You may contact us by emailing us at legal@cra.com if you have any questions or concerns.
Authorized Agent: You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
California Do-Not-Track Notice: We do not track End Users over time or their activity across third party websites; accordingly, we do not respond to Do Not Track (DNT) signals.
Notice to International Residents: Charles River is headquartered in the United States and has service providers operating in the United States. The Application is primarily operated and managed on servers located and operated within the United States. In order to submit information through the Application, you may be sending your Personal Information to the United States. Accordingly, if you reside or are located outside of the United States, your Personal Information may be transferred to or accessed in a country that may not provide the same level of protection for your Personal Information. We are committed to protecting the privacy and confidentiality of Personal Information when it is transferred.
Additional Information for Users in the European Economic Area and United Kingdom: Charles River and our service providers may receive and/or access your Personal Information in jurisdictions that may not provide levels of data protection equivalent to those in your country of residence. By using the Application, or otherwise interacting with us, regardless of where you live or where you provide information to us, you consent to our use and our service providers’ use of your Personal Information worldwide and to the transfer of your Personal Information to countries outside of your country of residence, including the United States. In certain circumstances, courts, regulatory agencies, law enforcement agencies, or security authorities in those other countries may be entitled to access your Personal Information.
Charles River will take adequate measures designed to protect the transfer of Personal Information of individuals in the European Economic Area (EU Member States, Iceland, Liechtenstein and Norway) (“EEA”), such as relying on the European Commission-approved Standard Contractual Clauses (“EU SCCs”), as may be updated from time to time, as a legal mechanism for such transfer, or other adequate transfer mechanism as required under relevant data protection laws, as well as additional safeguards, where appropriate. A copy of these clauses may be obtained by contacting us at the email address provided herein.
For transfers to or from the United Kingdom (“UK”), we make use of the EU SCCs, as modified by the UK’s International Data Transfer Addendum (collectively the “UK SCCs”). For individuals located in the EEA or the UK, the term “Personal Information,” as used in this section, is equivalent to “personal data” under applicable European and UK data protection legislation.
If you are located in the EEA, the UK, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your Personal Information, as defined by the General Data Protection Regulation (“GDPR”), and the following notices apply to you:
Legal Basis for Processing: When we process your Personal Information, we will do so in reliance on the following lawful bases:
Data Retention: We store data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Your Rights: For individuals in the European Union, according to the GDPR, you have the following statutory rights:
If would like to exercise your rights, please let us know by sending an email at legal@cra.com.
You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.
Changes to this Privacy Policy: Charles River reserves the right to change this Privacy Policy from time to time.
Enforcement: Charles River regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns to us at the addresses indicated below.
Links to Other Sites: The Application may provide links to third-party websites, such as those of our business partners and online advertisers. You should review their privacy policies to learn more about what, why, and how they collect and use personally identifiable information.
For Questions or Concerns: If you have questions or concerns regarding this statement, you should first contact legal@cra.com. Other correspondence may be sent to:
Chief Compliance Officer
Charles River Analytics, Inc.
625 Mt. Auburn Street
Cambridge, MA 02138 USA
This Privacy Policy was last amended on January 5, 2023.
