Privacy Policy - Snow Companies

Privacy Policy

Effective: January 1, 2020
Updated: July 1, 2020

Bringing patients together to connect with one another and exchange ideas with the life science industry is our passion.  We engage with patients every day, so we understand the importance of patient privacy.  This Privacy Policy identifies the types of personal information that we may collect from you, how we collect, protect, and use your personal information, how your personal information may be shared, how you can control that sharing, and the rights you have in the personal information we collect from you.  We do not and will not sell your personal information. In addition, this Privacy Policy informs how long we will keep your personal information and how to contact us if you have any questions about this Privacy Policy or our use of your personal information.

Who are we?

Snow Companies, LLC, together with its affiliates Snow Link, LLC, Snow Health, LLC, Snow P2P, LLC, and Patient Ambassador Company, LLC, (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 know that every person impacted by a chronic health condition, whether as a patient or as a friend or family member, has a story to tell.  We have developed proprietary and innovative techniques to help you – the person impacted by a chronic health condition — to Find Your Voice™ and Share Your Story™.

How do we collect your personal information?

We collect personal information in one of the following ways:  (1) directly from you when you call us to register for an educational program or participate in one of our many events;  (2) directly from you at a program or event if you sign-up and opt-in to receive communications from us; (3) directly from you when you submit a response card provided by your health care provider; (4) directly from you when you submit a Patient Ambassador Nomination form through our website, https://snow-companies.com (the “Website”)  to nominate yourself for one of our Patient Ambassador® programs; (5) directly from one of our clients if you previously opted-in to receive communications from them and we are handling those communications; or (6) directly from you when you submit an application for employment or otherwise become employed by us.

What personal information do we collect?

We collect only the personal information that you voluntarily provide to us.  See the information we collect [here]. The information we ask you to provide varies based upon the purpose for collecting your information. 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 telephone number. We may ask about your personal health, including any diagnoses or chronic health conditions. If you are interested in participating in a patient engagement program, we collect the information you included on the Patient Ambassador Nomination form or on a response card. If you are interested in participating in a patient engagement program, you will be asked to provide your date of birth and physical address, information about your personal experiences with a chronic health condition, and other information about your life, such as your family status, your occupation, your educational background, your medical history, and your activities and hobbies.  If you are contracted to participate in a patient engagement program, we will collect your social security number and banking details in order to provide your honorarium and any expense reimbursement. Finally, we may request that you provide a photograph or other image of yourself.

If you are interested in exploring employment opportunities at Snow, we will collect the personal information that you provide on your job application, which may include your name, personal contact information, and your educational and professional background and experience.

How do we use your personal information?

Your relationship with Snow determines how we use your personal information.  We will use your personal information only to fulfill the 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 to manage your participation based upon the program’s unique requirements.  This might 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 you may incur.  We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Personal information submitted as part of an application for employment is used solely to evaluate your qualifications and experience and to contact you to discuss any employment opportunities. If you become an employee of Snow, we will use this personal information as necessary for human resources purposes.

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.

How do we share personal information?

WE DO NOT SELL YOUR PERSONAL INFORMATION. We may share your personal information only as provided in this Privacy Policy.  We may share your personal information with a third party if needed to further the purpose for which it was received.   For example, if you register for a program, we may share your personal information with our client who is sponsoring the program.  We only share personal information with third parties with whom we have a contractual relationship that requires your personal information to be secured and protected against disclosure and not used for any purpose except performing the business purpose for which it was collected.

In addition, we will share or transfer your personal information to a third party 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; (6) you have given consent.

The information that we have shared with third parties in the preceding 12 months is limited to personal identifiers and health information.

Is any information collected automatically?

Our Website uses Google Analytics, a third-party web analytics service provided by Google LLC.  Google Analytics uses automated technologies to collect information, such as device identifiers, server logs, IP addresses of devices used to access our Website, domain name, identifiers associated with your devices, the type of device used to access the Website, the operating system used, information about your web browser, language preferences, clickstream data, your interactions with the Website (such as the web pages visited, length of time spent on the Website and specific web pages, any links that you click, videos you watch and features you use), the pages that led or referred you to the Website, the date and time you used the Website, geolocation information, and other information about your use of the Website. We use this information to better understand how users find and interact with our Website, provide a better user experience, and diagnose technical issues.  We do not collect any personally identifiable information in this manner. To learn more about Google Analytics, please visit www.google.com/analytics/learn/privacy.html. You may opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout?hl+en=GB.

What about cookies?

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We and our third-party service providers may use beacons in emails to help us track response rates, identify when our emails are accessed or forwarded, and for other purposes listed below.

To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer. You may adjust the cookie settings on your web browser at any time and can stop certain types of cookies from being downloaded on your computer by selecting the appropriate settings.

Our Website is not designed to respond to “do not track” signals received from browsers. Please note that, without cookies or other automated tools, you may not be able to use all of the features of the Site.

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 the personal information about you 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. To exercise any of these rights, please submit a written request to privacy@snow-companies.com, or Privacy Officer, Snow Companies, LLC, 133 Waller Mill Rd., Williamsburg, VA 23185, or, via phone, at 844-819-6925. We will respond to your request promptly upon receipt, or as required by law. If you are a resident of California, please review the California Privacy Notice below.

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: privacy@snow-companies.com; via regular mail: Snow Companies, LLC, 133 Waller Mill Rd., Williamsburg, VA 23185.

Updates to this Privacy Policy

This Privacy Policy 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 Policy 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: privacy@snow-companies.com; 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.

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 privacy@snow-companies.com, 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 the CCPA, 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 privacy@snow-companies.com 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.

NO

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 the purpose of the California Consumer Privacy Act, “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.
Privacy Policy