Aptus Health Inc., its subsidiaries and divisions, (collectively, “Aptus Health Inc.”, the “Company”, “we”, “us” and “our”) value your confidence in us and we respect your privacy. We hold your privacy concerns in high regard. This Privacy Notice describes to you our practices regarding the personal information which you give to us, or we obtain about you, from our websites, including but not limited to www.aptushealth.com, www.univadis.com, and www.tomorrownetworks.com (collectively, our "websites, products and/or services").
By using our websites, products or services, you expressly consent to our collection, use, and disclosure of your information as described in this Privacy Notice and agree that you are entering into a voluntary business relationship with us for the purpose of conforming with any applicable federal, state and local laws relating to solicitations, including via email, telephone or fax.
We do not knowingly collect or maintain personal information from any person under the age of majority. No parts of our websites, products or services are designed to attract anyone under the age of eighteen.
INFORMATION COLLECTED AND HOW WE USE IT
One of our primary goals in collecting personal information from you is to give you a meaningful, enjoyable and customized experience while using our websites, products and services and to allow us to develop new products and services that are relevant to visitors like you. Personal information also allows us to provide specific services and features that most likely meet your needs, and to customize the webpage or service to make your online experience smooth and efficient.
What We Collect
In the course of using our websites, products or services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you and administer your use and enjoyment thereof (“Personal Information”). Personal Information may include, but is not limited to, your name, shipping address, phone number, fax number, email address, date of birth, and demographics. For the use or purchase of certain products or services, we may also ask you to provide us with professional designation, specialty, state license number, medical school and year of graduation and (during a purchase) credit card information and billing address. If you voluntarily provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. When you voluntarily participate in one of our surveys or programs (as described in further detail below), we may collect additional information from you.
In addition to collecting Personal Information that you provide, we may also monitor the use of our websites, services and/or products by collecting aggregate, anonymous, Non-Identifiable information (“Non-Identifiable Information”). Typically, Non-Identifiable Information tracks usersʼ patterns throughout our websites and products, and it may include information such as your browser type, operating system, date/time stamp for your visit, IP address, domain name, referring URLs, statistics about the number of visitors to the site, the number of pages visited, and user response rates. Non-Identifiable Information enables us to provide a more enjoyable and personalized experience, as well as tracking errors.
Certain Non-Identifiable Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifiable Information when they are taken alone or combined only with other Non-Identifiable Information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifiable Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve our services and to analyze and understand how our websites and products are used. We may also use the combined information without aggregating it to serve you specifically, for instance, to deliver a product to you according to your preferences or restrictions, for advertising or advertising targeting purposes.
In addition to the foregoing, Personal Information may also be collected in the following forms:
- Device IDs. We may collect and store a unique device ID associated with your particular device (“Device ID”). We use your Device ID to track the number of unique users using our services and to enable you to interact with and use our services. We link your Device ID with the technical information accessed through your use of our websites, products, and services so that we may administer resets to your account or to delete information when you request that we do so or for other administrative purposes.
- Surveys and Promotions. You may also elect to participate in market research surveys or promotions. By submitting answers to these surveys or promotions, you are providing specific feedback to us. Participation in a survey or program is voluntary and you have the opportunity to decline participation or honoraria. If you elect to participate in a survey or program, we may disclose your information to certain third parties (as described below), provided you have given us your consent to do so.
Additionally, when you use our products, services or websites, we may monitor your use of the websites by collecting aggregate information through the use of “cookies.” Cookies are small pieces of information that a website transfers to the memory or hard drive on your computer. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. As is true of most web sites, we also gather certain information automatically and store it in log files. For instance, when you visit one of our websites, our web server will automatically recognize some Non-Identifiable Information, including but not limited to the date and time you visited our site, the pages you visited, the referrer (the website you came from), the type of browser you are using (e.g. Firefox, Internet Explorer), the type of operating system you are using (e.g., Windows or Mac OS), and the domain name and address of your Internet service provider (e.g., AT&T, Verizon, AOL).
Most web browsers have options that allow you to control whether or not to accept cookies. However, disabling cookies in your browser may prevent access to some parts of our websites, services, or products.
Note that websites which are intended for users in the EU, and with respect to websites operating as part of a particular patient feedback program in an EU country or for EU participants, we will not utilize cookies or other tracking devices on such sites without your consent for such use.
Clear Gifs (Web Beacons/Web Bugs)
We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a userʼs computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of a period at the end of this sentence. We do not tie the information gathered by clear gifs to our Web usersʼ personally identifiable information.
Social Media Widgets
Aptus Health Inc. websites include Social Media Features, such as the Twitter and Linkedin buttons and Widgets or interactive mini-programs that run on that site. These Features may collect your IP address, which page you are visiting on that site, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these Features are governed by the privacy notice of the company providing it.
Market Research Information
In using our websites, products and/or services, you may also elect to participate in market research surveys or programs. By submitting answers to these surveys or programs, you are providing specific feedback to us and/or certain third parties (as described below). Participation in a survey or program is voluntary and you have the opportunity to decline participation or honoraria. If you elect to participate in a survey or program, we may disclose your information to certain third parties (as described below), provided you have given us your consent to do so.
Information Collected from Other Sources
We may occasionally supplement your information with information we receive from other sources including, but not limited to (a) companies that provide our products or services by way of a co-branded or private-labeled website, (b) companies (e.g., pharmaceutical companies) that sponsor surveys or programs on our websites (the entities in (a) and (b), collectively, “Partner Companies”), (c) downloadable software applications from our websites or (d) professional organizations such as the American Medical Associations, which we will add to the information which we already hold about you.
How Information is Used
We use the information we collect to administer our business activities, improve our websites, products and services, provide customer service, make available products and services to our users and customers, and for the recruiting, marketing, and other business purposes of Aptus Health Inc. and our Partner Companies (as defined below).
We also use this information in helping us to create and manage your account, verify your identity, verify your eligibility for products and services, deliver interactive educational programs, provide you support, initiate and fulfill orders, complete transactions, and administer the websites.
We may also use your personal information to communicate with you. For example, we may correspond with you, possibly through email, direct mail, fax, or phone calls related to your transactions and orders, participation in our surveys, programs and services, invitations to new surveys or programs and services, deliver information about new surveys, programs or services, and to alert you to developments in the use of pharmaceuticals or selected information from the pharmaceutical industry related to your medical specialty. We use contact and demographic information to offer participation in surveys or programs. We may need to respond to your comments or requests for information; or we may contact you if needed in the course of processing or shipping products or services offered through our websites. We may also use contact and demographic information to extend offers to you from our Partner Companies.
We may create aggregate Non-Identifiable Information from personal information about our users, sales, products or traffic patterns (“anonymous information”); this anonymous information does not include any personally identifiable information. We use this anonymous information to analyze request and usage patterns so that we may enhance the content of our websites, products, surveys and/or services. Aptus Health Inc. reserves the right to use and disclose anonymous information to third parties in its discretion.
Disclosing Personal Information
We will share your personal information with third parties only in the ways that are described in this privacy notice. We do not sell your personal information to third parties.
In order to provide you with our website services, and/or products, we may share your information with our affiliates (i.e. those companies related to Aptus Health Inc. by common ownership or control) for everyday business purposes as described herein. We may also share your information with our suppliers, agents, contractors, or other companies or individuals that provide services for or on our behalf (“Service Providers”) in connection with the services they perform. Our Service Providers are required not to sell, share, or use your personal information other than to provide the services requested by Company. Uses and disclosures of personal information by external individuals and organizations acting on Aptus Health Inc.ʼs behalf are governed by agreements that require personal information to be protected appropriately.
We may disclose your personal information to other companies we collaborate with solely for activities related to our websites, products, and services or those jointly offered or developed by Aptus Health Inc. and that Partner Company (our “Partner Companies”). Our Partner Companies may also use this information to provide services requested by Aptus Health Inc. and/or for their recruiting, marketing or other business purposes. For example, without limitation, (1) if you have elected to participate in a survey or program, we may share your personal information with the sponsors of the survey or program, when we report the results of the survey or program to the sponsors; and (2) if you accessed our websites, product, or service through a co-branded websites, we may share your personal information with the co-branded website provider. We do not control the privacy practices of our Partner Companies.
There are specific limited instances when personal information may be shared with accredited Continuing Medical Education (“CME”) providers for their fulfillment of their reporting obligations under the Accreditation Council for Continuing Medical Education (“ACCME”) and other accrediting bodies. We do not control the privacy practices of these third parties.
Disclosure by Law
Aptus Health Inc. may use or disclose personal information if it believes in good faith that such use or disclosure is necessary to (a) help identify any person attempting to break into or damage our websites, (b) to investigate, prevent, or take action regarding any illegal activities, (c) to comply with relevant laws, or legal or regulatory obligations, (d) to respond to subpoenas or warrants served on Aptus Health Inc., or (e) to protect or defend the rights or property of Aptus Health Inc. or its customers. Without limiting the foregoing, we may share personal information with law enforcement agencies if we believe that we have evidence of a violation of computer security or related laws.
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
PROTECTION OF YOUR DATA
Aptus Health Inc. has a number of security measures in place to help protect and safeguard your personal information from accidental loss, misuse, unauthorized access, disclosure, alteration or accidental destruction. Although no web site can guarantee the absolute security of your information, we are committed to taking commercially reasonable precautions as described below.
These procedures include the use of firewalls, secure connections on the Aptus Health Inc. websites, and frequently the use of Secured Socket Layers (SSLs) that encrypt pages that collect Personal Information. Personal information is stored in limited access servers and physical access to our servers requires individual authorization and authentication. Only authorized Aptus Health Inc. employees or contractors carrying out permitted functions are allowed access to personal information. In addition, each employee and contractor of Aptus Health Inc. is required to sign a confidentiality agreement requiring him or her to keep confidential all personal information of users and customers. We train our employees and contractors on proper use and handling of personal information. Employees and contractors who violate these policies may be subject to disciplinary action, termination of their employment and legal action. Our Service Providers are also required to maintain security measures similar to Aptus Health Inc.. However, for added protection, we ask that you keep your login information and passwords confidential.
If Aptus Health Inc. learns of a security breach that results in the unauthorized disclosure of your Personal Information, we may attempt to notify you electronically so that you are able take appropriate protective steps. By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. Aptus Health Inc. may post a notice on its websites if a security breach occurs. If this happens, you will need a web browser or mobile device enabling you to view the notice. Aptus Health Inc. may also send an e-mail to you at the e-mail address you have provided to us for a notification pursuant to this paragraph. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), you should notify us at firstname.lastname@example.org
In addition to the foregoing, please be aware of the following issues relating to our security measures:
- Phishing. Identity theft and the practice currently known as “phishing” are of great concern to Aptus Health Inc.. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commissionʼs website.
- Users Outside Of the United States. Your personal information may be processed in the country in which it was collected and/or other countries, including the United States, where laws regarding the processing of information may be less stringent than the laws in your country.
- Links to Other Sites. Certain features of our websites and products contain links to other websites and online services. If you choose to visit a third party service or an advertiser by clicking a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third partyʼs website or online service. The fact that we provide a link to a websitʼs content or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. This Privacy Notice is not applicable to the websites or content of any such third parties. We do not exercise control over third party websites or services. These other websites or services may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy notices or statements of any such third party websites and services that you may use.
UPDATING YOUR DATA
It is important to us that you are able to take an active role in your experience with us. We highly recommend that you confirm and update your profile regularly. You can update or change your profile, which includes Personal Information, online at any time by contacting us through email or mail at one of the addresses below. You may request deletion of your personal information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We will respond to your request to access within 30 days. While updating your profile, you can select the type of messages and communications that you want to receive, which will further customize your experience as described below. The contact information for updating your data is given below.
Promotional Communications. As described above, we may periodically provide you (via email, mail, phone, or fax) marketing communications promoting the websites, products and services of Aptus Health Inc., our Partner Companies, and/or other third parties. When you receive marketing communications from us, you may indicate a preference to stop receiving further communications from us by “opting-out” (a) via the unsubscribe instructions provided in the e-mail you receive or (b) by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you notice of any updates to our Privacy Notice and other service-related, non-marketing communications.
Your Privacy Rights. As described above, we may provide your personal information to third parties for their marketing purposes. You may indicate a preference for us to stop providing your information to third parties for their marketing purposes by “opting-out” by contacting us directly (please see our information below). After you opt-out, we will stop disclosing your personal information to third parties for their marketing purposes, unless you have “opted-in” by (a) contacting us directly (please see our information below) or (b) by signing up for another survey and/or program. If you wish to discontinue receipt of marketing e-mails from third parties to whom we've already disclosed your personal information, please contact the third parties directly to update your preferences.
For instructions on changing any of your privacy preferences, accessing your information, updating your information, or for any privacy or data-protection-related questions, please contact us at email@example.com
Aptus Health Inc.
Attn: Customer Service
55 Walkers Brook Drive, Suite 500
Reading, MA 01867-3274
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is subject to occasional revision, and if we make any substantial changes in the way we use your personal information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our websites. Any material changes to this Privacy Notice will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our site prior to the change becoming effective. These changes will be effective immediately for new users of our websites, products or services. Please note that at all times you are responsible for updating your personal information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our websites, products, or services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
OTHER RELEVENT INFORMATION
We may share some or all of your personal information with our affiliates, in which case we will require our affiliates to honor this Privacy Notice.
If Aptus Health Inc. is (or its assets are) sold, acquired, merged with another entity, or if Aptus Health Inc. becomes insolvent, and/or declares bankruptcy (each a “Company Change Event”), the websites, products and services and any information obtained through them, including personal information, may be transferred or sold to another entity in connection with the Company Change Event. That entity will assume the rights and obligations regarding your personal information as described in this Privacy Notice. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
The headings of sections of this Privacy Notice are for convenience and are not to be used in interpreting this Agreement. As used in this Privacy Notice, the word “including” means “including but not limited to.”
Aptus Health Inc.ʼs websites may contain links to and from other websites, products or services. These other sites are not covered by this Privacy Notice, and we are not responsible for the privacy practices or the content of these other sites.