Pri-Med Privacy and Ethics Policy

 

Pri-Med Privacy & Ethics Policy
Last Updated December 3, 2011

 

DBC Pri-Med, LLC and pmiCME, LLC (collectively "Pri-Med”) has created various platforms to provide Pri-Med Services (as defined below) including, but not limited to web sites developed and operated by Pri-Med, applications developed or offered by Pri-Med (collectively and individually, “Site”).  The Site has been created for one or more of the following purposes: (i) to provide information about Pri-Med and to provide users with the opportunity to learn more about Pri-Med accredited seminars and continuing education courses (the "Activities") and other Pri-Med non-accredited live, online and print courses (the “Offerings”), (ii) to register for and/or participate in such Activities or Offerings (the "Pri-Med Services "), and/or (iii) to engage with industry through advertisements and similar promotional offerings available on pri-med.com and through promotional and informational offerings from industry available at Pri-Med events and in Pri-Med applications. This Privacy Policy sets forth Pri-Med policy with respect to information, including personally identifiable data ("Personal Data") that is collected from individuals who use the Site and from individuals who otherwise register for and/or participate in the Pri-Med Services.

What Information Does Pri-Med Collect?

Personal Data That You Provide Through the Site: Pri-Med collects Personal Data from you when you voluntarily choose to provide such information, such as when you contact Pri-Med with inquiries, register for access to Pri-Med Activities or Pri-Med Services, and/or use certain Pri-Med Services. Wherever Pri-Med collects Personal Data Pri-Med makes an effort to provide a link to this Privacy Policy or, where the Personal Data is collected in person, via mail or via the telephone, Pri-Med will endeavor to provide you with a copy of this Privacy Policy or notify you where it can be located. Pri-Med may rely upon third party service providers to collect and process your registration for Activities and other Pri-Med Services. These service providers are instructed that they may use your Personal Data only as specified by Pri-Med Privacy Policy.
By voluntarily providing Pri-Med with Personal Data, you are consenting to Pri-Med's use of it in accordance with this Privacy Policy. If you provide Personal Data to this Site, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Pri-Med and the authorized third parties referred to herein for the purposes described in this Privacy Policy.

Other Information: 

  • Non-Identifiable Data: When you interact with Pri-Med through the Site, Pri-Med may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Pri-Med may store such information itself or it may be included in databases owned and maintained by Pri-Med affiliates, agents, or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to the Site, the number of visitors to each page of the Site, and the domain names of Pri-Med visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

    In operating this Site, Pri-Med may use a technology called "cookies." A cookie is a piece of information that the computer that hosts the Site gives to your browser when you access a Web site. Pri-Med cookies help provide additional functionality to the Site and help Pri-Med analyze Site usage more accurately. For instance, the Site may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the site. In cases in which Pri-Med uses cookies, Pri-Med will not use such cookies to collect Personal Data unless such collection has been disclosed to you in advance. Please see the section entitled "Personal Data That You Provide Through the Site" for information about the Personal Data that Pri-Med collects. On most Web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Pri-Med recommends that you leave cookies turned on because they allow you to take advantage of some of the Site's features.
  • Aggregated Personal Data: In an ongoing effort to better understand and serve the users of Pri-Med Services, Pri-Med often conducts research on Pri-Med customer demographics, interests, and behavior based on the Personal Data and other information provided to Pri-Med. This research may be compiled and analyzed on an aggregate basis, and Pri-Med may share this aggregated data with Pri-Med affiliates, agents, and business partners. When Pri-Med shares this information in aggregate form, it does not identify you personally. Pri-Med may also disclose aggregated user statistics in order to describe Pri-Med Services to current and prospective business partners and to other third parties for other lawful purposes.

What Are Your Choices?

You can use the Site without providing any Personal Data; however, if you choose to not provide Personal Data you may not be able to register for and/or use certain Pri-Med Services.

How Does Pri-Med Use Your Personal Data and Other Information?

Pri-Med uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, Pri-Med may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact Pri-Med by e-mail, Pri-Med may use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to Pri-Med Services, Pri-Med will use your Personal Data to provide access to such services.

If you register for and/or attend Activities, Pri-Med will use your Personal Data to provide you with documents and other materials related to such Activities while in attendance at the Activities, and Pri-Med may also mail you documents and materials related to such Activities and other products, services and Activities Pri-Med believes will be of interest to you.

Pri-Med and Pri-Med affiliates may also use your Personal Data and other personally non-identifiable information collected through the Site to help Pri-Med improve the content and functionality of the Site, to better understand Pri-Med users, and to improve Pri-Med Services. Pri-Med and Pri-Med affiliates may use this information to contact you in the future to tell you about services or products Pri-Med believes will be of interest to you. If Pri-Med does so, each communication Pri-Med sends you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or to have your name deleted from Pri-Med mailing lists please contact Pri-Med as indicated below. Pri-Med may also share your Personal Data with certain third parties as described further in the section labeled "Does Pri-Med Share Your Personal Data?"
If Pri-Med intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected, and given the option to opt-out of such use.

 Does Pri-Med Share Your Personal Data?

Pri-Med is not in the business of selling your information. Pri-Med considers this information to be a vital part of the relationship with you. There are, however, certain circumstances in which Pri-Med may share your Personal Data with certain third parties without further notice to you, as set forth below:

  • Business Transfers: As Pri-Med develops Pri-Med business, Pri-Med might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be part of the transferred assets.
  • Related Companies: Pri-Med may also share your Personal Data with Pri-Med subsidiaries and affiliates for purposes consistent with this Privacy Policy.
  • Event Sponsors: If you sign-up to attend one of Pri-Med Activities, Pri-Med may share your registration information with non-related companies that are involved in supporting the applicable event, including, without limitation, pharmaceutical companies.
  • Business Partners: From time to time, Pri-Med may offer you the opportunity to participate in discount plans and similar benefit programs from one or more of Pri-Med business partners. If you opt-in to participate in the discount plans or other benefit programs of Pri-Med business partners, Pri-Med will disclose your Personal Information to such business partners so that they may register you for the applicable discount plan and/or benefit program.
  • Agents, Consultants, and Related Third Parties: Pri-Med, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, and processing payments. When Pri-Med employs another company to perform a function of this nature, Pri-Med endeavors to provide them only with the information that they need to perform their specific function and Pri-Med instructs them to limit their use of the Personal Data accordingly.
  • Legal Requirements: Pri-Med may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Pri-Med, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

Exclusions

This Privacy Policy shall not apply to any unsolicited information you provide to Pri-Med through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as bulletin boards, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All such Unsolicited Information shall be deemed to be non-confidential and Pri-Med shall be free to reproduce, use, disclose, and/or distribute such Unsolicited Information to others without limitation or attribution.

 

Children

Pri-Med does not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the Site. Pri-Med encourages parents and legal guardians to monitor their children's Internet usage and to help enforce Pri-Med Privacy Policy by instructing their children to never provide Personal Data on this Site without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to Pri-Med through this Site, please contact Pri-Med and Pri-Med will endeavor to delete that information from Pri-Med databases.

 

Links to Other Web Sites

This Site may frame or contain references or links to other Web sites not operated or controlled by Pri-Med, including Web sites of Pri-Med Related Companies and unrelated companies with which Pri-Med has a business relationship (the "Third Party Sites"). The policies and procedures Pri-Med describes here do not apply to the Third Party Sites. The links from this Site do not imply Pri-Med review or endorsement of the Third Party Sites. Pri-Med suggests contacting those sites directly for information on their privacy policies.

 

Advertising & Marketing

We may target our advertising and marketing messages depending on preferences you choose to share with us. The Site may personalize its content based on your interests. For example, you may see different content on our site in different areas based on information that you have shared with us or based on observations we have made regarding your previous usage.

We make clear distinctions between our editorial content or accredited CME content vs. any advertising or sponsored content and this includes how we inform you of our certified educational activities and industry advertisement, promotion or offerings. Through Pri-Med policies and procedures, we ensure that there is clear disclosure on what is a certified educational activity and what is an industry advertisement, promotion or offering.

All advertisements are clearly marked and are physically separate from editorial or CME content. We maintain a clear separation between all of our promotional and educational activities.

We do no accept advertisements for any products that are offensive or illegal. We reserve the right to reject any advertisement for any reason.

We do not endorse any of the products or services mentioned in the advertisements.
We expect advertisers and their advertisements to comply with all Federal (United States) and local regulations regarding direct-to-physician advertising, including the Federal Food, Drug, and Cosmetic Act as well as relevant FDA guidance documents.
Advertisers do not have access to personal data of registrants from our web site and must respect all terms herein this Privacy Policy

Photography

From time to time, Pri-Med takes photographs at our live events and may capture individuals as the focal point.  All attendees and personnel should be aware that footage gathered by staff members in public areas of the convention may be used in our external facing marketing materials. By registering for a live Pri-Med event, you are giving consent to Pri-Med to own any images that you may appear in and use them in marketing materials.

Editorial Policy

Our Editorial Policy details how content appearing in our promotional print, online programs, and email newsletters is selected, authored, and reviewed; and sources for our information. This policy pertains only to content found in e-mail newsletters from Pri-Med and on certain areas of www.Pri-Med.com, including Patient Education, Clinical Guidelines, and Resources. Editorial practices for Accredited CME can be found within our Code of Conduct on www.pmicme.org

•Patient Education

Representative patient education materials are provided on www.pri-med.com in the form of customizable handouts. These materials come from various sources, which are identified on the material.

• Third-Party Editorial Content

Examples of third-party editorial content that appear on www.pri-med.com include clinical guidelines and patient education. Sources for third-party editorial content include government agencies and nonprofits, who are identified on the materials. Our editorial staff may review content from outside sources to ensure accuracy before it is posted to our website. Third-party editorial content has also been reviewed and approved by the provider’s own staff. 

Security

Pri-Med takes reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Site may not be secure. Therefore, you should take special care in deciding what information you send to Pri-Med via e-mail. Please keep this in mind when disclosing any Personal Data to Pri-Med via the Internet.

Other Terms and Conditions

Your access to and use of this Site is subject to the Terms of Use.

Changes to Pri-Med Privacy Policy

The Site and Pri-Med business may change from time to time. As a result, at times it may be necessary for Pri-Med to make changes to this Privacy Policy. Pri-Med reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

 Access to Information; Contacting Pri-Med

To keep your Personal Data accurate, current, and complete, please contact Pri-Med as specified below. Pri-Med will take reasonable steps to update or correct Personal Data in Pri-Med possession that you have previously submitted via this Site.
Please also feel free to contact Pri-Med if you have any questions about Pri-Med Privacy Policy or the information practices of this Site.
 
You may contact us as follows:
Chief Compliance Officer
DBC Pri-Med LLC
111 Huntington Avenue
Boston, MA 02199
Tel: 617-488-4531
Fax: 617-406-4388
E-mail: compliance@pmiCME.org