Effective March 7, 2018
1. Information We Collect and How We Use It
We, third-party advertising companies, and service providers may use a variety of technologies that automatically or passively collect certain information whenever you visit any Coalition Website or otherwise interact with us or our content (“Usage Information”). Usage Information may include the hardware model, browser, and operating system you are using, the URL or advertisement that referred you to a Coalition Website you are visiting, all of the areas within a Coalition Website that you visit, your time zone, location information, and mobile network (if applicable), among other information. In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device you use to access a Coalition Website. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.
a. Commonly Accepted Practices
Personal Information and Usage Information collected from you may be used for commonly accepted practices, including:
- Allowing you to use features we offer or to provide related customer service;
- Tailor content and offers we display to you;
- Product service fulfillment, such as the use of addresses for shipping and credit card information for payment;
- Sending electronic publications to online subscribers;
- Administration of our websites and monitoring usage of our websites;
- Internal operations, such as the use of identity-verification technologies, and the review of server logs;
- Legal compliance and public purposes, such as subpoena compliance and credit reporting;
- Marketing of products and services to you by the Coalition;
- Purposes disclosed at the time that you provide your Personal Information or otherwise with your consent.
In addition, we may use and disclose non-personal information, including information that has been de-identified (by removing all information that can be used to directly identify or contact you as a specific individual, typically by using a mathematical process known as hashing), at our discretion, including to make inferences about offers and content that may be of interest to you as well as to serve you with relevant advertising and allow others to do so.
b. Tracking Technologies
The methods that we may use to collect Usage Information include the following.
- Cookies. Cookies and local storage are data files placed within a browser on a device when it is used to visit a Coalition Website. Certain web browsers and browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms. For example, a Flash cookie is a data file placed on a device via the Adobe Flash plugin. Cookies and local storage can be used for a variety of purposes, including to store a unique identifier for your device that recognizes your device as you visit a Coalition Website or other web sites or online services and to remember your preferences. Most browsers provide you with the ability to disable or decline cookies and local storage. You will need to check your browser’s settings for further information. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies or to adjust your Flash privacy settings on your device, some features of a Coalition Website may not function properly.
- Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”), may be included in our web pages and e-mail messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to a Coalition Website, to monitor how users navigate a Coalition Website, to count how many e-mails that were sent were actually opened or to count how many particular videos or links were actually viewed. In addition, we may use these and a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes and to enforce our intellectual property rights.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with websites and other online services. The code is temporarily downloaded onto your device from our web servers, is active only while you are connected to the Coalition Website and is deactivated or deleted thereafter.
c. Email Addresses and Mailing Lists
The Coalition collects and uses the email addresses and mailing addresses of its visitors for purposes of providing information and services. In addition, the Coalition collects email and mailing addresses in connection with registration for and attendance at conferences, webinars and other events, subscriptions for publications, the purchase of products and services, and in other circumstances. We may use your e-mail address or other Personal Information to send commercial or marketing messages to you regarding the Coalition’s products or services. In addition, we may also use your name, mailing address, e-mail address, or other Personal Information (i) to send commercial or marketing messages on behalf of unrelated third parties, and/or (ii) in a mailing list sold to third parties for the marketing of their products and services. For example, we may share contact information you provide when you register for a conference or webinar with conference exhibitors or webinar sponsors so that they may send you commercial messages. You may opt-out of any or all of such disclosures as provided below.
Our online surveys may ask respondents for contact, demographic and other personally identifiable information. The ways in which such information may be used or disclosed will be described in the survey materials. We also may use contact information from our surveys to send you information about products and services of the Coalition, partner organizations and/or unrelated third parties.
e. Information from Other Sources
The information we collect is gathered from several sources. Such sources may include, but are not limited to: mailing list enrollment; conference, webinar, distance learning and other event registration; website visits; newsletter subscriptions; and product sales. We may combine the information you submit when using one of our services with information (i) collected from your use of other Coalition services, (ii) collected by Coalition partner organizations, or (iii) obtained from third parties. The combined information may be used in a similar manner to any other information we collect.
2. Third Party Advertisers and Links
a. Third Party Advertising and Analytics Service Providers
We may allow third party ad servers or ad networks to serve advertisements within the Coalition Websites and elsewhere on the Internet. We also use analytics providers to provide us with information regarding the use of the Coalition Websites and the effectiveness of our advertisements. These third party ad servers or ad networks use their own tracking technology on your device (e.g., cookies and web beacons) to select and send advertisements and links directly to your browser. They automatically receive your IP address when this happens. We may share non-personal information, including information that has been de-identified with ad servers, ad networks, analytics providers, and other third parties for the purposes of serving you more relevant advertisements.
We may use a variety of companies to serve our advertisements. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and you may want to visit the following webpages, which provide “opt-out” mechanisms for participating companies: http://networkadvertising.org/managing/opt_out.asp; http://www.aboutads.info/choices/. You may also be able to opt-out from interest based advertising on your mobile device through your mobile device settings. You may also opt-out from receiving targeted ads while on Coalition Websites through your account settings as further described below in “Your Choices.” Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.
The Coalition does not provide any personally identifiable information to these third party ad servers or ad networks without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. You should consult the respective privacy policies of these third party ad servers and ad networks for more information on their practices and for instructions on how to opt-out of certain practices.
b. How We Respond to “Do Not Track” Signals
Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many websites and online services, the Coalition Websites do not alter their practices when they receive a “Do Not Track” from a visitor’s browser. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
c. Third Party Links and Content
The Coalition Websites and publications contain many links to other websites. In addition, the Coalition may maintain a presence on third-party sites such as Facebook®, Linked-In® or others. These other websites may send their own cookies to users, collect data or solicit Personal Information. The Coalition is not responsible for the privacy practices or the content of these other websites. Please check with the other sites to review their privacy policies and how they may collect or use information.
3. Information Sharing
The Coalition may share non-personally identifiable information, such as information that has been de-identified, aggregated user statistics, or a Coalition identification or transaction number, with third parties in our discretion. We do not share your Personal Information with third parties for those third parties’ own direct marketing purposes unless you consent (opt-in or opt-out) to such sharing. California Residents, please see below for additional information on “Your California Privacy Rights.”
a. When You Request That We Share Your Information
We may share information when you request that we do so. For example, you may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to their privacy practices. Or, you may choose to interact with a third party application or feature, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
b. Third Parties Providing Services on Our Behalf
We may share information about you, including Personal Information, with third-party vendors to enable them to perform services on our behalf. Additionally, we may share various information relating to our users and fraudulent or potentially fraudulent activities with our fraud prevention and similar vendors, and they will use this information to help us and their other clients prevent fraudulent and illegal transactions.
c. Administrative and Legal Reasons
We may also transfer and disclose user information, including Personal Information, to third parties: (i) in the event we are required to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Terms and Conditions or other policies applicable to a Coalition Website or our services or to protect the personal safety, rights, property or security of the Coalition, our customers, or a third party. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion.
d. Business Transfers
The Coalition may share Personal Information with its parent, or its subsidiaries and affiliates, primarily for business and operational purposes. The Coalition reserves the right to disclose and transfer all information related to a Coalition Website, including Personal Information: (i) to a subsequent owner, co-owner or operator of a Coalition Website or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, bankruptcy, the sale of certain of the Coalition’s ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process.
California Civil Code Section 1798.83 permits residents of California to request certain details about how their Personal Information has been shared during the calendar year with third parties for those third-parties’ own direct marketing purposes, unless the business permits California residents to opt in to, or opt out of, this type of sharing. The Coalition qualifies for this alternative option. As noted above, we will not share Personal Information about you with third parties for their own direct marketing purposes if you do not opt-in, or if you choose to opt-out, at the time the Coalition offers you that choice.
If you are a California resident and you have questions about our practices with respect to sharing Personal Information with third parties for their direct marketing purposes and your ability to exercise choice, please write us at email@example.com. You must put the statement “Your California Privacy Rights” in the subject field of your email or in the address line of your envelope. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
5. Information Security
Please understand that no one can give an absolute assurance that information intended to be maintained as private, whether transmitted via the Internet or otherwise, cannot be accessed inappropriately or unlawfully by third parties. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a computer. We have taken and will continue to take commercially reasonable steps to ensure the secure and safe transmission of your personal information.
6. Children’s Privacy
The Coalition Websites are not intended for children under eighteen (18) years of age. The Coalition does not knowingly solicit or collect personal information from or about any such children, and the Coalition does not knowingly market its products or services to any such children. If the Coalition becomes aware that it has inadvertently received personal information from a user under the age of eighteen (18), it will delete such personal information from its records.
IF FOR ANY REASON THE COALITION WOULD LIKE TO USE THE INFORMATION YOU HAVE SUBMITTED FOR SUBSTANTIALLY DIFFERENT PURPOSES OTHER THAN THOSE OUTLINED AT THE TIME YOU ORIGINALLY SUBMITTED YOUR INFORMATION, THE COALITION WILL AFFIRMATIVELY REQUEST PERMISSION FROM YOU TO USE SUCH DATA FOR THOSE SUBSTANTIALLY DIFFERENT PURPOSES.
8. Accessing and Updating Personal Information
You may request access to your personal information, corrections and/or deletions of the same by using the Contact Information set forth below. We will use reasonable, good faith efforts to promptly address your concerns, subject to legal retention obligations and legitimate business needs.
When making a request, individual users are asked to identify themselves and the information requested to be accessed, corrected or removed. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. Correcting or removing data is done free of charge to the user unless doing so requires a disproportionate effort. After deleting your information from active servers, copies may remain in our backup system.
9. Contact Information
- By email at firstname.lastname@example.org
- By phone at (877) 422-2349
- By mail at: The Coalition to Protect America’s Health Care, P.O. Box 30211 Bethesda, MD 20824
10. Your Choices
We also welcome users' requests not to receive certain forms of communication from the Coalition and third parties and not to have certain information shared with nonaffiliated third parties. If you prefer that we not disclose your Personal Information to nonaffiliated third parties, you may request us not to make those disclosures (except as required by law) by contacting us as described above. If you elect to opt out of certain disclosures, we may not be able to offer you certain services and products. Please note that Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state or local government records, widely distributed media or disclosures to the general public required by law.
You may also opt-out from many third parties who serve online advertising, including some who serve Coalition ads elsewhere online, by visiting http://www.networkadvertising.org/managing/opt_out.asp; or http://www.aboutads.info/choices/. Opting out does not mean you will not see any ads when browsing Coalition Websites, but the ads you see will no longer be customized to you based on your profile or interactions with Coalition Websites.
11. LISTSERV® Email Lists and Social Media Sites
12. Consent to Transfer
The Coalition is based in the United States and the information we collect is governed by United States law. By accessing or using a Coalition Website or providing us with any information, you consent to the transfer, processing and storage of your information in and to the United States and other countries, jurisdictions in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
13. Terms and Conditions