This Policy only applies to the Services identified above, and does not apply to information which you may send us by other means. 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 April 13, 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. 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 notify you by email (if USHC has a valid email address to use) and give you thirty (30) days to opt-in to the changes as they pertain to your information. 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 (“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:
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:
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
There are other areas of the Services where Personal Data or other information may be collected from you in an automated manner. When you visit the Sites or use the Apps, for example, we may automatically collect certain Device Information about your computer, browser or device that includes information about your web browser, such as your IP address, time zone, 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.
Identification of site visitors through 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 “Sharing your personal information.” 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 for the following purposes:
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:
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.
If USHC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice and obtaining your consent to the new processing activities. 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.
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 that you agree and consent 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:
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 email@example.com 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 [ADD LINK TO “DO NOT SELL MY PERSONAL INFORMATION” NOTICE OF RIGHT TO OPT-OUT PAGE], 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; and 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 firstname.lastname@example.org.
USHC does not knowingly collect any information from minors, nor are the Services directed at or intended for minors. If a minor uploads/posts information to the Sites or through the Apps that is publically available, the minor has a right to request that such information be removed from public viewing. A minor may request uploads/posts or other information to be removed by sending a detailed message to email@example.com. Any removal of content by USHC does not ensure or guarantee complete removal of the content in all places. The content may have been reposted by other parties, or federal or state law may require maintenance of the content or information.
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 or through the Sites or Apps. 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 sixteen (16) years of age. USHC does not knowingly solicit or collect information from individuals under the age of sixteen (16). If we determine that we have inadvertently collected information from someone under sixteen (16) years of age, USHC will delete this information from our database.
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”).
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 in support of legitimate interests as described in this Policy.
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 your account on the Sites and/or Apps.
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 EEA have the following rights regarding your Personal Data:
Under the GDPR, Users in the EEA also 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: (i) mandated by law, contract or similar obligations applicable to USHC’s business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) 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 firstname.lastname@example.org.
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.
The Services may contain links to external online locations, including those embedded in third-party advertisements or sponsor information, 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.
Your acceptance of these terms
By using our Services, you signify your acceptance of this Policy. If you do not agree to this Policy, please do not use our Services. Your continued use of the Services following the posting of changes to this Policy will be deemed your acceptance of those changes.
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 April 13, 2021.
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