PART 1:
To provide you confidence that we adhere to accepted healthcare industry privacy standards and comply with our own privacy practices, we participate in the following external, independent verification programs:
URACURAC - FreeFamilyHealth Health has been awarded e-Health accreditation from URAC, the American HealthCare Accreditation Association. URAC is an independent accrediting body that has reviewed and approved FreeFamilyHealth Health's FreeFamilyHealth Web sites for compliance with its more than 50 quality and ethics standards that are based on the Hi-Ethics Principles. FreeFamilyHealth Health helped create the Hi-Ethics Principles as a founding member of the Hi-Ethics alliance. Hi-Ethics is an organization of health Web sites committed to a set of ethical principles designed to ensure that consumers can confidently realize the full benefit of the Internet to improve their health and the health of their families. To verify our compliance, click on the URAC logo. Please note that the URAC certification applies only to sites under the FreeFamilyHealth domain.
Click to VerifyTRUSTe - FreeFamilyHealth Health is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, nonprofit organization whose goal is to build users' trust and confidence in the Internet by promoting the use of fair information practices. As required of TRUSTe licensees, we will inform you of the following in this Privacy Policy:
* What personally identifiable information of yours is collected;
* What organization is collecting the information;
* How the information is used;
* With whom the information may be shared;
* What choices are available regarding collection, use and distribution of the information;
* What kind of security procedures are in place to protect the loss, misuse or alteration of information under our control; and,
* How you can correct any inaccuracies in the information.
To verify our compliance, click on the TRUSTe logo. Please note that the TRUSTe certification applies only to sites under the FreeFamilyHealth domain.
Health on The Net FoundationHealth on The Net Foundation - FreeFamilyHealth Health complies with the principles of the HON Code of Conduct established by the Health on the Net Foundation. To verify our compliance, click on the HON logo. Please note that the Health on The Net Foundation certification applies only to sites under the FreeFamilyHealth domain.
PART 2: ABOUT THIS PRIVACY POLICY AND USING OUR SITE AND TOOLS
This Privacy Policy applies to the FreeFamilyHealth Health Web sites owned and operated by FreeFamilyHealth Health, including the FreeFamilyHealth site, the FreeFamilyHealth Health Manager site, the RxList.com site and the Health-101 sites. Reference to "FreeFamilyHealth Health" means FreeFamilyHealth Inc., including any company that FreeFamilyHealth Inc. controls (for example, a subsidiary that FreeFamilyHealth, Inc. owns). FreeFamilyHealth Health Web sites include any site that FreeFamilyHealth Health owns or controls (for example, a Health-101 site). FreeFamilyHealth Health may share information among its subsidiaries or sites that it owns or controls, but it is always protected under the terms of this Privacy Policy.
The FreeFamilyHealth Health Web site contains links to other sites. Once you enter another Web site (whether through an advertisement, service, or content link), be aware that FreeFamilyHealth Health is not responsible for the privacy practices of such other sites. We encourage you to look for and review the privacy statements of each and every Web site that you visit through a link or advertisement on FreeFamilyHealth Health.
We hope that reading our Privacy Policy gives you a clear idea of how we manage information about you. Throughout our Privacy Policy, we have underlined various terms and hot-linked them to our Glossary or to the corresponding Section within the Privacy Policy to help you better understand their meaning.
While you may use some of the functionality of FreeFamilyHealth Health without registration, many of the specific tools and services on our website require registration. If you use our Web site without registering, the only information we collect will be Non-Personal Information through the use of Cookies or Web Beacons. If you choose to register with our Web site for certain Interactive Tools or other services, we require you to submit Personally Identifiable Information. Depending on the tool or service you have selected, we may also collect Personal Health Information. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to FreeFamilyHealth Health. Inaccurate information will affect the information you receive when using our site and tools and our ability to contact you as contemplated in this Privacy Policy. For example, your email address should be kept current because that it is how we communicate with you.
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PART 3: NON-PERSONAL INFORMATION WE COLLECT ABOUT YOU
Even if you do not register with FreeFamilyHealth Health, we collect Non-Personal Information about your use of our Web site, special promotions and newsletters.
A. Cookies
We collect Non-Personal Information about your use of our Web site and your use of the Web sites of selected sponsors and advertisers through the use of Cookies. Every computer accesses a FreeFamilyHealth Health Web site is assigned a different Cookie by FreeFamilyHealth Health. The information collected by Cookies (i) helps us dynamically generate advertising and content on Web pages or in newsletters, (ii) allows us to statistically monitor how many people are using our Web site and selected sponsors' and advertisers' sites, (iii) how many people open our emails, and (iv) for what purposes these actions are being taken. We may use Cookie information to target certain advertisements to your browser or to determine the popularity of certain content or advertisements. Cookies are also used to facilitate a user's log-in, as navigation aides and as session timers. Cookies used by FreeFamilyHealth Health Manager are also used to restrict underage use of the tools.
Most browser software can be set to reject all Cookies. Most browsers offer instructions on how to reset the browser to reject Cookies in the "Help" section of the toolbar. If you reject our Cookies, certain of the functions and conveniences of our Web site may not work properly but you do not have to accept our Cookies in order to productively use our site. We do not link Non-Personal Information from Cookies to Personally Identifiable Information without your permission and do not use Cookies to collect or store Personal Health Information about you.
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B. Web Beacons
We also may use Web Beacons to collect Non-Personal Information about your use of our Web site and the Web sites of selected sponsors and advertisers, and your use of special promotions or newsletters. The information collected by Web Beacons (i) allows us to statistically monitor how many people are using our website and selected sponsors' and advertisers' sites, (ii) how many people open our emails, and (iii) for what purposes these actions are being taken. Our Web Beacons are not used to track your activity outside of our Web sites or those of our sponsors'. We do not link Non-Personal Information from Web Beacons to Personally Identifiable Information without your permission and do not use Web Beacons to collect or store Personal Health Information about you.
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PART 4: PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT ABOUT YOU
We collect Personally Identifiable Information that you provide to us when you register as a member of FreeFamilyHealth Health and/or when you update your member profile. We use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific services you select, send you emails about Web site maintenance and updates, and inform you of significant changes to this Privacy Policy.
A. Newsletters & Emails to You
At registration and at various times as you use FreeFamilyHealth Health, you will be given the option of receiving recurring informational/promotional newsletters via email from FreeFamilyHealth Health and/or directly from third parties. These emails will not contain Personal Health Information. At the time you sign up for our email newsletters or any time thereafter, you can choose to Opt-In to receiving additional promotional emails from FreeFamilyHealth Health.
In order to subscribe to such newsletters via email, we need your contact information, such as name and email address. You can unsubscribe from the newsletters by simply clicking on the "unsubscribe" link at the bottom of any email newsletter. An email to our automated unsubscribe service will be created on your computer. Click the "send" button. You will then be unsubscribed from that newsletter within two to three business days. You may also unsubscribe or change any of your email preferences by clicking on the applicable links in your email newsletter or by changing your profile within the FreeFamilyHealth Health Manager. If you are experiencing difficulties with our automated unsubscribe service, please use our new Customer Support Form. FreeFamilyHealth Customer Service will unsubscribe you from that newsletter in two to three business days.
In some cases, when you click on a link or an advertisement in an e-mail or newsletter, your browser may be momentarily directed to the website of a third party which, acting on behalf of FreeFamilyHealth Health (see Disclosure to Third Party Contractor Web sites, below), notes or "counts" your response to the e-mail or newsletter before re-directing your browser to your selected destination; this re-direction process will not be apparent to you.
When you use FreeFamilyHealth Health's "Email a Friend", FreeFamilyHealth Health emails the article or other content you designate to your friend's email address and identifies your email address as the sender. FreeFamilyHealth Health uses the friend's email address to send your friend the particular email you requested.
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B. Emails You Send to FreeFamilyHealth Health
This Privacy Policy does not apply to content, business information, ideas, concepts or inventions that you send to FreeFamilyHealth Health by email. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them in an email to FreeFamilyHealth Health. We try to answer every email within 48 business hours, but are not always able to do so.
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C. Message Boards and other Public Forums
As a service to our users, FreeFamilyHealth Health features message boards, chat rooms and other public forums where users with similar interests or medical conditions can share information and support one another or where users can post questions for experts to answer. We also offer online discussions moderated by medical or healthcare experts.
Any information shared (including Personally Identifiable and Personal Health Information) that you reveal in a chat room, message board, Ask Our Expert posting or online discussion such as FreeFamilyHealth University is by design open to the public and is not a private, secure service. You should think carefully before disclosing any Personally Identifiable or Personal Health Information in any public forum. What you have written may be seen, disclosed to or collected by third parties and may be used by others in ways we are unable to control or predict, including to contact you for unauthorized purposes.
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D. Website Registration and Interactive Tools on FreeFamilyHealth Health
After you have registered as a member of FreeFamilyHealth Health, you may choose to use certain FreeFamilyHealth Health interactive content, tools and services that may ask you to voluntarily provide other types of information about yourself including Personal Health Information. Some of the tools (like certain quizzes or calculators) do not retain your Personal Health Information, while others (like Ovulation Calendar) store your Personal Health Information in accordance with the authorization you provide at the time you use the tool.
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E. Subscription Services
From time to time, FreeFamilyHealth Health offers users the opportunity to register for paid subscription services. Each subscription service has its own Service Agreement that governs your use of the service and the information we collect to provide the service, including your credit card information. The Service Agreement will be disclosed to you at the time of registration for that subscription service.
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F. Children
We are committed to protecting the privacy of children. Neither FreeFamilyHealth Health nor any of its services are designed or intended to attract children under the age of 13. We do not collect Personally Identifiable Information from any person we actually know is under the age of 13. A parent or guardian, however, may use FreeFamilyHealth Health Manager to establish a personal health record and a FreeFamilyHealth Health Manager home page for a minor. The parent or guardian is solely responsible for providing supervision of the minor's use of FreeFamilyHealth Health Manager. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through FreeFamilyHealth Health Manager for the minor.
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G. Market Research
From time to time the FreeFamilyHealth Health market research department, or its operations contractors acting on its behalf, conducts online research surveys in order to gather feedback about our site, our sponsors and opinions on important healthcare issues, through email invitations, pop-up surveys and online focus groups.
When participating in a survey, we may ask you to submit Personally Identifiable Information. This Personally Identifiable Information is used for research purposes, and is not used for sales solicitations. When a survey is sponsored by a third party, Aggregate Information of the survey results is reported to the sponsor. Personally Identifiable Information collected through market research will be used only by FreeFamilyHealth Health and its service providers and contractors and will not be given or sold to a third party without your consent or as otherwise permitted by this Privacy Policy. For market research surveys we will not knowingly accept survey responses from or conduct interviews with any person under the age of 18. Some surveys may provide remuneration to participants such as a small cash fee for your time or an entry into a sweepstakes for a larger prize. Each survey will disclose whether or not it is a paid survey.
In addition to collecting survey responses from our members, Cookies may be used to authenticate respondents or to help you pick up where you left off in a survey. If you have Cookies disabled you may not be able to participate in some studies. Cookies may be used to connect survey data with FreeFamilyHealth Health site usage characteristics. You will be notified when we would like to use Cookies in this way and your consent will be requested for these Cookies.
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PART 5: FreeFamilyHealth HEALTH MANAGER - REGISTRATION, USE AND TOOLS
FreeFamilyHealth Health Manager allows you a secure place to store your Personal Health Information and provides tools and services in order to better manage your health and the health of your family. FreeFamilyHealth Health Manager requires additional registration whether you access it through (i) FreeFamilyHealth Health, (ii) your employer's Web site or (iii) your healthcare sponsor's website. Regardless of how you access the FreeFamilyHealth Health Manager the following apply:
A. FreeFamilyHealth Health Manager Home Page
Personal Health Information that you enter into one of the FreeFamilyHealth Health Manager tools is used to provide you personalized and clinically relevant information on your personalized Health Manager home page and throughout the Health Manager product. FreeFamilyHealth Health Manager creates a personal home page specifically for you. You control and authorize who can gain access to this page.
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B. Concept Unique Identifiers
FreeFamilyHealth Health Manager tailors the information you receive on your personal Health Manager home page to reflect your interests, concerns and personal health characteristics. We attach a concept unique identifier (CUI) to every piece of information that you provide us. For example, if you complete the HealthQuotient and indicate that you have diabetes, that single piece of information is tagged with a CUI that is specific to diabetes. Every user that indicates he or she has diabetes receives this CUI tag. Each time you view your personalized Health Manager pages, this CUI tag is matched to content from FreeFamilyHealth Health about diabetes, and if our automated algorithms determine that this is likely to be an important topic to you, it will appear on your personalized pages.
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C. Aggregate Data
FreeFamilyHealth Health Manager may combine, in a non-identifiable format, the Personal Health Information you provide with information from other users to create Aggregate Data that may be disclosed to third parties. Aggregate data does not contain any information that could be used to contact or identify you. For example, FreeFamilyHealth Health Manager may use information gathered to create a composite profile of all the users of a particular third party site. These third party Web sites may use this information to understand community needs and to design appropriate programs and activities on their site. FreeFamilyHealth Health Manager will not disclose your Personal Health Information to any third party without your prior permission, except as otherwise permitted by this Privacy Policy.
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D. Secure Message Center
FreeFamilyHealth Health Manager has the ability to use Personally Identifiable Information that you provide to send you personalized emails or secure electronic messages. During registration for the FreeFamilyHealth Health Manager, you have the option of choosing whether you receive emails pertaining to your health interests, including news, announcements, reminders and opportunities. The FreeFamilyHealth Health Manager email service requires an "Opt-in" authorization from you.
Information that FreeFamilyHealth Health Manager deems related to your Personal Health Information will be delivered to you through the Secure Message Center on your personal health home page.
If you decide, that you would prefer not to receive personalized email or secure electronic messages through from the FreeFamilyHealth Health Manager tool, you may "Opt-out" of the service by clicking on the settings tab on your Health Manager home page and changing your email preference. If your employer has implemented the FreeFamilyHealth Health Manager on your behalf, you will receive email at your work-related email address that has been authorized by your employer but to which you have not specifically Opted-in. These emails will be sent in accordance with instructions from your employer and you are not be able to Opt-out of receiving such emails.
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E. Interactive Tools on FreeFamilyHealth Health Manager
Interactive tools within the FreeFamilyHealth Health Manager, gather self-reported Personal Health Information. In addition, certain of these tools can store Personal Health Information coming from third party data interchange agreements between your employer, health plan, pharmacy benefits manager and other third parties that provide data interchange services. We maintain and limit the use of that information to the Opt-in permission you have provided at the time you use the tool.
FreeFamilyHealth Health does not knowingly engage in business with a company that uses Spyware nor does FreeFamilyHealth provide Users with downloadable software that collects or uses any PII without full disclosure and consent.
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F. Data Warehouse Analysis
Upon authorization by your health plan, healthcare provider or employer, FreeFamilyHealth Health Manager may send your Personal Health Information in a form that cannot be used to personally identify or contact you to a data warehouse for analysis of health trends and effectiveness of health programs. We require these data warehouses to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases.
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PART 6: Information Collected by Third Parties Not Acting on FreeFamilyHealth Health's Behalf
Sponsors or advertisers on FreeFamilyHealth Health may use their own Cookies, Web Beacons or other online tracking technologies in the banner advertisements served on FreeFamilyHealth Health and in emails, special promotions or newsletters we send you. Some advertisers use companies other than FreeFamilyHealth Health to serve their ads and to monitor users' responses to ads, and these companies ("Ad Servers") may also collect Non-Personal Information through the use of Cookies or Web Beacons on our Web site. In certain situations, information collection may be facilitated by momentarily directing your browser to the Web site of an Ad Server or other third party acting on behalf of the sponsor, partner, or advertiser before re-directing your browser to its selected destination (e.g., back to FreeFamilyHealth Health to show the ad, or to the advertiser's website); this re-direction process will not be apparent to you.
We do not control these third parties' use of cookies or Web Beacons, or how they manage the non-personal information they gather through them. However, we do require sponsors, advertisers and Ad Servers who collect cookie or web beacon information through our Web site to agree that they will not collect any Personally Identifiable Information from our site without your consent. They have promised us they will not link any non-personal cookie or web beacon information collected by them on our site to Personally Identifiable Information they or others collect in other ways or from other sites except as may be described in connection with a particular program. For example, in connection with "Sponsored Links" furnished by Google, non-personal information sent by your browser to Google when you click on a sponsored link or submit a query may be used by Google as described in its privacy policy. In addition, FreeFamilyHealth Health's Advertising Policy is posted on our Web site and will provide additional detail about our relationship with advertisers and the companies that serve ads. You should review the privacy policy of other sites you visit or link to from our site to understand how these other sites use cookies and how they use the information they collect through the use of cookies or web beacons on their own sites. Certain Ad Servers allow you to prevent them from collecting data through the use of cookies. In order to do so, you must opt-out of such data collection with each individual site. Currently, you can Opt-out of Cookies for several Ad Servers by visiting the Network Advertising Initiative gateway Opt-out site. This website will also allow you to review the Ad Server's privacy policies.
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PART 7: DISCLOSURE OF YOUR INFORMATION
Except as set forth in this Privacy Policy or as specifically agreed to by you, FreeFamilyHealth Health will not disclose any Personally Identifiable or Personal Health Information it gathers from you on our website. We may only release Personally Identifiable or Personal Health Information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In the event that we are legally compelled to disclose your Personally Identifiable or Personal Health Information to a third party, we will attempt to notify you unless doing so would violate the law or court order. In addition, we may disclose Personal Information as described below.
A. Disclosure to FreeFamilyHealth Health Operations and Maintenance Contractors
FreeFamilyHealth Health operations and maintenance contractors sometimes have limited access to your Personally Identifiable Information in the course of providing products or services to FreeFamilyHealth Health. These contractors include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of our Web site. Unless you have Opted-out of receiving emails and newsletters from FreeFamilyHealth Health, these contractors also may have access to your email address to send newsletters or special promotions to you on our behalf or to send emails to you for purposes such as conducting market research on our behalf. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for FreeFamilyHealth Health. We also contractually require that our operations and maintenance contractors 1) protect the privacy of your Personally Identifiable Information consistent with this Privacy Policy, and 2) not use or disclose your Personally Identifiable Information for any purpose other than providing us with products and services as required by law.
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B. Disclosure to Third Party Contractor Websites
Certain content and services offered to you through our website are served on Web sites hosted and operated by a company other than FreeFamilyHealth Health ("Third Party Contractor Web sites"). FreeFamilyHealth Health does not disclose your Personally Identifiable Information to these Third Party Contractor Web sites without your consent, but you should be aware that any information you disclose once you access these other Web sites is not subject to this Privacy Policy. FreeFamilyHealth Health does not endorse and is not responsible for the privacy practices of these Third Party Contractor Web sites. You should review the privacy policy posted on the other Web site to understand how that Third Party Contractor Website collects and uses your Personally Identifiable Information. FreeFamilyHealth Health makes an effort to make it obvious to you when you leave our website and enter a Third Party Contractor Web site, either by requiring you to click on a link or by notifying you on the site before you visit the third party site. In addition, if you see a phrase such as "Powered by" or "in association with" followed by the name of a company other than FreeFamilyHealth Health, then you are on a Web site hosted by a company other than FreeFamilyHealth Health.
FreeFamilyHealth Health also provides links to sites provided by Third Party Contractor Websites that have business arrangements with FreeFamilyHealth Health to pay commissions based on sales of products or services generated through FreeFamilyHealth Health. An example of this would be Veritas Medicine in our Clinical Trials channel.
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C. Disclosure to or by Co-branded Channel Partners
FreeFamilyHealth Health is a contractor and provides co-branded content and services to Channel Partner Web sites hosted and operated by companies other than FreeFamilyHealth Health Channel Partner Websites. You can only access these co-branded content and services only through the Channel Partner Web site, and usually from the health section of these other Web sites. The co-branded FreeFamilyHealth Health pages that you may access through a Channel Partner Web site may have different registration processes and opportunities for information collection, and Personally Identifiable Information that you provide on these pages may be shared with the Channel Partners. FreeFamilyHealth Health does not share Personal Health Information with Channel Partner Web sites without your consent. Each of these co-branded FreeFamilyHealth Health Web sites has its own privacy policy posted on that site, which explains what information is disclosed by FreeFamilyHealth Health to the Channel Partner and vice versa. If you visit one of these co-branded FreeFamilyHealth Health sites, please read the privacy policy that is posted on that site, as well as the individual privacy policy of the Channel Partner Web site.
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D. Disclosure to Linked Sites
In addition to the Third Party Contractor Web sites that you may access as described above, for your convenience there are links to Third Party Web sites operated by companies that are not affiliated with the FreeFamilyHealth Health Web site and that do not have contracts to provide content or services through the FreeFamilyHealth Health Web site. These links may be found in advertisements, referenced within content, or placed beside the names or logos of sponsors. FreeFamilyHealth Health does not disclose your Personal Information to these Third Party Websites without obtaining your consent. FreeFamilyHealth Health does not endorse and is not responsible for the privacy practices of these sites. If you choose to link to one of these Third Party Web sites, you should review the privacy policy posted on this other website to understand how that Third Party Web site collects and uses your Personally Identifiable Information.
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E. Disclosure of Aggregate Information
FreeFamilyHealth Health may provide Aggregate Information to third parties. For example, we might inform third parties regarding the number of users of our website and the activities they conduct while on our site. We might also inform a pharmaceutical company (that may or may not be an advertiser on our site) that "30% of our users live east of the Mississippi" or that "25% of our users have tried alternative medicine." Depending on the circumstances, we may or may not charge third parties for this Aggregate Information. We require parties with whom we share Aggregate Information to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases.
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PART 8: HOW FreeFamilyHealth HEALTH HANDLES PRIVACY AND SECURITY INTERNALLY
Listed below are some of the security procedures that FreeFamilyHealth Health uses to protect your privacy:
* Requires both a personal username and a password in order for users to access their Personally Identifiable Information or Personal Health Information.
* Uses firewalls to protect information held in our servers.
* Utilizes Secure Socket Layer (SSL) encryption in transmitting Personally Identifiable Information to our servers. In order to take advantage of encryption technology, you must have an Internet browser which supports 128-bit encryption.
* Closely monitors the limited number of FreeFamilyHealth Health employees who have potential access to your Personally Identifiable Information.
* Requires all FreeFamilyHealth Health employees to abide by our Privacy Policy and to be subject to disciplinary action if they violate it.
* Backs-up our systems to protect the integrity of your Personally Identifiable and Personal Health Information.
FreeFamilyHealth Health Manager provides additional protection for your Personal Health Information as follows:
* Maintains Audit Trails so you can know who has accessed your FreeFamilyHealth Health Manager record. This can be viewed by clicking on "Activity" in the Settings window, which is accessible from your FreeFamilyHealth Health Manager home page.
* Provides secure messaging within the FreeFamilyHealth Health Manager tool so that information related to your personal health related characteristics is sent through a secure, encrypted connection.
* Provides geographic redundancy of FreeFamilyHealth Health Manager servers, which enhances your ability to access your information by storing identical information at two separate, secure locations. Both sites maintain physical security through pass code locked door access and pass code authority.
* Limits access to Personally Identifiable Information to authorized users. FreeFamilyHealth Health enables you to have full control over who has access to your Personal Health Information. For example, you may decide to permit your physician or other health care professional access to the personal health information you maintain within our tools. Only the person who creates a record can grant access to other users.
Despite FreeFamilyHealth Health's efforts to protect your Personally Identifiable Information and Personal Health Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.
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PART 9: UPDATING YOUR INFORMATION AND CONTACTING FreeFamilyHealth HEALTH
A. Updating Your Personally Identifiable Information
FreeFamilyHealth Health tools that collect and store self-reported data allow you to correct, update or review information you have submitted by going back to the specific tool, logging-in and making the desired changes. FreeFamilyHealth may store user submitted data (PII and/or PHI) in an active database for a period of six (6) months. After six (6) months, user submitted data, including PII and/or PHI will be held in an active database or on an inactive back-up medium for a period of not less than six (6) years.
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B. Removing your Personal Information
If you have a complaint or problem, please use our new Customer Support Form. Our customer service department will forward your complaint to the appropriate internal FreeFamilyHealth Health department for a response or resolution. We try to answer every email within 48 business hours, but may not always able to do so. If you want to (1) delete your Personally Identifiable Information from our systems, (2) update the Personally Identifiable Information that you have provided to us, or (3) change your preferences with respect to marketing contacts or other activities, select the privacy option on our Contact US form.
If you do not receive adequate resolution of a privacy related problem, you may write to FreeFamilyHealth Health's Privacy Help Desk at:
info@freefamilyhealth.com
C. Updating Your Personal Health Information in FreeFamilyHealth Health Manager
Self-Reported Information - Please log-in to the FreeFamilyHealth Health Manager, access your "settings" tab, and the functions will show you how to correct, update or review your information. We remove Personal Health Information only at the request of the authorized user. In order to verify that it is the authorized user requesting removal of his/her Personal Health Information, we require you to send a signed statement, including your name, address, email address and birth date, to the address below authorizing FreeFamilyHealth Health Manager to remove your Personal Health Information from our active databases and other readily searchable media. Upon receiving your request, your personal health identifiers stored in active databases and other readily searchable media will be removed so that you cannot be identified or associated with any Personal Health Information you previously provided. Email your requests to:
info@freefamilyhealth.com
We will notify you after your personal health identifiers have been removed.
Professionally Sourced Health Information - For Personal Health Information at FreeFamilyHealth Health Manager, your ability to correct, update or remove previously provided Personally Identifiable or Personal Health Information only covers information within the reasonable control of FreeFamilyHealth Health Manager. We place certain restrictions on your ability to correct, update or remove professionally sourced health information that you have authorized to be entered into your FreeFamilyHealth Health Manager record. You may potentially authorize physicians, other health care providers, health plans, hospital systems, pharmacists or laboratories (or their respective Web sites) to provide data into your FreeFamilyHealth Health Manager record. While you can remove this professionally sourced information from your record for the purpose of controlling the viewing or sharing of that information, FreeFamilyHealth Health Manager will maintain an audit log, a notice of that transaction and a copy of the information deleted.
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D. Limitations on Removing or Changing Information
Upon your request, we will delete your Personally Identifiable or Personal Health Information from our active databases and where feasible from our back-up media. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to FreeFamilyHealth Health from our servers.
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E. TRUSTe Watchdog
If you have contacted FreeFamilyHealth Health about a privacy related concern and you do not believe that the problem has been addressed, you may file a complaint with TRUSTe.
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PART 10: CHANGES TO THIS PRIVACY POLICY
Personally Identifiable Information - We will inform you if a material change to the Privacy Policy, which means a change that expands the permissible uses or disclosures of Personally Identifiable Information allowed by the prior version of the Privacy Policy. Your continued use of the FreeFamilyHealth Health Web site will indicate acceptance of the changes. You may of course choose to Opt-out of continuing to use the FreeFamilyHealth Health Web site. Please exit the site immediately if you do not agree to the terms of this Privacy Policy or any revised policy.
Personal Health Information - We will inform you if a material change in the Privacy Policy is made that involves the use of your Personal Health Information, and your express Opt-in authorization will be requested. If you choose to not accept the new privacy policy, then the current privacy policy conditions will remain in effect, so long as FreeFamilyHealth Health Manager continues to make the functionality available. FreeFamilyHealth Health reserves the right to discontinue or limit functionality in all its products including FreeFamilyHealth Health and FreeFamilyHealth Health Manager.
Non-Significant Changes ? FreeFamilyHealth Health may make non-significant changes to the Privacy Policy that do no affect Personally Identifiable Information or Personal Health Information. For these instances, FreeFamilyHealth Health may not notify the user of such non-significant changes.
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PART 11: GLOSSARY
Aggregate Information or Data: As a website gathers individual pieces of Non-Personal Information (see definition below) from its users, it may combine similar data from many or all the users of the website into one big "batch". For example, the site may add up the total number of people in Peoria, Illinois, (but not their names) who are seeking information about weight loss and compare that to the number of people in Petaluma, California seeking the same information.
This sort of statistical information is called aggregate data because it reflects the habits and characteristics of a large group of anonymous people. Web sites may use aggregate data or share it with their business partners so that the information and services they provide best meet the needs of the users. Aggregate data also helps advertisers and sponsors on the Web know how effectively they are reaching and meeting the needs of their target audience.
browser: Short for web browser, a browser is software application used to locate and display web (Internet) pages. The three most popular browsers are AOL, Microsoft Internet Explorer, and Netscape Navigator. In addition, most modern browsers can present multimedia information, including sound and video, though they require plug-ins for some formats.
cache (also called cache memory): Once your Web browser accesses a web page, it references that page and the graphics on it within your computer's "cache" (or more simply, your computer takes a "snapshot" of every page you visit and stores it in the "cache".) The next time you visit that same page, your download time will be quicker as the images and much of the page is already available on your computer for your browser to reference instantly instead of waiting for the page and images to download again. FreeFamilyHealth Health Manager does not cache pages.
Channel Partner Web site: A third party Web site to whom FreeFamilyHealth Health provides content and services for that web site's health channel.
Click Stream Information: A record of all the pages you have visited during your visit to a particular Web site or the services you accessed from the site or from an email. Click Stream Information is associated with your browser and not with you personally. It records the archives of your browser.
Cookie: A small data file that is stored on the hard drive of the computer you use to view a Web site. Cookies are placed by that site or by a third party with a presence on the site, such as an advertiser using a Web Beacon (see definition below) and are accessible only by the party or site that placed the Cookie (i.e. a Cookie placed on your computer by FreeFamilyHealth Health isn't accessed by any other site you visit but a Cookie placed on your computer by an advertiser may be accessed by any site on which that same advertiser has a presence). Cookies can contain pieces of Personally Identifiable Information (PII). FreeFamilyHealth Health encrypts any PII it stores in its Cookies. These Cookies often are used to make the site easier to use. For example, if you check a box to ask that we store your user name on your computer so that you don't have to enter it each time you visit the site, it's stored in a Cookie on your computer.
encryption: The translation of data into a secret code. Encryption is the most effective way to achieve data security. To read an encrypted file, you must have access to a secret key or password that enables you to decrypt it. This is typically done by secure computer systems.
firewall: A system designed to prevent unauthorized access to or from a public or private network. Firewalls can be implemented in both hardware and software, or a combination of both. Firewalls are frequently used to prevent unauthorized Internet users from accessing private portions of public networks. All messages entering or leaving the network pass through the firewall, which examines each message and blocks those that do not meet the specified security criteria.
Non-Personal Information: Information that is not traceable back to any individual and cannot be used to identify an individual. For example, Click Stream Information is Non-Personal Information, as is information such as gender, age, city and state when not linked with other Personally Identifiable Information.
Opt-In: Means you are actively indicating your preference to participate in a program, email, feature, tool, or enhancement on a Web site. Typically, if you "Opt-in" you must provide certain information, usually Personally Identifiable Information, to the Web site or otherwise actively indicate your choice or preference to participate in the Web site program. For example, if you wish to receive a diabetes newsletter by email from FreeFamilyHealth Health, you must enter your email address and choose the type of newsletter by checking a box next to a statement such as: "Yes, I'd like to receive a free subscription to FreeFamilyHealth's Diabetes Newsletter."
Opt-Out: Means that if you do not take some action you are indicating your preference to participate in a program, email, feature, tool or enhancement on a Web site. Typically, if you "Opt-out" you must uncheck a box next to a stated preference or otherwise take some indicate action to indicate your preference not to participate in a program. For example, if you do not wish to receive promotional emails from FreeFamilyHealth Health or its sponsors, you must uncheck the box in your email preference center that states: "Please send me special offers and communications from FreeFamilyHealth Health and/or its partners that would interest me."
password: A secret series of characters, typically alphanumeric (meaning it consists of both letters and numbers) that enables a user to access a file, computer, or program. The user must enter his or her password before the computer or system will respond to commands. The password helps ensure that unauthorized users do not access the system. In addition, data files and programs may require a password.
Ideally, the password should be something that nobody could guess. In practice, many people choose a password that is easy to remember, such as their name or their initials. This is one reason it is relatively easy to break into many computer systems.
Personal Health Information (PHI): When your Personally Identifiable Information (PII) is combined with known health characteristics. For example, if you indicated that you have a certain disease or condition, when that information is combined with your PII, it becomes Personal Health Information.
Personally Identifiable Information (PII) (also called Personal Information): Information that can be traced back to an individual (contrast with Non-Personal Information and Aggregate Information). Examples of PII include your name, home address, telephone number, email address, and Social Security number.
If other pieces of information are linked to PII, they also become PII. For example, if you use a nickname to chat online and give out your real name while chatting, your nickname becomes PII when linked with other PII.
server: A computer that provides services to other computers. A "web server" stores web site files and "serves" them to people who request them.
SSL (Secure Sockets Layer): A security protocol developed by Netscape for transmitting private information via the Internet. SSL works by using a private key to encrypt data that's transferred over the SSL connection. Both Microsoft Internet Explorer (http://www.webopedia.com/TERM/S/Internet_Explorer.htm) and Netscape Navigator (http://www.webopedia.com/TERM/S/Navigator.htm) support SSL, and many Web sites use the protocol to obtain confidential user information, such as credit card numbers. By convention, URLs that utilize an SSL connection start with https: instead of http.
username: A name used to gain access to a computer system or program. Usernames, and often passwords, are required in shared systems, such as the Internet. In most such systems, users can choose their own usernames and passwords.
Usernames are also required to access some bulletin board and online services such as FreeFamilyHealth Health Manager.
virus: A program or piece of code that is loaded onto your computer without your knowledge and runs against your wishes. Viruses can also "replicate" themselves by copying their code to other computers. All computer viruses are manmade. A simple virus that can make a copy of itself over and over again is relatively easy to produce. Even such a simple virus is dangerous because it will quickly use all available memory and bring the system to a halt. An even more dangerous type of virus is one capable of transmitting itself across networks and bypassing security systems. There are numerous virus protection programs available. See the "How You Can Protect Yourself" section.
Web Beacons (also often referenced as "clear GIFs", "web bugs", "1-by-1 GIFs", "Single-Pixal GIFs", "1 x 1 Pixals", or "clear Pixals"): Tiny graphic image files, imbedded in a web page in GIF, jpeg or HTML format, that provide a presence on the web page and send back to its home server (which can belong to the host site, a network advertiser or some other third party) information from the Users' browser, such as the IP address, the URL of the page on which the beacon is located, the type browser that is accessing the site and the ID number of any Cookies on the Users' computer previously placed by that server. Web Beacons can also be used to place a Cookie on the Users' browser.
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