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Effective January 1, 2016

Adherence Website Privacy Statement

Adherence has developed this Privacy Policy (“Policy”) to advise you of the ways in which Adherence collects, uses, shares and protects your information. This Policy includes Adherence’s Website Privacy Statement. Any person accessing, browsing or otherwise using a website where this Privacy Statement is posted (each, a “Site”) either manually or via an automated device or program, is a “User” for purposes of this Policy.

User Consent to Policy

By accessing, browsing, or using a Site, each User acknowledges that he or she has read, understands, agrees and consents to the terms and conditions of this Policy. Each User consents to the collection, use, and disclosure of User information including personal and non-personal information and anonymous browsing information (together, “Information”) pursuant to the terms of this Policy. If you do not consent to these terms and conditions, please do not access, browse, or use any Site or provide Information to Adherence via any Site.

Information Collected by Adherence

Adherence may collect different types of Information from Users, including personal information, non-personal information, and anonymous browsing information, collectively referred to as “Information” in this Policy.

A.        Personal Information

Adherence may collect the name, title, company name, address, phone and/or fax number, job title, email address, credit card number, and other personal information provided by a User who contacts Adherence or any of Adherence’s representatives through a Site, via email or otherwise, submits a request for information, proposals, or to receive compliance updates, attends a webcast, live conference, or other Adherence-sponsored or hosted event, or engages in any other activity through a Site in which personal information is provided to Adherence.

By submitting Information to Adherence on or through the Site, a User acknowledges that he or she has read this Policy, understands it, agrees to its terms, and authorizes Adherence to collect, use and disclose Information pursuant to the terms of this Policy.

B.        Anonymous Browsing Information and Non-Personal Information

Users can browse a Site without revealing personal information. In this context, Adherence’s servers may collect certain non-individually identifying browsing information, such as your Internet Protocol address, your computer’s operating system, the name of the domain you used to access the Internet, the Web site you came from, and the Web site you visit next. This information is collected passively through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs, or other technologies, examples of which are explained further in Section C below. Anonymous browsing and non-personal information is not used, nor is it intended to be used, by Adherence to personally identify an individual.

C.        Passive Gathering of Information Electronically

Adherence and any third parties that may advertise or provide other services on a Site may automatically collect certain types of passive, anonymous information whenever you use a Site or certain Site services, or click on advertisements on a Site or in Adherence’s periodicals. If Adherence or these third parties collect this anonymous information, it will be done passively through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs and similar technologies as explained below.

HTML Cookies: Adherence and certain third party advertising partners may use “cookies.” When you use a Site, the pages you see, along with something called a “cookie,” may be downloaded to your computer, mobile device, or tablet (collectively, “Equipment”). Cookies are small pieces of information that are stored by your browser on your Equipment. These cookies do not contain or collect any personal information, but may be used to deliver content on a Site specific to your interests and for other purposes, such as security and administrative functions. For example, cookies are used to store your preferences for certain types of information so that you do not have to input those preferences every time you use a Site. Adherence and its third party advertising partners do not as of the effective date of this Policy use cookies to deliver targeted advertisements to you when on a Site or third party websites. Most web browsers automatically accept cookies, but you usually can change your browser to limit or prevent cookies. Cookies in themselves do not personally identify the individual user, but rather the Equipment that is being used to access a Site. You may have the opportunity to set your Equipment to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. Different browsers may address cookies differently. If you set your browser to not accept cookies, it may result in certain personalized services not being provided to you when you use your Equipment.

Web beacons, Pixels and Clear GIFs: Adherence and certain third party advertising partners may use web beacons, pixels and clear GIFs. These electronic technologies are transparent image files that, if used, allow Adherence and its advertising partners to track website usage information, such as the number of times a given web page has been viewed and whether and when you have opened a HTML email, how many times the email was forwarded and which links in the email were clicked. Unlike cookies, these technologies are not placed on your Equipment. If used, this information will help us to improve a Site and our advertising materials and will help our advertising partners by measuring the effectiveness of these communications with you. These technologies may be used in association with cookies to understand how visitors interact with a Site or advertisements.

How Adherence Uses the Information

Adherence uses the Information collected from Users to respond to Users’ questions and/or comments, market or provide products, services or information to Users, process Users’ purchases, or provide related account status. Personal information, non-personal information, and anonymous browsing information may be used to gather broad demographic information used in marketing, promotion, analytics, or similar activities. This information may be aggregated to measure the number of visits, average time spent, page views and other statistics about Users of a Site. Adherence also may use this data to monitor Site performance and to make a Site easier and more convenient to use. Adherence also may use Information collected from its Users to enforce its agreements with Users, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that Adherence complies with applicable laws.

Adherence Sharing of your Information

Adherence only will share Information that it collects or receives regarding its Users with third parties under the following circumstances:

·   Consent: If Adherence has a User’s consent to share any Information, it may do so.   

·    Agents: Adherence may utilize other companies and individuals to perform functions on its behalf such as marketing new or additional Adherence products and services, sending postal and electronic mail to Users, processing credit card payments, fulfilling orders, delivering products and services, hosting discussion forums, and providing customer service. These third parties have access to Information needed to perform their functions, but may not use it for other purposes.

·    Aggregate Anonymous Information: Adherence may provide to others the aggregate statistics about our Users’ site activity for purposes of marketing, promotion, analytics or similar activities. None of these statistics will identify Users personally.

·    Protection of Adherence or Others: Adherence may disclose Information about our Users to others if we have a good faith belief that we are required or permitted to do so by law or legal process, to respond to claims, to protect the rights, property or safety of Adherence or others, or take action regarding illegal activities or suspected fraud.

·    Business Transfers: In the event that Adherence decides to sell all or part or its assets, Adherence reserves the right to include Information among the assets transferred to the acquiring company.

·    Conference and Roundtable Attendees. Adherence may provide the names, titles, company names, addresses, phone information, and e-mail addresses of conference or roundtable attendees to current, past, or prospective conference or roundtable attendees, exhibitors, sponsors, or co-sponsors.

Accessing, Changing or Deleting Your Personal Information

Adherence allows you to change, correct inaccuracies in or delete your personal information by contacting Adherence at (917) 885-2596 or sending an email to info@adherencellc.com

 

Data Integrity

Users are responsible for the accuracy of the Information they provide to Adherence.  Adherence will use reasonable efforts to maintain the accuracy and integrity of User Information and update it as appropriate.  

Choices for Use or Sharing of Certain Information

Adherence values your concerns about the privacy of your personal and non-personal information. Therefore, we offer you the opportunity to choose how certain information is used by Adherence.

Any emails sent by Adherence that are subject to the U.S. CAN-SPAM Act will include an option to unsubscribe from further correspondence. Please note that even if you opt-out from receiving certain email from Adherence, you will continue to receive transactional and/or relationship messages, such as messages conforming a product purchase, or an event you registered for.

As stated above, Adherence may share names, titles, company names, addresses, phone information, and e-mail addresses of conference and roundtable attendees with current, past, or prospective conference or roundtable attendees, exhibitors, sponsors, or co-sponsors. If you do not wish to receive further communications from these persons, you must contact them directly and make such a request. Adherence is not responsible for how these third parties handle conference and roundtable attendee information.

Linked Internet Web Sites

The Site may provide hyperlinks, which are highlighted words or pictures within a hypertext document, that, when clicked, take you to another place within the document, to another document altogether, or to other Web sites not controlled by Adherence. These hyperlinked Web sites may contain privacy provisions that are different from those provided herein. Adherence is not responsible for the collection, use, or disclosure of information collected through these Web sites, and Adherence expressly disclaims any and all liability related to such collection, use, or disclosure.

Children’s Privacy Protection

No Site is directed towards children under 13 years of age, and Adherence does not knowingly collect any information from children under 13 years of age through any Site. If you are under 13 years of age, you are not permitted to submit information to Adherence through any Site.

Security

Each Site has commercially reasonable security measures to protect against the loss, theft, misuse, and alteration of the Information that is submitted to Adherence and is under Adherence’s control. You should be aware, however, that Adherence has no control over the security of other websites that you might visit or use, even when a link to those websites is available on or through the Site. If you share your Equipment or use Equipment that is accessed by the general public, remember to sign off and close your browser when you finish using the Site.

Adherence wants you to feel confident using the Site; however, no system can be completely secure. Therefore, Adherence makes no representations or warranties with regard to the sufficiency of its security measures. Adherence shall not be responsible for any actual or consequential damages that result from a lapse in compliance with this Policy as a result of a security breach or technical malfunction. Certain information may be transmitted to you by email. Although it is illegal to intercept or disclose these messages under U.S. Federal law, these transmissions are not secure. In addition, Users’ communications through a Site are, in most cases, viewed only by you and anyone to whom you address your message. As the operator of a Site, Adherence may need to review or monitor your electronic mail and other communications from time to time as may be required by law. Therefore, you should not expect to have a right to privacy in any of your electronic communications.

In the event of a breach of the confidentiality or security of your personal information, Adherence will notify you if reasonably possible and as reasonably necessary under applicable laws, so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. You should also take care with how you handle and disclose your personal information. Please refer to the Federal Trade Commission’s web site for information about how to protect yourself against identity theft.

Amendments to Privacy Policy

We may occasionally update this Policy, as noted by the “effective date” at the beginning of the Policy. If we update this Policy in a manner that is materially less restrictive in our use or disclosure of personal information that we collected prior to the update, we will provide you with prior notice of the pending update and seek your consent by posting notice on the Site or by contacting you using the email address in our records. We encourage you to periodically review this Policy to stay informed about our collection, use, and disclosure of Information. Your continued use of a Site constitutes your agreement to this Policy and any updates.

Your California Privacy Rights

California law permits customers of Adherence who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. At this time, Adherence does not disclose personal information of “customers,” as defined under the California “Shine the Light” Act, to third parties for their direct marketing purposes. If Adherence changes this policy, it will update this provision and provide instructions on how you may make a request for details concerning such information.

Enforcement and Dispute Resolution

If you have any questions, complaints, or disputes regarding the manner in which Adherence handles or protects your Information, please bring it to our attention (see “How to Contact Adherence,” below). In compliance with the Safe Harbor Privacy Principles, Adherence commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union citizens with inquiries or complaints regarding this privacy policy should first contact Adherence (see “How to Contact Adherence,” below).

If any complaints related to this Policy cannot be resolved through Adherence’s internal process, Adherence has further committed to refer unresolved privacy complaints under the Safe Harbor Privacy Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Adherence, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.  

Adherence retains sole and absolute discretion in resolving all questions relating to the administration, interpretation and application of this Policy. This authority includes construing the terms of this Policy, including any disputed or doubtful terms.

No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

Jane Shahmanesh and Saleemah Ahamed

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jane@adherencellc.com
saleemah@adherencellc.com

Adherence Compliance Group +1-917-885-2596
220 W. 93rd Street, #8C New York NY 10025