Privacy Notice
Last Updated: July 2024
Patient stories – it’s what we’re all about! Our passion is bringing patients together to connect and exchange ideas, both with other patients as well as with the life science industry. We engage directly with patients every day, whether it be to register someone for an educational program, to support one of our many Patient Ambassadors®, to screen someone who is interested in publicly sharing their health journey, or to support one of our many patient engagement initiatives. If you’re reading this, then we likely have interacted with you in some way. We respect your privacy and want you to understand how we collect and process the personal information, including health-related information, that you share with us. This Privacy Notice explains our approach to any personal data that we might collect from you (i) when you use our website at www.snow-companies.com (the “Site”) or our services (“Services”) (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal data we collect, why we collected it and your rights in respect of our processing of your personal data). Please see our Data Privacy Framework: Consumer Privacy Policy for information about our processing of information from individuals in the EU, UK, and Switzerland.
First, however, we want you to know that we DO NOT and WILL NOT sell your personal information.
Scope of this Privacy Notice
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control).
Further, this Privacy Notice is not intended to cover the processing of workplace personal data. Accordingly, if you are engaged as a worker for us, please see our Workplace Privacy Notice which sets out further information about how we may process your personal data in connection with your employment and/or engagement.
Who are we?
Snow Companies, LLC, together with its affiliates, (collectively “Snow”, “we”, “us,” or “our”) is the industry leader in patient engagement. Our clients – primarily pharmaceutical, biotech, and medical device companies – engage us to help them connect with patients and develop innovative programs to support the patient community. We consider patients and their caregivers to be our customers. We know that every person impacted by a chronic health condition, whether as a patient, a caregiver, or a friend or family member, has a story to tell. If that person is you, we want to help you Find Your Voice™ and Share Your Story™.
How do we collect your personal information?
We collect your personal information only when you are interacting with us in some way, whether over the phone, via email, or through web pages and websites that we own or manage. For example, we collect your personal information when you:
(1) register for or attend an educational program,
(2) participate in one of our many live or virtual events,
(3) request information and materials,
(4) send us a response card or email to indicate your interest in learning about our programs,
(5) submit a Patient Ambassador Nomination Form through the Site,
(6) allow us to interview you to consider your eligibility for various programs, or
(7) are contracted to participate in a program or event.
When you use the Site, we may collect certain Behavioral Data and Technical Data (defined below) through the use of cookies and similar technologies. For more information, please see the Website insight and analysis section below.
What personal information do we collect?
The specific categories of information that we collect from you are determined by the business purpose for which you are providing it to us. For example, if you call to register for a program or request to receive future communications, we may collect your name, address, email address, and phone number. We may ask for your age to confirm that you are at least 18 years of age. We may ask about your personal health, including any diagnoses or chronic health conditions, to determine if you are eligible to participate in a client-sponsored initiative. If you are interested in participating in a patient engagement program, we collect the information you include on the Patient Ambassador Nomination Form or on a response card. The personal information we collect from you is limited to what is adequate, relevant, and reasonably necessary based upon the purpose for which it was provided.
The categories of information that we collect may change as your relationship with us changes. For example, if you are contracted to serve as a Patient Ambassador®, we may need to collect your date of birth, physical address, social security number, and banking information to process payment of your honorarium or expense reimbursement. We also may request that you provide a photograph or other image of yourself.
Categories of personal data we may collect and process about you include:
| Identity Data | First name; last name. |
| Contact Data | Home address; email address; telephone number; social media handle. |
| Applicant Data | Date of birth; gender; country; nationality; work experience; dietary requirements any other personal data that you may provide in advance of/during your supply of services to us. |
| Image Data | Photos; video recordings. |
| Financial Data | Bank account details. |
| Health Data | Information that you voluntarily share about your health condition, medical history, and treatment experience. |
| Behavioral Data | Data relating to your browsing activity, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any services you viewed through the Site. |
| Technical Data | IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device. |
How do we use your personal information?
1. If you browse the Site
When you browse the Site, we collect and process Behavioral Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way.
2. If you link to social media sites and interact with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose. Where that data is collected through your use of our Site, the data may include certain Behavioral Data and Technical Data. For more information about how we use this personal data, please see the Website insight and analysis section below.
3. Website insight and analysis
We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site. The data that is collected includes Behavioral Data and Technical Data. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use this data to analyze how you use our Site and our Services and the effectiveness of our Site and Services, including:
- to analyze how you use, and the effectiveness of, our Site and Services;
- to count users who have visited our Site and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site and Services;
- to measure the effectiveness of our content;
- to learn what parts of our Site are most attractive to our users, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see;
- to help us understand the type of marketing content that is most likely to appeal to our visitors and customers.
Our legal basis for processing
Where your data is collected through the use of cookies that are not strictly necessary, we rely on consent to collect your personal data and for the onward processing purpose. In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of performance cookies to analyze how you use our Site, it is in our legitimate interest to use your personal data in such a way to improve our Site and Services.
4. Provision of services
We will use your personal information only with your consent to fulfill the business purpose for which it was collected. For example, if you call us to register for a program, we will use your personal information to process your registration and to remind you of the program. If you are contracted to participate in one of our patient engagement programs, we will use your personal information, including your health data, to manage your participation, which may include arranging travel, coordinating training activities, facilitating communications between you and the program’s sponsor, helping you develop your personal story, scheduling programs and events on your behalf, processing the payment of honoraria, and reimbursing reasonable travel expenses. We will not collect additional categories of personal information or use your personal information for any other purposes without your consent.
We may store information that is not personally identifiable, such as your area code, your zip code, or a medical diagnosis, separate and apart from any personally identifiable information for our own internal purposes, such as tracking and data analysis. We also may deidentify your information, which means we will remove all personal identifiers from your information and use it in the aggregate for business and analytic purposes.
Our legal basis for processing
To the extent the above involves personal data, it is in our legitimate interests (or those of our clients) to process personal data in this way to enable us to provide our services. We will obtain your express consent prior to collecting and processing your health data. Where we process your personal data on behalf of our clients as a data processor, we do not require a legal basis for such processing. Where your data is collected through the use of cookies that are not strictly necessary, we rely on consent to collect your personal data and for the onward processing purpose.
5. Business administration, finance, and legal compliance
We may use an individual’s personal data (including Identity Data, Contact Data, and Financial Data) for the following business administration and legal compliance purposes:
- to facilitate the operation or effective management of our businesses;
- for financial, accounting and tax purposes;
- to comply with our legal obligations;
- to enforce or protect our legal rights;
- to deal with complaints;
- to protect the rights of third parties (including where health or security of an individual is endangered (e.g. a fire); and
- in connection with a business transition or sale such as a merger, re-organization, acquisition by another company, or sale of all or a portion of our assets.
Our legal basis for processing
Where we use personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we will rely on our obligation to comply with law (including any court order) to process such personal data.
How do we share personal information?
WE DO NOT SELL YOUR PERSONAL INFORMATION.
We may share your personal information with our contractors, service providers, and other third parties who support our business activities and help us provide services to our clients. Our contractors, service providers, and third parties are bound by contractual obligations to keep personal information confidential, secure, and protected against disclosure and to use it only for the purposes for which it was provided. For example, if you register for a program, we may share your personal information with our client who is sponsoring the program.
Otherwise, we will share or transfer your personal information only when (1) we are required by law to do so, such as for the reporting of adverse events; (2) we are required to do so by a court order or subpoena; (3) requested by government agencies, such as law enforcement authorities; (4) disclosure is necessary to establish, exercise or defend our legal rights; (5) we believe disclosure is necessary or appropriate to prevent physical or other harm; or (6) you have given consent.
How do we protect your personal information?
We protect your personal information using the same procedures and mechanisms we use to protect our own confidential and proprietary information. Snow enforces strict security and data integrity measures to protect the privacy of all personal information. We adhere to internal policies and practices that protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Snow will take reasonable steps to ensure that all personal information is reliable for its intended use, accurate, complete, and current.
Your data privacy rights.
You have the right to review your personal information that we maintain. You also have the right to correct, amend or delete any information that is inaccurate. You have the right to know the identity of any third parties with whom we have shared your personal information. You may request that we delete your personal information, but only to the extent that we don’t have a legal obligation to maintain it. We may require that you provide acceptable proof of identity prior to allowing you access to your personal information.
In addition, you have the right to confirm whether we process your personal information and to receive a copy of your personal information that we maintain. Snow does not process any personal information for targeted advertising or sales purposes.
To exercise any of these rights, please submit a written request to [email protected], or Snow Companies, LLC, 133 Waller Mill Rd., Williamsburg, VA 23185 Attn: Privacy Officer, or via phone at 844-819-6925. We will respond to your request promptly upon receipt, or as required by law. If you are not satisfied with our response, you may submit your request directly to Snow’s legal counsel at [email protected]. If you are a resident of California, please review our California Privacy Notice.
Do we collect personal information from minors?
Our Website is designed for a general audience and is not directed to children under the age of 13. Snow does not knowingly collect or solicit personal information from children under the age of 13 through the Website or through any other means. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact our Privacy Officer using one of the following methods: via email: [email protected]; via regular mail: Snow Companies, LLC, 133 Waller Mill Rd., Williamsburg, VA 23185 Attn: Privacy Officer.
Updates to this Privacy Notice
This Privacy Notice may be updated from time to time, so we encourage you to review it regularly if you have shared personal information with us. We will always include the date of last revision at the beginning of the Privacy Notice posted on our Website. Any questions or complaints regarding your personal information should be directed to Snow’s Privacy Officer using one of the following methods: via email: [email protected]; via regular mail: Snow Companies, LLC, 133 Waller Mill Rd., Williamsburg, VA 23185.
California Privacy Notice
If you are a California resident, you have certain rights as described below.
WE DO NOT AND WILL NOT SELL YOUR PERSONAL INFORMATION.
Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
How to Submit a Request: To submit an access or deletion request, please send an email to [email protected], or call us at 1-844-819-6925.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: full name, email address, physical address, and phone number. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information: If you choose to exercise any of your rights under California law, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact [email protected] to request this Statement in an alternative format.
The chart below shows the categories of personal information from consumers that Snow has collected within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, physical address, telephone number, mobile phone number, email address, a Social Security number. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, medical information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Health information only. | YES |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
For determining your privacy rights under California law, “Personal Information” does not include:
- Publicly available information from government records;
- Deidentified or aggregated consumer information;
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
