Aptus Health Holdings, Inc., Aptus Health International, Inc., and their subsidiaries and divisions (collectively, the “Company,” “we,” “us” and “our”) value your confidence in us and we respect your privacy and have prepared this Privacy Notice to describe our policies and practices for safeguarding the personal information which you provide to us, or which we obtain about you, through our services that link to this Notice. Our services include our websites, newsletters, mobile applications, reference tools, sponsored content, continuing medical education and communications (the “Services”). Our Services are operated by our different affiliated companies. Each Service will be identified by its particular operator (e.g., websites will have a footer with the name of the operator, and mobile applications will identify the operator in the “About” tab).
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 information from you is to give you a meaningful, enjoyable and customized experience while using our Services and to allow us to develop new products and services that are relevant to you. Your information also allows us to provide specific services and features that are likely to meet your needs and preferences, and to customize our Services to make your online experience more rewarding.
In the course of using our Services, we may ask you to provide us with certain personally identifiable information (“Personal Information”) that we use to provide you the Services and to contact or identify you. For example, when you register for one of our sites or sign up for one of our newsletters, we will request your name, specialty and contact information to provide you with content that is tailored to your practice and interests. Although most of our Services require you to register with us, you may use some of our Services – for example browsing our public-facing websites –without providing any 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 information and credentials, such as your degree, specialty, license number, medical or other graduate school and year of graduation. During a purchase, we will also request credit card information and billing address. If you voluntarily offer 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.
- 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, 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. 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. We use contact and demographic information to offer participation in surveys or promotions.
- Communications. We may also use your Personal Information to communicate with you. For example, we may correspond with you through email, direct mail, fax, or phone calls to facilitate your transactions and orders, participation in our surveys, programs and services, to deliver information about new surveys or 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 may need to respond to your comments or requests for information, or to contact you 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 (as defined below).We may also need to contact you in order to fulfill our legal requirements.
We automatically collect various types of aggregated, anonymized, and other non-identifiable information (“Non-Identifiable Information”) through the Services. Non-Identifiable Information may include browser type and version, operating system, date/time stamp, IP address, domain name, referring URLs, statistics about the number of visitors to the site, the number of pages visited, click-stream data and user response rates. Non-Identifiable Information helps us to maintain and optimize the Services and to ensure that our Services work properly. Please see the Cookies section below to learn more about how we collect certain Non-Identifiable Information.
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, such as to deliver a product to you according to your preferences or restrictions, or for advertising or advertising targeting purposes. When we combine Personal Information with Non-Identifiable Information in this way, we treat it as, and apply all of the safeguards in our Privacy Notice applicable to, Personal Information.
Most web browsers have options that allow you to control whether or not to accept cookies and give you the option to delete all cookies, including all of our cookies. Please note, however, that disabling cookies in your browser may prevent access to some parts of our Services. Our Services are not currently configured to respond to a browser’s Do Not Track signals.
We also partner with third parties who may place cookies and other tracking technologies on our Services to serve you targeted advertising, to help us analyze how our Services are used, and to help us improve our Services. These third-party cookies do not collect Personal Information through our Services and we do not tie them to our users’ Personal Information, and, as such, they are not covered by the safeguards in our Privacy Notice for Personal Information. As indicated above, you may configure browsers to reject all cookies if you do not want cookies (including these third-party cookies) to be placed on your device. You may also opt out of targeted advertising from members of the Network Advertising Initiative (NAI), European Interactive Digital Advertising Alliance (EDAA), the Digital Advertising Alliance or entities that follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website, EDAA website and DAA website.If you would like to opt-out of mobile ad campaigns and mobile application downloads monitored by AD-X click here. In order to control the collection of data for analytical purposes by Google Analytics, click here.
Clear Gifs (Web Beacons/Web Bugs)
We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which helps us to better manage content on our site by informing us what content is viewed or clicked on. Clear gifs are tiny graphics with a unique identifier similar in function to cookies. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and e-mails 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 users’ Personal Information.
Social Media Widgets
Our Services 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 our Services. Your interactions with these features are governed by the privacy notice of the company providing it.
Market Research Information
In using our 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 Partner Companies (as defined below). Participation in a survey or program is voluntary and you have the opportunity to decline participation. If you elect to participate in a survey or program, we may disclose your information to the sponsoring Partner Company, 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) software applications or (d) professional organizations such as the American Medical Association, which we will add to the information which we already hold about you.
Disclosing Personal Information
We will share your Personal Information with third parties only in the ways that are described in this Privacy Notice or as directed by you. We do not sell your personal information to third parties.
In order to provide you with our Services, we may share your information with our affiliates (i.e., those companies related to Aptus Health by common ownership or control) for everyday business purposes, in which case we will require our affiliates to comply with this Privacy Notice.
We may also share your information with our suppliers, vendors, agents, contractors, or other companies or individuals that provide services to us or on our behalf (“Service Providers”) in connection with the services they perform. We require our Service Providers to protect your Personal Information with the same or equivalent safeguards as those in this Privacy Notice, and we do not permit them to use or disclose your Personal Information other than to provide the services requested by us.
If Aptus Health or its assets are sold, acquired, or merged with another entity, or if Aptus Health becomes insolvent or declares bankruptcy (each a “Company Change Event”), the 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 governing your Personal Information as described in this Privacy Notice. You will be notified via e-mail or a prominent notice on our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
We may disclose your Personal Information to our Partner Companies with whom we collaborate solely for activities related to our Services or those jointly offered or developed by Aptus Health and that Partner Company. Our Partner Companies may also use this information to provide services requested by Aptus Health. For example, without limitation (1) if you have elected to participate in one of our Partner Company’s surveys or programs, 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 Services through a co-branded website, we may share your Personal Information with the co-branded website provider. In the first example, your Personal Information would be handled according to our Partner Company’s privacy notice, which will be presented to you at that time. In the second example, your Personal Information would be handled according to both this Privacy Notice and any privacy notice posted by our co-branded website provider.
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 to 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 may use or disclose Personal Information if it believes in good faith that such use or disclosure is necessary (a) to help identify any person attempting to break into or damage our websites or other property, (b) to investigate, prevent, or mitigate illegal activities, (c) to comply with applicable law, (d) to respond to valid subpoenas or warrants served on Aptus Health, or (e) to protect or defend the rights or property of Aptus Health 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.
PROTECTION OF YOUR DATA
Aptus Health has a number of security measures in place to help protect your Personal Information from unauthorized access, disclosure, alteration or destruction. Although no online service can guarantee the absolute security of your information, we are committed to implementing appropriate physical, technical and administrative safeguards, as described below.
These procedures include the use of firewalls, secure connections on our websites, and frequently the use of Secured Socket Layers (SSLs) to 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 employees or contractors carrying out permitted functions are allowed access to Personal Information. In addition, each employee and contractor of Aptus Health is required to sign a confidentiality agreement requiring him or her to keep confidential all Personal Information of users and customers. We regularly 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’s. Nonetheless, for added protection, we ask that you keep your login information and passwords confidential.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically about security, privacy, and administrative issues relating to your use of the Services.
UPDATING YOUR DATA
We hope you will be 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, at any time online or by contacting us through email or mail at one of the addresses below. You may request that we delete your Personal Information, but please note that we may be required 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 for access to your Personal Information 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.
As described above, we may periodically provide you (via email, mail, phone, or fax) communications promoting the Services of Aptus Health, 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 communication you receive or (b) by contacting us directly (please see contact information below). Despite your indicated communications preferences, we may send you notice of any updates to our Privacy Notice and other service-related, non-marketing communications. Where required by law, we will obtain your consent before sending you any promotional communications.
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 firstname.lastname@example.org or:
Aptus Health Holdings, 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. 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 or by prominently posting notice of the changes on our websites. We will also obtain your consent where required. Changes will be effective immediately for new users of our Services.
OTHER RELEVANT INFORMATION
- 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. For such transfer of personal information from the European Economic Area (EEA) to non-EEA countries, Aptus Health relies on additional safeguards such as Standard Contractual Clauses.
- Links to Other Sites. Certain features of our Services 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 links, you will be directed to that third party’s website or online service. The fact that we provide a link to a website’s 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 and we do not exercise control over third party websites or services. We encourage you to read the privacy notices of any such third party websites and services.
Privacy Notice updated on 10-27-2016