Privacy Notice

Effective:  January 1, 2020
Updated:  January 8, 2023

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 shared with us. This Privacy Notice describes the types of personal information that we may collect, how we collect it, protect it, and use it, how long we will keep it, how we may share it, and, lastly, your data protection rights and how to exercise them.
First, however, we want you to know that we DO NOT and WILL NOT sell your personal information.

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. (1) register for or attend an educational program, 
2. (2) participate in one of our many live or virtual events,
3. (3) request information and materials,
4. (4) send us a response card or email to indicate your interest in learning about our programs
5. (5) submit a Patient Ambassador Nomination Form through our website, https://snow-companies.com (the “Website”)  
6. (6) allow us to interview you to consider your eligibility for various programs, or
7. (7) are contracted to participate in a program or event.

If you are interested in employment opportunities with us, we collect personal information directly from you when you submit an application for employment.

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 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.
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?

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 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.

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.  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.

How do we share 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.

WE DO NOT SELL YOUR PERSONAL 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 or identify when our emails are accessed or forwarded, and other similar purposes.
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 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 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 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 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 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: [email protected]; via regular mail: Snow Companies, LLC, 133 Waller Mill Rd., Williamsburg, VA 23185.

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.

Privacy Shield  

Snow Companies complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Snow Companies has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. Please review our Privacy Shield Policy.  If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Snow Companies commits to resolve complaints about our collection or use of your personal information. Snow Companies also commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Snow Companies at: [email protected].

Snow Companies has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit jamsadr.com or send an email to [email protected] for more information or to file a complaint. The services of JAMS are provided at no cost to you.

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 [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.	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 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.