1. Introduction

We are committed to safeguarding the privacy of our website visitors and the representatives of our member organizations.

This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

In this policy, “we”, “us” and “our” refer to HL7 Vulcan, an HL7 FHIR accelerator operating as part of Health Level Seven International. For more information about us, see Section 13

 

2. The personal data that we collect

2.1 In Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name and email address. The source of the contact data is you, provided directly through our contact forms or mailing list subscription.

2.3 We may process information contained in or relating to any communication that you send to us (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our contact forms (managed through Monday.com) will generate the metadata associated with communications.

2.4 We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our hosting provider Hostinger, WordPress, and Google Analytics.

 

3. Purposes of processing and legal bases

3.1 In Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations – We may process your personal data for the purposes of operating our website and responding to general correspondence and enquiries. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and operations as an HL7 FHIR accelerator.

3.3 Communications – We may process contact data and/or communication data for the purposes of communicating with you by email, providing support services to our members and volunteers, and responding to enquiries. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, members, volunteers, and the proper administration of our website and operations.

3.4 Mailing list communications – We may process contact data for the purposes of sending updates and information to our mailing list subscribers and designated representatives of member organizations. The legal basis for this processing is consent (for mailing list subscribers) or our legitimate interests (for communications with member organization representatives), namely keeping our community informed about HL7 Vulcan activities and developments.

3.5 Research and analysis – We may process usage data for the purposes of researching and analyzing the use of our website. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website and operations generally.

3.6 Record keeping – We may process your contact data and/or communication data for the purposes of creating and maintaining our records through our Monday.com CRM system. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our operations in accordance with this policy.

3.7 Security – We may process your personal data for the purposes of security and the prevention of any criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website and operations, and the protection of others.

3.8 Legal claims – We may process your personal data where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this process is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.9 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

 

4. Providing your personal data to others

4.1 Your personal data submitted through our website contact forms will be processed and stored through Monday.com, our CRM system provider.

4.2 Your personal data held in our website database will be stored on the servers of our hosting services provider, Hostinger (https://www.hostinger.com/</a >).

4.3 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside your jurisdiction under applicable data protection law.

5.2 As HL7 Vulcan operates as part of Health Level Seven International, which is based in the United States, your personal data may be transferred to and processed in the United States. We serve a global community, and personal data may be transferred internationally as necessary for the purposes set out in this policy.

5.3 The hosting facilities for our website are situated in locations provided by our hosting provider Hostinger. Transfers to these locations are protected by appropriate safeguards in accordance with applicable data protection laws. You can find more information about Hostinger’s data protection practices at https://www.hostinger.com/privacy-policy</a >.

5.4 You acknowledge that personal data that you submit through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

 

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data for as long as reasonably required to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Specifically:

• contact data will be retained for a reasonable period following the date of the most recent contact between you and us;
• communication data will be retained for a reasonable period following the date of the communication in question;
• usage data will be retained in accordance with Google Analytics retention settings; and
• mailing list data will be retained until you unsubscribe from our mailing list.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

7. Your Rights

7.1 In this Section 7, we have listed the rights that you have under data protection law

7.2 Your principal rights under data protection law are:

• the right to access – you can ask for copies of your personal data;
• the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
• the right to erasure – you can ask us to erase your personal data;
• the right to restrict processing – you can ask us to restrict the processing of your personal data;
• the right to object to processing – you can object to the processing of your personal data;
• the right to data portability – you can ask that we transfer your personal data to another organization or to you;
• the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
• the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en</a > and Individual rights – guidance and resources | ICO</a >

7.4 You may exercise any of your rights in relation to your personal data using the contact details set out below.

 

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

 

9. Cookies that we use

9.1 We use cookies for the following purposes:

• authentication and status – We use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are provided by WordPress);
• analysis – we use cookies to help us to analyze the use and performance of our website (cookies used for this purpose are provided by Google Analytics and the Elementor plugin);
• cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

 

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics, which gathers information about the use of our website and uses cookies for this purpose. We use the information gathered by Google Analytics to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://policies.google.com/technologies/partner-sites</a > and you can review Google’s privacy policy at https://policies.google.com/privacy</a >. The cookies used by Google Analytics are named _ga and _ga+container-id.

 

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:

• https://support.google.com/chrome/answer/95647</a > (Chrome);
• https://support.mozilla.org/en-US/products/firefox/privacy-and-security</a > (Firefox);
• https://help.opera.com/en/latest/security-and-privacy/</a > (Opera);
• https://support.apple.com/en-gb/guide/safari/welcome/mac</a > (Safari); and
• https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd</a > (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

 

12. Amendments

12.1 We may update this policy from time to time by publishing a new version on our website.

12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

12.3 We may notify you of significant changes to this policy by email if you have subscribed to our mailing list.

 

13. Our details

13.1 This website is owned and operated by HL7 Vulcan, an HL7 FHIR accelerator operating as part of Health Level Seven International.

13.2 Health Level Seven International is located at 455 E. Eisenhower Pkwy, Ste 300 #025, Ann Arbor, MI 48108, USA.

13.3 Our website can be found at www.hl7vulcan.org.

13.4 You can contact us:

• using our website contact form; or
• using the contact email provided on our website; or
• by email, using james.mcdermott@ex.comhl7vulcan.org.

 

14. Data protection contact

14.1 For questions or concerns regarding data protection and privacy, you can contact: james.mcdermott@ex.comhl7vulcan.org