Privacy Policy
Samodrei Privacy Notice
I. Introduction / II. Overview / III. Data collections and uses / IV. Choice and transparency / V. Updates to this notice
I. Introduction
When you use Samodrei, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.
This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.
II. Overview
A. Scope
This notice applies to users of Samodrei’s services anywhere in the world, including users of Samodrei’s apps, websites, features, or other services.
This notice describes how Samodrei collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world. This notice specifically applies to:
-
Prescriber recipients: individuals who prescribe pharmaceutical drugs approved by the FDA
-
Product Advocates: individuals who provide education or other services to Prescribers
This notice also governs Samodrei’s other collections of personal data in connection with Samodrei’s services. We may also collect the personal data of those who start but do not complete applications to be Product Advocates through an Samodrei app, or in connection with our mapping technology and features.
All those subject to this notice are referred to as “Product Advocates” or “users” in this notice.
Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular region only if permitted under the laws of those places. Please contact us through the addresses provided on the website with any questions regarding our practices in a particular geographic region.
B. Data controller and transfer
Samodrei LLC. is the data controller for the personal data collected in connection with use of Samodrei’s services anywhere else.
Samodrei operates, and processes data, globally. We may also transfer data to countries in order to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant geographic locations, or other transfer mechanisms as may be available under applicable law.
Questions, comments, and complaints about Samodrei’s data practices can be submitted via Samidrei website.
III. Data collections and uses
A. The data we collect
Samodrei collects:
-
Data provided by users to Samodrei, such as during account creation
-
Data created during use of our services, such as location, app usage, and device data
Data from other sources, such as Samodrei partners and third parties that use Samodrei APIs
The following data is collected by or on behalf of Samodrei:
1- Data provided by users. This could include:
-
User profile: We collect data when users create or update their Samodrei accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo).
This could also include gender and/or occupation.
We may use the photos submitted by users to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”
-
Background check and identity verification: We collect background check and identity verification information for Product Advocates. This may include information such for license verification and right to work. This information may be collected by an authorized vendor on Samodrei’s behalf.
-
Demographic data: We may collect demographic data about users, including through user surveys. In some geographic regions, we may also receive demographic data about users from third parties.
2- Data created during use of our services. This includes:
-
Location data (Product Advocates): Samodrei collects this data when the Samodrei app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
-
Location data (Product Advocates). We collect precise or approximate location data from Product Advocates mobile devices if they enable us to do so. Samodrei collects this data from the time a Product Advocate starts a Samodrei activity until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to make available locations of Prescribers and providing compensation. Samodrei collects location data, and links location data collected during a trip with the Product Advocate account, even if the Product Advocate has not enabled us to collect location data from their device. This enables us to confirm that services provided by the Product Advocate were conducted and payment is authorized.
-
Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
-
Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
-
Communications data: We enable users to communicate with Samodrei through Samodrei’s mobile apps and websites. To provide this service, Samodrei receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Samodrei may also use this data for support services and for analytics.
3- Data from other sources. This includes:
-
Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
-
Samodrei business partners through which users create or access their Samodrei account, such as payment providers, social media services, or apps or websites that use Samodrei’s APIs or whose APIs Samodrei uses.
-
Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
-
Contracted recruiting companies.
-
Publicly available sources.
-
Marketing service providers.
Samodrei may combine the data collected from these sources with other data in its possession.
B. How we use personal data
Samodrei collects and uses data to enable reliable and convenient delivery of services. We also use the data we collect:
-
To enhance the legal compliance aspects of the activities associated with our users and services
-
For customer support
-
For research and development
-
To enable communications between users
-
To send marketing and non-marketing communications to users
-
In connection with legal proceedings
Samodrei does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.
Samodrei uses the data it collects for purposes including:
1- Providing services and features. Samodrei uses the data we collect to provide, personalize, maintain, and improve our products and services.
This includes using the data to:
-
Create and update users’ accounts.
-
Verify a Product Advocate’s identity, background history, and eligibility to work.
-
Offer, process, or facilitate payments for services provided by a Product Advocate.
-
Track and share the progress of Product Advocate activities.
-
Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
2- Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:
-
Screening Product Advocates through reviews of background checks, where permitted by law.
-
In certain regions, using information derived from driver’s license photos, and other photos submitted to Samodrei, for safety and security purposes. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity.
-
Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
3- Customer support. Samodrei uses the information we collect to provide user support.
4- Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products.
5- Marketing. Samodrei may use the data we collect to market our services. This includes sending users communications about Samodrei services, updates and events.
Although we may send users communications about Samodrei partners’ services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising.
We may use the data we collect to personalize the marketing communications that we develop and use, including based on user location, past use of Samodrei’s services, and user preferences and settings.
6- Non-marketing communications. Samodrei may use the data we collect to inform Product Advocates of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Samodrei or its partners.
7- Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Samodrei’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
8- Automated decision-making
We use personal data to make automated decisions relating to use of our services. This includes:
-
Matching available Product Advocates and Prescribers. Users can be matched based on availability, proximity, and other factors.
-
Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Samodrei, its users, and others.
To object to a deactivation resulting from these processes, please contact Samodrei customer support.
C. Cookies and third-party technologies
Samodrei and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Samodrei uses cookies and similar technologies for purposes such as:
-
Authenticating users
-
Remembering user preferences and settings
-
Delivering and measuring the effectiveness of advertising campaigns
-
Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.
D. Data sharing and disclosure
Some of Samodrei’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.
Samodrei may share the data we collect:
1- With other users
This includes sharing:
-
For those who participate in Samodrei’s referral program, we share certain personal data of referred users, with the user who referred them, to the extent relevant to determining any referral bonus if applicable.
2- At the user’s request
This includes sharing data with:
-
Samodrei business partners. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; those with an API or service with which we integrate; or other Samodrei business partners and their users in connection with promotions, contests, or specialized services.
3- With the general public
Questions or comments from users submitted through public forums such as Samodrei blogs and Samodrei social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.
4- With Samodrei subsidiaries and affiliates
We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Samodrei processes and stores data in the United States on behalf of its international subsidiaries and affiliates.
5- With Samodrei service providers and business partners
Samodrei provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:
-
Payment processors and facilitators
-
Background check and identity verification providers
-
Cloud storage providers
-
Google, in connection with the use of Google Maps in Samodrei’s apps (see Google’s privacy policy for information on their collection and use of data)
-
Facebook, in connection with the use of the Facebook Business Tools in Samodrei’s apps and websites (see Facebook’s privacy policy for information on their collection and use of data)
-
Marketing partners and marketing platform providers, including social media advertising services
-
Data analytics providers
-
Research partners, including those performing surveys or research projects in partnership with Samodrei or on Samodrei’s behalf
-
Vendors that assist Samodrei to enhance the safety and security of its apps
-
Consultants, lawyers, accountants, and other professional service providers
-
Insurance and financing partners
6- For legal reasons or in the event of a dispute
Samodrei may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Samodrei’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services.
This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
7- With consent
Samodrei may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.
E. Data retention and deletion
Samodrei retains user data for as long as necessary for the purposes described above.
Users may request deletion of their accounts at any time. Samodrei may retain user data after a deletion request due to legal or regulatory requirements or for the reasons stated in this policy.
Samodrei retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data.
Users may request deletion of their account at any time through the Settings > menus in the Samodrei app.
Following an account deletion request, Samodrei deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit.
F. Grounds for processing
We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Samodrei’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent. We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:
A- To provide requested services and features
In order to provide our services, we must collect and use certain personal data. This includes:
-
User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their activities and enable users to make payments or receive earnings
-
Background information, which is used to verify an applicant’s eligibility to be a Product Advocate
-
Product Advocate location data, which we use to track Prescriber visits
-
Usage data, which is necessary to maintain, optimize, and enhance Samodrei’s services
-
Information relating to user support
B- For purposes of the legitimate interests of Samodrei or other parties
This includes using personal data to maintain and enhance our users’ safety and security.
This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Samodrei’s Terms of Use.
In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.
C- To fulfill Samodrei’s legal obligations
Samodrei may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. Samodrei may also share information with public health authorities where required or permitted by law.
D- With consent
Samodrei may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.
A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.IV. Choice and transparency
Samodrei enables users to access and control the data that Samodrei collects, including through:
-
In-app settings
-
Device permissions
-
In-app ratings pages
-
Marketing opt-outs
Samodrei also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Samodrei restrict its processing of user personal data.
A- Privacy settings
Settings menus in the Samodrei app for Product Advocates give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from Samodrei. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.
-
Location data
Samodrei uses Product Advocate device location services to confirm Prescriber visits for compensation purposes.
-
Notifications: discounts and news
Users may enable Samodrei to send push notifications about opportunities and news from Samodrei. Push notifications may be enabled or disabled through the Settings > menu in the Samodrei app.
B- Device permissions
Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the Samodrei app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the Samodrei app seeks before their first use of the app and use of the app constitutes a grant of such permission.
C- Marketing opt-outs
Users may opt out of receiving promotional emails from Samodrei (unsubscribe). Users may also opt out of receiving emails and other messages from Samodrei by following the unsubscribe instructions in those messages.
D- User data requests
Samodrei provides users with a variety of ways to learn about, control, and submit questions and comments about Samodrei’s handling of their data. To make a request, please go see Terms of Use.
-
Accessing data: Product Advocates can ask for an explanation of the data we collect from them and how we use it.
-
Receiving data: Product Advocates can ask for a copy of data that Samodrei collects from them with their consent or as necessary to provide our services.
-
Changing or updating data: Product Advocates can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Samodrei’s apps. They may also ask that Samodrei change or update their data, including if they believe such data is inaccurate or incomplete.
-
Deleting data: Product Advocates may request deletion of their account at any time through the Settings > Privacy menus in the Samodrei app, or through Samodrei’s website.
Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. Samodrei may continue to process data after such objection or request to the extent required or permitted by law.
V. Updates to this notice
We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.
We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Samodrei apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.
After such notice, use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.