I. Personal Information We Collect
II. Use of Your Information
III. Protection of Information; How PPP Handles Privacy Internally
IV. Your Privacy Choices
V. Updating Your Personal Information and Contacting PPP
VI. Children’s Privacy
* To review definitions of key words, see our Glossary
Information We Collect From Visitors
Visitors to each of our Web sites can access the Web site’s home page, and browse some areas of the site, without disclosing any personally identifiable information. We do track information provided to us by your browser, including the Web site you came from (known as the “referring URL”), the type of browser you use, the time and date of access, and other information that does not personally identify you. On some of our sites, you must register with us to use portions of the site.
Information We Collect When You Register
Visitors registering for services on our Web sites are asked to provide us with identifying information, such as name, contact information, and other identifying information. On our registration screen, we clearly label which information is required for registration, and which information is optional and may be given at your discretion. You will also be given a choice about whether or not you want to receive e-mail information.
Additionally, when visitors participate in Internet CME activities:
- We ask participants to complete an assessment of how well they achieved the objectives in order to provide feedback concerning the value of the activity. In addition, we may ask participants to complete a knowledge test as part of a CME activity in order to provide feedback concerning their understanding of the content.
- We ask participants to evaluate CME activities in order to improve those activities and future ones.
- We ask whether participants want to be notified of new CME activities as they become available on our site. If they want to change their status regarding this notification at a later time, they can change it themselves on the registration page or ask us to change it. (contact us.)
Information From Outside Sources
We may also collect information about physicians or other healthcare professionals who register on our Web sites from other sources in order to verify their licensure status and identity. In some cases, we ask customers for information after they register, such as credit card information. Where necessary (for example, to process an order for a purchase), our Web sites may contact financial or credit organizations to confirm customer credit card information and/or to complete the transaction.
- We also collect information that you voluntarily provide to us through responses to surveys, polling, questionnaires, and the like.
- When you are using a forum or message board on our Web sites, you are posting a message with your user name available for all registered users to see. When you are posting publicly, any user of our Web site can see your message. You should not post any information you want to keep private to a forum board or any other public forum on our Web sites.
- We may also ask you to provide additional information such as your email address if you want to obtain additional services or information or to resolve complaints or concerns.
In addition, we gather information about you that is automatically collected by our Web server, such as your IP address and domain name. PPP will use this information to personalize its offerings and presentations to you, facilitate your movements throughout our Web sites, provide personalized services, and communicate with you individually.
Your Web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, Web sites that are cookie enabled will not recognize you when you return to the Web site, and some Web site functionality may be lost; for example, our Web sites may not be able to authenticate you, and you may not be able to access parts of the Web sites.
The Help section of your browser will tell you how to prevent your browser from accepting cookies.
Cookies do not normally contain personally identifiable information. If you have provided us information about yourself, we may associate your registration information with cookies our Web site places on your computer’s hard drive. Associating a cookie with your registration data allows us to offer increased personalization and functionality. For example, you will be able to use all of our sites after you have signed in to one of our sites. Without cookies, this functionality is not possible.
In addition, we may use other tracking systems. See Web Bugs and Log Files.
We create aggregate data about visitors to our Web sites for the development and improvement of activities. We also use it for market analysis. We may provide information from our Web sites in aggregate form, with identifying information removed, to third parties. For example, we may tell a third party what percentage of our registered users reside in a particular geographical area. When aggregate protected information is provided, we pool it from many individual records and strip it of any data that could be used to identify an individual before it is used. Any third party that receives aggregated protected data must agree not to attempt to re-identify the people it belongs to. Depending on our agreement with the third parties, we may or may not charge for this information.
We may target our marketing depending on information we have about you. For example, a user who we know has attended a CME activity may receive information related to the topic of the CME activity, or a user who we know is a healthcare professional who treats depression may receive information for new depression therapies.
We may also personalize our Web site based on your interests. For example, you may see different articles in different places on our Web site based on information you have shared with us, or information we have gained by reviewing your previous visits, or information we may have gained from your interactions with a third party that shares information with us.
When we share information with third parties, we ask that they agree in writing to abide by PPP privacy policies.
If we discover that a third party inappropriately disclosed personal information about any of our visitors, we will take immediate action to prevent further occurrences.
If you identify yourself as an affiliate of one of our Institutional Members (groups for whom we are providing records of CME participation), a report of your participation in CME activities offered on a PPP Web site will be forwarded to the institution you named in your user profile. This information will include your name and earned CME credits.
We use the information that we collect through CME/CE activities in several ways:
- We are accredited by the Accreditation Council for Continuing Medical Education (“ACCME”) to provide continuing medical education for physicians. As an ACCME accredited entity, we are required periodically to submit aggregated data about CME participants and the CME activities we certify. We also provide personally identifiable information to other accredited CME/CE providers who certify CME/CE activities posted on our Web sites, as required by the ACCME and other accrediting bodies. These reports may include personally identifiable information about you and credits issued to you, for the purpose of maintaining records that you can request from the accredited provider for up to six (6) years;
- Commercial supporters of CME/CE activities on our Web site will receive only aggregated data about CME/CE activities that are relevant to their interests and/or the courses they support;
- Our CME staff and customer support staff will have internal access to files containing personally identifiable information, including evaluation forms and aggregated CME /CE participant information. These files can be accessed in order to respond to your questions or comments. Our staff may also use personally identifiable information, including registration information and evaluation data, in assessing educational needs and planning marketing activities.
How PPP Handles Privacy Internally
Our Commitment to Security
We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and ensure correct use of information we collect online.
We have implemented technology and security policies, rules, and other measures to protect the personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. We also protect your information by requiring that all our employees and others who have access to, or are associated with, the processing of your data respect your confidentiality.
PPP uses security methods to determine the identity of its registered users so that appropriate rights and restrictions can be enforced for that user. Reliable verification of user identity is called authentication. PPP uses both passwords and usernames to authenticate users. In certain restricted and limited situations IP addresses are used for authentication instead of the password and user name. Users are responsible for maintaining their own passwords.
We regularly test and update our technology to help protect your personal information. However, such precautions do not guarantee that our Web site is invulnerable to all security breaches. We make no warranty, guarantee, or representation that use of our Web site is protected from all viruses, security threats or other vulnerabilities and that your information will always be secure.
In addition to aggregate information (discussed previously), we may share some kinds of information 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. For example, we may host some of our Web sites on another company’s computers, hire technical consultants to maintain our Web-based health sites, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, if you are a healthcare professional, we may validate your licensure status and other information against available databases that list licensed health care professionals. In order to perform their jobs, these other companies may have limited access to some of the personal information we maintain about our users. We require all such companies to comply with the terms of our privacy policies, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us. We use our best efforts to limit the use of other companies in areas where personally identifiable information may be involved.
- Promotional Offers: Sometimes we send offers to selected groups of visitors. We provide a variety of mechanisms for you to tell us you do not want to receive such promotional offers. For example, we may provide an opt-in box for customers to receive a coupon or 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 material from us by sending us an e-mail to firstname.lastname@example.org .
- Legal Requirements: We may release account and other personal information when we believe release is required to comply with law. We may release protected information, if, in our judgment after review by an attorney, the release is compelled by law or regulation, or if the release may be necessary to prevent the death or serious injury of an individual.
On certain of our sites, when you complete Registration of your Profile, you will be given the option of receiving recurring informational/promotional e-mails from PPP and/or third parties. You may opt-out from receiving these e-mails when you provide the information at any time. We may also ask for contact information (such as, name and email address) if you wish to request e-mail information. You can unsubscribe from such e-mails very easily. When you have received an e-mail message from a program you wish to stop follow the unsubscribe instructions on such e-mail, if any, or click on the “Forward” button in your mail program, then send us an e-mail with the subject unsubscribe to email@example.com . PPP will then unsubscribe you from receiving such e-mails.
You will be given the opportunity to choose (opt-out) whether your personal information is (a) to be disclosed to a third party or (b) to be used for a purpose that is different from the purpose originally intended or authorized by sending an e-mail to firstname.lastname@example.org . In addition for certain protected sensitive information you will be given an affirmative or explicit opt-in choice.
We have provided you access to your personal information so that you may: (a) delete the Personal Information that you have provided to us from our systems, and (b) update the Personal Information that you have provided to us.
You can also contact us in order to change your preferences that you have provided us by e-mailing us at email@example.com .
We are committed to protecting the privacy of children. You should be aware that this Site is not intended or designed to attract children under the age of 13. We do not collect personally identifiable information from any person we actually know is a child under the age of 13.