Version 1.0. Last Revised: 12/17/2015
We are firmly committed to protecting the confidentiality and security of your Personal Information. The term “Personal Information” means any information which can be used to identify a person including by way of example, but not limitation, name, date of birth, mailing address, social media and other third party platform account identifiers, home phone number, mobile phone number, e-mail address, credit card information, and/or Social Security number. The term “Health Information” means any information, in any form, related to the past, present, or future health or medical status, condition, or treatment of a person, including, by way of example, but not limitation, names of doctors, health conditions, medicines, and/or prescription information and history.
COLLECTION AND USE OF NON-PERSONAL INFORMATION
How We Collect Non-Personal Information
When you visit the Site, and during your interactions with the Site, we may collect Non-Personal Information from you. "Non-Personal Information" means a data element or collection of data elements that by itself cannot ordinarily be associated with a specific individual. Non-Personal Information includes by way of example but not limitation, the Internet browser or computer operating system you are using, your navigation of the Site including the pages of the Site that you access, the amount of time spent on various portions of the Site, the length and dates of your visits to the Site, and certain Site data captured through your interactions with the Site and other sites. Non-Personal Information may include information provided by you through the Site or otherwise (e.g., through a third-party site) that is not Personal Information or Health Information. Certain Non-Personal Information may be collected on an aggregated, anonymous basis through web server logs, cookies, ad servers, tracking pixels, web beacons, and similar Internet tracking devices (collectively “Tracking Mechanisms”). Web servers automatically collect Non-Personal Information, with your IP address, when you request pages of the Site or other sites. Based on certain interactions with the Site, third-party sites, mailings, other communications with us, and/or our system configurations, certain Non-Personal Information may be associated with your Personal Information such that your Non-Personal Information is identifiable with you. You may be able to opt-out of certain third-party associations by following customization and/or opt-out options as described below.
How We Use Non-Personal Information
The collected Non-Personal Information may be used by us and our affiliated companies for a variety of analytic and developmental purposes including to improve and enhance the Site and our products and services, to create new products and services, to customize your experience on the Site and other sites that you visit on the Internet, to identify and/or offer products, services and website functionality that may be of interest to you, and other legitimate business purposes.
We may use different kinds of cookies including session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, to determine ways to improve the Site, Site content, and the services offered through the Site. These cookies are deleted from your hard drive when you close your browser session. Persistent cookies are used to collect non-personally identifiable information such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp and number of clicks.
You may set your browser to accept cookies, warn you when a cookie is sent, or turn off all cookies (except Flash cookies). Check your web browser’s help menu or your mobile device settings to find out how. Some mobile devices store cookies not only in areas connected to the web browsers but also in an app-specific area, so you may have to check your app settings options to determine how to manage or delete cookies stored in these other areas. If you do not accept cookies, some features, services, or activities available through the Site may not function correctly and you may be unable to access certain content.
We may embed tracking pixels within various pages of the Site to enable use of site analytics. The site analytics enable us to determine the usage frequency of various areas of the Site and identify areas of the Site for enhancement. While you are visiting and after you leave the Site, we may use web beacons to notify you of areas of the Site and other aspects of our organization and its affiliated companies in which you may be interested. Certain tracking pixels and web beacons may be cleared or reset through configuration of your web browser such as by clearing your cache. We may use ad servers to provide you with offers of possible interest.
We use your IP address so that we can send data (such as the pages you request) to you and collect Non-Personal Information during the process. We aggregate this Non-Personal Information with similar Non-Personal Information collected from other users to track overall visitor traffic patterns and help us understand Site usage and preferred and most frequently used pages, products and services, to provide you with better service, to improve Site use and functionality, and to provide you with information on other products and services that may be of interest to you.
We may analyze Non-Personal Information in the aggregate to study outcomes, costs, and provider profiles, and to suggest benefit designs for employers or health plans. These studies may generate Aggregate Data (described below) which we may utilize for a variety of purposes.
We may perform statistical analyses of the traffic patterns, Site usage, and behaviors associated with the Site. We may use these analyses to generate Aggregate Data from the original Non-Personal Information. We may combine, separate, aggregate, or otherwise parse and process Non-Personal Information. The parsing and processing of such information may generate Aggregate Data. “Aggregate Data” is summary level data, such as the number of web visitors in a specific geographic area. Aggregate Data does not contain information that can be used to identify or contact you, such as your name, address, telephone number or e-mail address, and does not reflect the original form of the Non-Personal Information collected from you.
We work with third parties to (a) operate and maintain the server(s) on which the Site operates, (b) provide Tracking Mechanism(s) that we embed in or use with the Site, (c) provide advertisements and other information to you about the Site, products, and services through a third-party site based on a prior visit to the Site, (d) analyze communication with us and interactions with the Site, (e) de-identify data, and (f) collect Non-Personal Information from you (e.g., on your interactions and/or experience with the Site and/or us). The third party may then share the Non-Personal Information, Aggregate Data, and/or other data with us.
We may disclose Non-Personal Information to third parties as follows:
· We may share Non-Personal Information with our affiliated companies, third parties who provide services to us, and other parties that you have authorized.
· We may disclose Aggregate Data to other companies or organizations for any legitimate business purpose.
· We may disclose products and services developed using the Non-Personal Information, including products and services that disclose anonymous and/or deidentified Site data for any legitimate business purpose.
· We will not sell your Non-Personal Information to other companies or organizations.
Some of the third parties, such as Google®, Twitter®, and LinkedIn® may provide customization and/or opt-out of certain Tracking Mechanisms through their respective sites. For example, Google's Ads Settings, DoubleClick opt-out page, Twitter’s promoted content settings, LinkedIn account settings, and Network Advertising Initiative opt-out page may limit the collection and usage of certain third-party Tracking Mechanisms.
COLLECTION AND USE OF PERSONAL INFORMATION
How We Collect Your Personal Information
Pharma Heroes Nomination
When you submit your e-mail address with the nomination, or agree to accept a nomination, we may provide you with certain Pharma Heroes campaign related e-mail(s) including, for example, the overall positive impact of the Pharma Heroes. You may unsubscribe from receiving such communications by following the opt-out instructions included within such e-mail(s).
When you communicate with us through social media, or provide a comment directed at us through social media, we may use social media to communicate with you. We may also directly communicate with you through social media in accordance with any expressed social media preferences in your communication preferences. We may also promote content of interest to you through social media. You may opt out or configure your social media account settings to limit promotion of such content.
We may use certain in-house or third-party functionality to analyze your communications with us and interactions with the Site. The analysis enables to us to monitor the services that we provide so that we can improve the services provided to you. These third parties will be required to protect any Personal Information in accordance with this Policy. Other analytics capabilities are reflected above in the description of Non-Personal Information.
How We Use Your Personal Information
· We will use your Personal Information to contact you regarding the Pharma Heroes program.
- We may utilize selected service providers to make targeted non-personal communications to an aggregated audience regarding our offerings and other potentially relevant benefit information of interest to you.
- We may share your Personal Information with other UBC companies (i.e., entities which are controlling, controlled by, or under common control with UBC) to provide you with more personalized and enhanced services.
· We may disclose your Personal Information to relevant third parties such as site technicians, auditors, lawyers, or other professional advisors.
· We may communicate with you via e-mail, facsimile, letter, text message, mobile phone, and similar mechanisms.
- We may use third-party agents for purposes of communicating with you and/or collecting information from you.
- Statements here and elsewhere on the Site concerning the treatment of your Personal Information may not apply with respect to information already in our possession.
In certain circumstances, we may be legally compelled to release your Personal Information in response to a court order, subpoena, search warrant, or law or regulation.
“Do Not Track” Signals and Similar Mechanisms
Our Site does not respond to web browser “do not track” signals and similar mechanisms. However, you may control certain Tracking Mechanisms as described above.
How You Can Correct/Update Your Personal Information
You can correct or update your Personal Information at any time using the following option(s):
· Via E-mail: Send an e-mail to us at email@example.com.
Transfer of Personal Information and Non-Personal Information
All Personal Information and Non-Personal Information obtained through our Site are owned by us. Accordingly, if we are acquired, merge with another entity, or divest one or more of our businesses, affiliates or subsidiary companies, the Sites, and any Personal Information and Non-Personal Information obtained through them, may be transferred to an applicable entity for the purpose of continuation of services, in accordance with applicable law.
USAGE BY CHILDREN
Our Site is neither intended for nor designed to attract users who are under the age of 18. We are committed to preventing the unintentional collection of Personal Information from children under the age of 13. Any Personal Information of a child under 13 that is provided to us must be provided by a parent or legal guardian, and not by a child under the age of 13 who is using the Site.
If you are the parent or legal guardian of a child under the age of 13 whom you have reason to believe has provided his or her own Personal Information to us, you have the right to request the removal of that child's Personal Information from our database. In order to request such removal, please send an e-mail to firstname.lastname@example.org. You will be required to verify your identity as the child’s parent or legal guardian in order to have their Personal Information removed.
We are committed to protecting the privacy and security of this Site. We take reasonable technical and procedural precautions to protect the information received by us. Our Internet infrastructure is protected using industry recognized commercial security products, including current encryption technology, and best practice procedures for maintenance of the website. In addition, our infrastructure is monitored 24 hours a day, seven days a week.
No method of transmission over the Internet or storage of data on an Internet server is 100% secure. Although we use commercially acceptable and reasonable precautions to protect your information, we do not guarantee its absolute security.
How to Send Us Your Comments
Specific questions regarding the enforcement of this policy should be directed to email@example.com.