This Privacy Policy applies to all personal information, personal data, and the like, (collectively, “Personal Information”) collected by or on behalf of MedAdvisor directly from an individual or from other Sources (as defined below). By using the Sources, you consent to the data collection and use practices described in this Privacy Notice. 
 
Personal Information does not include “Protected Health Information” (“PHI”) that MedAdvisor collects, stores, uses, and discloses on behalf of “Covered Entities” governed by the Health Insurance Portability and Accountability Act of 1996, and the Department of Health and Human Services’ implementing regulations, as respectively may be amended from time to time (collectively “HIPAA”).  MedAdvisor’s collection, use, and disclosure of PHI is governed by HIPAA, and is subject to the various Notice of Privacy Practices of MedAdvisor’s Covered Entity partners.  If you have questions regarding MedAdvisor’s use of Covered Entity PHI or the Covered Entities Notices of Privacy Practices, please contact us at data.privacy@adherishealth.com.   

MedAdvisor may collect Personal Information that includes information that identifies an individual or relates to an identifiable individual, including but not limited to, your name, physical address, telephone number, e-mail address, company affiliation, and associated interests.
MedAdvisor may also collect other information which is not Personal Information – information that does not reveal your specific identity or does not directly relate to an individual. This other information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information.  Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code.
 
In some instances, we may combine Personal Information with other information, such as combining a precise geographical location with your name. If we combine Personal Information with other information, we will treat the combined information as Personal Information.

Such sources may include the various MedAdvisor sites that link or refer to this Privacy Notice (such as any website operated by or on behalf of MedAdvisor, social media pages and HTML-formatted e-mail messages) together with any and all offline sources including sales and marketing activities (collectively, the “Sources”).  The Sources may provide links to or the ability to connect with non-MedAdvisor websites, social networks or applications (“Third-Party Sites”). Clicking on those links or enabling those connections may allow the third party to collect or share information about you. Those Third-Party Sites are beyond MedAdvisor control. We encourage you to check the privacy policies and terms of use of any Third-Party Sites before providing your Personal Information to them.

MedAdvisor collects information in a variety of ways that fit broadly into the following general categories:

• Direct Interactions: From your use of and interaction with us through the Sources and other activities such as sales inquiries and transactions.
  
  
• Publicly Available Data/Data from Third Parties: Other data you may have made publicly available, such as social media posts, or data provided by third-party sources, such as marketing opt-in lists or data aggregators.
  
  
• Automated Interactions: From the use of technologies such as cookies and other tracking technologies.

Cookies: "Cookies" (which may be html files, Flash files or other technology) are text files that help store user preferences and activity. "Web beacons" (also known as image tags, gifs or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. The Sources and/or third parties may use “cookies,” “web beacons” and other similar tracking technologies (collectively, “Tracking Technologies”) to collect information from you automatically as you use the Sources, browse MedAdvisor websites and the web.
 
Other Tracking Technologies: We use Tracking Technologies to help tailor our content, understand website and internet usage, improve or customize the content, offerings or advertisements through the Sources, personalize your experience with respect to the Sources (for example, to recognize you by name when you return to a MedAdvisor website), save your password in password-protected areas, save your online video player settings, help us offer you programs or services that may be of interest to you, deliver relevant advertising, maintain and administer the Sources and for other purposes described in the "Uses of Information."
 
These Tracking Technologies collect “click stream” data and information regarding your use of the Sources, such as your visits, use of our features and preferences, and may also collect your IP address or some other identifier unique to the device you use to access the Sources (“Identifier”). Your Identifier may be automatically assigned to the device you use to access the Sources. By using the Sources, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to track your activities and your use of the Sources through these Tracking Technologies.
 
MedAdvisor’s use of Automated Interactions may change over time as technology evolves. The descriptions above are designed to provide you with some details about MedAdvisor’s current approach to information collected from Automated Interactions.

Operations

We use Personal Information and other information collected to (a) allow you to participate in the public areas and/or other features of the MedAdvisor websites; (b) respond to your questions or other requests; (c) contact you regarding your use of the Sources, for informational purposes related to the Sources or, in our discretion, regarding changes to this Privacy Notice or related policies; (d) improve the Sources and for internal business purposes; (e) tailor your experience of the Sources and/or otherwise customize what you see when you use the Sources; (f) where applicable to conduct ongoing compliance screening against publicly available watch and sanctions lists and (g) otherwise to maintain, operate and administer the Sources and for other purposes disclosed at the time you provide the information. The legal bases for the processing of your personal data will depend on the reason you provided your personal information via the Sources: (i) the performance of a contract with you or in order to take steps at your request prior to entering into such contract, (ii) use of your Personal Data is necessary for us to comply with a legal obligation, (iii) our legitimate interests, which will be assessed in connection with the specific use of Personal Data, or (iv) your consent, which will be requested and given via the other Sources.
 
Disclosure to Third Parties

In addition to aggregate information (discussed previously), we may share Personal Information, in whole or in part, with third parties, as described below.

• Companies and people who work for us: We contract with other companies and individuals to help us provide services including the Sources. For example, we may host some of our Sources on another company's computers, hire technical consultants to maintain our sites, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, we may validate your identity and other information against available databases. In order to perform their jobs, these other companies may have limited access to some of the Personal Information we maintain about our users. Other companies may collect information on our behalf through their web sites. We require that such companies not use your information for any purpose other than fulfilling their responsibilities to us. We also require that such companies keep your Personal Information confidential and comply with applicable laws. 

• Promotional and informational offers: Sometimes we send offers to selected groups of users. To accomplish this, we may use third parties working on behalf of MedAdvisor. We provide a variety of mechanisms for you to tell us you do not want to receive such promotional or informational offers. For example, we may provide an opt-in box for customers to receive information that is sent by a third-party fulfillment house, and we make clear that, by opting in, you are submitting your data to a third-party. You can elect not to receive promotional or informational material from us by following the instructions to opt-out that may be included in materials we provide you or by making a request to opt-out, as specified below.

• Business transfers: If we transfer a business unit or an asset (such as a MedAdvisor website) to another company, we may transfer the Personal Information we have collected to the relevant third party.

• Legal requirements: We may be obligated to cooperate with various law enforcement inquiries. MedAdvisor reserves the right to share or transfer your information to comply with a legal requirement, disclose any activities or information about you to law enforcement or other government officials as we, at our sole discretion, determine necessary or appropriate, in connection with an investigation of fraud, for the administration of justice, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability. We may release information if, in our judgment the release may be necessary to prevent the death or serious injury of an individual.

Information we collect that is not Personal Information or Personal Information that has been converted to information which cannot be used to identify you is not limited in any way by this Privacy Notice and can be used and disclosed by us in any manner and for any purpose.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties

The security of your Personal Information is very important to MedAdvisor. We use commercially reasonable physical, electronic and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, regardless of our efforts and the device you use to access the Sources, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. In the event that your Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, MedAdvisor will notify you by e-mail, fax or U.S. mail. MedAdvisor will give you notice promptly, consistent with the reasonable needs of law enforcement and/or MedAdvisor to determine the scope of the breach and to investigate and restore the integrity of the data system.

Opt-Out - You may elect not to have your personal information either (a) disclosed to a third party, or (b) used for any purpose materially different from the third parties or purpose(s) stated within this Privacy Notice. 

• Right of access. You can request an electronic copy of your personal information contained within our system.

• Right to rectification. If your personal information is inaccurate or incomplete, you are entitled to have it updated or completed.

• Right to delete. You may ask us to delete or remove your personal information in certain circumstances.

• Right to restrict or object to processing. You may ask us to restrict or block the processing of your personal information in certain circumstances or request no contact from us.

• Right to data portability. You have the right to obtain your personal information from us that is contained in our system for transfer to a third party, in certain circumstances.

• Right to withdraw consent. If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

In order to make a request to exercise any of these rights, please contact us by email, data.privacy@adherishealth.com.  

We may update this Privacy Notice occasionally. When we post changes to this Privacy Notice, we will also revise the “Last Updated” date at the end of this Privacy Notice. If there are material changes to this Privacy Notice, we will notify you by email or by means of a notice on our home page. We encourage you to review this Privacy Notice periodically to be informed of how we are using your information and to be aware of any changes to the Privacy Notice. Your continued use of the Sources after the posting of any amended Privacy Notice shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Notice are effective immediately after being posted by us.

MedAdvisor will retain your Personal Information:as needed to provide you products or services;

• as needed for the purposes outlined in this Privacy Policy or at the time of collection; 

• as necessary to comply with our legal obligations (e.g., to honor opt-outs), resolve disputes and enforce our agreements; and/or

• to the extent permitted by law. 
  
  

At the end of the retention period, MedAdvisor will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.

MedAdvisor is a global corporation and has developed global data practices designed to ensure your Personal Information is appropriately protected. Please note that your Personal Information may be transferred, accessed, and stored globally as necessary for the uses stated above in accordance with this Privacy Policy. By using the Sources, you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than those of your country.

If you have questions or concerns about this Privacy Notice or the protection of your information, please contact us at data.privacy@adherishealth.com.  You may also report concerns to the data protection authority that is authorized to hear those concerns. The relevant authority is the data protection authority in your country or state of residence, or the country or state in which the alleged unlawful use of your personal information occurred.