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Privacy Policy
Last updated: November 22, 2025
Onsera Health Privacy Notice Your privacy is important to us. Please read this Privacy Notice (“Policy”) and any other privacy notice or fair processing notice Onsera Health, Inc. (“Onsera”, “we” and “us”) may provide on specific occasions carefully, as it is meant to help you understand what information we collect, why we collect it, how we process it and your rights. This Policy has been drafted as to be applied to personal information processing activities globally in compliance with US Law and the EU General Data Protection Regulation (GDPR). This Policy supplements our other notices and is not intended to override them.
1. Policy Scope
This Policy applies to ways in which we interact with individuals, which we referred to herein as “Data Subjects”, in connection with our business, including, without limitation:
- visitors to our website located at www.Onserahealth.com (the “Website”) and users of any services we provide;
- individual representatives of third-party sellers, placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and other service providers, whether or not engaged by Onsera;
- directors, officers, employees and other representatives of Onsera;
- individuals applying for or enquiring about employment with us;
- individuals who consider or do invest with us and their representative agents with whom we interact during the normal course of business.
2. Privacy Law and Principles
This Policy has been drafted in accordance with the GDPR (EU General Data Protection Regulation) but may be applied to personal information processing activities globally. The processing activities may be more limited in some jurisdictions due to the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that Personal Data. In those instances, we may adjust our internal policies and/or practices to adapt to the requirements of local law.
We always strive to:
- process Personal Data lawfully, fairly and in a transparent way
- obtain Personal Data only for valid purposes that we have clearly explained to you and not use in any way that is incompatible with those purposes.
- collect Personal Data relevant to the purposes we have told you about and limited only to those purposes.
- take reasonable steps to ensure that Personal Data is accurate and kept up to date.
- subject to applicable legal or other requirements, keep Personal Data only as long as necessary.
- use appropriate technical and/or organizational measures to ensure appropriate security of the Personal Data. These measures are adjusted according to the current state of the art.
Please see the following sections for more information about specific jurisdictions:
3. Additional and supplementary privacy notices
Employees
We provide our former or existing employees with supplementary privacy notices where we are required to do so and dependent on the employees’ geographies and jurisdictions.
General
We may also provide additional privacy notices for certain entities within Onsera, categories of Data Subjects (e.g., certain investors or prospective investors in a fund managed or advised by Onsera), and certain geographies and jurisdictions.
We provide our former or existing employees with supplementary privacy notices where we are required to do so and dependent on the employees’ geographies and jurisdictions.
General
We may also provide additional privacy notices for certain entities within Onsera, categories of Data Subjects (e.g., certain investors or prospective investors in a fund managed or advised by Onsera), and certain geographies and jurisdictions.
4. Important information and who we are
The website www.Onserahealth.com is provided by Onsera Health, Inc. (‘we’, ‘our’ or ‘us’). We are the Controller of and responsible for your Personal Data as set out in this Policy.
5. What types of Personal Data do we collect?
Personal Data When we use the term “Personal Data” we mean information relating to an identified or identifiable person. Such information that makes it possible to draw conclusions about your identity, such as your name, telephone number or address. Different pieces of information, which collected together, can lead to the identification of a particular person. The personal information that we collect depends on the context of your interactions with us and the website, the choices you make and your relationship with us and may include the following types of Personal Data:
- Appointment and Interview Data
- Behavior: information about daily habits and moods.
- Candidate data: your resume, application letters and forms; job details, work history interview notes and any other information you provide us with as part of your application process.
- Commercial data: including tax information, bank account details, credit card number, money transfers including communications on bank transfers, assets, investor profile, credit history, debts, and expenses
- Communication Data: any information you voluntarily provide, including online or through communication with us.
- Contact data: data such as your postal address, tax ID, personal or work email address, mail address, work address, phone number, or other similar identifiers.
- Education and Training data: information about your education, qualifications, training, degrees, certifications, specialisms, school name; school contact details; student number; qualification details; field of study; attendance dates; graduation.
- Identification data: name, passport number, tax ID, study identification number, internet protocol address, account name, social security number, driver’s license number, age, gender, biological sex and date of birth.
- Images: including your picture and other visual information.
- Location data: includes your IP address, telephone codes, address, clinic or hospital, work address, country of birth and/or residence, questionnaires. The physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals.
- Marketing data includes preferences in receiving marketing from us and our third parties and communication preferences.
- Payment data: money owed and paid and bank account for payment, tax details.
- Technical data: includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access our website.
- Profile Data includes username and password, interests, preferences, feedback, and survey responses.
- Publicly available data includes identity and contact data from publicly available data sources such as LinkedIn, Facebook.
- Relationship data: Guardians and Parents relationship to minor data subject
- Observations preferences and opinions: information included in questionnaires and consent.
- Cookies and other similar technologies: includes information about how you use our website and services and online activity based on your interaction with us, our websites and applications for example searches, site visits browsing actions and patterns. Please read our Cookie Statement for more information.
- Other Information: relevant to conducting business with us or becoming our customer or Information classified as personal or protected information by state, federal, or other applicable law.
6. What is Sensitive or Special Category Data?
Sensitive or Special Category Data is Personal Data that needs more protection because it is sensitive.Where you choose to provide us with this information or we have a lawful reason for collecting it, we will only process that sensitive personal information in such jurisdiction if and to the extent permitted or required by applicable law.
7. Do you collect sensitive Personal Data?
We may collect sensitive Personal Data (in some jurisdictions this is called “Special Category Data”) depending on your relationship with us e.g. we collect sensitive data from candidates or potential customers:
- Health data: data concerning health, sick absence notes, disabilities, medical history, medications, work accident injuries, examination notes and test results from the study (e.g., blood type, vital signs, urine test, x-rays, physical exams, known conditions, medical survey or questionnaire results, and other study-specific procedures required by the study protocol)
- Demographic Data: including ethnicity and race.
- Sex: including sex life and sexuality.
- Pregnancy Information: Information about women who are pregnant, such as Medical history, including information about any previous pregnancies, and list of current conditions, medications taken during pregnancy, date of last period (menstruation), the date pregnancy was confirmed by lab testing, and estimated pregnancy due date, results of all tests performed during pregnancy, problems or illnesses you have during pregnancy, updates on the status of pregnancy, outcome of pregnancy (e.g., birth of full term child, birth of a premature child, miscarriage, or early termination of the pregnancy), follow-up information on newborns will also be asked for, and pregnant partner names and signed consent.
8. How do we collect your Personal Data?
From you directly
We collect personal information that you voluntarily provide to us when you complete our electronic questionnaire, express an interest in obtaining information about us, participate in activities with us or on the Website or otherwise when you contact us.
Information Collected through Technical means
Indirectly, such as your browsing activity while on our website to provide you with a good user experience when you browse our website and to allow us to improve it; we will usually collect information indirectly using the technologies explained in our Cookie Statement. When you visit our website and its subdomains as referenced above, and the landing pages of marketing campaigns that we may create and run from time to time. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some services to, among other things, track the actions of users of the services (including email recipients), and compile statistics about usage of the services and response rates as well as general demographic information and aggregated information.
Information we receive from third parties in each case where permissible and in accordance with applicable law
Sometimes we collect your Personal Data from third parties such as Clinical Research organization, agencies, marketing agencies, market research companies, our suppliers, contractors, partners or consultants, group companies.
Information we receive from public sources
We may collect personal information about you from publicly available sources, including any social media platforms such as LinkedIn, public websites and public agencies.If you are located outside of the United States, please be aware that the Personal Data we collect may be processed and stored in the United States. The United States is a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen. For more jurisdiction specific information on how we use and process your information see the sections linked below:
We collect personal information that you voluntarily provide to us when you complete our electronic questionnaire, express an interest in obtaining information about us, participate in activities with us or on the Website or otherwise when you contact us.
Information Collected through Technical means
Indirectly, such as your browsing activity while on our website to provide you with a good user experience when you browse our website and to allow us to improve it; we will usually collect information indirectly using the technologies explained in our Cookie Statement. When you visit our website and its subdomains as referenced above, and the landing pages of marketing campaigns that we may create and run from time to time. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some services to, among other things, track the actions of users of the services (including email recipients), and compile statistics about usage of the services and response rates as well as general demographic information and aggregated information.
Information we receive from third parties in each case where permissible and in accordance with applicable law
Sometimes we collect your Personal Data from third parties such as Clinical Research organization, agencies, marketing agencies, market research companies, our suppliers, contractors, partners or consultants, group companies.
Information we receive from public sources
We may collect personal information about you from publicly available sources, including any social media platforms such as LinkedIn, public websites and public agencies.If you are located outside of the United States, please be aware that the Personal Data we collect may be processed and stored in the United States. The United States is a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen. For more jurisdiction specific information on how we use and process your information see the sections linked below:
9. How and on what basis do we use your Personal Data?
We may use your Personal Data for a variety of purposes, and (to the extent applicable) on the basis of various legal bases, including, but not limited to, the following:
- Complying with legal or regulatory obligations, such as our obligations regarding know-your-client and anti-money laundering due diligence;
- Performing a contract with you or to take steps at your request before entering into a contract, including to: (i) provide you with information regarding Onsera products or services; (ii) assist you and answer your requests; (iii) evaluate whether we can offer you a Onsera product or service and under what conditions; and (iv) responding to know-your-client and anti-money laundering information requests presented by counterparties with whom we do business on your behalf or for your benefit; and
- Other legitimate business interests
We will not use your Personal Data for any purposes inconsistent with this Policy and the purpose for which it was collected, without your permission or otherwise in accordance with applicable law.For further information on this for EEA/UK residents see here.
In the event that Onsera is sold as a going concern, Personal Data may be disclosed to the buyers or the potential buyers and/or their advisers as part of the due diligence process. Any such transfer or disclosure of Personal Data will be carried out in accordance with the relevant and applicable data protection regulations, as well as be accompanied by appropriate confidentiality agreements.
10. With whom do we share your Personal Data?
Within Onsera. We share your Personal Data among Onsera entities and affiliates for the purposes set forth above. In general, Onsera entities and affiliates, in turn, are not permitted to share your information with other non-affiliates entities, except as described herein or otherwise permitted by applicable laws.To Third Parties. We share your Personal Data with third parties in certain circumstances, including the following categories of recipients:
- Service Providers. We share Personal Data with service providers that perform services on our behalf (e.g., third-party service providers to operate the Website) and with service providers and other counterparties to our clients and investors. These service providers may have access to your Personal Data but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. We generally require these providers by contract to keep the information confidential. These service providers are contractually and legally bound by our instructions to have appropriate technical and organizational measures in place to protect your personal data.
- Transaction or Other Corporate Event. Your Personal Data can be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, financing, or sale of company assets, including bankruptcy proceedings, or other investment activity, and could be transferred to a third party as one of the business assets in such a transaction. It also can be disclosed in the event of insolvency, bankruptcy, or receivership. In such an event, we will post prominent notice of the change in ownership.
- As Required by Law. We may also disclose your Personal Data if we are required to make disclosures by applicable law or to the government or private parties in connection with a lawsuit, subpoena, investigation, or similar proceeding, or as part of our legislative or regulatory reporting requirements.
- Anonymised Data. We may anonymise (aggregated data) your Personal Data so that it can be used and distributed for future research studies, our own service improvement and/or shared with third parties for improvement of their services. Where applicable, you will be provided with further information in the relevant informed consent form(s).
11. Do you have a choice about the data we collect and use about you?
Yes, you may always choose what personal information (if any) you wish to provide to us. In cases where you are requested to affirmatively provide information, such as to complete a form, or an application, or a survey on our website, you may decline to do so. Please understand, however, that in some cases certain information is required to complete an application, form, survey or contract and if you decline to provide the information requested you may not be able to submit your application or particate in the applicable activity or service. If you would like to restrict our placement of cookies on your device, please see our Cookie Statement.If you would prefer not to receive e-mail marketing messages from us, please use the opt-out instructions included in the email message to opt-out of additional communications.You may be given additional choices in the context of particular preferences tools or functions that we make available through our website.
12. Children’s Privacy
This website is intended for general audiences and not for children. Although the Website is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. If a child under the age of 13 or the equivalent age as specified by law in your jurisdiction has provided personal information (as defined by the Children’s Online Privacy Protection Act) or Personal Data (under the GDPR) to us through the Website, a parent or guardian may inform us using the contact details set out under the “Contacting us or making a complaint’ heading below, and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this Policy.
13. How do we protect your Personal Data?
We take seriously the obligation to safeguard your Personal Data. Your Personal Data held by us will be kept confidential in accordance with applicable Onsera Health policies and procedures. We will use all reasonable efforts to ensure that all Personal Data is kept secure and safe from any loss or unauthorized disclosure or use. All reasonable efforts are made to ensure that any Personal Data held by us are stored in a secure and safe place and accessed only by our authorized employees and transferees. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we do not have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
14. Transferring your information overseas
We do business globally and may centralize certain aspects of our information processing activities and data storage in different countries. We may therefore have to share and transfer your Personal Data from one country to another, or even across multiple jurisdictions. Your Personal Data may therefore be subject to privacy laws that are different from those in the country where the personal information is collected or those in your country of residences. We will ensure your personal information has an appropriate level of protection and will undertake appropriate due diligence and risk assessments prior to transferring the information. We will ensure the transfer your personal information in line with applicable privacy laws. Often, this protection is set out under a contract with the organization that receives your Personal Data. You can find more details of the protection given to your information when it is transferred overseas by contacting us.Where a privacy regulatory authority requires a corresponding privacy regulatory approval before we transfer your Personal Data outside your jurisdiction, we will obtain the approval before transferring your Personal Data. For EU/UK individuals, we can only transfer your Personal Data outside of the EEA where there is a legal basis for the transfer under Article 46 of the UK GDPR. For example, only when the country of the recipient(s) ensures an adequate level of protection, or there are suitable contractual protections in place (including approved Standard Contractual Clauses, UK IDTA and/or UK Addendum to the EU Standard Contractual Clauses).
15. Keeping your Personal Data current
In general, we seek to ensure that we keep your Personal Data accurate and up to date. However, you are responsible for, and we kindly request that you inform us of, any changes to your Personal Data (such as a change in your contact details). To update or edit your Personal Data that we have on file, including your communication preferences, please contact us using the contact details set out under the “Contacting us or making a complaint” heading below or by sending an e-mail to info@Onserahealth.com.
16. How long do we keep your Personal Data?
In general, we will process and store your Personal Data for as long as it is necessary in order to fulfil our contractual, regulatory and statutory obligations, which may differ depending on the relevant Onsera entity or jurisdiction. Subject to those qualifications, our goal is to keep such data for no longer than necessary in relation to the purposes for which we collect and use the Personal Data (we refer to the purposes as set forth above). If you have any specific questions in this respect, please feel free to contact us. Personal Data collected during employee recruitment process will be retained for 6 months after an unsuccessful application.
17. Withdrawing Consent
If we rely on your consent to process your personal information, which may be express or implied consent according to the applicable law, you have the right to withdraw consent at any time. You can withdraw your consent by using the contact details set out under the “Contacting us and making a complaint” heading.Please note that this will not affect the lawfulness of the processing before the withdrawal. We will stop any processing of your personal data based on your consent unless we have another lawful basis for processing your personal data for a different purpose.
18. Changes to this Policy
We may update this Policy from time to time. If we make any material changes to this Policy, we will change the "last updated" date of the Policy and notify you by your chosen form of communication, where this is appropriate. Changes to this Policy are effective when they are posted on this page.
19. Do Not Track
Onsera Health does not track Data Subjects over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.
20. Onserahealth.com Website Servers
Onserahealth.com is operated from servers in the United States. Please be aware that a website may contain links to other websites hosted by third parties. Onsera does not control and is not responsible for the content or privacy practices and policies of such third-party websites. We encourage you to be aware when you leave the Website and to read the privacy policies of each third-party website, especially if such website collects Personal Data from you.
21. Onserahealth.com Website Servers1. Additional Information for Residents of the European Economic Area (the “EEA”) and the United Kingdom (the “UK”)
For purposes of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 and the UK GDPR (as defined in the UK Data Protection Act 2018 (as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2018 (SI 2019/419)) (both referred to herein as the “GDPR”), in addition to the information above, the below applies to any Data Subject whose Personal Data we collect whilst they are resident in the EEA or the UK.
22. Further details about our processing of your personal information
The table below describes the ways we plan to use your Personal Data, and which Lawful Basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Lawful Basis
Types of Personal Data
Legitimate Interest
We use your Personal Data on the basis that it is necessary for legitimate interest, to evaluate applications and candidates for a vacant role prior to entering into an employment or services contract for that role with the most suitable candidate. When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law.
We use your Personal Data on the basis that it is necessary for legitimate interest, to evaluate applications and candidates for a vacant role prior to entering into an employment or services contract for that role with the most suitable candidate. When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law.
Recruitment of candidates (contractors, employees, and providers)
We will use the Personal Data we collect about you to assess your skills, qualifications, and suitability for the role for which you applied. This may include software using Artificial Intelligence and could be considered as Automated-Decision Making.
We will use the Personal Data we collect about you to assess your skills, qualifications, and suitability for the role for which you applied. This may include software using Artificial Intelligence and could be considered as Automated-Decision Making.
We may use the following Personal Data:
· Appointment and Interview Data
· Candidate data: Communication Data
· Contact data · Identification data
· Location Data· Publicly available data
· Observations preferences and opinions
· Education and Training data
· Appointment and Interview Data
· Candidate data: Communication Data
· Contact data · Identification data
· Location Data· Publicly available data
· Observations preferences and opinions
· Education and Training data
Contact
Business Contracts
Ensuring compliance with Vendor, Supplier, Consultancy and other third-party Contracts
Ensuring compliance with Vendor, Supplier, Consultancy and other third-party Contracts
We may use the following Personal Data:
· Commercial data
· Communication Data
· Education and Training data
· Contact data
· Identification data
· Location
· Payment data
· Commercial data
· Communication Data
· Education and Training data
· Contact data
· Identification data
· Location
· Payment data
Legitimate interest
Note 1: When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law.
Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law.
Note 1: When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law.
Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law.
Managing our business
We process Personal Data, as necessary and provided that your rights and interest are not overridden, for our own legitimate business interest. This relates to us managing our business to enable us to maintain and monitor the performance of our website and services and to constantly look to improve the website and the services it offers to our visitors, including when we respond to your queries, communications and complaints.
We process Personal Data, as necessary and provided that your rights and interest are not overridden, for our own legitimate business interest. This relates to us managing our business to enable us to maintain and monitor the performance of our website and services and to constantly look to improve the website and the services it offers to our visitors, including when we respond to your queries, communications and complaints.
We may use the following Personal Data:
· Communication Data
· Contact data
· Location Data
· Marketing Data
· Technical data
· Profile Data
· Usage Data
· Other Information
· Communication Data
· Contact data
· Location Data
· Marketing Data
· Technical data
· Profile Data
· Usage Data
· Other Information
Legitimate interest (see Note 1)
Provide and maintain our Websites
To provide and maintain our Website including to monitor the usage of these, troubleshooting, data analysis, network security and system testing necessary for our legitimate interests in maintaining the useability, security and integrity of our website.
To provide and maintain our Website including to monitor the usage of these, troubleshooting, data analysis, network security and system testing necessary for our legitimate interests in maintaining the useability, security and integrity of our website.
We may use the following Personal Data:
· Communication Data
· Contact data
· Location Data
· Marketing Data
· Technical data
· Profile Data
· Usage Data
· Communication Data
· Contact data
· Location Data
· Marketing Data
· Technical data
· Profile Data
· Usage Data
Legitimate interest (see Note 1)
Recommendations and marketing
We will rely on your consent when the law requires us to do so, such as when we use advertising cookies and similar technologies to send you marketing emails. Otherwise, we may rely on legitimate interest as legal basis for other marketing activities to make recommendations to you about services that may interest you. You will always have the right to opt out of marketing directed to you. To do so, please see section ‘Contacting us or making a complaint’
We will rely on your consent when the law requires us to do so, such as when we use advertising cookies and similar technologies to send you marketing emails. Otherwise, we may rely on legitimate interest as legal basis for other marketing activities to make recommendations to you about services that may interest you. You will always have the right to opt out of marketing directed to you. To do so, please see section ‘Contacting us or making a complaint’
We may use the following Personal Data:
· Identity data
· Contact data
· Technical Data
· Marketing and communications data · Usage data
· Identity data
· Contact data
· Technical Data
· Marketing and communications data · Usage data
Legitimate interest (see Note 1)
Advertising
As above. To measure and analyze the effectiveness of the advertising we serve you.
As above. To measure and analyze the effectiveness of the advertising we serve you.
We may use the following Personal Data:
· Identity data
· Contact data
· Location data
· Technical Data
· Marketing and communications data · Usage data
· Identity data
· Contact data
· Location data
· Technical Data
· Marketing and communications data · Usage data
Legitimate interest (see Note 1)
Data subject rights
Verifying your identity when you exercise your data subject rights. Fulfilling data subject rights requests.
Verifying your identity when you exercise your data subject rights. Fulfilling data subject rights requests.
We may use any categories of Personal Data we hold on you depending on the details and nature of your data subject request.
Legitimate interest (see Note 1)
Fraud and business reorganization or group restructuring.
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise.
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise.
We may use all categories of Personal Data except sensitive data, including health data depending on the legal requirement, law and circumstances.
Legal obligations
To comply with applicable law, for example in response to a request from a court or regulatory body, where such request is made in accordance with the law.
We may use all categories of Personal Data depending on the legal requirement, law and circumstances.
Consent
Note 2: We may have to get your consent to use your Personal Data, when we want to contact you for marketing purposes. Wherever consent is the only reason for using your Personal Data, you have the right to change your mind and/or withdraw your consent at any time by clicking the Unsubscribe button at the bottom of an applicable email or by contacting us.
Note 2: We may have to get your consent to use your Personal Data, when we want to contact you for marketing purposes. Wherever consent is the only reason for using your Personal Data, you have the right to change your mind and/or withdraw your consent at any time by clicking the Unsubscribe button at the bottom of an applicable email or by contacting us.
Marketing
To measure and analyze the effectiveness of the advertising we serve you and make recommendations to you about services that may be of interest to you. We may collect IP addresses and store Cookies or similar technologies on visitors’ devices.
To measure and analyze the effectiveness of the advertising we serve you and make recommendations to you about services that may be of interest to you. We may collect IP addresses and store Cookies or similar technologies on visitors’ devices.
We may use the following Personal Data, depending on what you consent to:
· Communication Data.
· Contact.
· Education and Training data · Identification data Location data
· Marketing data
· Profile Data
· Publicly available data
· Observations preferences and opinions
· Usage Data
· Communication Data.
· Contact.
· Education and Training data · Identification data Location data
· Marketing data
· Profile Data
· Publicly available data
· Observations preferences and opinions
· Usage Data
Consent (see Note 2)
Data analytics
We use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
We use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
We may use the following Personal Data, depending on what you consent to:
· Identity data
· Transaction data
· Technical Data
· Profile data
· Usage data
· Identity data
· Transaction data
· Technical Data
· Profile data
· Usage data
23. Artificial Intelligence
Artificial Intelligence (AI) can be used as an umbrella term for a range of algorithm-based technologies that solve complex tasks by carrying out functions that previously required human thinking. Where we direct you to the use of any third-party AI tools, you will always be provided with a separate Information Sheet/country specific privacy notice, explaining the nature of the processing and its purpose and where applicable, a consent form, before your Personal Data is used for any AI-assisted decision making. Regardless, Onsera Health will not use AI-assisted decision-making tools or AI-assisted outcomes for the purpose of medical diagnosis or for the purposes of medical advice. We would recommend you consult your doctor or healthcare practitioner for any medical advice. You have rights related to how your information is used for purposes of AI. Please see the next section on ‘Data Subject Rights’.
24. Data Subject Rights
Onsera Health uses your Personal Data in compliance with applicable privacy laws. Most notably, the General Data Protection Regulation (GDPR) and US data protection legislation and some laws in other regions such as Canada have rights that allow you greater control of and access to your personal data. The application of these and any other privacy rights you may have depends on applicable data protection law and if you would like more information about your specific rights under data protection law in your jurisdiction and how to exercise those rights, please contact us at: info@Onserahealth.com Applicable law may allow or require us to deny your request, or we may have destroyed, erased, or made your Personal Data anonymous in accordance with our record retention obligations and practices.
GDPR
Under the GDPR, in certain circumstances, you have certain individual rights with respect to the Personal Data that we hold about you. In particular, you may have the right to:
GDPR
Under the GDPR, in certain circumstances, you have certain individual rights with respect to the Personal Data that we hold about you. In particular, you may have the right to:
- Request access to any Personal Data held about you (commonly known as a “data subject access request”) This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- Request correction of the Personal Data that we hold about you. This enables you to have any inaccurate information we hold about you corrected;
- ·Request erasure of your Personal Data. This enables you to request data held about you to be deleted, provided the there is no reason for Onsera Health to continue processing it to perform a contract, defend a legal claim or to comply with applicable laws or regulations. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing;
- Request the restriction of or object to the processing of your Personal Data. This enables you to ask us to suspend or restrict processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- · Request transfer of appropriate Personal Data to a third party where this is technically feasible.
Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. To exercise any of these rights, please contact us using the contact details set out under the “Contacting us and making complaints” heading. We may need to request further information from you to help us confirm your identity to help facilitate your request. This is a security measure to ensure that Personal Data is not mistakenly disclosed. Alternatively, you may also verbally exercise any of your rights during your visit to a Onsera Health clinic or by calling us. We will consider and act upon any requests in accordance with applicable privacy laws. We aim to respond to all requests without undue delay and within one calendar month of receiving the request. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may extend it by another two months where we are legally allowed to do so. If that is the case, we will notify you.
25. Automated Decision Making
We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Data, including profiling, especially where such processing has legal or other significant effects on you. We may process some of your Personal Data automatically, with the goal of assessing certain personal aspects (profiling), comply with legal or regulatory obligations to combat money laundering, terrorism, financing, and offenses that pose a danger to assets. We also use assessment tools in order to be able to allow communications and marketing to be tailored as needed, all following applicable law. However, where we process your Personal Data based on solely automated processing which may have legal or other significant effects, we will only do so with your explicit consent where you will always have the right to object.
26. Contacting us or making a complaint
27. Additional Information for Residents of California
The information below may apply to Data Subjects who are residents of California.
California Data Subject Rights
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. For more information on these disclosures, please contact us using the contact details set out under the “Contact and Complaints” heading above.
In addition, Data Subjects in California may have a right under the California Consumer Privacy Act (“CCPA”) to request erasure of their Personal Data or access to Personal Data that we have collected in the last twelve (12) months.
You may submit requests for access or erasure of your personal information by contacting us at info@Onserahealth.com.
Individuals who submit requests for access or erasure of personal information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until identity is verified.
If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, or our systems or networks.
If you are making a request for erasure, we will ask that you confirm that you would like us to delete your personal information again before your request is addressed.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission.
If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request. Agents who make requests on behalf of individuals, will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified. Under the CCPA, you cannot be discriminated against for exercising your rights to access or request erasure of their Personal Data.
California Data Subject Rights
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. For more information on these disclosures, please contact us using the contact details set out under the “Contact and Complaints” heading above.
In addition, Data Subjects in California may have a right under the California Consumer Privacy Act (“CCPA”) to request erasure of their Personal Data or access to Personal Data that we have collected in the last twelve (12) months.
You may submit requests for access or erasure of your personal information by contacting us at info@Onserahealth.com.
Individuals who submit requests for access or erasure of personal information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until identity is verified.
If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, or our systems or networks.
If you are making a request for erasure, we will ask that you confirm that you would like us to delete your personal information again before your request is addressed.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission.
If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request. Agents who make requests on behalf of individuals, will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified. Under the CCPA, you cannot be discriminated against for exercising your rights to access or request erasure of their Personal Data.
28. SMS Communications and TCPA Compliance
Onsera Health complies with the Telephone Consumer Protection Act (TCPA) for all SMS communications. We will only send SMS messages to individuals who have provided prior express written consent. Please note that upon your consent to receiving these SMS communications, you may be subject to standard messaging and data rates, subject to your mobile carrier. Each message will include clear opt-out instructions (e.g., reply STOP). We will not send SMS messages outside the hours of 8:00 AM to 9:00 PM local time of the recipient.
You may withdraw consent for SMS communications at any time by replying STOP to any message or contacting us via the details above. We maintain records of SMS consent in compliance with TCPA requirements. Failure to comply with TCPA can result in statutory penalties. We take compliance seriously and implement safeguards to prevent violations.
You may withdraw consent for SMS communications at any time by replying STOP to any message or contacting us via the details above. We maintain records of SMS consent in compliance with TCPA requirements. Failure to comply with TCPA can result in statutory penalties. We take compliance seriously and implement safeguards to prevent violations.
Should you have any queries about how your information us used, or requests or complaints regarding the Website, this Policy, the Terms of Service and/or our use of your Personal Data please contact us via the Onsera Privacy Team
By email: info@Onserahealth.com
By post: US:1200 Morris Turnpike, Suite 3005, Short Hills, NJ 07078, USA
By phone: US: (917) 352-4495 (8am – 5pm ET)
By email: info@Onserahealth.com
By post: US:1200 Morris Turnpike, Suite 3005, Short Hills, NJ 07078, USA
By phone: US: (917) 352-4495 (8am – 5pm ET)