Last Updated and Effective: December 27, 2024
We respect your privacy when you visit or join a Health Union community.
Please read this Privacy Policy carefully to understand how we collect, use, share, and protect your personal information, as well as the rights and choices you have with respect to your personal information and how you can contact us to get answers to your questions.
This Privacy Policy applies to the Personal Information Health Union, LLC. and our subsidiaries and affiliates (“Health Union,” “we,” “us,” or “our” ) obtain in various contexts, both online and offline, including when you access or use our websites, mobile applications, or any other applications that link to this Privacy Policy; interact or communicate with us; purchase our products, services, or features; engage with us on social media; interact with our advertising or marketing materials; participate in or interact with any of our programs, events, research activities, Social Health Network, or other digital properties. This Privacy Policy also applies to the Personal Information we collect about individuals who apply for a position with us. Our “Services” for the purposes of this Privacy Policy include our websites (or “Sites” ), products, features, and advertising services, as well as the provision of our online health communities. Our privacy practices are subject to the applicable laws of the places in which we operate, so you may see additional region-specific terms that only apply to customers located in those geographic regions, or as required by applicable laws. For certain products, services, and features, there may be additional notices about our practices. This Privacy Policy supplements any other privacy policies provided or communicated to you. Please read those additional privacy disclosures to understand how they apply to you.
This Privacy Policy does not apply to third-party websites, applications, widgets, or other experiences linked to or offered on our Services ( “Third Party Sites” ). Accessing any Third-Party Site is done at your own risk.
This Privacy Policy and our Terms of Use govern our Services. If you need help understanding or have questions, please contact us before using or continuing to use our Services.
What if I reside in Europe?
Health-Union, LLC is a U.S.-based company. The laws of the United States govern our Services and websites. If you’re a resident of the European Union, the European Economic Area, or the United Kingdom, see the “Europe” section for data protection officer contact details.
What if I have more questions?
Just ask! Contact us at privacy@health-union.com, and our Privacy Team will promptly respond.
Table of Contents.
Information We Collect
Personal Information You Provide to Us
Information Automatically Collected When You Use the Services
Other Sources of Information
How We Use Personal Information
Provide, Maintain, and Improve the Services
Research and Development
Security and Legal Compliance
Marketing and Advertising
How We Share Personal Information
How We Share Non-Personal Information
Cookies, Tracking Tools, Advertising, and Opt-Out
Data Security and Retention
Your Privacy Rights and Choices
How To Exercise Privacy Rights Requests
California Resident Rights
Texas Resident Rights
Europe
Contact Us
Privacy Appendix
Privacy Rights Request Form
The type of information we collect depends on how you use our Services. To see all the categories of Personal Information we collect from you, click here.
What is “Personal Information”?
Personal Information is information or data that can identify or describe an individual. Some examples are first and last names, email addresses, phone numbers, device IDs, and cookie identifiers.
What is Sensitive Personal Information?
Sensitive Personal Information is a category of Personal Information that can be used to exploit or discriminate against a person. For example, a health diagnosis, gender, sexual orientation, and national or ethnic origin. We only collect Sensitive Personal Information if you choose to provide it to us. For example, if you participate in our surveys, clinical trial research, or Social Health Network, we may collect Sensitive Personal Information about your medical diagnosis or health.
What is Non-Personal Information?
Non-Personal Information is information that doesn’t identify or connect to an individual. We create Non-Personal Information by aggregating Personal Information or transforming it into a code. This process is “hashing,” “deidentifying,” or “pseudonymization.” We then create audience segments or models with common interests, intent, or other characteristics. We don’t attempt to re-identify de-identified data, and we rely on the assessments of statistical experts to help us protect such data from being linked with any information that could be tied to you or your device. We also contractually forbid Service Providers and Business Partners from reidentification of users.
We collect identity, contact, and health information if you give it directly to us. For example, we collect your Personal Information if you create an account or engage with our Services. This includes interactive activities and communicating with us. Other examples include signing up for a newsletter, responding to a poll, or taking a survey.
Our Services feature public forums or areas to ask questions, share thoughts, and provide support. These areas are open to the public and are not private. We strongly advise you to avoid posting any sensitive or personal information in these public areas.
Account Information. We collect account information, preferences, social media profiles, profile pictures, activities, interactions, and other information you choose to share.
Contact Information. This may include your name, age, date of birth, e-mail address, telephone number, and mailing address.
Profile Information. Providing profile information is voluntary and can be deleted or changed at any time. It’s entirely up to you if you’d like to share details in your profile. Your profile is set to private by default, but you may change your settings to make your profile public. Website administrators and moderators can view private user profiles.
Education/Employment/Advocacy History. If you participate in the Social Health Network or are a job applicant or independent contractor, you may provide us with your resume or curriculum vitae, education, social media channels, or certification information.
Health Care Providers (HCP). Depending upon how you use the Services, you may provide us with National Provider Identifier (NPI), job title, professional qualifications, certifications and credentials, medical license number, specialty or area of practice, medical facility or organization affiliation.
Your Content. We’ll collect the content you choose to share or upload. This includes text, photos, videos, posts, comments, attachments, and any associated metadata. As a reminder, posting information is not required to use our Services. All posted information is publicly viewable. We encourage you to omit any Personal Information or other sensitive information from Your Content. Health Union does not intend for Users to include Personal Information in User Content and does not review or approve all User Content before posting.
Communications. For example, if you contact us with questions, feedback, or have a request.
Research Activities. We collect your responses if you participate in a survey, poll, or other research activities. We also collect demographics and educational, medical, or financial background information.
Marketing Preferences. This includes your marketing and communication preference settings.
Job Applicants / Employees. As part of the application process, we may collect your contact information as well as certain information about you, including, race, ethnicity, previous employment and education history, references, information relating to disabilities, physical or mental health information, sexual orientation, veteran status, trade union membership, immigration or naturalization records, information relating to your criminal record and background check, interview notes, test scores, and any correspondence between us.
If you accept a position with us, we may collect some of the information listed above as well as other information necessary to manage your employment relationship, including your government identification number or tax file number and bank account information.
Other Information. Any other information we collect that isn’t listed here will be used as described in this Privacy Policy or as otherwise disclosed when collected.
We also collect technical information and activity information when you visit our websites. We use tracking technologies, such as cookies, web beacons and pixels, to collect some of this information. To learn more about how we use these technologies, please see Cookies, Tracking Tools, Advertising, and Opt-Out. Information we automatically collect when you use the Services includes:
Device – information about your device(s) and browser. This includes your IP address, MAC address, and geographic location. We also collect browser/browser plug-in type and version, operating system and platform, and operating information. Finally, we collect device type, device and application identifiers, mobile carriers, and cookies.
Activity – information about your visits to the Services, such as the full URL clickstream to, through, and from the Services, dates and times, and pages you view. This includes how long you stay on a page, how long you visit other pages, how you interact with the Services (such as clicking a link, or scrolling), and how you browse away from the page. We also collect search terms, how long you browse search results, and which search results you view.
Location – based on your IP address, we may infer a general location, such as country, state, and city. We may collect other geolocation information from third parties and sensors on or around your device. Health Union does not use geofencing, which targets users with promotions within a narrow geographic boundary by creating a virtual “fence” around a business location. However, for users other than Health Care Professionals (HCP), we do not create targeting parameters based on GPS coordinates.
Technical – information about the technical performance of the Services, such as page response times or download errors. We collect and use this information to provide and help you use our Services. This includes access to third-party websites and services, such as URL requests, destination IP addresses, or device configuration details.
Chat technologies – we may use third-party services that employ cookies and software code to operate chat features that you can use to communicate with us through the Services. These other third parties may access and use information about webpages visited on our website, your IP address, your general location (e.g., country, state, city), and other personal information you share through online chats for the purposes described in this Privacy Policy.
Other Sources of Information.
We combine information you provide us on the Site or about your use of the site with information from third parties. This consumer data includes your interests, demographic information, and marketing inferences. These sources include:
- Data providers, such as information services and data licensors. Data Providers may also share information about HCPs, including HCP interactions with and interest in information regarding certain medications or conditions.
- Health and medical claims data, including diagnosis and procedure codes, prescription treatments, historical prescribing activity (for HCPs only), and other related health information
- Public sources include government records and the National Provider Identifier (NPI) Registry;
- Research partners, such as universities, companies, and other organizations for research; and
- Service Providers, such as IT, analytics, advertising service providers and ad networks, help us provide our Services and analyze how you interact with them. We also use vendors to generate leads and create customer profiles.
- Social Networks, such as Facebook or Google. You may use your social network account or other third-party sites to sign into the Services. This sends your social media account information or content to your account with us. If you use our Services or share information with social media sites, please know others may read, collect or use your information.
Job Applicants. We collect Personal Information from employment/recruitment agencies or background screening providers for the recruitment process. We also use third-party service providers who provide services to us or on our behalf. These include, but aren’t limited to, payroll processors, benefits administration providers, and data storage or hosting providers.
Links to Third-Party Sites. Some services, content, and advertisements on our Services are hosted on or linked to Third Party Sites. Health Union does not control or endorse any Third-Party Sites. We aren’t responsible or liable for the content, privacy, or security policies of Third-Party Sites. Third-Party Site privacy policies apply if you provide Personal Information to Third-Party Sites. Please be aware that if you click on or interact with an advertisement on our Site, the advertiser may still assume that you meet its target criteria, even though we haven’t shared your Personal Information.
To see all the categories of Personal Information we collect from you, click here.
How We Use Personal Information.
We use Personal Information for the following business purposes or as otherwise described when we collect it. We use Personal Information to:
Provide, Maintain, and Improve the Services
- Provide the online community, offer personalized connect, educational resources, and other social activities and events;
- Create and manage accounts and user profiles;
- Respond to your communications, contacting you if necessary or requested, and sending you information about Health Union or the Services;
- Send communications such as announcements, updates, security alerts, password resets, technical support, or other administrative messages; and
- Commercial and economic interests to develop, market, sell, or provide products and services, including advertisements, on the Services and other websites.
Research and Development
- Send you information on participating in research surveys, panel interviews, paid clinical trial opportunities, and more;
- Operate and test the Services. For example, conducting surveys, market research, managing communications, and analyzing our current Services, products, and promotions; and
- Analyze and report on ad campaigns and performance, such as the number of ad views and click rates on ads.
Security and Legal Compliance
- Meet our obligations under the law, regulation, court order, or other legal processes;
- Maintain internal organization functions, such as for tax purposes or for an audit;
- Detect and protect against fraud, errors, or criminal activity;
- Protect the rights, property, and safety of you, Health Union, or another party;
- Prevent, detect, and investigate security incidents and possibly illegal or prohibited activities; and
- Resolve disputes and respond to claims that a post or other content violates third-party rights.
Marketing and Advertising
Direct Marketing – Email Communications – You can unsubscribe or opt-out of receiving emails by clicking the unsubscribe link at the bottom of all our communications. Or email us at privacy@health-union.com. There’s no charge to unsubscribe and you may do so at any time.
Interest-Based Advertising – Subject to your consent and applicable data privacy laws, we and our partners use cookies and other technologies to display advertisements on our Services and other online websites. We use Personal Information to:
- Analyze and improve our content and advertisements;
- Show advertisements for marketing for the Services or the websites, products, or services of our business and advertising partners; and
- Create audience segments or models and provide targeted advertising for clients and Business Partners.
Job Applicants/Employees. If you’re a job applicant, we use your Personal Information to determine your fitness for a position, make relevant adjustments during the recruitment process, and monitor equal opportunities. If you are an employee, we may use your Personal Information as necessary to perform the employment contract with you.
How We Share Personal Information.
We share Personal Information with data service providers and advertising platforms for the purposes listed in the How We Use Personal Information section, including for the purpose of developing and delivering third party marketing and advertising. We share Personal Information with other third parties, including when:
- You have expressly consented to the sharing of the information (for example, if you ask for information about a clinical trial, we’ll share your Personal Information with the clinical trial sponsor);
- Our service providers need to help us operate our business and provide our Services to you, as described in this Privacy Policy;
- When we have a good faith belief that access, use, preservation, or disclosure of such Personal Information is reasonably necessary as required or permitted by law, for a government request, or to protect the rights, property, or safety of Health Union, its users, or the public; and
- We transfer or assign Personal Information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation.
Please note – In some situations, the other company will control the received information once we share Personal Information with another company. That information is subject to the other company’s privacy practices. To see all the categories of Personal Information we share, click here.
Job Applicants. As part of the recruitment process, we share Personal Information of job applicants with employment/recruitment agencies or background screening providers.
How We Share Non-Personal Information.
We share or make available Non-Personal Information, including aggregated or anonymized data:
- With analytics, search engines, or other service providers that help us improve our Services;
- To report to our affiliates, licensors and service providers, advertising partners, and ad networks about the use of various aspects of the Services;
- With other users or prospective users of the Services; and
- To advertisers and advertising networks to select and show relevant advertisements.
Cookies, Tracking Tools, Advertising, and Opt-Out.
Please note that the following information in this section does not apply to Users located in the European Union (EU). Health Union does not collect or keep any cookies or beacons on Users known to be located in the EU.
We use cookies, beacons, and similar technologies to help our Sites function and improve our Service. This creates a better experience when you use our Services.
Our service providers, advertising partners, and ad networks use cookies and beacons to collect and share information about your activities on our Services and other websites and for tailored advertising.
Tailored advertising uses previously collected data about a person, a web browser, or a device to create personalized or “tailored” ads. These ads may use User attributes, preferences, interests, or intent linked to or infer about that User, browser, or device. These advertisements can appear across different websites, applications, or on devices.
Third parties not affiliated with us also collect your information. This information includes tracking your browsing history when using our Services. We don’t have control over these third-party collection practices. If you wish to reduce such third-party collections, adjust your browser’s settings or install plug-ins and add-ins.
Browser Cookies. A browser cookie is a small file placed on your computer’s hard drive. The cookie communicates with our servers or companies that collect data for us. When you access our Services, a cookie is placed on your web browser to recognize your device in the future. If you return, the cookie remembers you from your last visit and keeps track of your activities.
Unless you adjust your browser settings to refuse all cookies, we will use cookies when you visit our websites or Services. You can use tools available on your computer or device to refuse, disable, or get alerts for browser cookies being set. But, if you refuse or disable all cookies, you won’t be able to use certain features or functions of our Services.
Beacons. Our Services and e-mails contain small electronic files called beacons. Sometimes these are called web beacons, clear GIFs, pixel tags, and single-pixel GIFs. We use these for email and other website-related statistics. For example, we use beacons to count the number of users who visited a page or opened an email. We use beacons in email marketing campaigns to track responses and interests in our content, offerings, and web pages. You can also use the tools on your computer or device to disable these technologies.
You always have the option to set your browser cookies setting as you wish. You can delete all cookies at any time. However, your browser must accept cookies to use all the Services’ tools and features. To manage your cookies, click COOKIE SETTINGS link located in every webpage footer.
Links to Third-Party Sites. Some services, content, and advertisements on our Services are hosted on or linked to Third Party Sites. Health Union does not control or endorse any Third-Party Sites. We aren’t responsible or liable for the content, privacy, or security policies of Third-Party Sites. Third-Party Site privacy policies apply if you provide Personal Information to Third-Party Sites.
Please be aware that if you click on or interact with an advertisement on our Site, the advertiser may still assume that you meet its target criteria, even though we haven’t shared your Personal Information.
Social Media Integration. Our Site may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook or Twitter, and when you do, we may collect additional information from you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We do not have control over the collection, use and sharing practices of social media platforms and encourage you to review their usage and disclosure policies and practices, including the data security practices, before using the social media platforms.
Information Provided If You Connect Your Account Via Facebook or Google. Our Services contain links to social media platforms such as Facebook or Google. If you connect to our Services through a social media platform, we collect your social media screen name, profile picture, and email address. We encourage you to review all social media platform usage and data disclosure policies and practices.
Google Analytics. We use Google Analytics to analyze the audience of the Services and improve our content. For more information about how Google Analytics collects and processes data, please visit the following site: https://policies.google.com/technologies/partner-sites. Google Analytics helps us and our third-party vendors (including Google) match the interests of Service visitors with relevant ads. This occurs through remarketing services. Once the visitor leaves the Services, custom advertisements appear on a Google search results page or other web pages. Data collected through “DoubleClick cookies” doesn’t include your Personal Information. We only use such data following this Privacy Policy and Google’s privacy policy. By visiting Google’s Ads Settings, you can set your preferences for how Google advertises to you. http://www.google.com/settings/ads. You can permanently opt out of the Google Analytics Advertising Features by visiting this page: http://tools.google.com/dlpage/gaoptout.
How We Respond to “Do Not Track” Signals. Some Internet browsers can be configured to send “Do Not Track” signals to websites or services you visit. These features aren’t all uniform, though. Industry participants also disagree with what “Do Not Track” means in this context. We currently do not respond to “Do Not Track” or similar signals except where we expressly indicate otherwise.
Digital Advertising Alliance. Some of our third-party advertisers and display networks participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising and Self-Regulatory Program for Multi-Site Data and allow consumers to opt-out of targeted advertising based on web activity tracking. For more information, visit http://www.aboutads.info/choices/. Even if our third-party advertisers or display networks participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising or Self-Regulatory Program for Multi-Site Data, and you opt-out of targeted advertising based on web activity tracking, you still will receive standard advertisements from us. You will still receive targeted advertisements from third parties and Health Union does not have any control over or responsibility for these advertisements. You will likely need to re-click the link and follow the instructions provided if you delete cookies or other similar technology or use a different computer, device, or browser.
Data Security and Retention.
Security. We strive to protect Personal Information. Health Union uses reasonable administrative, physical, and electronic security measures to protect against personal information loss, misuse, and alteration. No Internet data transmission or storage can ever be guaranteed entirely secure.
It may be possible for third parties not under Health Union’s control to intercept or access transmissions or communications. Neither Health Union nor our service providers can ensure or warrant the security of the information you send us over the internet. Any transmission of data you make over the Internet is at your own risk. Remember, our open forums and discussion areas are publicly viewable.
You should protect your data by carefully selecting and protecting your password. Limit access to your computer or device and browser. Always sign out of your account when finished.
Retention. We retain your Personal Information for as long as you have an account with us or if we have ongoing and legitimate business needs. In some cases, we need to keep Personal Information for a longer period of time. For example, to resolve disputes, collect or pay fees, meet legal obligations, or when otherwise allowed or required by law, rule, or regulation. We also keep anonymous or aggregated information that cannot identify you personally.
Data Transfers. Health Union is a global business and headquartered in the United States. We transfer to, store, and process the information we collect in the country or territory where our business partners or service providers are based or have facilities. This could be a location different from your home country. Other countries or territories may not have the same data protection standards as your home country. We protect Personal Information that we transfer in accordance with this Privacy Policy. We also require our business partners or service providers to adhere to this Privacy Policy and privacy laws.
Your Privacy Rights and Choices.
You may have – under certain data protection laws – legal rights when it comes to how we handle your Personal Information. However, these rights aren’t absolute, and in some instances, we may deny your request if a legal exception applies or if we’re legally required to keep or process your Personal Information in a way incompatible with your request. Once we process your request, we’ll let you know if this is the case.
Depending on your country, province, or state of residence, you may have the right to:
Access – You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. To submit a data access request, you or your authorized agent must fill out this form or email privacy@health-union.com.
Deletion – You have the right to request that we delete your Personal Information, but there are some exceptions. For example, if we need to keep your Personal Information to provide you the Services or process a transaction. To request the deletion of your Personal Information, you or your authorized agent must fill out this form or email privacy@health-union.com.
Correction – You have the right to request that we correct your Personal Information, subject to some exceptions. However, you can edit, update, or correct your information anytime by signing into your account and selecting “profile settings.”
Opt-out of tracking or profiling for targeted advertising purposes (Also called “Do Not Share or Sell My Personal Information,” “Limit the Use of My Sensitive Personal Information,” and “Do Not Profile”).
You have the right to opt-out of the sharing or selling of your Personal Information. If you submit an opt-out request, we won’t ask you to consent to the sharing or selling of your Personal Information for at least 12 months. To opt-out of the share or sale of your Personal Information, you or your authorized agent must fill out this form or email privacy@health-union.com Please use the subject line “Do Not Sell.”
Your request to opt out will apply only to the browser and the device from which you submit the request. For more information on managing tracking settings on different devices, visit theNAI.org.
Appeal – You may appeal our decision to your request regarding your personal information.
We’ll email you to request additional information if you exercise your right to appeal. Within 60 days of receipt of the appeal, we notify you via email of any final decision or response. If you’re a resident of Colorado, Connecticut, or Virginia and your appeal is denied, we will provide you with contact information to file a complaint with the appropriate state Attorney General.
Non-discrimination – You have the right not to receive discriminatory treatment for exercising any of your privacy rights.
How To Exercise Privacy Rights Requests.
You can submit a privacy request by:
Some of the privacy requests must be verified to confirm the request came from you. We may contact you by phone or e-mail to verify your request. Please make sure you (1) provide enough information so we can verify you are the person about whom we have collected personal information (i.e., your Username) and (2) give us enough detail so we understand, check, and can respond. Without this information, we may not be able to complete your request.
We usually request more information from you to confirm your identity; this may include, but is not limited to, your email address, mailing address, account name, and/or date of last interaction with us.
This is a security measure and legal requirement. It helps keep your Personal Information safe and protects against inadvertent disclosure. We will only use the Personal Information you provide to verify your identity and complete your request.
Once you have submitted your request, we will respond within the time frame permitted by the applicable law. We may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law. If we deny your request, we’ll explain why.
You may designate an authorized agent to submit a request on your behalf. To do so, you must (1) verify your own identity directly with us; and (2) provide the authorized agent with written documentation of their authority to act on your behalf, such as: (a) a power of attorney; or (b) sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
Children’s Privacy. As stated in our Terms of Use, our Services are not intended for children or individuals under 18 years of age. We do not knowingly collect Personal Information from children or individuals under 18 years of age. Individuals under the age of 18 should only use our Services with the permission and supervision of a parent or guardian. Individuals under 18 should not attempt to provide us with any Personal Information. If you think we have received Personal Information from children or individuals under the age of 18, please contact us immediately at privacy@health-union.com. By registering for an account or submitting any Personal Information to us, you represent and warrant that you are 18 years of age or older.
California Resident Rights.
In addition, California Civil Code Section 1798 entitles California Users to request information concerning whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. We do not share Personal Information with third parties for their direct marketing purposes without your consent. In certain circumstances, California residents under 18 years old may request and obtain the removal of Personal Information about you and posted on our Services. Please be mindful that this would not ensure the complete removal of the content posted on our Services by you. To make any request under California privacy law, please contact us at privacy@health-union.com.
Please see our Appendix for additional information in accordance with California privacy law. If there are any conflicts between this section and any other provision of this Privacy Policy and you’re a California resident, the more protective portion shall control the extent of such conflict. If you have questions about this section or whether any of the following rights apply to you, please contact us at privacy@health-union.com.
Texas Resident Rights.
This section also provides additional information about how we process the personal data of Texas consumers and the rights available to them under the Texas Data Privacy and Security Act (“TDPSA”).
Notice: We may sell your sensitive personal data.
Europe.
This section only applies if you are a resident of a member state of the European Union (EU), the United Kingdom, or the European Economic Area (EEA).
If you have questions or concerns about the use of your Personal Information, please contact us at the address below.
International Transfers.
Personal Information we collect is transferred to and stored by our group companies, IT vendors, and other service providers (as specified in How We Share Personal Information) who operate on our behalf. We also transfer information to several business application providers – such as CRM and marketing applications – and marketing service providers. These providers are primarily located in the United States but are also located in other jurisdictions.
In certain cases, there may not be an adequacy decision by the European Commission and/or United Kingdom authorities in respect of those countries. Adequacy of data protection is instead ensured by Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation or any equivalent clauses approved by the authorities in the United Kingdom, including any additional safeguards as required by EU / UK data protection laws that we have in place with that third party. Please contact our Data Protection Officer at the address below for a copy.
Data Retention.
We retain your Personal Information for as long as necessary for the purpose(s) for which it was initially collected. The criteria we use to determine the retention period are as follows:
- whether there are contractual or legal obligations that exist which require us to retain the information for a period of time;
- whether there is a legal claim that relates to any business (or otherwise) relationship you have with us, or that is otherwise related to your relationship with us; and
- whether any applicable law, statute, or regulation allows for a specific retention period.
Privacy Rights.
You have – under applicable data protection laws – the following rights when it comes to our handling of your Personal Information. Please note that many of these rights aren’t absolute. We may have grounds for refusing to comply with your request to exercise them (for example, where we are (a) required or permitted by law to process your personal data in a way that is incompatible with your request or (b) able to rely on exemptions under data protection law which entitle us to process your personal data in a way that is incompatible with your request). Where such circumstances apply, we’ll inform you of this when you request to exercise your rights.
- Right of access – you have the right to request a copy of the Personal Information we have about you and to request supporting information explaining how the Personal Information is used;
- Right of rectification – you have the right to request that we rectify inaccurate Personal Information about you;
- Right of erasure – you have the right to request that we erase Personal Information about you;
- Right to restrict processing – in some situations, you have the right to request that we do not use the Personal Information you have provided (for example, if you believe it to be inaccurate);
- Right to data portability – you have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and to transmit such information to another controller;
- Right to withdraw consent – where we process your Personal Information based on consent (including direct marketing consent), you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Even in case of a withdrawal, we may continue to use your Personal Information as permitted or required by law; and
- Right to object – where we are processing your Personal Information based on a legitimate interest (or those of a third party), you may challenge this. But, we may be allowed to continue processing your Personal Information where we show that we have compelling legitimate grounds to process your information (which override your rights and freedoms), or where continuing to process your Personal Information is relevant to the establishment, exercise, or defense of legal claims. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
If you’d like to exercise any of these rights or have questions, please fill out this form or contact us at privacy@health-union.com.
You won’t have to pay a fee to access your personal data (or to exercise any of the other rights). But, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information or access someone else’s personal information on their behalf (or to exercise any of the other rights). This is a security measure to ensure that Personal Information is not disclosed to anyone who does not have the right to receive it. We may also contact you to ask you for further information about your request to speed up our response.
We try to respond to all legitimate requests within 30 days. If your request is complex or you’ve made several requests, it may take us longer to complete. We’ll notify you if that happens and keep you updated. If we can’t comply with your request, we’ll explain why.
Data Protection Officer Contact Information.
You may contact our Data Protection Officer using the contact information below with any issues or questions about our processing of personal information.
You have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (Tel: 0303 123 1113 or at www.ico.org.uk). Alternatively, you can also complain to the supervisory authority in the Member State of the EU or EEA where you reside. We would appreciate the chance to deal with your concerns before you approach the ICO or supervisory authority, so please contact us.
Questions or concerns? Please contact us at privacy@health-union.com.
Send written correspondence to:
Health Union, LLC
Attn: Legal – Privacy Officer
1218 Chestnut Street, 3rd Floor
Philadelphia, PA 19107
Privacy Appendix.
This appendix seeks to provide additional information to all US residents in accordance with California privacy law and supplements the information provided in the Privacy Policy above. As explained in our Privacy Policy, we sell and share Personal Information as such terms are defined under California law. The business or commercial purposes of selling and sharing Personal Information is for third-party companies to perform services on our behalf, such as marketing, advertising, and audience measurement. We do not sell or share Personal Information of known minors under 18 years of age.
As the term is defined by the CCPA, we “sold” and “shared” the following categories of Personal Information in the last 12 months: identifiers/contact information, Internet or other electronic network activity information, and inferences drawn from the above. Each category was “sold” or “shared” with advertising networks and data analytics providers.
Please see the chart below to learn more about the categories of Personal Information we collect, how we collect it, why we collect it, with whom we share it, and how long we retain it. Please see the instructions provided above in the Your Privacy Rights section to submit a privacy request.
