Privacy Policy

Effective Date: September 15, 2023

Date of Last Review: August 16, 2023

We, MED-Project USA (“MED-Project”), a Washington D.C. non-profit corporation, along with our affiliates, consider your privacy important. We are committed to protecting the privacy and security of personal information and to transparency about how we use personal information (also known as personal data). This MED-Project Public Privacy Policy Disclosure Statement (“Privacy Notice”) describes how your personal information is collected, used, and shared when you visit our websites, including med-project.org, and other information systems that link to this Privacy Notice (“Services”). The following disclosures explain our information-gathering and usage practices. This notice does not address our use of personal information outside the context of these Services.

Within the context of the Services, this notice explains how we use and disclose personal information. It also discusses how you can control certain uses and disclosure of personal information. We will update this notice from time-to-time, or as our privacy practices change, to ensure it accurately describes how we use your information. When we do so, we will update the dates above. We recommend that you review this notice from time-to-time for the latest information. If we change our practices in a material way, we will provide appropriate notice to you, usually through an e-mail message or through a banner or pop-up within our Services.

If you have any questions regarding this notice or our use of your information, please contact us using one of the methods detailed below.

Please note that MED-Project does not sell personal information and has never previously sold personal information.

How We Use and Share Your Personal Information

Please be aware that we use third-party tracking technologies to share information with third parties for analytics purposes, as described in the table above. These tracking technologies may include the use of third-party cookies and tracking pixels.

Personal information disclosure and sharing

In addition to the sharing with the third parties described in the table above, we may also share your information with:

• Service providers. We share your personal information with third parties that provide services to us. We typically engage these kinds of third parties with contracts that require them to use your personal information only for the purpose of delivering the services for which we have engaged the third-party and as required by law. These kinds of third parties provide business, professional, administrative, or technical support functions for us, such as payment processing, billing, data storage, quality assurance, and auditing.
• Legal compliance recipients. We disclose personal information to the courts, the government, law enforcement agencies, litigants, and similar recipients when required by law.
• Successors. We may disclose personal information associated with any part of our business to a successor or potential successor.

We also may disclose personal information with third parties with your consent or at your direction.

How We Store Your Personal Information

We use reasonable administrative, technical, and physical safeguards to protect personal information in our possession. While we make every effort to help ensure the integrity and security of our network and systems, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be completely secure, accurate, complete, or current.

We retain personal information for as long as is necessary for the purposes for which we use it, or for so long as required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when we determine how long to retain personal data:

• Retention periods established under applicable law
• Industry best practices
• Whether the purpose of processing is reasonably likely to justify further processing
• Risks to individual privacy in continued processing
• Applicable data protection impact assessment
• IT systems design considerations/limitations
• The costs associated with continued processing, retention, and deletion

Children's Privacy

We are very concerned about the safety of children using the Internet. We do not knowingly collect any personal information from those under the age of 16.

If we discover (or are informed) that we have collected personal information from a visitor under the age of 16, we will promptly delete such information.

Your Privacy Rights

Depending on the law in the state where you live, you may have certain rights regarding your personal information under the law. To exercise your rights, please submit a request by contacting us through any of the means outlined below.

Your rights may include the right to confirm whether we process your personal information, to access a portable copy, to seek correction of errors, to request deletion, and the right to opt-out of the sale of your personal information or the sharing of your personal information for behavioral advertising purposes.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization.

Your 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; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Depending on the law in the state in which you live, you may also have the right to appeal using the contact information below. When you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accord with the timelines set forth in applicable law.

Contact Us

To exercise your rights, or for more information about our privacy practices or other inquiries, please contact us by any of the following methods:

• By e-mail at legalaffairs@med-project.org
• By phone at 833-633-7765
• By postal mail at: MED-Project USA and Affiliates
  1800 M Street NW, Suite 400 South
  Washington, D.C. 20036

Right of California Consumers

Note: If you are not a California resident, the following rights may not apply to you.

Rights to Opt-out

You have the right to direct us to not sell or share your personal information for cross-contextual behavioral advertising purposes. However, because we do not sell or share your personal in formation and have never done so, there is no need to contact us to exercise this right.

You also have the right to request that we restrict our processing of sensitive personal information to only that which is necessary to deliver our products and services to you. However, we do not process sensitive personal information, so there is no need to contact us to exercise this right.

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, 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 disclosed your Personal Information for a business purpose, the Personal Information categories that each category of recipient obtained.

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, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 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.

Right to Correction

You also have the right to make a request for the correction of errors or inaccuracies in your personal information.

Exercising Access, Data Portability, Correction, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 833-633-7765
• E-mailing us at legalaffairs@med-project.org

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. You may appoint an authorized agent by providing us with a notarized affidavit. 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,
• Verification requirements may include name, address and/or phone number
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

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 (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only 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 do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We do not, and have never, sold Personal Information at any time.

Non-Discrimination

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 for goods or services, which are offered free of charge to all participants, including through granting benefits or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different level or quality of goods or services.

Personal Information Collection and Disclosure

California law requires these disclosures relating to our collection and disclosure of personal information within the past 12 months.

A. Collection of Personal Information

B. Disclosure of Personal Information

In the past twelve months, we have sold or shared information for crosscontextual behavioral advertising purposes to third parties as described in the table below. The table also shows which categories of information we have disclosed for our business purposes and lists the categories of recipients of such personal information.

Please refer to the section entitled, “Personal information disclosure and sharing,” above, for more information on our privacy practices with regard to service providers.