Our Privacy Commitment
At Blue Matter we recognize the importance of and are fully committed to protecting the privacy of personal information related to all individuals with whom we interact – including members of the public, employees, regulatory authorities’ representatives, health care organizations’ representatives, and business partners.
About this Privacy Statement
This Privacy Statement (the ‘Statement’) is an overview of how Blue Matter and its worldwide Affiliates (to learn more about Blue Matter’s Affiliates and how to contact them directly please visit our corporate website at: https://bluematterconsulting.com/ – Contact Us section) process personal information about individuals, and illustrates Blue Matter’s commitment to ensuring that individuals can exercise choice and control over their personal information in accordance with local laws.
Scope of this Privacy Statement
This Statement is specifically intended to provide information for our website users, members of the public who interact with Blue Matter, and individuals with whom we do business (including, but not limited to, staff at regulatory authorities, personnel of suppliers and partners, and visitors to Blue Matter offices). This Statement also provides information about specific privacy practices towards specific categories of data subjects such as to individuals who may be considered for employment (“Job Applicants” or “Candidates”).
References to “Blue Matter”, “group”, “affiliates”, “we”, “us” and “our” are references to Blue Matter Corporation and its worldwide affiliates.
Please read this Statement before using Blue Matter’s website (https://bluematterconsulting.com/) or otherwise providing your personal information to us. By visiting our Website or by providing us your personal information, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Statement.
Personal Information Blue Matter May Process About You
Blue Matter may process personal information about you including, but not limited to:
- General information such as name, postal and/or email address, phone number, date of birth, and other information such as photographs and digital imagery, payment- related information, government issued identification in accordance with applicable laws (e.g. driving license, passport, professional license number), agreements, your communications preferences; queries you make to Blue Matter;
- Professional information, such as your job title, educational information, professional qualifications, work experience, programs and activities in which you participated;
Sources of Information
In most cases, Blue Matter will collect information directly from you, although sometimes we will obtain information about you from public or third party information sources including (but not limited to):
- Blue Matter may collect information about you from public or third party sources for marketing purposes (e.g. when you choose to download material made available by Blue Matter over third-party websites) and to verify professional information (including but not limited to access to publicly accessible information, national registries or third party databases);
- Blue Matter may collect information from your computer or other device you use when visiting Blue Matter ’s website such as Internet Protocol (IP), domain name, Internet Service Provider (ISP), information about date and time of your request and other information provided by tracking technologies. Please see our Cookies Statement here.
- Information may be shared within the Blue Matter Group of Companies, which includes our worldwide Affiliates.
Why Blue Matter Processes Your Personal Information
Blue Matter will only process your personal information for purposes permitted by applicable laws, which may vary depending on where you live, and where Blue Matter operates. The purposes of the data processing activities may include:
- Managing Blue Matter’s relationship with individuals for example, responding to questions and comments, inviting individuals to Blue Matter’s events;
- For collaboration purposes, for example to enable Blue Matter to make more informed and objective decisions when identifying, engaging with professionals and key opinion leaders, and managing the collaboration relationship with such professionals;
- Recruitment, processing professional information to assess individual’s suitability for job openings at Blue Matter;
- Market Research, processing information about individuals for lawful market research purposes. We collect information through surveys and interviews to help us improve our
- Direct Marketing and Business Development Purposes, we process personal information to provide promotional material and engage in marketing and promotional activities with individuals in accordance with applicable local laws (You have choices about this – see “Individual Choices: Rights and Access to Information” section of this Statement).
- Website functionalities, to ensure that content from our Website is presented in the most effective manner for you and for your device.
- Any other purpose that is relevant to the relationship between Blue Matter and you.
Blue Matter will process personal information for further purposes, where lawful to do so (such as for archiving, scientific or market research purposes) or when legally obliged to do so.
Methods in Which Blue Matter Collects and Uses Personal Information for Marketing and Business Development Purposes
Blue Matter may collect personal information in a variety of ways for purposes related to its own marketing and business development efforts. These methods are outlined below:
- Downloads on the Blue Matter Corporate Website – Blue Matter makes some materials (white papers, reports, etc.) available for download on its own corporate website. This material is freely available for downloading. Blue Matter may, at its discretion and subject to visitors’ consent, request that visitors also provide their basic identification and contact information (such as name, title, company, e-mail address, and similar data) to enable Blue Matter to provide such visitors with additional promotional material related to the content of the material downloaded, as well as to contact them for marketing and introductory/business development purposes. Providing your consent to Blue Matter to process your data for the above marketing and business development purposes is optional and is not a condition for downloading the material. If you choose to provide your consent you may later change your mind and withdraw it at any time as provided below. All information provided will be stored securely by Blue Matter in its customer relationship management (CRM) system and made accessible only to authorized Blue Matter personnel for the agreed purposes. Blue Matter relies on its legitimate business interests for processing anonymized and statistical information relating to the downloads, such as number of downloads, location (country), industry, etc) for internal statistical analysis purposes.
- Downloads on Third-Party Websites – Blue Matter periodically makes its materials (white papers, reports, etc.) also available for download on certain third-party websites. These third-party web sites are typically well-recognized industry news sources. This material is freely available for downloading. Blue Matter may, at its discretion and subject to visitors’ consent, request that visitors also provide their basic identification and contact information (such as name, title, company, e-mail address, and similar data) to enable Blue Matter to provide such visitors with additional promotional material related to the content of the material downloaded, as well as to contact them for marketing and introductory/business development purposes. Providing your consent to Blue Matter for processing your data for the above marketing and business development purposes is optional and is not a condition for downloading the material. If you choose to provide your consent you may later change your mind and withdraw it at any time as provided below. Your information will be collected by these third-parties, in accordance with their own privacy policies and subject to specific contractual arrangements with Blue Matter, for and on behalf of Blue Matter and will be subsequently provided to Blue Matter for further processing for the agreed above purposes. All information provided will be stored securely by Blue Matter in its customer relationship management (CRM) system and made accessible only to authorized Blue Matter personnel for the agreed purposes. Blue Matter relies on its legitimate business interests for processing anonymized and statistical information relating to the downloads, such as number of downloads, location (country), industry, etc. for internal statistical analysis purposes. Information aimed at Blue Matter will not be processed by such third-party websites for their own purposes.
- Newsletter / Blog Subscriptions – Blue Matter may enable visitors to its corporate website / blog to subscribe to a corporate newsletter or to receiving updates/news from the blog. To subscribe, visitors would be required to enter basic contact information (including name and e-mail address). This information would be stored in Blue Matter’s CRM system which is accessible only to authorized personnel. This information shall be used to deliver the blog or newsletter content, unless visitors specifically opt-in to also receive other forms of communication, such as information about Blue Matter’s services, invitations to Blue Matter events, and similar. Subscription to Blue Matter’s blog and/or corporate newsletter is optional; if you choose to subscribe, please note that you can change your mind and withdraw your consent at any time by following the unsubscribe link at the end of each email communication.
- Off-Line Personal Data Collection – Blue Matter may collect personal information directly from individuals in off-line settings. These settings may include face-to-face meetings, telephone conversations, conversations at conferences, and the like. Blue Matter may collect this information and store it in its CRM system which is accessible only to authorized personnel. Blue Matter may use this information to reach out to selected individuals for introductory or business development purposes.
Legal Basis of Processing
Blue Matter processes personal information under one or more of the following conditions:
- Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason);
- Where it is necessary to comply with contractual obligations with you;
- Where the processing is necessary for our compliance with a legal obligation; or
- Where the processing is in Blue Matter’s legitimate interest, for example, Blue Matter processes information for statistical purposes, for purposes related to its marketing and business development efforts, information about Blue Matter’s visitors and supplier personnel, for the improvement of our services, to provide security measures to protect Blue Matter’s employees, contractors, information and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations).
Data Sharing and Cross-Border Data Transfers
Blue Matter’s headquarters are in the USA, however its operations are both in Europe and in the USA. Personal information about you may be accessible to Blue Matter’s offices in the European Union (EU), as well as to some Blue Matter’s Affiliates outside the EU/ European Economic Area (“EEA”), and selected vendors and partners, established in the EU or globally. Your personal information may be accessed by staff or suppliers in, transferred to and stored at, a location outside the EU or the EEA in which data protection laws may not afford the same level of data protection as the one in the EU/EEA. Where Blue Matter processes personal information in countries that may not provide the same level of data protection as in the EU or in your own country where you are resident, Blue Matter will implement reasonable and appropriate legal as well as technical and organizational security measures to ensure the security of the processing and in particular to protect your personal information from unauthorized access, use or disclosure including, but not limited to, maintaining binding contractual arrangements with all third parties processing personal information of individuals, for and on behalf of Blue Matter, as well as executing, where necessary, adequate data transfer mechanisms, in the form of standard contractual clauses, for any cross-border data transfers from the EU to controller or processors established in third countries, as adopted and approved by the European Commission, or by the competent supervisory authorities, with the aim to achieve an adequate level of data protection of the personal information of those individuals.
For residents of EEA – whenever we transfer your information outside of the EEA, we will either ask for your explicit consent or take any and all necessary steps to ensure that adequate safeguards are put in place to protect your information (unless we are permitted under applicable data protection law to make such transfers without additional formalities e.g. where the recipient country is considered an adequate destination). Such safeguards include the use of European Commission approved standard contractual clauses as mentioned above.
The confidentiality of Personal Information transmitted over the Internet cannot be guaranteed. Blue Matter urges you to exercise increased caution when transmitting Personal Information over the Internet, as we cannot absolutely guarantee that unauthorized third parties will not gain access to your Personal Information.
Disclosure of Your Personal Information to Third Parties
Blue Matter does not sell personal data to third parties.
Blue Matter may disclose personal information to third party recipients where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal information will be disclosed only in accordance with local applicable laws, and appropriate safeguards will be established, where possible, to protect your personal information. Blue Matter may disclose personal information to any member of our group of companies.
In order to conduct Blue Matter’s business, Blue Matter may also disclose information to third parties such as public/regulatory authorities/governmental bodies (government, including social and benefits departments), third parties that provide services to Blue Matter (such as but not limited to service providers conducting audits, providing IT services, etc.). Blue Matter may also disclose information if Blue Matter or substantially all of our assets are acquired by a third party, in which case personal information held by us about individuals will be included as transferred assets, or if Blue Matter is under a duty to disclose or share individuals’ information in order to comply with any legal or regulatory obligation or request.
Blue Matter may also disclose information to enforce any agreements it has with individuals; or to protect the rights, property or safety of Blue Matter’s employees or others (e.g. visitors to Blue Matter premises).
Automated Decision Making and Individuals’ Rights
Blue Matter does not undertake decisions based solely on automated processing, including profiling, of individual unless we inform you otherwise.
Individual Choices: Rights and Access to Information
Access, Revision, Deletion
Under applicable privacy laws (e.g. European data protection and privacy laws), you may have a right to request a copy of personal information of you held by Blue Matter. You may also have the right to revise, correct, or delete such information. Your rights to such information may be subject to limited legal and regulatory restrictions.
Choices about Marketing
Whenever we collect and use your information for marketing and business development purposes we will inform you and ask for your consent; Please note that your consent is voluntary and you will have the right to object to your personal information being further processed for the purposes of direct marketing at any time. You can exercise this right and prevent such processing by using the “opt-out” or “unsubscribe” functionality in electronic communications to update your preferences. You can also exercise the right at any time by contacting us as set out below.
Objection to Processing and Additional Rights
Under applicable privacy laws (e.g. European data privacy law), where Blue Matter relies on legitimate interests or public interest to process information, and where Blue Matter conducts direct marketing, individuals can formally object to processing of their information for these purposes (in addition to the “Choices about Marketing” set out above). Individuals should clearly state “objection to processing” when contacting Blue Matter to exercise this right to objection.
In certain circumstances, you have the additional rights to restrict aspects of the processing of your information or ask for a copy of your data to be provided to you, or a third party, in a digital format.
Exercising Your Individual Rights
Your exercise of the above-mentioned rights is subject to certain exemptions to safeguard the public interest and our own legitimate interests. If you decide to exercise any of these rights, we will check your entitlement, we may request to confirm your identity and in any case we shall respond within a calendar month from receipt of such a request, unless there are valid grounds for extending the response periods, essentially due to the need to confirm your identity, to request additional information or to ask you to specify or limit your request, in case your request is too general or too complex to be handled within the initial deadline. Blue Matter may not be able to comply with a request where personal information has been destroyed, erased or made anonymous in accordance with applicable laws and regulations as well as with Blue Matter’s record retention obligations and practices. In the event that we cannot satisfy a request with regards to your personal data, we will endeavor to provide you with an explanation, subject to any legal or regulatory restrictions.
If we do not handle your request timely or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority. Further information and contact details of the competent supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en
To exercise your individual data protection rights please contact our Privacy Office by email at firstname.lastname@example.org. Alternatively, you may contact us by post at the address available at Contact Us section below.
How Long Blue Matter Retains Your Personal Information
We will retain your personal information for no longer than is necessary for the processing purpose(s) for which your information was collected and any other permitted associated purpose. Information may be retained for a longer duration where applicable laws or regulations require or allow Blue Matter to do so. Your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.
Security of Processing of Personal Information
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement, applicable data protection laws and regulations and international industry security standards. All information you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. Blue Matter has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal information protected from unauthorized access, disclosure, alteration, and destruction. Such measures may include but are not limited to: access controls, separation of duties, and similar security protocols.
Access to your personal information is limited to a restricted number of Blue Matter employees whose duties reasonably require such information and third parties with whom Blue Matter contracts to carry out business activities on its behalf. Our employees have been trained on the importance of privacy and how to handle and manage personal information appropriately and securely.
Applying to Work at Blue Matter
Blue Matter processes information to identify job applicants, assess job applications, and for other human resources processes necessary for evaluating and considering job applications. The information processed may include information such as your job title, education information, professional qualifications, work experience, publications and scientific activities, professional networks, and programs and activities in which you participated.
In the course of an application, Blue Matter may process further information, such as government issued identification number, tax status, bank account details, details of any known disability/workplace accessibility needs, background information, travel and expenses, performance management, emergency contact details, compensation, hours of work, holidays and benefits related information.
Blue Matter’s website is not intended or designed to collect or use any personal information from children (“children” are individuals who have not reached the age of majority in their residential jurisdictions). We do not knowingly collect personally identifiable information from or provide online services to any individual we know to be under the age of 13.
Should you suspect that a child of whom you are the parent or legal guardian has provided us with Personal Information, please contact Blue Matter using one of the methods specified below and we will work with you to address this issue.
Changes to This Privacy Statement
Blue Matter reserves the right to amend this Privacy Statement from time to time to reflect technological advancements, legal and regulatory changes, and Blue Matter’s business practices and processing activities, subject to applicable laws. If Blue Matter changes its privacy practices, an updated version of this Privacy Statement will reflect those changes by posting any revisions on Blue Matter’s corporate website with the respective update date listed on the bottom of this Statement. All changes to this Statement shall become fully effective thirty days (30) after the update date posted below. We therefore encourage you to view any amendments when you visit our Website from time to time to stay informed of how we are using your personal information.
If you have questions about this Privacy Statement, or to obtain more information about Blue Matter’s privacy practices, please contact us.
You can contact our Privacy Office by email at email@example.com or by postal mail at:
- (for residents of the European Economic Area)
European Data Privacy Office
14-18 Holborn | 5th Floor
London | EC1N 2LE | United Kingdom
- (for residents of USA)
Chief Privacy Officer
205 E. 42nd Street | Suite 19003
New York | NY 10017 | USA
- (for residents of Switzerland)
Usteristrasse 12 | 8001 Zurich
Last Updated: April 2019