Effective Date: March 21, 2021

Welcome. 

The FLCCC Alliance respects the privacy of visitors to our websites and online services and values the confidence of our partners, patients, and employees. This Privacy Policy and Notice of Information Practices (“Privacy Notice”) sets forth the FLCCC Alliance’s practices regarding the collection, use and disclosure of information that you may provide through the website(s) that we operate, their subdomains, and all portals, applications, products, services, events and any interactive features, applications or other services that link to this Privacy Notice (“Website” or “Site”), as well as Personal Information provided to the FLCCC Alliance by any means. Additional privacy disclosures may be made at the time of collection of the information. Please read the entire Privacy Notice before using our Website or our Services. By using the Website, you agree to abide by the terms of this Privacy Notice. This Privacy Notice is also part of our Terms and Conditions, which govern your use of the Website.

Your Safety and the Security of Your Personal Information

As with all information on the internet, we urge our users to proceed with caution to maintain their digital privacy. Our priority is your safety and security online. We only use the information you provide to us to provide you with the services we offer, and we will not ask you for information that is not required for our services.  Please do not provide us with additional personal or health information if it has not been requested, and do not provide us with protected health information of any patient. If you provide us with personal information, such as uploading a photo or video to our social media, or commenting on another user’s video, please make sure that your content does not include personal information that could be used to specifically identify you or those around you, such as full names, physical addresses or locations, passwords, or other personal information that is not available to the public.  

Please note that email sent to or from FLCCC is not encrypted, and such information is not secured.  Email communication also is not compliant with HIPAA security standards, and any personal information, including protected health information, could be exposed if sent through insecure means.  FLCCC is not responsible for the privacy or security of information sent via email, and disclaims any liability under HIPAA or other federal, state, or international laws relating to information privacy. 

While we maintain a variety of security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide through the Website, no data transmission over the Internet or stored on a server can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction or inadvertent disclosure of your information. Please see our Terms and Conditions for additional information. 

Collection of Information

We may ask you for some or all of the following types of information when you access various content or features of the Website or submit content, or directly contact us:

• Contact information, such as name, email address, postal address, organization, and telephone number; 
• The contents of your message to us in any “Contact Us” form, email communication, or telephone call; 
• If you request to join the Alliance, we may ask for your medical specialty, city, state and country, URL address, hospital or organizational affiliation, or the components of MATH+ you have used and your comments or observations on the MATH+ protocol use;   
• Online identifiers, such as Internet Protocol (“IP”) address, cookies, username, and password;
• Information from social media and payment processor (such as PayPal) accounts;
• Language preference
• Search queries; and
• Correspondence and other information that you send to us.

We also may collect certain information automatically when you visit the Website, including:

• Your IP address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
• Other unique identifiers, including mobile device identification numbers (e.g., IDFA, Android/Google Advertising ID, IMEI);
• Your browser type and operating system;
• Your device characteristics; 
• Sites you visited before and after visiting the Sites;
• Pages you view and links you click on within the Sites, including remembering you and your preferences;
• Your device location and/or other geolocation information, including the zip code, state, or country from which you accessed the Sites; 
• Information collected through cookies, web beacons and other technologies;
• Information about your interactions with email messages, such as the links clicked on and whether the messages were received, opened, or forwarded; and
• Standard Server Log Information.

We may use cookies, pixel tags and similar technologies to automatically collect this information. Cookies are small bits of information that are stored by your computer’s web browser. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Website, you consent to our use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Website. You can get more information about Cookies and Tracking Technologies, and instructions on how to opt out of these items, in our Cookie Policy.

Use of Information

We may use information that we collect through the Website or in person for a variety of purposes, including to:

• Operate and improve our Website, products, information, and services;
• Understand you and your preferences to enhance your experience and enjoyment using our Website, products, and services;
• To perform our contractual obligations with you and with others;
• Respond to your comments and questions;
• Provide and deliver products, information, or services you request;
• Meet our audit, compliance, and regulatory obligations as a non-profit; 
• Send you information, including emails, newsletters, confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
• Communicate with you about upcoming events and news about products, information and services offered by the FLCCC Alliance or our affiliates;
• Link or combine with other personal information we get from third parties, to help understand your needs and provide you with better service;
• To provide statistics or research on issues relating to the Alliance;
• Comply with a law, court order, or other judicial or administrative process; 
• Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
• As otherwise described to you at the point of collection or pursuant to your consent.

Sharing of Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

• Corporate Parents, Partners and Affiliates. As applicable, we may share your information with affiliated entities for a variety of purposes, including research, business, operational and marketing purposes.
• Service Providers. We may share your information with service providers that perform certain functions or services on our behalf (such as to host the Website, manage databases, process data, third party payment processors (like PayPal), perform analyses or send communications for us).
• Other Parties When Required by Law or as Necessary to Protect the Website. We may disclose your information to third parties in order to: protect the legal rights, safety and security of the FLCCC Alliance, affiliates and the users of our Website; enforce our Terms and Conditions; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government entity, whether or not legally required.
• In Connection with a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
• Other Parties with Your Express or Implied Consent. We may share information about you with third parties when you consent to such sharing (e.g., if you use a link to share an article from www.flccc.net to social media, or if you ask us to provide your information to a third party).
• Aggregate Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregated website usage data or demographic reports or research results.  This information is not considered personal information.
• In addition, we may allow third parties to place and read their own cookies, web beacons and similar technologies to collect information through the Website. For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, and analytics. Please note that you may need to take additional steps beyond changing your browser settings to refuse or disable some of these technologies. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Website may no longer be available to you. You understand that when you use the Website, these analytics providers may collect information related to your use of the Website.  You may have more options in our Cookie Policy.

Response to “Do Not Track” Signals

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. However, because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. You can learn more about Do Not Track here. 

Children’s Privacy

The FLCCC Alliance respects the privacy of children, and no part of our Site is targeted to attract anyone under the age of 18. The FLCCC Alliance does not knowingly collect, use, or disclose personal information from children under the age of 18 without prior parental consent. If you believe we have information regarding a child under the age of 18 that you have not authorized, you may contact us at [email protected] to request deletion of that information. 

International Transfers of Information 

If you are visiting the Site from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Site will be created on servers located in the United States, and all information you provide will be maintained on web servers and systems located within the United States. Your information, including your Personal Information, may be transferred to – and maintained on – computers located in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. Your consent to this Privacy Notice, followed by your submission of your information represents your agreement to the collection, storage, processing and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States.

The FLCCC Alliance will take all the steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Notice and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Your Choices Regarding Your Personal Data

If you receive emails or other communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive, or by contacting us directly at our contact information below. If you opt out, we may still send you non-promotional emails, such as emails about our ongoing business transactions (such as a donation receipt). We ask that you keep your information updated, and you may request changes or updates to your personal information by sending a request to us at [email protected]. Users in certain jurisdictions may have additional rights, as outlined below.

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of or located within the European Economic Area (“EEA”), you have certain additional data protection rights. These rights include:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below. 
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where the FLCCC Alliance relied on your consent to process your personal information.

Legal Basis for Processing Personal Information Under GDPR

In most instances, the FLCCC Alliance is a controller of Personal Information; however, in some instances the FLCCC Alliance may be a processor of Personal Information. FLCCC Alliance’s legal basis for collecting and using the Personal Information described in this Privacy Notice depends on the Personal Information we collect and the specific context in which we collect it.

The FLCCC Alliance may collect or process your Personal Information because:

• We need to provide a service to you;
• You have given us your consent to do so;
• The processing is in our legitimate interests and it is not overridden by your rights; or
• To comply with the law.

Retention of Information

The FLCCC Alliance will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

The FLCCC Alliance will also retain Personal Information and usage data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

Disclosure of Personal Information

Disclosure for Law Enforcement – Under certain circumstances, the FLCCC Alliance may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

The FLCCC Alliance may disclose your Personal Information in the good faith belief that such action is necessary to:

• To comply with a legal obligation; 
• To protect and defend the rights or property of the FLCCC Alliance; 
• To prevent or investigate possible wrongdoing in connection with the Service; 
• To protect the personal safety of users of the Service or the public; and/or
• To protect against legal liability.

Exercising Your Rights Under GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the details in the Contact Information section below. You may make a request related to your personal information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time. 

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us at [email protected]. 

For more information about GDPR, please contact your local data protection authority in the EEA. 

Your Additional Data Protection Rights Under the Lei Geral de Proteção de Dados (LGPD)

If you are located in the national territory of Brazil, you have certain additional data protection rights under the Lei Geral de Proteção de Dados (“LGPD”). These rights include:

• The right to confirmation of the existence of the processing;
• The right to access the data;
• The right to correct incomplete, inaccurate or out-of-date data;
• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;
• The right to the portability of data to another service or product provider, by means of an express request;
• The right to delete personal data processed with the consent of the data subject;
• The right to information about public and private entities with which the controller has shared data;
• The right to information about the possibility of denying consent and the consequences of such denial; and
• The right to revoke consent.

Legal Bases for Processing Data Under the LGPD

The FLCCC Alliance’s legal bases for collecting or processing your Personal Information are as follows:

• We need to provide a service to you;
• You have given us your consent to do so;
• The processing is in our legitimate interests and it is not overridden by your rights; or
• To comply with the law.

Duration of Processing

The FLCCC Alliance will process and retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

The FLCCC Alliance will also retain Personal Information and usage data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

Exercising Your Rights Under the LGPD

If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the details in the Contact Information section below. You may make a request related to your personal information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in order to obtain the information. We will respond to your request within 15 days or let you know if we need additional time. 

California – Shine the Light Act – Third Party Marketing 

California Civil Code Section 1798.83 permits California residents to request information regarding the disclosure of their personal information to third parties for the third parties’ direct marketing purposes. At this time, the FLCCC Alliance does not share any personal information with third parties for their direct marketing purposes. Furthermore, as a non-profit 501(c)(3), FLCCA is not subject to the California Consumer Privacy Act (CCPA) at this time. 

Social Networking Services

The FLCCC Alliance may work with certain third-party social media providers to offer you their social networking services through our Website. For example, you can use third-party social networking services, including but not limited to Facebook, Twitter, and others to share videos and other information about your experience on our Website with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Website. These third-party social networking services also may notify your friends, both on our Website and on the social networking services themselves, that you are a user of our Website or about your use of our Website, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.

Policy Updates

This Privacy Notice may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the policy in the upper left corner of this Privacy Notice so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Notice regarding use or disclosure of personal information, we will provide advance notice through the Website. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. If you are concerned about how your personal information is used, please visit our Site often for this and other important announcements and updates. 

Contact Information

If you have any questions about this Privacy Notice, please contact us at:

Privacy Officer

Front Line COVID-19 Critical Care Alliance
2001 L Street NW, Suite 500

Washington DC  20036

Email: [email protected]

Phone: 513-486-4696