Modified: August 1st, 2019
- Information We Collect
- How We Use Information We Collect
- Consents and authorizations
- How our Services Allow Users to Share Information
- How We Share The Information We Collect International
- The Importance of Protecting Our Services and the Information they Safeguard
- Cookies and Similar Technologies
- Third Party Services
- Changes to this Policy
- How to Access and Control Your Personal Data
1. Information We Collect
Information You Submit: When you use our Services, you can (depending on the Service you use) submit information by:
□ Typing-in data (such as when you register for our Services, or type a message to send to us or another user, or type a search request, or complete an optional form);
□ Uploading a document, image or other data file; or
□ Authorizing us to retrieve and import information from another user or other third party on your behalf.
Engagement Tools and Data: Our Services also gather information whenever you visit, log in or otherwise interact with them. As with other websites and interactive services, whenever you interact with our Services, your computer, mobile phone or tablet (a Device) and its software transmit a request to us. That request includes non-personal information received from your Device (and its software) necessary for us to identify and appropriately route the information your Device is requesting. These requests and replies are the backbone of all websites and Internet services. Therefore, whenever you:
□ Visit and navigate through our Services
□ Click on a link
□ Open a webpage or web form
□ Open a web-enabled email sent by us
□ Post a comment or question on a blog or user forum
□ Send a message via our interactive chat or instant message feature
□ Otherwise take an action or interact with elements of our Services or its pages, content or features,
your Device, and its software, are sending non-personal information to us.
In addition to managing the appropriate routing of information, we use so-called cookies; web beacons, server logs and other Engagement Tools to enhance the quality of the service and content you receive. For example, we use Engagement Tools to:
□ Save user preferences;
□ Preserve session settings and activity;
□ Help authenticate users;
□ Allow users to auto-fill sign-in pages of websites they frequently visit;
□ Tailor the delivery of ads and other content; and
□ Analyze the performance of our Services and its various features and content.
Therefore, even if you do not register with us or submit any personal information on our Services, our Engagement Tools automatically receive information about your Device and the software running on it. We call such data Engagement Data.
Engagement Data often includes elements such as the date and time a request is made, the model of the Device making the request, the type and version of operating system running on a Device (e.g., Mac OS or Microsoft Windows), the browser making the request (e.g., Internet Explorer, Chrome or Firefox), routing information, IP address, the Device s geographic location, search terms a user enters, what URL a Device most recently visited, and, if a mobile application is used, an anonymous unique number. Engagement Data generally does not personally identify a Device s user. However, it can be combined with personal information. If so, we treat such combined information the same way we treat personal information. Additionally, in the event that our Engagement Tools collect data elements that contain personal information, we treat those data elements as personal information.
You have the ability to control how certain Engagement Tools operate by modifying the settings on your Device or its software. Most browsers, for example, allow you to refuse accepting cookies, and many mobile Devices allow you to disable the sending of location information. In some cases, doing these things could diminish the performance of our Services or render them inoperable.
Third Party Tools: From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites. We work with certain third parties who deploy their own engagement tools on our Services. In some instances, they do so exclusively on our behalf. In other instances, they may retain and use the data they collect pursuant to publicly available privacy policies. These Third Party Tools are frequently deployed by companies providing online advertising services or analytics, but they may be deployed in other contexts as well, such as social media plug-ins. We treat personal and non-personal information that we receive from these Third Party Tools the same way we treat personal and non-personal information that we directly collect from our Services. We, however, do not control how these third parties manage the information they gather. Please see our Third Party Tools for more information.
Personal and Non-Personal Information: Information you submit to us that identifies you or can be used to contact you (e.g., email or mailing address) is your personal information. This includes identifiers that a governmental authority, financial institution or insurance carrier may use to uniquely identify you (e.g., a physician identification, patient identification). When we combine non-personal information with personal information, or non-personal information with other non-personal information in a way that renders the combined information personal information, we treat that combined information the same way we treat personal information. When we combine personal information with information from third party sources, we also treat that combined information the same way we treat personal information.
We may use your Personal Information to recommend certain resources. We may use your Contact Data to send you information about Liberate our products or Services, to contact you when necessary, including to remind you of upcoming or follow-up appointments, and in conjunction with your use of certain Interactive Tools. We may use your Demographic Data, your Traffic Data, or your Medical Data to customize and tailor your experience on the Site, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences. We may also use your de-identified Personal Information to run (or authorize third parties to run) statistical research on individual or aggregate health or medical trends. Such research would only use your Personal Information in an anonymous manner that cannot be tied directly back to you.
2. How we Use the Information We Collect
□ Operating, maintaining, managing and administering our Services, including processing registrations and providing customer support;
□ Responding to questions and communications, which we retain in the ordinary course of business;
□ Administrative announcements about features, functionality, terms or other aspects of our Services; and, if applicable, informing you about offers for services or products we believe may be of interest (for further information, see also Service Emails and other Communications below);
□ Safeguarding and protecting our Services, the information they safeguard, the rights of third parties and in response to legal process, in each case, as more fully described below in The Importance of Protecting our Services and the Information they Safeguard; and
We use non-personal information for the following purposes:
□ Auditing, research, measurement and analysis in order to maintain, administer, enhance and protect our Services, including analyzing usage trends and patterns and measuring the effectiveness of content, advertising, features or services;
□ Creating new features and services;
□ Contextual and cookie-based automated content delivery, such as tailored ads or search results;
□ Health and medical research; public health and service activities; healthcare- and medical-related services; and
We may also use non-personal information to prepare aggregate reports for current or future advertisers, sponsors or other partners to show trends about the general use of our Services. Such reports may include age, gender, geographic, demographic or other general user information, but do not include personal information.
We Never Sell Your Personal Information
We will never sell your Personal Information to Any Third Party.
Legal Basis for processing Personal Information (EEA Visitors only)
If you are a visitor located in the European Economic Area, Liberate UK is the data holder of your personal information. Liberates Data Protection Officer can be contacted at firstname.lastname@example.org.
3. Consents and Authorizations:
4. How our Services Allow Users to Share Information
One-on-One Communications: Our Services can be used to facilitate one-on-one communications between users. Examples include:
□ Send a patient content: Deck, video, audio;
□ Sending an appointment or other reminder to another user.
In any one-on-one communication, users are sending information to one another. Depending on the message, this could include contact and other personal information. See also Service Emails and other Communication below.
Communities, Blogs, Forums: Our Services may include publicly displayed communities, blogs and other public forums that allow users to communicate with groups of users or the general public. All information a user posts in one of our communities will be available to a wide range of individuals, and should be presumed public. We strongly advise users to exercise care in selecting what information they share with our communities or public forums, and strongly recommend against sharing any personal, health or other sensitive information that could directly or indirectly be traced to any individual, including yourself.
Records: Our Services allow users to store personal and health information (Records), including Records created for that user. Our Services permit users to share all or portions of these Records at their discretion.
You should be aware that this Policy covers only the information submitted through our Services. If you contact or exchange information with another person or through a means other than our Services, such activity is not covered by this Policy.
What Other Users Do with Information You Share with Them: Because our Services enable users to share the information you share with them, you should take care in selecting with whom you share your Records and other information. Although our Services process such transmissions, we cannot take responsibility for the actions of other users or persons with whom you share your Records and other information.
Service Emails and other Communications: Our Services may allow HCP users to communicate with patients and caregivers through our Service-branded emails, SMS and other electronic communication channels. These type of communications may be real time communications or communications triggered automatically upon the occurrence of certain events or dates – such as a repeated sign-in failure, a video email from the HCP to their patient, an appointment reminder and the like.
Email communications received from users and our administrative announcements are often transactional or relationship messages, appointment requests, reminders and other treatment or Service notifications. You can opt out of receiving certain messages and Liberate Services may provide a means to modify the frequency of receiving them. In cases in which we believe user emails are not primarily transactional or relationship messages, it will include the capability to opt-out of receiving further e-mails. If you sign-up to receive marketing or informational announcements from us, such emails will include capability to opt-out of receiving such e-mails in the future.
Our Services may deploy Engagement Tools (such as cookies, web beacons and server logs) on outbound emails to users and others to collect Engagement Data, and we may use vendors to assist us in sending outbound emails to users who may deploy Third Party Tools.
5. How We Share Information We Collect
We will not share personal information you submit except under the following circumstances:
□ When you choose to share such information through our Services. Under certain circumstances this may require a specialized consent before our Services complete certain such transmissions;
□ When you are otherwise notified at the time we collect such information or we otherwise have your express consent;
□ When we share such information with our current and future affiliates;
□ When we protect our Services, the information they safeguard, the rights of third parties and in response to legal process, as more fully described below in The Importance of Protecting our Services and the Information they Safeguard;
□ In connection with a sale, merger, transfer, exchange, reorganization or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by the services to which this Privacy applies. If such a transaction occurs, the acquiring company s use of your personal information will remain subject to this Policy; and
It is important for you to understand that other users who submit to, or receive from, our Services personal information about you, may share that information with other persons, even without separately notifying you or seeking your consent.
6. The Importance of Protecting our Services and the Information they Safeguard
Many of our Services are protected by technical measures intended to safeguard the confidentiality, integrity and accessibility of sensitive information our users store and share on our Services. Further, certain regulations require us to investigate potential or suspected threats on our Services or the confidentiality, integrity or availability of the information they safeguard. Accordingly, we may preserve, use and disclose information – including personal and non-personal information – when we have a good faith belief it is necessary or advisable to:
□ To protect ourselves, you and third parties.
7. Cookies and Similar Technologies
Navigational Information Collected by Our Customers
Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on via the Service. Liberate does not control our customers’ use of these tools, nor do we control the information they collect or how they use it.
Flash Cookies and Other Third Party Tracking Technologies
Third Party Tracking Technologies
9. Third Party Services
This Policy applies only to our Services. It does not apply to services offered by third parties, including websites and other online services that our Services may display links to or advertisements for. When you click on such links or advertisements, you will be visiting websites or interactive services operated by third parties, who have their own information collection practices and may also collect information through the use of tracking tools, such as cookies, web beacons, server logs and the like. When you click on or interact with an ad appearing in our Services, the advertiser or sponsor may infer that you meet targeting criteria that they may have used in connection with the sponsoring such ad. This may lead to similar ads being targeted to you on our Services or elsewhere. We do not have control over how any third party gathers or uses information, so you should review their privacy policies to learn of their information gathering and handling practices.
10. Changes to this Policy
We work hard to continuously improve and enhance our Services. Some of these improvements and enhancements may result in changes to this Policy. We will post such changes along with their effective date on this page, and if the changes are significant, we will provide a more prominent notice. Because our Policy can change at any time, we encourage you to reread it periodically to see if there have been any changes that affect you. If you disagree with any changes to this Policy and do not wish your information to be subject to the revised Policy, you will need to deactivate your account before the new Policy becomes effective. Your use of our Services following any such change constitutes your agreement that all information collected from or about you through our Services after the revised Policy is posted will be subject to the terms of the revised Policy.
11. How to Access and Control Your Personal Data
Our Services aim to provide you with access to the personal information you submit and the means to update it. This can be accomplished by logging into our Services or contacting us using the contact information below. Under certain circumstances, we may ask you to verify your identity before your request is processed. This will be done free of charge except where it would require a disproportionate effort. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
If you desire to deactivate your account you may do so through your account profile page. Upon confirming that you genuinely wish to delete your account, your account will be deactivated and your personal information and Records will be made permanently inaccessible, including to us. Residual data may continue to exist in an encrypted form on secure data backups.
We retain archived information for a period of five years (or longer if required by law) as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Policy.
Applicable law grants patients certain rights to access and correct certain health information their healthcare providers retain about them. Patients should submit requests to access or correct their health information directly to their healthcare providers.
You should also be aware that we store indefinitely non-personal information, including Engagement Data and de-identified health information, as well as all information that you have share on any of our public forums, blogs, communities, surveys and the like.
Liberate Ideas, Inc.
26 Park Street
Montclair, NJ 07042
Data Protection Officer (DPO): RM Faust
Last Updated August 1st 2019