Full policy

Welcome to the Educational Commission for Foreign Medical Graduates web sites and mobile application (collectively, the “Services”) owned and operated by the Educational Commission for Foreign Medical Graduates (“ECFMG”), a member of Intealth. This page contains the terms, covenants, conditions, and provisions (the “Terms and Conditions”) upon which you (the “User”) may access and use these Services.

Terms and Conditions

By using the Services, you, the User, indicate that you understand and accept these Terms and Conditions and our Privacy Notice (collectively “the Agreement”) and that you agree to be legally bound by them. If you do not agree to these Terms and Conditions, please discontinue your use of the Services.

Please note that ECFMG reserves the right to change the Terms and Conditions under which the Services and their offerings are extended to you. Your continued use of the Services following reasonable notice of such modifications (including by e-mail or by updating the date at the top of this page) will be deemed acceptance of any changes to these Terms and Conditions.

1. Grant of License. This Agreement provides you, the User, with a personal, revocable, nonexclusive, nontransferable license to use the Services conditioned on your continued compliance with the Terms and Conditions of this Agreement. Users may print and download materials and information from the Services solely for personal and noncommercial use, provided that all hard copies contain all copyright and other applicable notices contained in such materials and information. Notwithstanding the foregoing and except as otherwise expressly permitted herein, a User may not modify, copy, distribute, broadcast, transmit, reproduce, publish, license, transfer, sell, scrape, mirror, frame, or otherwise use any information or material obtained from or through the Services. As a further condition of use of the Services, all Users warrant to ECFMG that they will not use the Services for any purpose that is unlawful, prohibited by any applicable regulation or is otherwise inconsistent with these Terms and Conditions.

2. Eligibility for Use of Services. To use the Services, you must be, and represent and warrant that you are, 18 years of age or older and able to agree with the Terms and Conditions. If you are agreeing to these Terms and Conditions on behalf of an organization or entity, you represent and warrant that you are authorized to agree and bind such organization or entity to these Terms and Conditions (in which case, the references to “you” and “your” in this Agreement, except for in this clause, refer to that organization or entity). If ECFMG has previously prohibited you from accessing or using the Services, you are not eligible to access or use the Services.

3. User Accounts. Your use of certain portions of the Services may require you to create a User Account, which requires a User ID, password, and, in some cases, answers to challenge questions. Anyone with knowledge of your User ID, password and the answers to your challenge questions, if applicable, can gain access to the restricted portions of the Services, your account and/or other information, and transactions available to you. Accordingly, you must keep your User Account information confidential. By agreeing to these Terms and Conditions, you agree to be solely responsible for the confidentiality and use of your User Account information, as well as for any communications entered through the Services using these authentication items. You agree to (a) immediately notify ECFMG of any unauthorized access or use of your User Account or any other breach of security, and (b) exit your User Account at the end of each session. ECFMG reserves the right to delete or change a User's Account information at any time and for any reason. ECFMG cannot and will not be liable for any loss or damage arising from your failure to comply with this Section 3.

4. Privacy Notice. You understand that your use of the Services may require the transmission of information that may be considered personal data. Please see Intealth’s Privacy Notice for a summary of Intealth’s and its member organizations’, ECFMG’s and FAIMER’s, practices regarding how we collect, use, and share the data we collect from and about you. Acceptance of these Terms and Conditions constitutes consent to Intealth’s Privacy Notice.

5. Accuracy of Account Information and Data. You have the sole responsibility for the accuracy, quality, integrity, legality, and reliability of all data you provide to ECFMG. You understand that your account information is current as of the date indicated and is not a definitive statement of your account. ECFMG will not be liable for any loss, cost, expense, or other liability arising out of any such data you provide to ECFMG.

6. Notices, Communications, and Electronic Signatures. You agree to accept all communications from ECFMG regarding use of the Services at the addresses you provide to ECFMG.

For applicants for USMLE examinations and/or ECFMG Certification, please promptly update any changes to your information by accessing ECFMG’s On-line Applicant Status and Information System (OASIS).

If you are subscribed to one or more of ECFMG’s e-mail newsletters, such as The ECFMG^® Reporter, and your e-mail address changes, you must update your e-mail address for each e-newsletter. To update your e-mail address in your e-newsletter subscription(s), visit the Publications page of the ECFMG Web Site at https://www.ecfmg.org/resources/publications.html, click on the newsletter(s) you receive, unsubscribe your old e-mail address, and subscribe your new e-mail address.

For applicants for employment, please promptly update any changes to your information by accessing the on-line employment application at https://www.ecfmg.org/about/careers.html.

Users of the ECFMG Medical School Web Portal (EMSWP) can request updates to their e-mail addresses by contacting their medical school's EMSWP Coordinator. The EMSWP Coordinator can request such changes for all Users at the medical school by accessing EMSWP at https://emswp.ecfmg.org. The medical school's EMSWP Coordinator can also request such changes by contacting ECFMG's EMSWP Administrator by e-mail at emswpadmin@ecfmg.org. ECFMG's EMSWP Administrator will review these requests and, if approved, implement the requested changes.

Users of the Electronic Portfolio of International Credentials (EPIC) Physician Portal can update their e-mail addresses by accessing EPIC at https://epic.ecfmgepic.org. Users of the EPIC Report Portal can request updates to their e-mail addresses by contacting their organization’s EPIC Coordinator. The organization’s EPIC Coordinator can request such changes for all Users at the organization by contacting EPIC Support Services at ECFMG at info@ecfmgepic.org.

Users of GEMx Electives can update their contact information, including e-mail address, by accessing their account at https://students.gemxelectives.org.

ECFMG is entitled to rely on the e-mail address and address of residence/postal mailing address that you last provided to us. You agree to waive all claims resulting from failure to receive communications because of changes in your addresses not communicated to ECFMG as specified above.

You agree to be bound by any affirmance, assent or agreement you transmit through the Services. You agree that, when in the future you use the Services, your agreement or consent to these Terms and Conditions will be legally binding and enforceable and the legal equivalent of your handwritten signature.

7. On-line Employment Applications. You may search for employment opportunities and apply for employment with Intealth and its member organizations, ECFMG and FAIMER, through the ECFMG Web Site at www.ecfmg.org. You agree to provide complete and accurate responses to all questions on the on-line employment application. You agree to be bound by all of the provisions set forth in the on-line employment application, including the "Applicant's Statement."

8. Intellectual Property Rights. All material contained in the Services, unless otherwise indicated, is owned by ECFMG and protected by law including, but not limited to, United States copyright, trade secret, and trademark law, as well as other state, national, and international laws and regulations. Except as expressly provided herein, ECFMG does not grant any express or implied right(s) to Users of the Services. Copyright and other proprietary rights in the Services, or portions thereof, may be held by individuals and/or entities other than ECFMG. Removing or altering the copyright notice on any material in the Services is prohibited. ECFMG owns a copyright in the Services as collective works and/or compilations, and in the selection, coordination, arrangement, and enhancement of the Services' content. Intealth, ECFMG^®, CSA^®, FAIMER^®, EPICSM, GEMxSM, ECHOSM, the Intealth logo, the ECFMG logo, the EPIC logo, the GEMx logo, the ECHO logo, and all other trademarks, names, logos, and icons identifying Intealth, ECFMG or ECFMG’s products are proprietary marks of ECFMG, or their respective owners.

9. Compliance with Applicable Laws. User's access to the Services is governed by all applicable federal, state, and local laws.

10. Code of Conduct. You agree not to do any of the following:

• Restrict or inhibit any other authorized user from using and enjoying the Services. This includes, without limitation: (a) using, or attempting to use, any account without the owner's permission, or (b) obtaining or soliciting another person's password or other personal information under false pretenses.
  
• Impersonate any individual or entity.
  
• Interfere (or attempt to interfere) with the operation of the Services. This includes, without limitation, interfering with, defeating, or circumventing any security function of the Services, or attempting to do so.
  
• Post, store, or transmit any knowingly inaccurate or misleading personal, financial, or organizational information.
  
• Post, store, or transmit any unlawful, threatening, defamatory, obscene, inflammatory, pornographic, profane, or otherwise objectionable (as determined by ECFMG) information or material. ECFMG reserves the right to edit or delete information or material that it determines to be objectionable.
  
• Post, store, or transmit any information or material that could constitute or encourage conduct that would be considered a criminal offense, give rise to civil liability, or otherwise violate any law.
  
• Use the Services to post, store, or transmit any information or software that contains a virus, worm, Trojan horse, or other harmful or disruptive component.
  
• Use the Services to post, store, or transmit materials in violation of another party's copyright or other intellectual property rights. You are solely responsible for determining whether any material you post, store, or transmit is subject to a third party's rights.
  
• Use the Services to post, store, or transmit materials in violation of another party's privacy or publicity rights. This includes, without limitation, posting, storing, or transmitting images without obtaining the permission of individuals identifiable in the images.
  
• Use the Services for any unlawful purpose.
  
• Modify, adapt, sublicense, translate, resell, retransmit, reverse engineer, decompile, or disassemble any portion of the Services.

11. Termination. The Agreement will continue to apply until terminated by either you or ECFMG. Without limiting the foregoing, ECFMG has the right to immediately terminate or suspend your access to the Services for any violation of the Agreement at any time with or without notice.

12. Assumption of Risk. Use of the Internet and the Services is solely at your own risk and is subject to all applicable local, state, national, and international laws and regulations. While ECFMG has endeavored to create secure and reliable Services, please be advised that the confidentiality of any communication or material transmitted to/from the Services over the Internet cannot be guaranteed. Accordingly, ECFMG and its employees, agents, directors, officers, proprietors, partners, representatives, shareholders, servants, attorneys, predecessors, successors, and assigns are not responsible for the security of any information transmitted via the Internet. The User assumes sole and complete risk for using the Services and must make his or her own determination as to these matters.

13. Law Enforcement. ECFMG reserves the right to view, monitor, and record activity in the Services without notice or permission from you. Any information obtained by monitoring, reviewing, or recording is subject to review by law enforcement organizations in connection with investigation or prosecution of possible criminal activity in the Services. ECFMG will also comply with all court orders involving requests for such information.

14. Links to Other Sites. ECFMG may offer links to other web sites (“third-party sites”) that may offer various products, services, and/or information. These links are for convenience only, and ECFMG Users should be aware that ECFMG’s Terms and Conditions do not govern use of these third-party web sites, and these sites may be governed by the third party’s own terms and conditions, privacy policy, and other similar terms. ECFMG cannot ensure that users will be satisfied with any products or services offered and/or purchased from such third-party sites. Before proceeding with any transaction with any third-party site, whether the transaction is on-line or off-line, it shall be the sole responsibility of the User to conduct whatever investigation such User deems necessary and appropriate.

15. Events Beyond ECFMG's Control. Users expressly absolve and release ECFMG from any claim of harm resulting from a cause beyond ECFMG's control including, but not limited to, failure of electronic or mechanical equipment or communication lines, telephone or other interconnect problems, computer viruses, unauthorized access, theft, operator errors, severe weather, earthquakes, or natural disasters, strikes or other labor problems, wars, terrorism, public health crises, or governmental restrictions.

16. Warranties Disclaimed. WHILE ECFMG ENDEAVORS TO PROVIDE ACCURATE AND TIMELY INFORMATION, THE INFORMATION AVAILABLE IN THE SERVICES MAY INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS. MOREOVER, ECFMG MAY MAKE MODIFICATIONS AND/OR CHANGES IN THE SERVICES OR IN THE INFORMATION AVAILABLE IN THE SERVICES AT ANY TIME, FOR ANY REASON.

YOU, THE USER, ASSUME THE SOLE RISK OF MAKING USE OF, AND/OR RELYING ON, THE INFORMATION AVAILABLE IN OR THROUGH THE SERVICES. ECFMG MAKES NO REPRESENTATIONS ABOUT THE SUITABILITY, COMPLETENESS, TIMELINESS, AVAILABILITY, RELIABILITY, LEGALITY IN YOUR JURISDICTION, OR ACCURACY OF THE INFORMATION AVAILABLE IN OR THROUGH THE SERVICES FOR ANY PURPOSE. SUCH INFORMATION IS PROVIDED ON AN "AS IS" AND “AS AVAILABLE” BASIS WITHOUT WARRANTY OF ANY KIND, INCLUDING ALL IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NONINFRINGEMENT.

IN NO EVENT SHALL ECFMG BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY CLAIM, LOSS, OR DAMAGE, DIRECT OR INDIRECT, INCLUDING WITHOUT LIMITATION, COMPENSATORY, PUNITIVE, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN ANY WAY CONNECTED WITH YOUR USE OF THE SERVICES, INCLUDING BUT NOT LIMITED TO: ANY DELAY, INABILITY TO ACCESS OR USE, OR INTERRUPTION TO THE SERVICES; ANY DELAY, INABILITY TO ACCESS OR USE, OR INTERRUPTION TO YOUR ACCOUNT; UNAUTHORIZED USE OR MISUSE OF YOUR ACCOUNT; ANY INACCURACY OF DATA; ANY LOSS OF DATA; ANY INFORMATION AVAILABLE IN THE SERVICES, OR OTHERWISE ARISING OUT OF THE UTILIZATION OF THE SERVICES, WHETHER BASED IN CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF ECFMG HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY. IN SUCH JURISDICTIONS, ECFMG'S ENTIRE LIABILITY AND YOUR EXCLUSIVE REMEDY WITH RESPECT TO YOUR USE OF THE SERVICES SHALL NOT EXCEED $1,000.00.

17. Indemnity. You agree to defend, indemnify, and hold harmless ECFMG and its affiliates and all of their employees, agents, directors, officers, proprietors, partners, representatives, shareholders, servants, attorneys, predecessors, successors, and assigns, from and against any and all claims, proceedings, damages, injuries, liabilities, losses, costs, and expenses (including reasonable attorneys' fees and litigation expenses), relating to or arising from your use of the Services or any breach by you of this Agreement. ECFMG reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you and you shall not in any event settle any matter without the written consent of ECFMG. You agree to cooperate as fully as reasonably required in ECFMG's defense of any claim.

18. Submissions. Through EMSWP's GEMx program, authorized institutional users may enter and publish images of and content about their institutions and the institutions’ programs. ECFMG also welcomes submissions in the form of feedback and suggestions about how to improve our products and Services. Any ideas, suggestions, information, know-how, material, images, or any other content (collectively, "content") received through the Services, however, will be deemed to include a royalty-free, perpetual, irrevocable, nonexclusive right and license for ECFMG to adopt, publish, reproduce, disseminate, transmit, distribute, copy, use, edit, create derivative works, display, (in whole or part) worldwide, or act on such content without additional approval or consideration, in any form, media, or technology now known or later developed for the full term of any rights that may exist in such content, and User hereby waives any claim to the contrary.

18. Copyright Complaints. We respond to notices of alleged copyright infringement under the Digital Millennium Copyright Act of 1998 (the "DMCA") to ensure that material from the Services does not infringe on the copyright, trademark, or other intellectual property rights of others. Notices to ECFMG regarding any alleged copyright infringement related to the Services should be directed to: Elizabeth Ingraham, Assistant Vice President, Communications & External Affairs, Intealth. E-mail: eingraham@intealth.org. Phone: (215) 823-2108. Facsimile: (215) 387-9963.

20. Governing Law. This Agreement has been made in, and will be construed and enforced in accordance with the laws of the Commonwealth of Pennsylvania without regard to its conflicts of law principles. Any action to enforce this Agreement will be brought in the federal or state courts presiding in Pennsylvania, and all parties to this Agreement expressly agree to be subject to the jurisdiction of such courts. The Services are controlled and operated by ECFMG from its offices within the United States.

21. Waiver. Failure to insist on strict performance of any of the Terms and Conditions of this Agreement will not operate as a waiver of any subsequent default or failure of performance. No waiver by ECFMG of any right under these Terms and Conditions will be deemed to be either a waiver of any other right or provision or a waiver of that same right or provision at any other time.

22. Severability. If any part of this Agreement is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and the liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most clearly matches the intent of the original provision and the remainder of this Agreement shall continue in effect.

23. Relationship. No joint venture, partnership, employment, or agency relationship exists between a User and ECFMG as a result of this Agreement or User's utilization of the Services.

24. Anti-Hacking. You may not, nor may you allow others to, directly or indirectly, attempt to or actually disrupt, impair or interfere with, alter or modify the Services or any content. You may not, nor may you allow others to, directly or indirectly, collect or attempt to collect any information about others, including, but not limited to passwords, account or other information.

25. Entire Agreement/Reservation of Rights. These Terms and Conditions, together with the Intealth Privacy Notice, which is hereby incorporated as if set forth fully herein, represent the entire Agreement between the User and ECFMG with respect to use of and material available in or through the Services, and supersede all prior or contemporaneous communications and proposals, whether electronic, oral, or written between the User and ECFMG with respect to the Services. Any rights not expressly granted herein are reserved.

26. Additional Assistance. If you have any questions or concerns about these Terms and Conditions, please contact Elizabeth Ingraham, Assistant Vice President, Communications & External Affairs, Intealth. E-mail: eingraham@intealth.org. Phone: (215) 823-2108. Facsimile: (215) 387-9963.

Full policy

Intealth and its member organizations, the Educational Commission for Foreign Medical Graduates (ECFMG® ) and the Foundation for Advancement of International Medical Education and Research (FAIMER® ) are committed to protecting the privacy and security of your Data, including Personally Identifiable Information (“PII”) (collectively “Data”). For purposes of this Privacy Notice (“Privacy Notice”), Intealth refers to: ECFMG and FAIMER (hereinafter referred to collectively as “Intealth,” “we,” “us,” or “our”). This Privacy Notice explains how we collect, process, use, and disclose your Data (i) in connection with, and in support of, our programs and services; (ii) in connection with your participation in Intealth-related educational and professional forums and collaborations; (iii) in support of our research endeavors; and/or (iv) in connection with an application for employment with Intealth.

Acceptance of Privacy Notice

Your use of the Intealth websites, programs and services, mobile applications, and related administrative processes signifies your understanding and acceptance of the terms of this Privacy Notice. If you do not agree to the terms of this Privacy Notice, please do not submit your PII or any PII you are responsible for to Intealth or use its websites, programs and services, and mobile applications. Further, your continued use of Intealth websites, programs and services, and mobile applications following our posting amendments to the Privacy Notice signifies your acceptance of the Privacy Notice as amended.

Nature of Services Provided

Intealth provides programs and services to individuals and to organizations including certification, professional verification, credentialing, training, educational opportunities, and visa sponsorship. Intealth also collaborates in research, publications, and educational opportunities and makes employment opportunities available to individuals seeking to join our teams.

PII and Other Data We Collect

We collect PII and other Data either directly from you, through automatic technologies, and from third parties or publicly available sources, as follows:

Data Collected from You

• Users in Connection with and in Support of Our Programs and Services. We collect the following PII directly from individuals in order to provide our programs and services including some PII that may be considered sensitive PII under the applicable law in the jurisdiction where you reside. The PII we collect may include but is not limited to an individual’s: name; image; address(es); e-mail address(es); birth date; birth country; passport and visa information; national identification numbers; ECFMG/ United States Medical Licensing Examination® (USMLE®) number; medical license number, licensing jurisdiction, and licensing dates; gender; ethnicity; citizenship; birth certificate; marriage certificate; relevant information about any claimed disability; driver’s license information; financial information; and educational and work experience. For those Users seeking visa sponsorship, we collect PII of family members and dependents (including minors) also seeking sponsorship (under a J-2 Visa), as follows: name, gender, date of birth, birth city, passport number, country(ies) of citizenship, country of legal personal residence, e-mail address, Student and Exchange Visitor Information System (SEVIS) number, and USMLE number (where applicable). Copies of passports, marriage certificates, and birth certificates must also be provided in support of sponsorship.
  
  In order to facilitate payment for our programs and services, we use third-party payment services through PayPal and Telecheck, which directly collect your financial Data (for example, your bank account information or credit card details); the financial Data you submit electronically is not collected, processed, or retained by Intealth. The use of your financial Data is governed by the Privacy Policies of those entities.
  
  In very limited instances, our programs and services permit Users to submit payment by providing financial Data directly to us using a paper form. In the event you elect to make a payment in this manner, your financial Data will be processed only for purposes of payment and will be deleted within one year of collection.
  
• Users Supporting Intealth or Participating in Educational and Professional Forums. PII is also collected from individuals working for organizations assisting Intealth to fulfill its services, donors, and individuals attending and/or presenting at Intealth educational and professional forums. The PII collected from such Users includes but is not limited to: name, title, address(es), date of birth, birth country, e-mail addresses, phone numbers, and professional credentials.
  
• Users Seeking Employment Opportunities. Intealth generally collects the following PII from Users seeking professional opportunities with Intealth: name, address(es), e-mail address, phone numbers, gender, ethnicity, veteran status, disability status, education history, employment history, professional references, required background clearance data, and other job-related information.

In most instances, collection of this PII is required for Intealth to provide the requested opportunities and/or programs and services, or in other instances may be required by law. Non-provision of certain information may bar our ability to provide you with these opportunities and/or the requested programs and services.

Data Collected Automatically

Intealth websites and mobile applications collect certain Data about you automatically, using certain passive technologies. Such Data includes technical information about browser type, areas of the site visited, date and time of access, and related data in order to improve the overall quality of your on-line experience. These passive technologies include:

• Web Server Logs and IP Addresses. Internet Protocol (“IP”) addresses and mobile device identifiers are numbers that identify the computer or device that you use to access the Internet. Depending on the way in which you access the Internet and where you access the Internet, your IP address may always be the same or very similar each time you access the Internet, or may change each time you access the Internet. Intealth systems automatically collect IP addresses and mobile device identifiers to enable our servers to send you the web pages that you request via your Internet Service Provider. We will never use your IP address to specifically target your location, but we may use your IP address to target the general geographic area from which you are visiting our website where there is a business need and a lawful basis to do so. We may use your IP address for security purposes, administering and maintaining our websites, to support our applications and the services that you access, for calculating our website usage levels, for the prevention and investigation of fraudulent activities, and/or for other business practice improvement.
  
• Cookies. A “cookie” is a data file that a website sends to your browser, which then stores it on the device you are using to browse the website. Intealth uses different types of cookies to improve delivery of your on-line experience. Cookies do not personally identify Users, although they allow our web servers to differentiate one User from another. Cookies also allow us to transact business with you on the Internet. Strictly necessary cookies are cookies necessary to enable the basic features of Intealth websites to function and/or to provide a service that you have specifically requested. Performance and analytics cookies allow us to measure and improve our performance and provide us with information about how our websites are used and how visitors move around our website. One specific type of performance and analytics cookie we use is Google Analytics. We use Google Analytics to assist us with understanding how Users interact with and use our website, which helps us improve our websites, applications, and offerings. Please refer to the Google Analytics Terms of Use and Privacy Policy for information regarding how Google may use and share the information collected by Google Analytics. You can opt out of being tracked by Google Analytics by visiting http://tools.google.com/dlpage/gaoptout. Functional cookies allow us to analyze your use of our websites to evaluate and improve our performance and to enhance and personalize your User experience by remembering User login details and other preferences. Non-essential cookies allow Intealth to keep track of Users who return to our website and for Users to share certain pages with social networks. Intealth uses all types of cookies on its websites and mobile applications. You can set your browser to refuse cookies except for strictly necessary cookies. However, disabling cookies may impact your ability to navigate all Intealth websites’ functionality.
  
• Web Beacons. Intealth web pages may use web beacons in conjunction with cookies to compile aggregate statistics about website usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) commonly used to track User traffic patterns from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of our websites. Some web beacons may be unusable if you refuse their associated cookies.
  
• “Do-Not-Track” Signals. Some web browsers transmit "do-not-track" signals to our websites. Although web browsers may incorporate and activate this functionality in different ways, Intealth currently does not respond to these signals.

Data Collected from Third Parties

We may also use or supplement the Data we have about you with information provided by other sources, such as the USMLE program, National Board of Medical Examiners^® (NBME^®), the National Resident Matching Program^® (NRMP^®), American Medical Association (AMA), Federation of State Medical Boards (FSMB), Association of American Medical Colleges (AAMC), Accreditation Council for Graduate Medical Education (ACGME), the Department of State (DOS), the Department of Homeland Security (DHS), medical schools, graduate medical education and training programs, current and former employers, licensing and regulatory authorities, professional organizations, and other organizations with which we collaborate in the provision of our programs and services. Where such information is received, Intealth will only use that data for the limited purposes for which it was provided to us.

How We Use Personal Information

Intealth may use your PII to:

• establish the applicable User account in our systems (e.g., as an applicant for our programs and services or as an applicant for job opportunities);
• process and fulfill requests for Intealth programs and services and employment opportunities;
• provide administrative notices and alerts to inform you of relevant aspects of programs and services (“administrative e-mails”);
• deliver newsletters and promotional materials that support Intealth’s mission and mandate (“promotional e-mails”);
• provide customer service in connection with our programs and services and employment opportunities;
• respond to legitimate business inquiries;
• support professional work and educational opportunities;
• confirm the identity of officials who verify credentials at verifying organizations;
• perform analyses and other internal assessments to administer our business and to improve the quality of Intealth business and service offerings;
• provide information and donor opportunities to support Intealth’s work and mission;
• facilitate engagement by alumni from our educational programs, including but not limited to alumni of our FAIMER regional institutes;
• address legal and regulatory inquiries made in the interests of serving the public;
• maintain permanent records of Users of Intealth programs and services as necessary to prevent fraud and serve the interests of the public;
• complete regulatory audits and compliance investigations;
• respond to inquiries from governmental and regulatory authorities;
• conduct statistical research and analysis that support our programs and services, mission, and other business interests;
• monitor for fraud and security threats; and/or
• fulfill any other purpose for which it was collected or provided to us, as stated at the time of collection, or as otherwise implied based on the context of the collection.

Intealth uses e-mail addresses collected for administrative and promotional purposes. Administrative e-mails are necessary to keep Users informed about critical aspects of programs and services. These must be received by Users in a timely manner. Therefore, the option to unsubscribe from administrative e-mails and alerts is not available to Users. However, if you wish to opt-out of promotional e-mails, please follow the unsubscribe instructions provided within individual newsletters and/or promotional e-mails.

Intealth reserves the right to aggregate PII provided by Users for statistical analysis and on-going research in accordance with our mission. To this end, Intealth compiles PII into aggregated data groups. Intealth may de-identify or pseudonymize the PII for statistically accurate data analysis without risking exposure of PII. Such data groups may then be shared with business partners, service providers, and/or vendors of Intealth or published on our website, in academic journals, or in presentations.

Basis for Processing PII

Applicable law in certain countries, including but not limited to countries in the European Economic Area, require that we collect and process PII only where we have an identified lawful basis to do so under applicable law. Depending on the program and service and/or opportunity provided and/or the processing activity involved, we collect and process your PII only where we have one of the following lawful bases to do so:

• You Provide Your Consent: You provide us with consent to collect and process your PII for a specific purpose;
  
• We Must Do So to Perform Our Contract with You: We process your PII to fulfill your request to provide programs and services or other opportunities;
  
• We Have a Legitimate Interest: We have a legitimate interest to process your PII that is not overridden by your interests, fundamental rights, or freedoms; and/or
  
• We Must Do So to Comply with Legal Obligations: We process your PII if it is necessary for us to comply with our legal obligations.

Where we process “special” or “sensitive” categories of PII, as defined by the General Data Protection Regulation, we do so only: (i) where you have given us your explicit consent to carry out such processing; or (ii) as otherwise permitted by law.

If you have questions or concerns about the lawful basis for which we collect and process your PII, please contact privacy@ECFMG.org or privacy@FAIMER.org.

Personal Information of Minors

Except as noted below, minors (i.e., persons under 18 years of age) are not eligible for participation in Intealth programs or services, and/or employment opportunities. Therefore, Intealth does not intentionally collect PII from minors. If Intealth identifies that a minor has submitted PII, we will take all reasonable steps necessary to delete the PII from our databases and not use or retain it for any purpose. Further, if you believe a minor has submitted PII to Intealth, please contact us at: privacy@ECFMG.org or privacy@FAIMER.org.

Intealth provides visa sponsorship for authorized foreign national physicians and unmarried, minor dependents of such authorized foreign national physicians under the age of 21. Under such sponsorship and to meet J-1/J-2 visa requirements, Intealth must collect PII of minor dependents for U.S. government agencies; however, such information is collected from the authorized foreign national physician, not the minor dependent.

Data Retention and Destruction

Intealth retains your Data for as long as necessary to fulfill the purposes we collected it for, for the duration of our business relationship with you, and in accordance with our Data Retention and Destruction Policy. Intealth may maintain a lawful basis for retaining certain PII indefinitely, for example, where Intealth services are benefiting the public interest in the area of public health, such as through verification of professional credentials. PII deleted from our active database in accordance with our Policy may be retained in de-identified format for research, data aggregation, and statistical purposes.

How We Disclose and Share PII

We may disclose and share your PII with third parties, as follows:

To Parties Authorized by Users

Fulfillment of Intealth’s programs and services or other opportunities often requires disclosure of PII to third parties. In such instances, Users provide explicit consent to such Intealth-defined uses and disclosures, and Intealth discloses limited and necessary PII about Users. Such disclosures may be made to the following, as applicable:

• organizations assisting Intealth to fulfill its programs and services including but not limited to verifying institutions (such as medical schools and post-graduate training institutions), identity verification providers, translation providers, test providers, USMLE, ACGME, NBME, NRMP, and the FSMB;
• other organization(s) or individual(s) in order to facilitate on-going services;
• U.S. or international governmental agencies and other organizations, including medical and other regulatory authorities; and/or
• any other individual, organization, or government or regulatory authority that a User specifies should receive the information.

There may be circumstances where you would like information in your Intealth records to be disclosed to a third party, such as a friend or family member. We will not disclose your information to such individuals unless you have authorized us to do so.

Intealth may also disclose PII to third parties, such as hospitals or medical regulatory authorities, where you have given such third parties authorization to obtain such information from Intealth.

To External Third Parties Under Contractual Relationships with Intealth

Intealth may disclose or provide access to your PII with vendors and service providers, including but not limited to the following:

• IT and systems administration services (such as cloud hosting services and e-mail or mail solutions);
• PCI-compliant payment processing solutions (e.g., PayPal, TeleCheck);
• Internet Service Providers;
• services that assist in processing employment applications;
• personnel administration services;
• vendors and services that assist with certification, credentialing, and visa sponsorship operations, including but not limited to identity verification providers, translation providers, test providers (including but not limited to English language proficiency testing providers), and investigative firms;
• professional advisors such as lawyers, bankers, auditors, and insurers; and
• program and other surveys (e.g., SurveyMonkey).

Where such disclosures are made, they are governed by agreements (such as confidentiality agreements, data sharing agreements, and data processing agreements) that require protection of your PII and that only permit use of your PII in a manner consistent with this Privacy Notice.

To Protect Our Legal Rights and Interests or Where Required by Law

Intealth may disclose PII to respond to valid subpoenas, court orders, legal processes, medical or other regulatory authority inquiries and investigations, or other governmental inquiries and investigations; to exercise our own legal rights to defend against legal claims/suits; to investigate, prevent, or take action against illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person or the general public; or as otherwise required by law.

In the Event of a Change in Corporate Status

In the event that Intealth is involved in a merger, acquisition, sale of assets, bankruptcy, and/or reorganization, your Data may be sold or transferred as part of that transaction. Any Agreement with such new entity or receiver will include appropriate privacy protections.

No Disclosures for Direct Marketing and Advertising

At this time, Intealth does not disclose, sell, rent, license, grant access to, or trade PII with third parties for direct marketing.

Cross-Border Transfers of PII

All PII collected and/or received by Intealth is stored and maintained on servers in the United States, where national and state privacy laws may not afford the same level of protection as where you reside. Further, fulfillment of many of our programs and services require the cross-border transfer of PII from Intealth to other countries, for example, to verify an individual’s credentials and/or to provide information to international medical regulatory authorities; similarly, the national and state privacy laws in those countries may not afford the same level of protection as where you reside. By using Intealth’s programs and services, you consent to the transfer of information to countries outside your residence, including but not limited to the United States, and acknowledge that your personal information will be processed in the United States. Intealth also employs cross-border transfer safeguards (including but not limited to standard contractual clauses) as applicable and appropriate to protect the privacy and security of your PII, and to use it in a manner strictly consistent with the purposes for which it is provided.

Data Privacy and Security

Intealth has implemented reasonable administrative, technical, and organizational safeguards to protect against foreseeable risks of unauthorized access, use, disclosure, destruction, or modification of PII and its information systems.

Please note, however, that despite the best efforts of Intealth, the confidentiality and security of information and Data transmitted to/from Intealth cannot be guaranteed as completely safe from intrusion.

Please do your part to protect the personal information that you share with Intealth. Keep your username, password, or other authentication information secure and limit the dissemination of your account information to third parties to those circumstances where dissemination is absolutely necessary. If you believe that your username, password, or other information associated with your Intealth account has been compromised, please contact us at: privacy@ECFMG.org or privacy@FAIMER.org.

Data Protection Rights

Depending on where you reside, your local privacy laws, including but not limited to the European Union’s General Data Protection Regulation, may provide you with certain rights with respect to your PII, as follows:

Access, Review, and Rectification

Some Users may have the right to access and review their PII collected and maintained by Intealth, with limited restrictions. Users can submit a formal request for access and review by contacting privacy@ECFMG.org or privacy@FAIMER.org. All such requests will be tracked and responded to in a timely manner, not to exceed 30 calendar days from the date of the request. Most Intealth services include password-protected portals where Users can review, correct, and update their PII in lieu of submitting a formal request.

Erasure and Restricting Processing

Under certain circumstances, some Users may have the right to request that their PII be deleted or removed from Intealth’s systems. This right is not absolute. Many of Intealth’s services are intended to prevent fraud and to serve the public interest in the area of public health. As a provider of these services, Intealth may have a lawful basis to refuse User requests for erasure of PII and/or to refuse User requests to restrict or object to processing PII.

Filing Complaints

Applicable Users have the right to make a complaint to Intealth by contacting privacy@ECFMG.org or privacy@FAIMER.org, and/or to request that Intealth direct the User to relevant supervisory authorities to file a formal complaint.

Privacy Notices of Unaffiliated Third-Party Websites

This Privacy Notice applies only to Intealth and Intealth’s privacy practices. The Intealth website and mobile applications include links to unaffiliated third-party websites and applications whose privacy practices may be different than ours. Users clicking on these links should be aware that they are leaving the Intealth website and/or application and are accessing the unaffiliated third-party website. Users should review the Privacy Notice of the unaffiliated third-party website before engaging their services or products.

Changes to This Privacy Notice

This Privacy Notice may be amended from time to time as new features, programs, and services are made available, as laws and regulations change, or as otherwise necessary and appropriate. Notice about amendments to the Privacy Notice will be communicated by administrative e-mails, posted on-line, or by other appropriate methods. User access and/or on-going use of Intealth programs, services, websites, and/or mobile applications after such amendments signifies acceptance of the Privacy Notice, as amended. The most current version of the Privacy Notice is available at www.ECFMG.org and www.FAIMER.org and includes the date the Privacy Notice was last updated.

How to Contact Us

If you have questions about the terms of this Privacy Notice or if you need more information, please contact Intealth at privacy@ECFMG.org or privacy@FAIMER.org.

Intealth
Attn: Privacy Office
3624 Market Street
Philadelphia PA 19104 USA
+(215) 386-5900