EasyCV Privacy Policy

Last Updated: December 2, 2023

For the purposes of this document, EasyCV refers to one corporate entity:

• EasyCV LLC., located in Needham, Massachusetts, United States

Your privacy is important to us. This privacy policy explains the information EasyCV, LLC (“EasyCV”, “we”, “our” or “us”) collects, uses and stores when an individual (“you” or “your”) uses our digitally-based curriculum vitae creation tool and dashboard through our website www.EasyCV.me (the “Site”).

EasyCV is committed to meeting all of the EU GDPR requirements.

As part of the GDPR obligations, companies are required to advise you of their policy in a clear and transparent manner. They are required to provide this information free of charge. Listed below are a few (but not limited to) of the requirements:

• Who is responsible to control your personal data (if any), and their contact information

• The purpose of its collection

• Specifically, what is collected

• If it is shared with any third parties, and why

• Details of transfers to third countries and how it is protected during this transfer

• Your ability to “Opt Out” or withdraw consent at any time

• Your ability to access your personal data

• If the collection is part of a statutory or contractual obligation

• The existence of any automated decision making or profiling

• The source, if data is collected by a third party

Users Outside of The United States
The Service and the servers upon which the Service are hosted are located in the United States. Personal information you submit using the Site will be transferred to and stored in the United States. By using the Site and submitting Personal information, you authorize this transfer.

Responsibility to Control Your Personal Data

EasyCV has designated its Data Privacy Officer to oversee the control of personal data and coordinate EasyCV’s compliance with the GDPR and the EU-US and Swiss-US Data Privacy Framework obligations. The contact information for the Data Privacy Officer appears near the end of this document.

Purpose of Collection

• EasyCV offers software licensing and CV import services

• EasyCV is used to manage and maintain physician and PhD CVs

• EasyCV can be used to provide comprehensive and customizable data reports and analytics including:

  • Scholarly activity report

  • Teaching and lecture activity report

  • Promotion dashboard

• EasyCV will normally retain an individual's CV data throughout his or her career as necessary to fulfill the purpose of the service, or as required by applicable laws or regulations. Users may edit and delete their own data, or users may request that EasyCV delete their data and account.

What is Collected

The data EasyCV collects constitutes personally identifiable information (PII) as defined by the GDPR and the Data Privacy Framework Principles.  The data is subject to strict access controls and when processed and transmitted by EasyCV, the data is encrypted.

EasyCV collects data from users through their use of the Site and other interactions users have with EasyCV staff. Users provide some of this information directly to EasyCV via the Site and we get some of it by collecting data about your interactions, use, and experiences with the Site.

Personal information is data that can be used to identify or contact an individual person. EasyCV has collected the following categories and examples of personal information from its users in the last twelve (12) months:

• Identifiers - Name, username, email address, phone number, date of birth, or other similar identifiers

• Commercial Information - Records of services purchased

• Internet or other electronic network activity information - Browsing history, search history, and information regarding a user’s interaction with the Site

• Geolocation data - Physical location, generally

• Professional or employment-related information - Employers, fellowships, residencies, invited lectures, teaching responsibilities, grant applications and scholarly publications.

• Education Information - Institution Attended, Dates of Attendance, Honors

In addition, audit logs contain:

• The user’s browser agent-string (also known as the User Agent)

• The user’s Cookie Value, if consented to by the user on the EasyCV website

• The user’s IP address

• The user's EasyCV ID

Definitions of the above terms

• The user’s browser agent-string is supplied by the user’s browser, and it tells the website information about the browser and operating system.  This allows the website to customize content for the capabilities of a particular device. On average, only one person in about 1,500 will have the same agent-string as you.  On its own, that isn’t enough to reveal a person’s identity, but in combination with other details like geolocation to a particular ZIP code the agent-string might be used to identify an individual.  Here is an example of an agent-string that was sent by a user using the Firefox browser, “Mozilla/5.0 (Windows NT 6.1; Win64; x64; rv:47.0) Gecko/20100101 Firefox/47.0”.

• The  Cookie Value, the website of the EasyCV client can set these values, once it has obtained a user’s consent to use cookies. EasyCV uses third parties’ analytic and tracking tools in conjunction with some cookies to better understand who and how people are using the Site and how to improve the effectiveness of the Site, and in the future, those tools may help serve targeted advertising to you. Third party companies may use cookies, pixel tags or other technologies to collect and store anonymous information, such as time of visit, pages visited, time spent using the Site, device identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with the Site with personal information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.

• An IP address is a numerical label which is used to identify one or more devices on the Internet.  EasyCV stores the entire IP address in its audit logs.

• The EasyCV ID is an anonymous, randomize identifier that is generated for each user device and stored as a cookie.  Commonly the cookie is named "SSID" and set to persist within the user's browser. This is used to associate multiple visits to a website by the same user, to ensure consistency of the user experience. By setting this cookie value to "0" (numeric zero), an end user effective opts-out of any further data collection by the EasyCV business service.

How EasyCV Uses Personal Information
EasyCV uses the personal information we collect from users to do the following:

• to administer your account;

• to provide you access to the Site;

• to send individual user data to authorized divisions, departments, or hospitals of medical institutions (“Authorized Institutions”) to search, create and export reports, download, and transmit at an individual or aggregate level for purposes of reporting for the Authorized Institution;

• for individual users to download and export their own curriculum vitae from the Site; and

• communications regarding our Site.

From time to time, EasyCV may use or augment personal information about you with information obtained from third parties.

EasyCV also uses the data to operate our business, which includes analyzing our Site, meeting our legal obligations. When we ask you to provide personal information, you can decline, but if you do, you may not be able to access or use the Site.

Disclosure of Personal Data

We may also disclose your Personal Information to any regulatory or law enforcement agency if we believe that such action is necessary to protect the rights, property or personal safety of EasyCV, its customers or any third party.

A subset of the data collected may be shared with EasyCV’s customers to provide its service to test variations in the digital customer experience on its client’s websites.

Sharing information with Third Parties
Authorized Institutions. We provide your personal information to departments, divisions, or hospitals within medical institutions (“Institutions”) you have authorized to access or linked to your account (“Authorized Institutions”). By accessing the Site, you authorize us, and we may disclose your Curriculum Vitae and related personal information to Authorized Institutions. YOU ACKNOWLEDGE AND AGREE THAT EASYCV WILL NOT HAVE ANY LIABILITY FOR ANY ACTIONS OF ANY INSTITUTION. AUTHORIZED INSTITUTIONS TO WHOM WE MAY DISCLOSE YOUR DISCLOSED CURRICULUM VITAE MAY SHARE YOUR DISCLOSED INFORMATION WITH OTHERS.

Service Providers. We may engage third party companies and individuals to help us provide the Site, provide customer support, perform Site-related services (e.g., Site maintenance services, database management, web analytics and improvement of the Site) or to assist us in analyzing how the Site is used (“Service Providers”). These Service Providers may have access to your personal information, but only to the extent needed to perform these tasks on our behalf, and we will contractually require them to protect and safeguard your personal information in accordance with applicable laws. We may also provide your information to our advertisers, so that they can serve ads to you that meet your needs or match your interests. While we will require third parties to follow applicable laws, and will not authorize them to use this information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.

While we do not sell any personal information to any third party, we may charge Authorized Institutions a fee to use the Site and access User Data.

EasyCV discloses for business purposes the following categories of personal information to third parties: identifiers, commercial information, internet or other electronic network activity information, geolocation data, professional or employment-related information, and education information.

Others
It may be necessary for EasyCV to disclose your personal information by law, legal process, litigation, and/or requests from public and governmental authorities. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our Site or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protecting Your Personal Information

Data Transfers Between Countries

All data transmitted by EasyCV from the EU to the US and vice versa is encrypted using TLS.

Delegated Controls to GDPR Compliant Third-Party Service and Platform Providers
EasyCV and our service providers implement security measures designed to protect your information from unauthorized access, disclosure or accidental loss or destruction. We utilize appropriate physical, technical and managerial safeguards designed to protect the information we collect from or about our users. EasyCV’s physical infrastructure is hosted and managed within Heroku’s secure data centers located in the United States, utilizing the Amazon Web Service (AWS) technology. Heroku/Amazon continually manages risk and undergoes recurring assessments to ensure compliance with industry standards.

Your Ability to "Opt Out" or Withdraw Consent

You can make choices about our collection and use of your information. You can control your personal data that EasyCV obtains, and exercise your data protection rights, by contacting EasyCV or using various tools we provide. For example, you can:

• Use the “unsubscribe” links contained in our email messages to stop receiving product information from us via email.

• Prevent the Site from obtaining your location by disabling location services on your device. However, doing so means you may not be able to use the Site.

Not all personal information processed by EasyCV can be accessed or controlled via the tools above.

If you want to access or control personal data processed by EasyCV that is not available via the tools above, you can always contact EasyCV at support@EasyCV.me. If you are a resident of certain states, you may have additional rights regarding your personal information, such as the right to:

• Request that EasyCV disclose to you the categories and specific pieces of personal information we have collected.

• Delete any personal information about you which EasyCV has collected from you

• Request that EasyCV disclose the following to you:

  • The categories of sources from which your personal information is collected

  • The business or commercial purpose for collecting your personal information

  • The categories of third parties with whom EasyCV shares personal information

To exercise the rights set forth above, you may submit a request to us at Support@EasyCV.me.

Non-Personal Information
We also collect data in a form that does not, on its own, identify any specific individual (non-personal information). We may collect, use, transfer, and disclose non-personal information to improve the Site and customize the user experience, or for any other legitimate purpose. We also may aggregate non-personal information in order to track trends and analyze use patterns on the Site. This information is aggregated and used to help us provide more useful information to our users. Aggregated data is considered non personal information for the purposes of this Privacy Policy.

This Privacy Policy does not limit our use or disclosure of non-personal information and we reserve the right to use and disclose non-personal information to our partners, advertisers, product manufacturers and other third parties at our discretion (including aggregated and/or anonymized information about our users and their use of the Site). If we do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.

EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF)

EasyCV complies with the EU-US Data Privacy Framework (the EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (the Swiss-US DPF) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom (“UK” including Gibraltar), and Switzerland transferred to the United States pursuant to DPF Principles.  EasyCV has certified that it adheres to the Data Privacy Framework Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification page, please visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over EasyCV’s compliance with the DPF Principles and EasyCV is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the DPF Principles, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the DPF Principles, should direct their query to dpo@EasyCV.me . If requested to remove data, we will respond within a reasonable timeframe. 

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to dpo@EasyCV.me .  

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-US Data Privacy Framework Principles, EasyCV commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, United Kingdom and Swiss individuals with DPF inquiries or complaints should first contact dpo@EasyCV.me.

EasyCV has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

Our Policies Concerning Children
You must be 18 years or older to use our Site. We do not knowingly collect or use personal information from anyone under this age. If we become aware that anyone under-age has provided us with personal information, we will delete that information and the associated account.

Changes to Our Privacy
We may occasionally update this Privacy Policy. When we do update this Privacy Policy, we will also revise the “Last Updated” date at the top of the Privacy Policy. Please review this Privacy Policy periodically to stay informed about how we are protecting the personal information we collect. If you continue to use the Site after we post an update to this Privacy Policy, you are indicating your acceptance of the updated Privacy Policy.

Contacting EasyCV for Privacy Inquiries or Dispute Resolution

You have the right to contact EasyCV directly to request a copy of the data that we have about you, or to confirm that EasyCV systems are clear of any PII about you. Please include evidence that you are the individual or legal guardian of the individual that is the subject of the request.

The same points of contact may be used to make any inquiries about EasyCV’s compliance with the EU GDPR and the DPF Principles or to initiate any privacy complaints.

Please contact us by email at dpo@EasyCV.me.