The Coalition to Strengthen America’s Healthcare (“Coalition”, “we”, “us” or “our”) respects the privacy of our website visitors ( “you” or “your”). This Privacy Policy (as posted on our website here and as amended from time to time and effective as of the date posted) (“Privacy Policy”) describes the types of information we may or do collect from you or that you may provide when you visit or use our protecthealthcare.org website (“Website”) or use our services (including providing information via our Website) (“Services”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. This Privacy Policy only covers information collected on our Website and does not cover any information collected at any other website, offline, or elsewhere by the Coalition (unless specifically stated).

By visiting a Website, you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, process, share, retain, and transfer your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website, or our Services. Your use of our Website and our Services is at all times subject to our Terms and Conditions (available at https://protecthealthcare.org/terms-conditions and as amended from time to time and effective as of the date posted (the “Terms”)), which is incorporated by reference herein. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

Information We Collect and How We Use It

This Privacy Policy covers our treatment of your personally identifiable information. “Personal Information” generally refers to any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person. However, the definition of Personal Information may vary depending on the state or country in which you reside, and that state’s or country’s definition will apply to your Personal Information in the context of this Privacy Policy. Please see additional information below on the particular information we may collect.

Personal Information does not include information publicly available from government records or information excluded by applicable law. Personal Information also does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

We also may collect Personal Information from you through means other than our Website. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It also may include emails, text messages, or other electronic communications that you send to us separate from our Website or by way of our Service Providers (as defined herein). However, if we combine the Personal Information we collect from you outside of our Website with Personal Information that is collected through our Website or by another means as described above, the Privacy Policy will apply to the combined information, unless specifically disclosed otherwise.

We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for or use our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

Types of Personal Information Collected

Category	Specific Items of Personal Information
Identifiers	·         first and last name, email address, postal address, unique personal identifier, e.g., phone number
Demographic	·         birth date, country of residence
Commercial Information	·         donation history
Internet or other electronic network activity	·         browsing, session, interaction, and search history related to our Website ·         cookies ·         pixel tags ·         material and pages viewed ·         time and date of access to the Website ·         Meta pixels ·         Hardware type ·         Browser type and version ·         IP address or other device identifier

 

We, third-party advertising companies, and service providers may use a variety of technologies that automatically or passively collect certain information whenever you visit any Website or otherwise interact with us or our content (“Usage Information”). Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following:

• Details of your visits to our Website, including, but not limited to, website traffic data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.

Behavioral Tracking. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner.

The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, speed up your searches, and/or, recognize you when you return to our Website.

Cookie Notice and Policy. The technologies we use for automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, IP address, and other technologies. Each of these is discussed below.

Browser Cookies

Browser cookies are small files placed on the hard drive of your computer or mobile device. They may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Browser cookies are managed by the web browser (Chrome, Microsoft Edge, Safari, etc.) on your computer or mobile device. Different types of cookies which have different purposes are used on our Website.

Essential Cookies

Essential cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies

Performance cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies

Functionality cookies enable our Website to remember the choices you have made when browsing. For example, we can store your general geographic area (but not precise geolocation) in a cookie so that the Website corresponding to your geographic area is shown. We can also remember your preferences, such as the text size, font, and other customizable aspects of the Website. Functionality cookies also may be able to keep track of the products, pages, or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of sites that are not under our control.

We also use cookies such as functionality cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website, to understand which parts of our content interest you the most, and which Service categories you request. This tracking uses De-Identified Personal Information data. Some of our service providers are allowed to place cookies on our Website. Those companies also may provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.

Local Storage Cookies

Certain features of our Website may use local stored objects to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.

At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count visitors who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pixel Tracking. In addition to using cookies, the Website may employ “pixel tracking,” a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our Services with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we also may be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.

Meta Pixels. We incorporate pixels provided by Meta Platforms, Inc. on our website. This enables us to track user behavior after they click on a Facebook ad and are redirected to our website. By doing so, we can assess the effectiveness of Facebook ads for statistical and market research purposes and sometimes retarget certain users. Please note that the data collected through this process remains anonymous to us, meaning we do not have access to personal information of individual users. However, Facebook stores and processes this data. Therefore, we are providing you with this information based on our current understanding. It is important to be aware that Facebook may associate this information with your Facebook account and utilize it for its own promotional activities, in accordance with Facebook’s Data Usage Policy available here. You have the option to authorize Facebook and its partners to display advertisements on and off Facebook (see here). Additionally, a cookie may be stored on your computer for these purposes.

GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with websites and other online services. The code is  temporarily downloaded onto your device from our web servers, is active only while you are connected to the Website and is deactivated or deleted thereafter.

Transmitting Personal Information from our Website. We respond to the Global Privacy Control (“GPC”) signal. The GPC signal is a browser-level signal that can reflect the desire to opt-out of having Personal Information shared or sold. Some browsers allow transmission of GPC signal. By broadcasting this signal, we will not transmit your Personal Information to third parties who perform analytics services or who advertise to you based on this information. Please note that when your browser broadcasts the GPC signal, we will limit the functionality of our Website and prevent the Website from transmitting your Personal Information to third parties. You may also submit an opt-out privacy request with your email, phone number and other Personal Information for us to complete the opt-out process.

Information We Collect from Third Parties

We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.

• Third-Party Services. If you link, connect, or login to your account with a third-party social media service (e.g., Facebook, Google, Instagram, Yelp, etc.), the third-party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party Service Providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from Service Providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partner ad networks. Other examples of such providers include, but are not limited to, backend processing, fulfillment, automation, certification, video hosting platform, email management, authentication, form processing, website usage tracking, managing calendar invites and scheduling, and database hosting and management.

Third-Party Use of Cookies and Other Tracking Technologies

• Some content or applications, including advertisements, on the Website is served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect or compile information regarding user interactions with ad impressions and other ad service functions as they relate to our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies 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 and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
• We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website. More information on how to opt-out of third-party advertiser tracking mechanisms is available here.

Google Tools. We use tools provided by Google as described below.

Google Analytics. We use, and/or some of our third-party Service Providers may use, Google Analytics or other analytics service to help us understand the use of our Website and Services. Google Analytics is a web analysis service provided by Google. Google utilizes data it collects to track and examine the use of our Website to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.

Google AdSense Advertising. We use Google AdSense Advertising (or other search engine or display network advertising) on our website. Google’s advertising requirements and principles are available here. They are put in place to provide a positive experience for users. We have implemented the following: (a) Remarketing with Google AdSense and (b) Google Display Network Impression Reporting.

Google DoubleClick for Publishers Cookie. We use Google’s DoubleClick for Publishers Cookie, which uses cookies to serve ads on our Website. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Website or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page here.

Google reCAPTCHA. We use Google reCAPTCHA, which identifies bots by collecting hardware and software information and sending that data to Google for analysis. More about Google reCAPTCHA is available here.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.

Posting Content

You also may submit information, such as comments, reviews, testimonials, etc., to be published or displayed (“posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “Content”). Your Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons. By posting any Content or submitting Content for posting you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, publicly display, perform, publish, transmit, transfer, distribute, translate, reproduce, rearrange, edit, redact, modify, aggregate, summarize, abstract, adapt, and create derivative works of the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed (“Right to Use”).

The Right to Use you grant us above also extends to any Content that you have posted on our Facebook or other social media account pages, or on other websites, e.g., Google, Yelp, Trip Advisor, Instagram, etc.

If we permit you to post Content, by posting any Content, or submitting Content for posting, you agree to with the following “User Content Posting Guidelines”:

To the extent our Website contains areas where you can post or submit to be posted Content such as comments, product reviews, testimonials, etc., you agree to post Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. You agree not to post or submit any Content that:

• Is off-topic, false, inaccurate, misleading, defamatory, libelous, stalking, threatening, obscene, pornographic, indecent, vulgar, offensive, which contains unlawful material or information, or which otherwise violate the legal rights (such as rights of privacy and publicity) of others;
• Harasses, degrades, intimidates, or is hateful toward an individual or group of individuals on the basis of religion, gender, sexual orientation or identity, race, ethnicity, age, or disability;
• Is not your own original creation or that you do not have permission to use or that infringes the copyright, trademark, patent, or other proprietary right of any person or that is used without the permission of the owner;
• Is intended to provide professional advice, including but not limited to, the provision of medical treatment, or legal, financial or investment advice;
• Promotes or provides instructional information about illegal or illicit activities;
• Purports to be from any person or entity, including but not limited to one of our employees, or falsely states or otherwise misrepresents your affiliation with a person or entity;
• Includes personal or identifying information about another person without that person’s explicit consent, or is doxxing or gaslighting;
• Contains malicious software code of any kind, including, but not limited to, code that contain viruses, malware, corrupted files, or any other similar software or programs designed to or that may interrupt, lock up, destroy, damage or limit the operation of another person’s computer or network or telecommunications equipment;
• Disrupts the normal flow of dialogue with an excessive number of messages (flooding attack) to the Website, or that otherwise negatively affects the ability of others to use the Website; or,
• Advertises or offers to sell any goods or services, or engage in surveys, contests, chain letters, or for any commercial purpose.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:

• To present to you our Website, and contents and provide information and notices (e.g., updates) related thereto.
• To provide you with Services, and information related thereto that you request from us and your related questions.
• To provide customer Service and support.
• To process transaction payments, refunds, and reimbursements for any Services that you choose to purchase from us.
• To send you emails and newsletters with Service, company, and other information and offers.
• Sending electronic publications to online subscribers
• To allow you to participate in interactive features on our Website.
• To ask for ratings and reviews and request your participation in surveys, polls, focus groups, Service trials, or other initiatives which help us to gather information used to develop and enhance our Services, and to provide you with any prizes, or awards as applicable.
• To enhance and improve our Website and Services, for example, by performing internal research, analyzing user trends and measuring demographics and interests and for analyzing how the Website and Services are used, diagnosing Service or technical problems, and maintaining security.
• To de-identify, aggregate, anonymize, etc., your Personal Information or other data.
• For internal purposes, such as Website, Service, and system administration or internal audits and reviews, and use of identification-verification technologies.
• To our affiliates, subsidiaries, divisions, and/or our members of our family of companies.
• To comply with applicable law(s) (e.g., to comply with a search warrant, subpoena or court order) or to carry out professional ethics/conduct investigations.
• In any other way we may describe and for which we obtain your consent when you provide the information.
• To manage donation history, transactions, and communications
• Registration, attendance, and management for events (e.g., webinars, conferences, meetings, distance learning, etc.)

In addition, we may use and disclose non-personal information, including information that has been de-identified (by removing all information that can be used to directly identify or contact you as a specific individual, e.g., by using a mathematical process known as hashing), at our discretion, including to make inferences about offers and content that may be of interest to you as well as to serve you with relevant advertising and allow others to do so.

Third Party Advertisers and Links

Third Party Advertising and Analytics Service Providers

We may allow third party ad servers or ad networks to serve advertisements within the Website and elsewhere on the Internet. We also use analytics providers to provide us with information regarding the use of the Website and the effectiveness of our advertisements. These third party ad servers or ad networks use their own tracking technology on your device (e.g., cookies and web beacons) to select and send advertisements and links directly to your browser. They automatically receive your IP address when this happens. We may share non-personal information, including information that has been de-identified with ad servers, ad networks, analytics providers, and other third parties for the purposes of serving you more relevant advertisements.

We may use a variety of companies to serve our advertisements. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and you may want to visit the following webpages, which provide “opt-out” mechanisms for participating companies: https://thenai.org/opt-out/; http://www.aboutads.info/choices/.  You may also be able to opt-out from interest based advertising on your mobile device through your mobile device settings.  You may also opt-out from receiving targeted ads while on Website through your account settings as further described below in “Your Choices.” Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.

The Coalition does not provide any Personal Information to these third party ad servers or ad networks without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. You should consult the respective privacy policies of these third party ad servers and ad networks for more information on their practices and for instructions on how to opt-out of certain practices.

We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and/or, (f) help you efficiently access your information after you sign in.

How We Respond to “Do Not Track” Signals

Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Third Party Links and Content

The Website and publications contain many links to other websites. In addition, the Coalition may maintain a presence on third-party sites such as Facebook®, Linked-In® or others. These other websites may send their own cookies to users, collect data or solicit Personal Information. The Coalition is not responsible for the privacy practices or the content of these other websites. Please check with the other sites to review their privacy policies and how they may collect or use information.

Social Media Plugins

We integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site login.

For example, when you visit our Website, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Website to your Facebook profile. This allows Facebook to assign your visit to our Website to your user account. Please note that as provider of the Website, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website to your Facebook user account, please log out of your Facebook user account.

If you do so, you authorize us to access certain social media site account information, such as your public social media profile (consistent with your privacy settings in the social media site). Plug-ins may transfer information about you to the Plug-in’s respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a Plug-in will transmit information directly to that Plug-in’s social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective social media site’s privacy policy (available on their website), and not by our Privacy Policy.

Text Messages.

Our Services may include sending you Short Message Service (“SMS”) messages, which may deliver up to two messages per day to your cellphone or other wireless device (unless you communicate further with us and we need to or can respond), but message frequency may vary.  We may use your information to contact you about your purchases, returns (if available), Website updates, conduct surveys, informational and service-related communications, including important security updates, or for other purposes. You may request us to stop sending text messages by replying “STOP” to the SMS text message you received or by sending “STOP” via SMS to 1-833-634-5339. After you send the SMS message “STOP” to us, we will send you a SMS message to confirm that you have been unsubscribed. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us, or by any reasonable means. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. For help, please reply to a text with HELP. Message and data rates may apply, depending on your cell phone plan. Carriers are not liable for delayed or undelivered messages.

Disclosure of Your Personal Information

We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more of the following purposes:

Type of Third Party	Purpose
Data storage or hosting providers	Secure storage and transmission of your data
Database and software service providers	Management and tracking of your data
Legal and compliance consultants, such as external counsel, external auditors, or tax consultants	Provide professional services to us
Payment solution providers	Secure processing of payments you provide to us
Fulfillment and shipping vendors	Fulfillment and delivery of Services
Survey and research providers	Perform surveys or studies on our behalf
Advertising partners, including social media providers	Deliver targeted advertisements
Technology providers	Assist in the development and management of our Website
Outbound call center providers	Perform outreach on our behalf regarding our Services
Publishers and learning providers	Develop services on our behalf
Digital credential providers	Deliver digital badges earned through your participation in learning programs
Our volunteers or committee members	Perform various functions on our behalf
Unrelated third-party list renters	One-time mail or email approved by us
Marketing providers	Sell mailing lists

 

The Coalition may share non-personally identifiable information, such as information that has been de-identified, aggregated user statistics, or a Coalition identification or transaction number, with third parties in our discretion. We do not share your Personal Information with third parties for those third parties’ own direct marketing purposes unless you consent (opt-in or opt-out) to such sharing. California Residents, please see below for additional information on “Your California Privacy Rights.”

Disclosures to Service Providers. We may disclose your Personal Information to third parties for the purpose of providing or improving the Services to you. We may disclose your Personal Information to third-party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, – marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, sending postal mail and email, removing repetitive information from customer lists, providing search results and links (including paid listings and links), processing credit card payments, or managing our conferences and other events. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).

Event-Related Disclosure. From time to time, we may conduct events, run contests, make special offers, or other activities (“Events”), possibly together with an exhibitor, sponsor or other Service Provider. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control such third parties’ use of your information that you provide directly to them. If you do not want your information to be collected by or disclosed to such third parties, you can choose not to participate in these Events.

Disclosure of De-Identified Personal Information. We may share De-Identified Personal Information with third parties for any purpose except as prohibited by applicable law, including, but not limited to, the following. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose.

Required Disclosures. Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process (e.g., subpoena), including, but not limited to, in order to respond to any government, regulatory, or licensing request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, service providers, or partners, or investigate, prevent; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations or to investigate, prevent, or take action regarding suspected or actual illegal activities; (e) assist government enforcement agencies or to meet national or other security requirements; (f) to protect the security or integrity of our Website, or Services; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others. We will attempt to notify you, where reasonably practicable, about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law or regulation, or (ii) we believe that providing notice would be futile, ineffective, create a risk of harm to an individual or group, or create or increase a risk of acts of fraud done upon us or our users. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

Business Transfers

Your Consent to Disclosure/Transfer/Assignment of Your Personal Information. You consent to (and shall not object) our disclosure, transfer, assignment, and/or sale of your Personal Information, De-Identified Personal Information, and other information you provide to us, as well as the rights you have granted or consented to in this Privacy Policy  (collectively, “Transferred Information”) to a potential or actual buyer or acquirer of assets or equity of our company or other successor for the purpose of considering or undergoing a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.

Your California Privacy Rights

California Civil Code Section 1798.83 (known as California’s “Shine The Light Act”) permits residents of California to request certain details about how their Personal Information has been shared during the calendar year with third parties for those third-parties’ own direct marketing purposes, unless the business permits California residents to opt in to, or opt out of, this type of sharing. The Coalition qualifies for this alternative option. As noted above, we will not share Personal Information about you with third parties for their own direct marketing purposes if you do not opt-in, or if you choose to opt-out, at the time the Coalition offers you that choice.

If you are a California resident and you have questions about our practices with respect to sharing Personal Information with third parties for their direct marketing purposes and your ability to exercise choice, please write us at privacy@strengthenhealth.org. Please put the statement “Your California Privacy Rights” in the subject field of your email or in the address line of your envelope. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Information Security

We have implemented technical, administrative, and organizational security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, destruction, alteration and disclosure. Your Personal Information is stored behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safe. Any payment transactions involving credit or debit cards will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers.

Please understand that no one can give an absolute assurance that information intended to be maintained as private, whether transmitted via the Internet or otherwise, cannot be accessed inappropriately or unlawfully by third parties. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a computer. We have taken and will continue to take commercially reasonable steps to ensure the secure and safe transmission of your personal information.

Data Retention

In general, our retention of Personal Information is reasonably necessary and proportionate to achieve the purposes for which the Personal Information was collected or processed, or for another disclosed purpose that is compatible with the context in which the Personal Information was collected, and not further processed in a manner that is incompatible with those purposes. The time period for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are a registered subscriber or member or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration. We will also retain Usage Data for analytics purposes. “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Accessing and Updating Personal Information

You may request access to your Personal Information, corrections and/or deletions of the same by using the Contact Information set forth below. We will use reasonable, good faith efforts to promptly address your concerns, subject to legal retention obligations and legitimate business needs.

When making a request, individual users are asked to identify themselves and the information requested to be accessed, corrected or removed. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. Correcting or removing data is done free of charge to the user unless doing so requires a disproportionate effort. After deleting your information from active servers, copies may remain in our backup system.

Contact Information

We welcome your comments, suggestions, and questions about our Privacy Policy and privacy practices. Please contact us as follows.

• By email at privacy@strengthenhealth.org
• By phone at (877) 422-2349
• By mail at: The Coalition to Strengthen America’s Healthcare, P.O. Box 30211, Bethesda, MD 20824.

Notices; Opting Out

By providing us with your phone number and/or email address (including by “following”, “liking”, linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address and/or phone number to send you Service-related notices by email, text, or by calling you, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications by email, phone, or text, of activity regarding our Services, the Website, your Personal Information, or any aspect of our relationship, to the email address or phone number you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.

You may also opt-out from many third parties who serve online advertising, including some who serve Coalition ads elsewhere online, by visiting http://www.networkadvertising.org/managing/opt_out.asp or http://www.aboutads.info/choices/. Opting out does not mean you will not see any ads when browsing Website, but the ads you see will no longer be customized to you based on your profile or interactions with Website.

Consent to Transfer, Transmission, and Processing Abroad

We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. You consent to our and our service providers’ transmission, processing, and/or transfer of your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.