Privacy Policy

This Privacy Notice explains how Health Policy Advantage, LLC (“we”, “us”, or “our”) collects, uses, shares and processes information obtained through our website, our social media sites and other websites and applications that link to this Privacy Notice (which we call our “Site”). We encourage you to read this Notice before using the Site. By using the Site, you signify your agreement to the terms and conditions of this Notice.

 

Please also see our separate Terms of Use and Cookies Notice, which also govern use of the Site along with this Notice. Should you have any questions about the Site, this Notice or our privacy practices and procedures, please contact us hello@healthpolicy-advantage.com. 

 

NO ATTORNEY/CLIENT RELATIONSHIP

Please note that this Privacy Notice pertains to general use of our Site and the information found on the Site and does not pertain to our use of your personal information in the course of our representation of you, should an attorney/client relationship be created.  Please note that use of the Site and information or materials found on the Site does not, itself, create an attorney/client relationship among you and us. If we agree to provide legal services on your behalf, our processing, use and disclosure of your personal information will be subject to separate terms and/or additional terms to those in this Notice.

 

INFORMATION WE COLLECT ON OR THROUGH THE SITES

The type of personal information we collect depends on how you are interacting with our Sites. In this Notice, where we use the term “personal information,” we mean information that can be used to identify (directly or indirectly) or contact a specific individual, such as an individual’s name, email address, telephone number, or online identifier. The personal information we collect through the Site may include the following:

 

Your Contact Information. This includes information such as a name, alias, address, phone number, social media account user ID, email address, and similar contact data.

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Organizational Information. This includes your employer or organizations that you are a member of, information about your colleagues or those within your organization, your status with an organization, and similar data to the extent you share the same through social media.

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User Content. This includes content, communications, suggestions, comments, questions, responses to questions, feedback and all other information that you send to us, that you provide to us when you contact us, or that you post on our Sites. This includes social media and other online content to the extent you interact with us on social media and other online services.

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Device Information. This refers to device and browser information, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data as described in our Cookies Notice.

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Usage Data. This refers to data collected automatically as a result of your use of the Site, whether generated by your use of the Site (for example, where you visit on the Site) or as a result of Site infrastructure itself (for example, the duration of a page visit). This includes usage metrics, content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user history (including clickstreams and page navigation), content viewed or searched for, page response times, page interaction information, advertising interactions and marketing preferences.

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Location data. This refers to the location of your device when you access the Site, which includes your country of residence. We do not, however, collect or process your GPS location.

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Your Image may also be collected along with other aspects of your likeness (such as still pictures of you, video, voice, and the like) to the extent you provide it to us.

 

HOW WE USE INFORMATION WE COLLECT ON OR THROUGH THE SITES

 

Transfer of Information

Processing and storage activities associated with this Site primarily take place in the United States of America, but may occur elsewhere. We cannot control the location, storage, and processing done by any of our business partners or service providers. We may store or process your information outside your city, province, state, or country, including through one of our contractors and service providers. Please note that your personal information may be stored in a country or state that operates under privacy and data protection laws different from those of your home jurisdiction. By accessing the Site and submitting information through the Site, you consent to the transfer, storage, and processing in the United States of America and outside of your jurisdiction. This Privacy Notice does not create rights enforceable by third parties.

 

Our Processing

We process your personal information in connection with our Site and for other business purposes as follows:

 

Fulfillment of and/or responding to your requests.

Provide, deliver, analyze, and administer our Site and related services (including in connection with the performance of a contract).

 

Comply with your instructions or to fulfill other, specified purposes for which you have given your consent.

For that which you have given us consent to process your personal information for specified purposes.

 

Process transactions related to our Services and administer accounts or profiles related to you or your organization (including registrations, subscriptions, purchases, billing events, royalty calculations, and payments).

 

For internal research and development purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our Site.

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Personalize and make recommendations related to our Site and other offerings.

Contact and communicate with you in connection with our Site or other notifications, programs, events, or updates that you may have registered for.

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Send you offers, advertising, and marketing materials, including to provide personalized advertising to you.

Detect and prevent fraud and abuse, as well as to identify and authenticate your access to our Sites or to identify and authenticate you before we provide you with certain information.

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Exercise our rights and to protect our and others’ rights and/or property.

Comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or authority, as well as to fulfill our contractual obligations with our customers when they arrange access to our Services for you.

 

Legal Notices

We may use your personal information to provide you with notice regarding a security incident or data breach, by: (i) sending a message to the email address you provide (as applicable); (ii) posting to a publicly facing page of our website; (iii) through major statewide media; and/or (iv) telephonic means, including calls and/or text messages, even if sent via automated means including automated dialers (standard text and data messaging rates may apply from your carrier). Notices sent by e-mail will be effective when we send the email, notices we provide by posting will be effective upon posting, and notices we provide through telephonic means will be effective when transmitted or dialed. You consent to receiving electronic communications from Health Policy Advantage, LLC relating to any security incident or data breach. It is your responsibility to keep your email address and any other contact information you provide to us current so that we may provide these communications to you.

 

Service and Marketing Messages

If you sign up for our newsletters and other marketing and informational messages, we may use your information to contact you about product and service offerings by email or otherwise. You have the right to opt-out of such messages. We may use your information to investigate, respond to and/or resolve legal, security or technical issues and complaints and as necessary for security purposes or to investigate possible fraud, violations of law or violations of this Notice or our Terms of Use. We may use your information to contact you about these security, legal and other service-related issues. Please be aware that you cannot opt-out of receiving such messages from us.

 

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or that you provide to fulfill our obligations to you (if any), the purpose for which you provide it (if any), for any other purpose for which we have your consent, or for legitimate business purposes which may include when required by law, subpoena, or other legal process or as necessary in the course of legal proceedings.

 

Internal Disclosure

We will share your personal data internally in order to improve our Site, to respond to your inquiries and fulfill your requests to the extent possible.

 

Disclosure to Our Service Providers

We may disclose personal information that we collect or you provide as described in this Privacy Notice to service providers and other third parties we use solely to support our business (such as the management of our data, maintenance, analysis, audit, fraud detection, communication and the like). They will have access to your information only as reasonably necessary to perform these tasks on our behalf and are obligated to keep it confidential.

 

Disclosure for Legal Reasons

We may transfer your personal information to a third-party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control (such as the result of a bankruptcy proceeding). We may disclose your personal information to third parties if we reasonably believe that disclosure of such information is helpful or reasonably necessary to comply with any applicable law or regulation, to comply with or respond to a legal process or law enforcement or governmental request, to enforce our terms and conditions or other rights (including investigations of potential violations of our rights), to detect, prevent, or address fraud or security issues, or to protect against harm to the rights, property, or safety of our company, our users, or the public.

 

YOUR REQUESTS CONCERNING YOUR INFORMATION

As noted above, this Statement pertains to general users of our Site and not to information collected in a representative capacity. For personal data that we have about you as a result of your use of the Site, you may make requests such as the following:

 

Deletion: You may ask us to erase or delete all or some of your personal data. Doing so may limit your ability to use certain functionality of the Site as well as our ability to process your requests and inquiries.

Correction/Modification: You may ask us to change, update, or fix your data in certain cases, including if it’s inaccurate.

Object to, or Limit or Restrict, Use of Data: You may ask us to stop using all or some of your personal data or to limit our use of it; however, doing so may limit your ability to use certain functionality of the Site as well as our ability to process your requests and inquiries.

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Right to Access Your Data: You can ask us for an identification of the personal data you have provided to us so long as we are able to verify your identity when you make such a request.

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To make a request or inquiry concerning your personal information, contact us at the information above and include the phrase “[Your State] Privacy Request” in the subject line. When you make a request, we ask that you help us by also identifying the following:

 

Tell Us Your Specific Request: Please specify your specific request and the personal information to which your request relates. If you are acting on behalf of another individual, please clearly indicate this fact and your authority to act on such person’s behalf.

Tell Us More about Your Relationship with Us: Please let us know how you are associated with us.

Help Us Verify Your Identity: Provide us enough information to verify your identify. If we cannot initially verify your identity, we may request additional information to complete the verification process (such information may include your picture, a copy of your driver’s license or other government-issued ID and/or a recent utility or credit card bill). Please note that if we cannot verify your identity, we may not be able to fulfill your request. Any personal information you disclose to us for purposes of verifying your identity may be shared with our third-party service providers and/or third parties (like your phone carrier) or government agencies for the purpose of verification.

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Direct Our Response Delivery: Depending on your request, we will provide a response to you via email. If you prefer to receive our response in another way, then please let us know your preferred delivery mechanism to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

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We may decline to process requests if we cannot verify the requestor’s identity, if we believe the request will jeopardize the privacy of others, if we believe the change would violate any law or legal requirement or cause the information to be incorrect, or for a similar legitimate purpose. In any case, where we provide information access, deletion or correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information. If we modify or delete some or all of your personal information, we will retain your personal data if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce obligations or fulfill any other requests from you (for example, to opt-out of further messages or for a copy of your data).

 

We will not discriminate against you for exercising any of your rights under applicable law. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

SECURITY AND PROTECTION

We implement industry standard security safeguards designed to protect your data. These include using encryption for certain data while it is being transmitted between your device or browser and our servers. Nevertheless, given the nature of communications and information technology, and that the use of the internet has inherent risks, although we regularly monitor for possible vulnerabilities and attack, we cannot warrant or guarantee that information provided to us through the Site or stored in our systems or otherwise will be absolutely free from unauthorized intrusion by others. By using the Site, you agree that the Site is provides “as is” and without warranty of any kind (whether express or implied) and we are not responsible for: (i) any disclosure of your personal information made by you to a third party through your use of the Site; (ii) any disclosure of your personal information obtained illegally from us; (iii) any accidental disclosure of your personal information made by us; and (iv) damage or injury you may suffer as a result of your use of the Site.

 

LAWFUL BASES OF DATA PROCESSING

We will only collect and process personal data about you where we have a lawful basis. Lawful bases include those uses and disclosures identified in this Notice, your consent, contract, and other legitimate interests. Such legitimate interests include protection to you, us and third parties, to comply with applicable law, to enable and administer our business, and to contact you concerning changes in law, invitation to our events and information about our services. We have analyzed the balance between our legitimate interests and your rights with the following considerations: (i) your personal data is collected and processed because you have subscribed to our email contacts, or have inquired into our services; (ii) your contact information is limited to your business details unless you chose to provide private contact details; (iii) the content of our communications focuses on business relevant to legal matters; (iv) our intention is to only generate meaningful consent or to contact you concerning services you have requested from us; and (v) the marketing messages we send to you contain an option to unsubscribe.

 

RETENTION AND WITHDRAWAL

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. Where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at the information above. We retain personal information in accordance with our enterprise records retention schedule, which varies by service, business function, record classes, and record types. We calculate retention periods based upon and reserve the right to retain personal information for the periods that the personal information is needed to: (a) fulfill the purposes described in this Notice, (b) meet the timelines determined or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.

 

THIRD PARTY COLLECTION

Please keep in mind that the Site may contain links to other websites or apps. Some content or applications on or in the Site may be served by third-parties, including content providers, application providers, analytics companies, your mobile device manufacturer, and your mobile service provider. These other sites and companies may place their own cookies or other files on your computer, collect data or solicit personal information from you. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) targeted content.

 

We do not control these third parties’ privacy practices or tracking technologies. If you have any questions about targeted content, you should contact the responsible provider directly. You are responsible for reviewing the privacy statements and policies of those other websites you choose to link to or from the Site, so that you can understand how those websites collect, use and store your information. We are not responsible for the privacy statements, policies or content of these other companies and websites or apps, including websites you link to or from the Site.

 

CHILDREN’S PRIVACY

Our Sites generally provide legal services and solutions and, as such, are intended for professionals and/or individuals over eighteen (18) years of age. We do not target children and do not knowingly collect any personal information from children under the age of eighteen (18). When a user discloses personal information on our Services, that user is representing to us that he or she is at least eighteen (18) years of age.

 

CHANGES

We may update our Privacy Notice from time to time to reflect changes in our practices. We will post any changes to our Privacy Notice on this page. If we make material changes to how we treat our users’ personal information, we will provide a notice that the Privacy Notice has been updated. The date the Privacy Notice was last modified is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Notice to check for any changes.

 

Cookie Notice

Our Privacy Notice generally explains our collection, processing, and storage of the personal information we collect from you online. This Cookie Notice is intended to supplement that Notice and explain how we deploy and use cookies and similar technologies on our websites websites and applications that link to this Privacy Notice (which we call our “Site”).

 

What are Cookies?

Cookies are small data files stored on your computer or other device when websites are loaded in a browser. They are used to remember you and your preferences through either a single visit to a Site (a “session cookie”) or over the course of repeated visits (a “persistent cookie”). Cookies help to facilitate the best possible user experience of our Site as they allow us to recognize your preferences and information from session to session and generally improve website functionality. Cookies may be set by the website you are visiting (a “first party cookies”), or by third parties who provide content or advertising or analytics services on that website (“third party cookies”).

 

Cookies are in addition to other tracking technologies known as “web beacons” or “pixels.” These are typically small transparent images that provide internet usage statistics and are often used in conjunction with cookies, although they are not stored on your computer in the same way as cookies. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

 

Flash cookies are designed to support browser content supported by Adobe® Flash. They will store information on your device, some of which will be specific to the Flash-enabled content. Please refer to the following help page for information on how to manage your privacy settings and deletion of Flash cookies:

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

 

Although these types of tracking technologies are not all commonly referred to as “cookies,” we will refer to them as “cookies” throughout this Cookie Notice for ease of reference.

 

The Types of Cookies We Use

 

We use Google Analytics to collect information about use of our Site. Google Analytics collects information such as how often users visit the Site, what pages they visit, what other sites they used prior to coming to this Site and what pages they go to after visiting our Site. Google Analytics collects only the IP address assigned to you on the date you visit the Site, and we do not combine the information collected through the use of Google Analytics with other personally identifiable information. Google Analytics uses a permanent cookie so as to identify you as a unique user the when you visit the Site and to maintain your preferences from session to session. Additional information concerning Google Analytics may be found at the Google Privacy Policy. You can also opt out of Google Analytics by installing Google’s opt-out browser add-on.

 

Third Party Content

Some of our Sites are offered through third party platforms and applications that use their own cookies. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons). As a result, cookies may be set by these third parties, and used by them to track your online activity. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.

 

What We Collect With Cookies

We use cookies to recognize you and/or your device(s) on, off, and across the different applications of the website and devices. We log usage data when you use the website, including when you view or click on content, browser type, browser language, perform a search or request, the date and time of your request or use one or more tools offered through the website. We use log-ins, device information internet protocol (“IP”) addresses, and cookies to identify you and log your use. When you access or leave our Sites, we receive the URL of both the site you came from and the one you go to next. We may also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. We do not collect information concerning your GPS location

 

How We Use Information We Collect With Cookies

We use cookies for several different purposes. We use cookies for technical reasons to enable the content being provided on the Sites as well as to provide you with a more personalized experience on our Sites. We also use cookies to analyze Site usage and for advertising purposes.

 

Restricting and Controlling Cookies

Although most internet browsers accept cookies, you can control these types of technology through your browser settings and similar tools and agree to refuse cookies altogether. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:

 

Cookie settings in Internet Explorer

Cookie settings in Firefox

Cookie settings in Chrome

Cookie settings in Safari web and iOS

If you refuse to accept cookies by activating the appropriate setting on your browser or smartphone, you prohibit us from delivering the full capability of the website and prevent the use of certain features and services that require these technologies.

 

Do Not Track Signals

We do not currently respond to, or take any action with respect to web browser “do not track”” signals or similar mechanisms as there is no uniform implementation of the same. Our third-party service providers may honor Do Not Track signals. For more information about “do not track” signals, please visit https://allaboutdnt.com/.

 

Consent for Cookies on Our Sites

By using our Site without changing your browser or device settings to disable cookies, you agree to this Cookies Notice and the use of cookies as described above. You may see a “cookie banner” on our websites. If you are visiting one of our Site from certain jurisdictions, you may be asked to accept cookies in accordance with this Notice. When you consent to this banner, we will assume that you consent to our use of cookies as described above for all future visits unless you contact us and notify us otherwise.

 

How to Contact Us with Questions or Concerns

If you have any questions about our use of cookies, you can find the most recent contact details in our Privacy Notice.