Effective Date of this Notice: November 13, 2020
Last Updated: November 13, 2020
I. Purpose of this Notice
The Henry M. Jackson Foundation for the Advancement of Military Medicine, Inc. (“HJF” or the “Company”) maintains and hosts this website, www.hivresearch.org, (the “Website”) in support of their work in HIV research and related infections. HJF collaborates on research with the U.S. Military HIV Research Program (MHRP) at the Walter Reed Army Institute of Research.
HJF is committed to protecting your privacy and other rights that you may have related to information that we collect about you or from you while you are using our Website, or at other times when you are engaging with HJF such as on the phone, in-person, electronically, or by mail. Some of the information that is collected may be considered personal data, which may be subject to the EU General Data Protection Regulation (“GDPR”). This Notice explains our practices regarding the collection, use, storage and transfer of this information and personal data (collectively referred to here as “Personal Information”) that is collected by, or provided to, HJF. Rights under the GDPR are also addressed in this Notice. Please review this Notice carefully.
By accessing, using, or registering on our website, or otherwise providing your Personal Information to HJF, you are agreeing to the collection, use, transfer, and storage of the Personal Information as described in this Notice and other notices that we may give you.
The Company reserves the right to modify this Notice at any time, without notice, to reflect changes in our practices and applicable law. Such changes will be incorporated into this document and posted on our Website and will become effective as soon as they are posted on our Website. The current version of this Notice supersedes any prior versions.
If you have any questions about the contents of this Notice, you may contact HJF by using the contact information shown at the end of this Notice.
II. When This Notice Applies
This Notice applies to you if you view our Website or if you provide us Personal Information through the Website or other means. Additional notices may apply to HJF employees who provide Personal Information during the course of their employment with the Company.
III. When will the Company Collect Personal Information?
The Company may collect or receive your Personal Information through a variety of ways – this includes (1) automatic collection of your Personal Information when you use our Website; (2) collecting Personal Information that you choose to submit through the Website, such as newsletter mailing list and publication supplement downloads.
IV. What Personal Information will the Company Collect?
- Personal Information we collect automatically when you use our Website
HJF collects certain information automatically when you access or use the Website. For example, HJF may monitor and compile statistical information concerning the usage of the Website. This information allows the Company to monitor its utilization and continuously improve its quality. Examples of this information would include, but not be limited to, the number of visitors to the Website, or to sections or pages within the Website, patterns of traffic flowing through the Website, length of time spent on the Website, or in sections or pages of the Website, the other sites that refer visitors to the Website, the pages of the Website that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Website.
In order to compile this information, HJF may collect and store your internet protocol (“IP”) address, your operating system version, your browser version, the pages you visit within the Website, the length of time you spend on pages within the Website, the site from which you linked to ours, and search terms you used in search engines which resulted in you linking to the Website. While all of this information can be associated with the IP address, it will not be associated with you as an individual, or associated with any other information you may submit through the Website, or that HJF may store about you for any other purposes.
Cookies are a small text files which are saved to your device when you visit the Website. Cookies help the Website function by remembering who you are and tracking activity across a website. The Website uses Google Analytics to receive anonymous web usage data. Google Analytics uses the following cookies:
Name:_ga; expiration: 2 years; purpose: Used to distinguish users
Name:_gid; expiration: 24 hours; purpose: Used to distinguish users
Name:_gat; expiration: 30 minutes; purpose: Used to throttle request rate
Please see https://policies.google.com/privacy#infochoices for more information about managing your privacy settings with Google.
HJF may also collect information about how the Website is accessed and used ("Usage Data"). This Usage Data may include information such as your computer’s IP address, browser type, browser version, the pages of the Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
- Personal Information that you choose to provide us while on the Website
While using the Website, you may want to provide us with Personal Information that we can use to contact or identify you and to respond to your inquiries or remain connected with you.
The following are some examples of Personal Information you may choose to provide while using the Website:
Activity Requiring Collection: You want to receive MHRP Publications, Alerts, Opportunities, or other News.
Reason for Collecting: To register to receive this information, you will provide us with information such as your name, mailing address, telephone number and email address.
Purpose and/or Basis for Collecting: We use this information to send you the communications you requested, and other information we believe may be of interest to you.
- C. Personal Information that you provide us at other times
There may be other times that you provide us Personal Information, over the phone, on a form, via email, through regular mail, or in-person. This Personal Information may be of the same type and for the same purposes as described above. Employees of HJF may be asked to provide additional Personal Information during the course of their employment.
V. The basis for using your Personal Information
We will only collect, use and share your Personal Information where we are satisfied that we have the need and the appropriate legal basis to do so. This may include, but is not limited to:
- Our use of your Personal Information is in our legitimate interest as an organization;
- Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you;
- Our use of your Personal Information is necessary to comply with a relevant or legal regulatory obligation; or
- You have consented to using the Personal Information;
VI. Sharing of Information
HJF may disclose your Personal Information in a secure manner with our affiliated companies for any of the reasons described above.
The Company may also use and share this information with third-party vendors to enable those vendors to provide services to the Company for which they have been retained, to enhance Website functionality, or in order to carry out any of the legal or business purposes listed above for collecting your information. The Company reserves the right to disclose any information obtained through or in connection with the operation of the Website in order to comply with a subpoena, court order, or similar legal process which compels the disclosure of such information. The Company will not knowingly sell, rent, or share information obtained through the use of its Website with any unaffiliated third parties for their commercial benefit except as permitted or required by law.
VII. Storage, Security and Confidentiality
Personal Information may be maintained in paper and electronic formats at Company work sites and on Company or vendor servers. Company employees who may have access to Personal Information are required to keep that information confidential. The Company also requires its contractors, part-time and temporary workers, service providers, subsidiaries, affiliates, and those employed by others to perform work on the Company’s behalf to maintain the confidentiality of your Personal Information. While the Company is committed to protecting your Personal Information from unauthorized use or disclosure and has security controls in place to limit the security risk and address any vulnerability if such a need arises, HJF cannot fully eliminate all security risks associated with the collection, use, storage and transfer of your Personal Information.
VIII. How long does the Company keep my Personal Information?
HJF will maintain your Personal Information in accordance with its customary business practices. Personal Information subject to GDPR will be stored as long as necessary to carry out the legal or business purposes for which it was collected.
IX. Children’s Privacy on the Website
HJF does not intend to collect any information from children under the age of 13 and the Website is not designed to collect information from children under the age of 13. Children under the age of 13 should not submit any Personal Information to us, through the Website or otherwise. If you believe that your child has provided us with Personal Information please see How to Contact the Company below for who you should contact.
X. Accessing the Website or Providing Personal Information from Outside the United States
If you reside outside the United States, any information that you may provide to the Company through the Website will be transferred out of your country and into the United States, which has data privacy laws that may differ from those in your home country. Your Personal Information may be less secure in the United States than in your own country. If you do not wish for your Personal Information to leave your country, please do not provide such information. By providing personal information via the Website, you expressly consent to the cross-border transfer of your information to the United States.
XI. Rights in Connection with your Personal Information Under the EU GDPR
Under the GDPR, individuals from European Union countries may have additional rights concerning the collection, use, storage, and transfer of their Personal Information. This portion of the Notice applies to you if you are an EU resident or an EU citizen using the Website or providing information to HJF. For Personal Information that we have collected, you may:
1) Request that HJF erase or delete all or some of it;
2) Request that HJF change, update or correct inaccurate information;
3) Ask the Company for a copy of the Personal Information you have provided us;
4) Ask HJF to stop using all or some of your Personal Information or to limit our use of it; and
5) Withdraw any prior consent you have given to HJF for the use of your Personal Information.
With regard to any requests made related to Personal Information maintained by HJF, HJF may:
- 1. Seek to verify the accuracy of the Personal Information before changing, updating or correcting it; or
- 2. Deny the request for deletion or erasure of Personal Information if the collection, storage, and use of such information is necessary for:
- a. compliance with a legal obligation to which HJF is subject;
- b. an overriding legitimate interest of HJF; or
- c. the establishment, exercise, or defense of legal claims.
You may object to any processing or maintenance of your Personal Information which has our legitimate interest as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you do raise an objection, we have the opportunity to demonstrate that we have an overriding legitimate interest in the Personal Information. For instance, the company needs to maintain Personal Information for all employees while employed with the Company, as well as for several years after employment ends.
See How to Contact the Company below if you would like to make a request related to your Personal Information.
XII. Updates to this Privacy Notice
The Company may update this Notice from time to time, so please review it frequently. If we change our Notice, we will post the revised version here, with an updated revision date.
XIII. How to Contact the Company
If you have any questions about this Notice, please contact the following:
MHRP Communications Department
6720A Rockledge Drive, Suite 400
Bethesda, MD 20817