Last Updated: November 25, 2019
What Information Do We Collect?
How Do We Use Your Information?
- We may collect certain personally identifiable information (“PII”) and other personal information you voluntarily submit as part of your registration/login into Our Sites or your choice to opt-in to any marketing campaigns or other links to Our Sites whether through emails or other communications sent by TI Health . The types of PII we may collect include your name, email address, device ID, telephone number and other similar contact data. This information may be combined with information already in our possession or made available to us through United States federal and state medical professional databases, other files we are licensed to receive, and/or information we obtain from other sources. We may also collect information as a result of your interaction with any of Our Sites, a TI Health owned and operated newsletter, or any communication received directly or indirectly from us. This means we may collect information from you through multiple locations, not just the initial one of Our Sites through which you register.
- We may capture certain usage, device and location information automatically on or through one or more of Our Sites, regardless of whether you provide us with personal information. This information may include your device and/or network information (e.g., Internet protocol (IP) address, user agent strings, device identification number (e.g., IMEI), geolocation data, browser type, page access history, linking information, click stream data, page visits, page views, and/or website log files). If we identify that you are accessing Our Sites through multiple devices, we will associate each such device with your profile.
- We will use operational data (e.g., cookies, log files, clear GIFs, pixels and/or similar devices) to identify our users and their device(s) in order to track our users’ interactions with Our Sites and communications; we use this operational data to enhance certain activities available on Our Sites or applications. You can remove or reject persistent cookies by following the directions provided in your Internet browser’s “Help” file. If you remove a persistent cookie, you may be requested to reregister or log in again upon returning to Our Sites or when opting-in to any of our other campaigns via email or newsletters. If you reject persistent cookies, the functionality of Our Sites or other communications (like our newsletters), or any part thereof, may be impaired or unavailable.
We may use the information we collect from you in the following ways:
How Do We Protect Personal Information?
- To identify and verify your professional medical status by checking your information against the information we acquire from third parties or public sources, including those made available by the AMA, NPI , and/or state licensing boards.
- To personalize and enhance your experience while interacting with Our Sites and applications.
- To deliver the type of content and services that we believe may be of interest to you, including emails, newsletters, alerts, and advertising targeted to your professional experience and/or interests, based on your professional activities and/or other information we possess.
- To monitor usage and interaction statistics on Our Sites and/or through responses to our communications.
- To establish your online account and authenticate you during a registration or login to any of Our Sites or our other communications.
- To allow us to respond quickly and efficiently to your questions and your requests for information.
- To administer a contest, promotion, survey, or other feature.
- To send you advertising, information and/or promotional material geared to your profession. If you would no longer like to receive promotional email communications from us, please refer to the “How Can You Manage Your Email and Mobile Marketing Preferences” section below.
- To share your response information to our communications with the sponsor(s) of the professionally relevant program with which you interact.
- To disclose your information to the extent permitted by law, as described more fully below.
Although we cannot guarantee the security of personal information that is transmitted over the Internet or stored on Our Sites, we have established and implemented reasonable physical, electronic, and administrative procedures designed to safeguard and secure the personal information we collect and maintain online. We protect your transactions involving your PII over the Internet using Secure Sockets Layer (SSL) technology. We restrict access to your PII in our database to our authorized employees, our agents, and certain of our authorized partners.
Please note that we do not have any control over or responsibility for information you share about yourself on or through any websites outside of Our Sites; including any third-party websites accessed or linked through Our Sites. All such sharing of information and content is done at your own risk. Any concerns over the sharing of information on or with a particular website not owned by TI Health should be handled by dealing directly with that website.
Our Sites, applications, and services are not intended for use by children under the age of thirteen (13). We will not knowingly collect any personal information from users under the age of thirteen (13) online through Our Sites. If you think that we have collected personal information from a visitor under the age of thirteen (13), please contact us at us firstname.lastname@example.org.
Do We Disclose the Information We Collect to Outside Parties?
How Do I Ask Questions and Provide Feedback Regarding Privacy?
- Provision of Information Because some of our programs are targeted toward medical professionals only, advertisers or agencies have asked us to restrict access to certain information, products, and services to medical professionals only. To ensure that we are delivering the information, products, and services as may be required by law, we may be required to disclose your information with third-party sources to meet legal requirements (e.g., Certified Medical Education and PDMA) and determine your eligibility to receive the materials.
- Subsidiaries and Affiliates. We may transfer PII to our subsidiaries and corporate affiliates.
- Website Consultants and Service Providers. We may disclose personal information to third-party consultants and service providers (e.g., hosting/support/maintenance providers, third-party payment processing agencies, and remedial/repair services) to the extent that they require such access in order to perform services for us.
- Third-Party Advertising. We typically do not provide PII to any third party for marketing/advertising purposes but may disclose for internal analytics and user targeting confirmation only. We may disclose information about you to third parties, such as a TI Health ID tied to a unique record, an NPI or email address, so that these parties may verify that our programs were targeting specific users on target list or specialty programs.
- Reorganization or Sale of the Company. In the event that we are merged with or become part of another organization, we are sold, we sell all – or substantially all – of our assets, or we are otherwise reorganized, all of our information, including your information may be one of the transferred assets to the acquiring or reorganized entity.
- As Otherwise Allowed by Law. We may transfer personal information to third parties where we are expressly authorized or required by applicable law to do so.
- Disclosure of non-PII. In addition to you providing us with PII, you may also provide us with, or we may otherwise acquire non-PII information (i.e., information which does not personally identify you). We reserve the right to use and/or disclose such non-PII as we choose, including to third parties, for any reason (e.g., marketing and advertising). This includes information that has been de-identified.
- Aggregated Information. We may aggregate information that you provide or is otherwise collected from or about you with information provided by other individuals in such a manner that the information is not personally identifiable to you. Once such information is non-PII, we reserve the right to use and/or disclose such non-PII as we choose, including to third parties, for any reason (e.g., marketing and advertising).
- Sponsors. We may share your voluntary responses to communications with the sponsor(s) of the professionally relevant program with which you interact.
What Are Your Rights?
You may have certain rights under federal or state laws and regulations in the event that we have any personally identifiable information about you. You may contact us at any time with regards to your rights. Under applicable law, you may have the right to request that we:
- Provide a detailed explanation regarding the personal information we have collected about you and how we use that information.
- Receive a copy of the personal information we have collected about you.
- Request correction of any inaccurate personal information that we have about you.
- Erase or delete any of your personal information.
- Request to opt-out of certain marketing communication from us.
- You can make these requests by contacting us at email@example.com.
You may also easily manage your marketing preferences by not providing information to us. However, to the extent that you choose to provide your PII to us, to a TI Health client, you can opt out of having your PII used for certain purposes.
Where We Store and Process Personal Data
- In addition, you may remove the email pixels that may track you and communicate information to us so long as they appear in the image cache of your Internet browser. You may remove the pixels simply by deleting the cache in which the pixel is stored.
- You may delete cookies by opening your browser’s “Internet Options” folder and making the appropriate selections.
- If you are unsure of how to clean your cache or delete cookies, locate the “Help” function in the browser menu. Entering in the search bar “clean cache” and “delete browser cookies” will return instructions specific to your browser.
We may transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data; such contracts will conform to the standard clauses specified under the GDPR and we will remain liable for the protection of such personal data.
We are committed to and complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. We have self-certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If third-party agents process personal data on our behalf in a manner inconsistent with the principles of either Privacy Shield framework, we remain liable unless we prove we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, TI Health commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at firstname.lastname@example.org. TI Health has further committed to refer unresolved Privacy Shield complaints to TRUSTe, an alternative dispute resolution provider located in the United States. If you not received timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit TRUSTe for more information or to file a complaint. The services of TRUSTe are provided at no cost to you. As further explained in the Privacy Shield Principles, binding arbitration is available to address residual complaints not resolved by other means. We are also subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).