COG Privacy Policy

The Children’s Oncology Group (COG) respects the principle of individual, personal privacy and is committed to protecting privacy through our compliance with this policy (“Privacy Policy”) as described below.

 By visiting the COG Website, you are accepting the practices described in the Privacy Policy. Please read this policy carefully to understand applicable policies and practices regarding your information and how we will treat it. If you do not agree with this Privacy Policy, other policies, and practices, your choice is to not use the COG Website. By accessing or using the COG Website, you agree to this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the COG Website.

 This Privacy Policy applies to the Children’s Oncology Group (COG) website located at www.childrensoncologygroup.org and defined as the collective body of all materials, features and functionality made available on the website, including without limitation COG Confidential Information as defined in the COG Website Terms of Use and Conditions of Confidential Access (the “Terms of Use”) or other access permitted under the law. Without limiting the generality of the above, it also includes any other pages associated with the childrensoncologygroup.org domain and www.cogmembers.org (collectively the “COG Website”) and any information that COG collects via the COG Website or interaction between you and the COG Website—including but not limited to email, mobile and desktop applications you download from the COG Website, other electronic messages between you and the COG Website.

 This Privacy Policy applies to all ways that the COG Website is accessed and/or used, whether via personal computers, mobile devices or otherwise, and other interactive features, applications (including mobile applications), or downloads that are operated by COG (“we” and “us”) that are made available by us.

This policy may change from time to time. When it does, COG will revise the date at the top of this page. Your continued use of the COG Website after such changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 What information we collect 

As a general matter, you can browse the COG Website without submitting information by which you may be personally identified. However, there are circumstances in which you may elect to provide us with information such as your first and last name, mailing address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“Personal Information”). We also collect certain data automatically when you interact with the COG Website, as described further below.

 The following lists the most common ways in which we collect your Personal Information.

• When you sign up to receive email newsletters, bulletins or other communications from us;
• When you participate in elections, surveys, or research;
• When you register for and participate in our meetings, programs, activities, initiatives, web forums and events;
• When you request information or assistance;
• When you send an email or call us (including one of our employees) through the contact information provided on the COG Website;

• When you interact with the Children’s Oncology Group pages or accounts on social media platforms—e.g., click on our social media links and/or provide information to us on those accounts;
• In conjunction with any verification of your account information;
• In conjunction with investigations into any activity that may violate the law or the COG Website’s terms and conditions;
• When you communicate with us through the COG Website; and
• In conjunction with any other place on the COG Website where you knowingly volunteer Personal Information.

 When you interact with the COG Website, we may keep an activity log that tells us how users interact with our services. In some cases, we collect this data through cookies, pixels and similar tracking technologies that create and maintain unique identifiers. Generally, we collect the following categories of such data to understand and enhance how visitors use the COG Website:

• We collect and store certain information about the devices used to access the website, such as computer, mobile device, or other device. This information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information;
• We automatically log certain information about use of the COG Website. This information includes a reading history of the pages viewed by users;
• We collect and store additional “traffic data” such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses; and
• We collect and store search terms and search results.

 We also collect and store certain other automatically collected data regarding our users’ use of the COG Website so that third parties may provide us with reports and analysis regarding usage and browsing patterns of the COG Website.

 How we combine your information

We may combine information gathered from the COG Website and information that we have received, gathered, acquired, or stored from other sources, both information collected offline by COG and information received from third parties—including information that currently exists in our files—into a single user record. We also may use and/or combine information that we collect offline or receive from third-party sources (e.g., contact information from government funders or grantor information) to edit, enhance, and/or check the accuracy of your user record.

 How we use your information

We use the information we learn from our users to help us personalize and continually improve your experience on the COG Website. We use Personal Informationin the following ways:

• Responding to your inquiries;
• Presenting our COG Website and its contents to you;
• Providing you with information and services you request from us;
• Communicating with you about your account or transactions with us and sending you information about features on our COG Website or about COG;
• Communicating with you about changes to our policies;
• Sending you newsletters, mailings, and information about studies, meetings, initiatives, activities, and events by email or another medium;
• Meeting or event registration;
• Optimizing or improving our programs, services, and operations;
• Verifying your account and account activities;
• Notifying you about changes to our COG Website or any services or information we offer or provide through it;
• Allowing you to participate in interactive features on our COG Website;
• Fulfilling any other purpose for which you provide it;
• Detecting, investigating, and preventing activities that may violate our policies or be illegal;
• Performing statistical and demographic analyses of users of the COG Website and their usage patterns; and
• Managing our organization.

 How we share your information

COG adheres to ethical standards and practices in our operations and is dedicated to protecting the privacy of all visitors to our COG Website. We do not sell, barter, give away, or rent your Personal Information. Except as disclosed below, we do not permit anyone outside COG to use or access your Personal Information, and in all cases we only share your Personal Information where it is in the legitimate interest of furthering the mission of COG.

 COG uses third-party service providers and independent contractors to help us operate the COG Website and administer activities on COG’s behalf, such as providing website analytics, maintenance or site improvement and operational support (collectively our “Service Providers”). These Service Providers may have access to Personal Information necessary to perform their function, but are required to protect the confidentiality of the information and to use it only for the limited purpose for which it was provided.

 If you believe that Personal Information you provided to us is being misused by a third party, please contact us at COGPrivacy@childrensoncologygroup.org.

We may also use or disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the COG Website; (b) protect and defend our rights or property, the COG Website, or our users; and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, our agents, or the users of the COG Website or the public.

How long we keep your data

We retain your Personal Information 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.

 How we use cookies

Like many websites, we use “cookies,” which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. We use cookies to track use of our COG Websites and online services. We may also use cookies to monitor traffic, improve the COG Website, and make it easier and/or relevant for your use. We use cookies to track individual sessions and logins. The COG Website is functional without the retention of cookies. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at http://www.allaboutcookies.org/.

 We may use web beacons or flash cookies on our COG Website. A web beacon or flash cookie (sometimes referred to as an “action tag” or “single-pixel GIF”) is an invisible graphic on a web page or email newsletter that is programmed to collect non-personally identifiable information about your use of a given website or newsletter, e.g., whether you opened the email. Like cookies, web beacons allow COG and its technology providers to summarize overall usage patterns for our analysis and provide personalized services to you. We do not share or provide personally identifiable information we may collect through such web beacons, such as names or email addresses.

 We do not allow third-party cookies.

COG strives to protect the transmission and storage of any information submitted by visitors to the COG Website. But no transmission and storage of data is completely secure, and submissions are at your sole risk.

 The COG Website may contain links to sites operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these other websites. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

 Children under the age of 16

Protecting the privacy of children is especially important. The COG Website is not intended for children under 16 years of age. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on the COG Website through any of its features on the COG Website, and do not provide any information about yourself to us, such as your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at COGPrivacy@childrensoncologygroup.org.

 Data security

COG is committed to the security, integrity and confidentiality of private information. We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification. We regularly review our security procedures to consider appropriate new technology and methods.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our COG Website. Any transmission of Personal Information is made at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

 California Residents’ Personal Information

In the following paragraphs, we seek to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA). Any terms defined in the CCPA and CPRA have the same meaning when used in this Privacy Policy.

 Information We Collect

We collect information that under California law identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.

 In particular, over the past twelve (12) months we have collected through our COG Website the following categories of Personal Information from consumers:

Use of Personal Information

We do not sell your Personal Information. In addition to the specific uses noted in this Privacy Policy, we may generally use or disclose the Personal Information we collect for business purposes, including:

• Auditing user interactions and concurrent transactions.
• Detecting security incidents and preventing fraud.
• Debugging.
• Performing our services.
• Advertising and marketing our Services.
• Performing analytics and quality control.
• Researching and testing to improve our Services.

 We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 Sharing Personal Information for a Business Purpose

In the preceding twelve (12) months, COG has disclosed the following categories of Personal Information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records Personal Information categories.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category H: Sensory data.
• Category I: Professional or employment-related information.
• Category K: Inferences drawn from other Personal Information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

 Access to Specific Information and Data Portability Rights

 You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• Upon request, the specific pieces of Personal Information we collected about you (also called a data portability request).
• If we disclosed your Personal Information for a business purpose, a list disclosing:
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

 Deletion Request Rights

 Subject to certain exceptions under the law, you have the right to request that we delete any of your Personal Information that we collected from you and retained. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

 We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 Exercising Access, Data Portability, and Deletion Rights

 To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at COGPrivacy@childrensoncologygroup.org.

 Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

 We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following based on your exercise of CCPA rights:

• Deny you Services.
• Charge you different prices or rates for Services.
• Provide you a different level or quality of Services.

 Other California Privacy Rights

We do not track users over time and across our Services; therefore, we do not respond to Do Not Track signals.

California Civil Code Section § 1798.83 permits website users that are California residents to request certain information regarding the disclosure of personal data to third parties for direct marketing purposes. To make such a request, please contact us at COGPrivacy@childrensoncologygroup.org.

 GDPR and personal information

Regulation (EU) 2016/679 – the General Data Protection Regulation (“GDPR”) is a European Regulation concerning the use and processing of Personal Information. The UK has adopted a similar regulation into law known as the UK GDPR. We are committed to processing your information in compliance with the GDPR or the UK GDPR.

 We will use reasonable efforts to securely process all Personal Information in line with the rights specified under the GDPR or UK GDPR, in particular those related to the following requests:

• Access to your Personal Information;
• Correction of the Personal Information that we hold;
• Deletion of your Personal Information;
• A restriction of processing of your Personal Information;
• The right to withdraw your consent to our processing of your Personal Information, if our processing is based on consent;
• Transfer of your Personal Information to another party and the right to receive it in a structured, commonly used and machine-readable format; or
• Objection to processing of your Personal Information for direct marketing purposes or if our processing is based on COG’s legitimate interest (or those of a third party) to use it.

 You may contact us at COGPrivacy@childrensoncologygroup.org to exercise any of these rights.

 If you believe that our processing of your Personal Information is inconsistent with your data protection rights under the GDPR or UK GDPR, and we have not adequately addressed your concerns, you have the right to lodge a complaint with the data protection supervisory authority of your country.

 The COG Website is published in the United States and is subject to laws of the United States. If you are located in a country outside the United States and voluntarily submit Personal Information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States. Any international transfer of your Personal Information from the European Economic Area or the United Kingdom will be made pursuant to appropriate safeguards, such as Standard Contractual Clauses. COG shall not be liable under any circumstances for damages resulting from use of information collected from visitors to the COG Website.

 We reserve the right to modify or amend the terms of this Privacy Policy from time to time without notice. Your continued use of our COG Website following the posting of changes to this Privacy Policy will mean you accept those changes.

 Questions and comments should be directed to COGPrivacy@childrensoncologygroup.org. Our physical address is 1333 S. Mayflower Avenue, Suite 260, Monrovia, CA 91016.

 If you have any questions or requests regarding this policy, if you would like to change your preferences, if you no longer wish to receive email updates from COG, or if you believe COG has erroneous or incomplete information about you, please send an email to COGPrivacy@childrensoncologygroup.org.