Please read this Policy carefully as it contains important information on who we are and how, when, and why we may collect, store, use, and share your information when you access or use our Services, which may include personal information or personal data as defined by applicable privacy laws (“Personal Data”). Depending on where you are located, this Policy also explains how you can exercise certain rights you may have in connection with your privacy and the Personal Data and other information we collect from you.
By using the Sites, Apps, or any other USHC Services, you agree to the terms of this Policy.
The Services are intended for Users eighteen (18) years of age or older. If you are not 18 years of age or older, you are not permitted to access or use the Services.
This Policy only applies to the Services identified above. Other sites, apps and other online locations may have their own privacy policies or notices which apply instead of this Policy, and you should consult those accordingly.
This Policy is effective as of September 28, 2021.
Changes to this Policy
We retain sole discretion to update this Policy from time to time. When we update this Policy, we will post a notification on the main page of our Sites and Apps and update the Policy’s effective date. You acknowledge and agree that it is your responsibility to review this Policy periodically and become aware of modifications. Any change to this Policy is effective immediately, and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so. Your continued use of the Services after any changes are made to this Policy constitutes your acceptance of the changes. If any of the changes are unacceptable to you, you should cease using the Services.
If any changes to this Policy substantially affect how USHC treats or handles Personal Data that has already been collected by USHC, we will endeavor to provide you with notice in advance of such changes by highlighting the changes on our Sites and Apps. We will seek your prior consent to any material changes, if and where this is required by applicable data protection laws. If you do not opt-in, your information will continue to be used in a manner that is consistent with the version of this Policy under which it was collected, or the information will be deleted.
Collection of Personal Data
Personal Data is generally defined as information that, by itself or in combination with other information, may be able to identify you or could reasonably be associated with you, your household or your accounts.
We may collect Personal Data from Users who voluntarily provide such information in a variety of ways on or through the Sites, Apps and/or other Services. For example, Users may be asked for Personal Data including:
- Contact Information such as your name, practice name, phone number, email address or mailing address;
- Professional Information like your practice name, office address, other business information or national provider identifier (NPI) number, area of expertise, and the professional education courses and other resources you use, attend or participate in through the Services; and/or
- Payment Information including your credit/debit card number or other financial information.
Additionally, USHC may collect inferences about USHC content we think may be of interest to you based on your apparent preferences from the categories of Professional Information we collect about you.
The voluntarily provided Personal Data summarized above is collected from you whenever you:
- visit our Sites or use our Apps or interact with our other Services;
- register an account on the Sites or Apps;
- register for an event;
- subscribe to a newsletter;
- respond to a survey;
- fill out a form;
- order training services or materials;
- create a username and password (or security question and answer); and/or
- seek information in connection with other activities, services, features or resources we make available on or through the Services.
USHC may collect some of your Contact Information and Professional Information from pharmaceutical companies that provide us with physician level data (PLD), which we then use to track the content you listen to and/or view on or through the Services. The pharmaceutical companies that provide us with your PLD may receive Professional Information about any USHC courses you attend or other Services you use as a result of this process. This exchange of PLD and other Professional Information may result in you receiving advertising content that is based on the USHC content you listen to and/or view, and other Services you use.
Users can always refuse to supply Personal Data, except that doing so may prevent Users from engaging in certain activities or content related to the Services.
Web browser cookies
When you access certain areas of the Sites or Apps, or interact with USHC advertising Services provided on our Sites and Apps or through third-party websites or online properties, USHC or third parties we work with may collect Personal Data or other information from you in an automated manner. When you visit the Sites or use the Apps or interact with an advertisement made available by USHC, for example, USHC or third parties we work with may automatically collect certain Device Information about your computer, browser or device that includes information such as your IP address, time zone, the web pages you accessed on our Sites or at certain third-party websites or online locations, the link that led you to USHC’s applicable Services, and some of the cookie identifiers that are installed on your device. USHC will treat such Device Information as Personal Data to the extent such Device Information is reasonably capable of identifying a particular individual.
Audience identification tool
We use an audience identification tool supplied by the Healthcare Communications Network℠, of which we are a member. More information on this Network is provided below under “Processing by third-party service providers.” A digital tag (e.g. a pixel) may be embedded in emails to you from us or the Healthcare Communications Network℠ which allows us to identify you and your Personal Data, to the extent such Personal Data is in our possession or the Network’s possession, when you visit or use our Services.
How we use collected information
We may collect and use Users’ Personal Data and other information for the following purposes:
- To improve customer service: Information you provide helps us respond to your customer service requests and support needs more efficiently.
- To prevent unauthorized access to and use of the Services: Your registration information will be used to safeguard your account.
- To enroll in an event: We may use order information to process the enrollment of Users in a meeting or event.
- To personalize User experience: We may use information to provide Users with advertising and other content on the Sites and Apps or through other Services on third-party websites or online properties that is tailored to your interests based on USHC courses you attend or how you interact with other Services.
- To monitor and improve how Users interact with the Services: We may use information in the aggregate to understand how certain groups of Users interact with the Services.
- To process any forms you complete and submit through the Services: We will use such submitted information for the purposes described in connection with any specific form the User completes.
- To send training services or materials: If a User submits an order or request for such training services or materials, we will use the submitted information to send these to the User.
- To perform internal operations related to the Services: We may use your Personal Data for fraud prevention, to troubleshoot software issues and operational problems, conducting data analysis and testing; and/or
- To send periodic emails or mail: We may use the email address and postal addresses to send Users information and updates based on the information Users provide us. We may also use email or mail to respond to User inquiries, questions, and/or other requests. A User will receive emails or mail which may include company news, updates, related product or service information, as well as information from third parties with whom we or our affiliated entities do business.
USHC may use third-party service providers which collect and aggregate information to analyze how Users move around the Services, in order to optimize the performance of the Services.
By providing to USHC the Personal Data and other information referenced above, you agree that USHC may use the Personal Data and other information in accordance with the terms of this Policy.
Sharing your personal information
We may share certain portions of Personal Data and other information with third-party service providers to help us operate the Sites, Apps, other Services, our business, or to administer activities on our behalf. This may include sharing your:
- Professional Information with a search service to help us look up your NPI number, or with pharmaceutical companies and providers of advertising services in connection with the exchange of your PLD as described above;
- NPI number and certain Contact Information such as your name, address, phone number and email address with third parties in the pharmaceutical industry;
- Device Information with our content delivery vendor and advertising and marketing service providers to provide content on the Sites and Apps or through other Services or third-party websites or online properties about courses, materials, products, or other services in which you may be interested, and with analytics service providers with whom we have contractually committed to provide data for analytical purposes; and/or
- Contact Information with our email and shipping vendors for the purpose of sending out newsletters, surveys, or marketing materials from USHC.
We may share your information with these third parties unless you have specifically requested to be removed from our database and USHC has no other legal obligation to retain your information and process it as necessary to fulfill contractual obligations or for other legitimate business purposes.
We participate in the Healthcare Communications Network℠ run by DMD Marketing Corp. Participation in the Healthcare Communications Network provides us with tools to better understand and analyze who is using our Sites and Apps, and to personalize User experiences on the Sites and Apps. We share certain of your Personal Data with the operators of the Healthcare Communications Network. This information includes your email address, your name, your NPI number and other information we obtain when you register on the Sites, Apps, or visit DMD Healthcare Communications Network. HealthCare Communications Network will use this information primarily to send you emails with information specifically tailored to your medical interest. You will receive an email providing you with a mechanism to unsubscribe from the Network’s emails and from our use of the Network’s tools to track and analyze your visits to our Sites or your use of the Apps.
We adhere to the Self-Regulatory Principles set forth by the Digital Advertising Alliance (DAA), and the Interactive Advertising Bureau’s (IAB) Self-Regulatory Principles for Online Behavioral Advertising. In addition, USHC may work with advertisers which are members of the Network Advertising Initiative (NAI), an association dedicated to responsible data collection use in digital advertising. To update your DAA AdChoices Opt-Out settings, select your region here: US, Canada, or Europe. To manage NAI member sites’ settings, click here. If you opt-out using these industry-provided opt-out tools, you will still see ads but they will not be personalized based on your online activity. Please note that if you disable cookies or upgrade your browser after opting out, you will need to opt-out again. Further, if you use multiple browsers or devices you will need to execute these opt-outs on each browser or device, and there is no guarantee the opt-outs will prevent all personalized or behavioral advertising.
If USHC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
The Services may allow you to share information, including Personal Data, with other third-party services and social networking websites, such as Twitter, Facebook, Instagram and LinkedIn. We do not share your Personal Data with these social media providers unless you direct the Services to do so. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings with these entities. Please consult these third parties’ privacy policies before using their platforms to make sure you are comfortable with the level of sharing.
Other than what is referenced above, the Personal Data and other data collected from you is not shared with nor sold to any person or entity outside of USHC. USHC does not knowingly collect or sell the Personal Information of minors under 16 years of age.
We may share User information with governmental agencies or other companies assisting us in fraud prevention or investigation if we: (1) reasonably believe we are permitted or required to do so by law; (2) are investigating actual or potential fraud or unauthorized transactions; or (3) believe that a User’s actions violate our Terms and Condition of Use or threaten the rights, property or safety of our company, our Users, or others.
Your choices regarding your Personal Data
Your provision of Personal Data and other information to USHC means you agree that we may collect, use and disclose your information under the terms of this Policy. If you do not agree with these terms, please do not to provide any Personal Data. However, certain Services can only be offered if you provide your Personal Data to USHC.
In connection with USHC’s collection and use of your Personal Data, and depending on where you reside, you may have the rights to:
- Request access to or correction of your Personal Data in USHC’s custody or control;
- Opt-out of any sale of your Personal Data, if applicable and subject to contractual and legal restrictions;
- Request details on the specific pieces of Personal Data that USHC has collected about you;
- Request that USHC delete or properly dispose of copies of Personal Data it has collected about you, subject to contractual and legal restrictions; and
- Not be discriminated against, in terms of the quality and prices offered in connection with our Services, because you exercised these rights regarding the collection, use and sharing of your Personal Data.
If you would like to request the ability to access, review, edit, delete or have us otherwise dispose of any copies of the Personal Data USHC collected from you, if you would like to opt-out of receiving further information, if you want to limit what Personal Data USHC shares, if you otherwise wish USHC to stop using your Personal Data in the manners specified in this Policy, or if you would like to exercise the above rights in any other way (subject to any applicable legal exceptions), please contact us at firstname.lastname@example.org or by calling us at 1-866-390-9909 (Toll-Free).
When you visit and interact with the Sites or Apps, certain third parties may get access to certain information about you as referenced above, such as your Device Information, Professional Information and PLD, for the purpose of providing you online advertising personalized to your interests based on your browsing behavior. To the extent any of this sharing or third-party access may be considered a “sale” of your Personal Data under applicable privacy laws and regulations, you may have the right to opt-out of sharing for targeted advertising purposes by clicking here, or by using the email address or toll-free phone number provided in the previous paragraph.
You may be able to opt-out of USHC sharing your Personal Data with the entities identified in this Policy unless the sharing of your Personal Data is necessary to perform one of the following business purposes: to count ad impressions and evaluate their effectiveness; to detect, protect against, and prosecute security incidents; to debug or troubleshoot functional errors that may arise with the Services; to complete short-term tasks related to an existing interaction you have with USHC; to maintain or service your account; to process payments and fulfill orders or other transactions you authorize; to verify your customer information; or to ensure the safety and quality of the Services.
Any removal of content by USHC does not ensure or guarantee complete or comprehensive removal in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information. USHC will do its best to accommodate your request to delete Personal Data we collected from you, but we cannot guarantee we can remove all Personal Data from the specified uses. If the request relates to information that USHC needs to make the Services function properly for you, you may not be able to use the Services properly moving forward.
USHC reserves the right to maintain proper records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your Personal Data.
You may grant an authorized agent written permission to submit requests regarding your Personal Information, but we may deny authorized agent requests absent proof that you authorized such agent to act on your behalf, or if we are unable to verify your identity.
USHC is required to verify the identity of any person or entity that requests the disclosure or deletion of Personal Data. If you have a password-protected account with us, we will use our existing authentication procedures to verify your identity. For most other requests, USHC will ask you to provide information that matches at least two pieces of Personal Data we store about you before responding to your request. If you would like to request the specific pieces of your Personal Data that USHC has collected, or if you would like us to delete highly sensitive information, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the consumer whose Personal Data you are requesting.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If you would like to opt-out of receiving further promotional emails from USHC, please follow the opt-out instructions at the bottom of the email or send USHC a detailed message at email@example.com.
Some browsers have a ”Do Not Track” feature or similar privacy controls or settings that lets you tell websites that you do not want to have your online activities tracked. USHC does not sell your Personal Data through the use of tracking technologies and the Services are not currently configured to recognize or respond to “Do Not Track” signals or similar technical requests sent by a User’s browser or other device settings. To learn more about other ways to possibly opt-out of certain kinds of tracking that could result in you receiving targeted advertising based on your behavior online, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select through these third-party services are browser- and device-specific, and there is no guarantee that these industry-provided opt-out tools will prevent all targeted advertising.
How we protect your information
As to Personal Data we collect, USHC’s Services use, implement and maintain industry standard security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data and other data stored on or through our Services, both in storage and in transmission.
However, while USHC takes the protection of your Personal Data seriously, you should exercise discretion in what information you disclose and/or transmit online, including on the Sites or Apps or through other Services. No data transmission over the internet can be assured to be completely secure, as any transmitted information may be intercepted by others before it reaches USHC. As a result, USHC does not ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. If you are concerned about sending information to USHC over the internet, please send the information by mail or call us to make other arrangements. USHC is not responsible for the security of information sent over the internet.
How long we keep your Personal Data
USHC retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. USHC reserves the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your Personal Data. If USHC determines that collected information is no longer needed, it will delete such information. Our collection times will be consistent with applicable law.
Use by Minors
Our Services are intended for individuals sixteen (16) years of age or older. USHC’s Services are not directed at, marketed to, nor intended for, individuals under 16 years of age. USHC does not knowingly solicit or collect information from individuals under the age of 16. If we determine that we have inadvertently collected information from someone under 16 years of age, USHC will delete this information from our database. If you are under 16 years of age, DO NOT use or provide any information about yourself on or through the Services, and DO NOT interact with any of the Services or their features. We do not and will not knowingly collect any information, including Personal Data, from any person under 16 years of age and USHC will take immediate steps to delete any such information if it is inadvertently received. If you believe a person under 16 years of age used our Services and provided USHC with any information that could be considered Personal Data under applicable law, please contact us at firstname.lastname@example.org. Again, any deletion by USHC does not ensure or guarantee complete or comprehensive removal of the information in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.
How we handle E.U. data
If you are a User residing within the European Economic Area (the “EEA,” which includes the 27 European Union Member States, Iceland, Norway and Liechtenstein), Switzerland or the United Kingdom (collectively, the “EU”), then USHC handles your Personal Data according to the terms of this Policy, unless the exceptions in this section apply, pursuant to the General Data Protection Regulation (“GDPR”) and other applicable data protection laws and regulations in the EU.
USHC will collect, process and use your Personal Data as described in this Policy and for the purposes set forth in this Policy. With the exception of uses for which we have obtained your consent, your Personal Data is processed to perform our obligations under a contract with you or where the processing is in support of our legitimate interests as described in this Policy and not overridden by your data protection interests or fundamental rights and freedoms under applicable data protection laws and regulations.
If you are a User residing within the EU, we will seek your consent before using your Personal Data to serve you relevant information, content and educational materials based on your personal preferences, interests, location and other information that you provide to USHC in connection with the Services.
We may share certain portions of Personal Data and other information with any member of our group of companies as reasonably necessary for the purposes set out in this Policy to help us operate our business and Services. You can learn more about our group of companies by visiting USHealthConnect.com.
The Healthcare Communications Network℠ run by DMD Marketing Corp. is not available to Users in the EU.
Under the GDPR, Users in the EU may have one or more of the following additional rights regarding USHC’s collection, use, and sharing of Personal Data on or through the Services:
- the right to request access to the Personal Data we hold about you;
- the right to update and correct any inaccurate Personal Data USHC holds about you;
- the right, in certain circumstances, to object to or withdraw any consent for marketing activities or processing of Personal Data that you might have provided to USHC;
- the right to request erasure of Personal Data;
- the right to request restriction of USHC’s processing of your Personal Data in certain circumstances (for example, if you contest the accuracy of the data); and
- the right, in certain circumstances, to request the portability of Personal Data that you have provided to USHC.
Under the GDPR, Users in the EU also may have the right to lodge a complaint about USHC’s processing of your Personal Data with a supervisory authority. In particular, such Users may lodge a complaint in the Member State where the User lives or works or where the alleged violation took place.
To protect your Personal Data, USHC’s Services use appropriate technical and organizational security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data and other data stored on or through our Services.
USHC retains Personal Data only for as long as necessary to fulfill the stated purpose for which the Personal Data was collected or otherwise processed, and thereafter for a variety of legitimate legal or business purposes. These may include retention periods that are: (1) mandated by law, contract or similar obligations applicable to USHC’s business operations; (2) for preserving, resolving, defending or enforcing our legal/contractual rights; or (3) needed to maintain adequate and accurate business and financial records. We will delete your Personal Data as soon as the respective purpose of use is not applicable anymore and no legal obligation to retain such data exists. If you have any questions about the security or retention of your personal data, you can contact us at email@example.com.
All Personal Data collected under this Policy may be stored on systems hosted in the United States, which are owned and operated by USHC or our third-party service providers, representatives and agents as described above. If you are located in the EU, we may need to share your Personal Data with third parties in other countries like the United States to provide our Services. This means that Personal Data collected within the EU could be transferred outside the EU. For example, your Personal Data may be transferred outside the EU:
- To our offices located in the U.S.;
- To services providers located outside of the EU; and/or
- Where there is an international dimension to the Services we are providing to you.
Your Personal Data may be disclosed to and processed by staff operating in the United States. Disclosure will be to individuals who work for USHC, our subsidiaries, related companies, and companies with which we have contracted to process or store this data on USHC’s behalf. The individuals and organizations that receive Personal Data as a result of international transfers out of the EU must follow our express instructions with respect to the use of Personal Data and they must comply with appropriate security measures to protect your information.
International use & transfers
If you are a User located outside of the United States, you are responsible for complying with any local laws regarding use of the Services and any related data collection. You also agree and acknowledge that by providing any information on or through the Services, including Personal Data, that such information will be transmitted to, and stored in, the United States.
If you are visiting from the EU or other regions with laws governing the collection, use and transfer of Personal Data across international borders, please note that you are agreeing to the transfer of your information to the United States. By providing your information, you consent to any transfer and processing in accordance with this Policy.
Applicable California privacy legislation permits visitors who are California residents to request certain information regarding USHC’s disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request to access such information, please contact USHC at firstname.lastname@example.org. Within thirty (30) days of receiving such a request, USHC will provide a list of the categories of Personal Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. USHC reserves its right not to respond to requests submitted other than to the address specified in this paragraph.
Other websites, mobile applications, and other services, whether online or offline, may have their own privacy policies, and you should consult those accordingly. The Services may contain links to external websites or other online properties or locations, including those embedded in third-party advertisements or sponsor information that may be made available by USHC, but which are not controlled by USHC. USHC is not responsible for the privacy practices and data collection policies for such third-party services. You should consult the privacy policies of those services for details.
Terms and Conditions of Use
The Terms and Conditions of Use for the Sites and Apps is incorporated by reference into this Policy. The Terms and Conditions of Use can be found here.
Information on our Services
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USHC intends to strictly enforce this Policy. If you believe there has been some violation of this Policy, please contact USHC.
This Policy was last updated on September 28, 2021.