This policy applies to personal information in the following circumstances:
- Personal information submitted from our website at www.c3ihc.com, www.telerx.com or any other website owned and controlled by Telerx on its own behalf (each, a “Telerx site”).
- Personal information submitted from web pages Telerx controls under the Telerx name on third party social media websites such as Facebook or LinkedIn (“social sites”).
This policy does not apply to personal information in the following circumstances:
- Personal information collected directly from our current, former or prospective clients, employees, contractors or vendors, regardless of how the personal information is collected.
- Personal information collected or submitted via any hard copy communications.
- Personal information collected or submitted via oral (e.g., telephone) or audiovisual (e.g., YouTube or Skype) communications.
- Personal information collected from other offline resources and communications, except in cases where such personal information is consolidated with personal information collected by Telerx online.
- Personal information collected from third-party online resources to which a Telerx site may link, where Telerx does not control the content or the privacy practices of the resources.
Please note that personal information that is not subject to this policy may be protected by applicable laws, rules and regulations (collectively, “regulations”). Regulations are constantly evolving, so Telerx works hard to ensure that all personal information is maintained in compliance with current regulations, whether or not the regulations are expressly addressed in this policy.
Telerx Client, Patient, Consumer, and Associate Privacy
Telerx maintains an uncompromising position on protecting our client’s proprietary and confidential information, as well as protecting patient, client, consumer, and associates privacy. Many of our corporate standard operating procedures are centered on compliance with regulations.
All our associates sign a confidentiality agreement at the time of hire. Telerx ensures strict adherence to privacy protection through a comprehensive system of policies and procedures that is supported with ongoing training. Strict controls are in place to protect personal information.
Examples of Personal Information
Examples of personal information include but are not necessarily limited to user identifications, passwords, complete or partial names, social security numbers, dates of birth, postal addresses, electronic mail addresses, telephone numbers, and other information that identifies particular individuals.
Who Will Have Access to Personal Information?
Personal information will be accessible to Telerx, including its associates on a need to know basis, and to individuals and organizations that use personal information solely for and at the direction of Telerx. Uses and disclosures of personal information by outside individuals and organizations acting on Telerx’s behalf are governed by agreements that require personal information to be protected appropriately. Personal information only will be used and disclosed by Telerx and individuals and organizations working on its behalf in a manner consistent with this policy, other applicable privacy notices, and as permitted or required by regulations.
The Location of Personal Information
Information collected through a Telerx site may be transferred, used and stored in the United States and in foreign jurisdictions in which Telerx, its users, clients or agents are located now or at any time in the future. Anyone who accesses a Telerx site consents to the capture, storage, transfer, use and processing of personal information in and between all of those jurisdictions. The data protection and other laws in some countries and jurisdictions are not as comprehensive or stringent as the privacy laws in other countries and jurisdictions.
Sharing Personal Information with Third Parties
In general, Telerx does not sell or share personal information except as described in this policy and other applicable privacy notices. However, circumstances may arise where Telerx may, for business reasons, decide to reorganize or divest all or portions of its business through sale, merger or acquisition. In these circumstances, personal information may be shared with actual or prospective purchasers. Telerx will obtain written assurances that personal information will be protected appropriately in these circumstances. Telerx reserves the right to disclose personal information, including e-mail addresses, for reporting to government authorities, to parties in relevant legal proceedings as authorized by a court or tribunal, and otherwise to the extent required or explicitly authorized by applicable regulations.
How Does Telerx Secure Personal Information?
Telerx takes reasonable steps to protect personal information as it is transmitted from a person’s computer to our online resources and servers. Telerx also takes reasonable steps to protect personal information in its possession from unauthorized access, disclosure, alteration or destruction. Telerx reminds individuals that they should also take reasonable steps to protect their personal information by securing copies of user identifications, passwords and related access codes for our online resources.
How Individuals May Access and Correct Personal Information About Them?
Any individual who would like to gain access to a copy of his or her personal information Telerx has collected pursuant to this policy may contact us at the Telerx privacy address stated below.
We may also allow individuals to update their personal information by modifying information previously entered into forms or data fields on a Telerx site. Where permitted by law, an individual’s ability to access and correct personal information will be limited where access and correction would limit Telerx’s ability to comply with a regulation, legal or ethical obligation, limit Telerx’s ability to investigate, make or defend legal claims, result in disclosure of personal information about a third party, or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to Telerx or a third party.
How Personal Information is Used?
Personal information may be used by Telerx to respond to requests for information about Telerx’s business and the services offered by Telerx to its clients, as well as for any other purpose permitted by regulations.
Information Collected From Computers or Other Electronic Devices
Some of the Telerx sites and other online resources use tracking technologies, such as cookies and single-pixel tags, to provide additional functionality that enables individuals to use these resources more effectively. Telerx uses tracking technologies in ways to collect nonpersonal information, such as to track accurately numbers of users or referring sites or advertisements to our online resources, or to remember whether an individual identified himself or herself as a health care professional or a resident of a particular country.
We also may collect nonpersonal information about the devices used to connect to a Telerx site, such as the type of device (e.g., computer, tablet, mobile telephone), device identification, usage information about the device, and how the device uses the Telerx sites and other resources.
A cookie is a small data file that is sent by web servers to a device’s hard drive or other memory, where the individual’s browser files are kept. Cookies enable websites to store small bits of information on a computer or other device, and retrieve that information at a later time.
Telerx uses two types of cookies: Session cookies, which are temporary cookies that are erased from the device’s memory when the Internet browser is closed or the device is turned off, and persistent cookies, which exist on device’s hard drive or memory until the persistent cookies expire. Both session cookies and persistent cookies may be erased or deleted by an individual.
Single-pixel tags, also known as web beacons or web tags are graphics that function similar to cookies. Single-pixel tags are not visible because of their small size. They are used to collect nonpersonal information, such as web pages viewed, the site the individual visited before, an advertisement clicked on by an individual, and whether promotional or other commercial e-mail messages are opened.
Choices About How Telerx Collects, Uses and Discloses Personal Information
Individuals often have up to four categories of choices on Telerx sites about personal information collection and use. These include:
1. No personal information collection
An individual may choose not to provide any personal information to Telerx online by electing not to enter any personal information into a form or data field on a Telerx site, and by not using any personalized services provided by our online resources. However, some of our online resources are available only to individuals who provide personal information or who use personalized services.
2. Limitations and options regarding uses and disclosures for other purposes
Some Telerx online resources may request permission to use and disclose personal information in order to add the individual to our contact lists, and to identify and offer additional services and promotions that we believe the individual might find interesting. Each individual may limit the use of his or her personal information by checking or un-checking options provided at the time the individual enters that information or that Telerx may offer in the future.
3. Limitation and options on tracking
Telerx online resources that use tracking technologies, such as cookies, to store personal preferences and selections also enable individuals to choose whether they want Telerx to use such technologies to remember the individual, or to provide additional services, by checking or un-checking options provided during registration, or at the time that the individual enters personal information into forms or data fields. Telerx’s online resources do not limit nonpersonal uses of tracking technologies for individuals.
4. E-mail communications
Individuals may choose to receive optional e-mail and other communications from Telerx by signing up for or subscribing to these communications on our Telerx sites and other online resources. An individual later opt-out of communications by visiting the Telerx site or other online resources where the individual subscribed, where available, and update e-mail communication selections, or by using the unsubscribe or opt-out instructions in the Telerx e-mail communications. An individual also may opt-out by contacting Telerx at the privacy address stated below. Individuals may opt out of e-mail communications tracking by opting out of receiving those e-mail communications altogether using one of the approaches described above. In some cases Telerx will not be able to turn off e-mail tracking and may still send communications.
Protection of Social Security Numbers
Telerx requires that Social Security Numbers be appropriately secured, in accordance with their sensitivity, from loss, misuse, and unauthorized access, disclosure, alteration or destruction.
Telerx does not knowingly collect personal information from children less than 13 years of age. Nor does Telerx authorize children less than 13 years of age to use any Telerx site. If Telerx learns that it has inadvertently collected personal information from a child under the age of 13, upon receipt of notice from the child or the child’s parent or guardian, Telerx will use reasonable efforts to delete that child’s personal information from Telerx’s systems.
California Privacy Rights
A California resident who has provided personal information to a business with whom she or he has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed her or his personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.
California Customers may request further information about our compliance with California’s privacy law by e-mailing email@example.com or contacting us as stated below. Please note that we are only required to respond to one request per customer per year, and we are not required to respond to requests made by means other than through this e-mail address.
Telerx’s Contact Address for Privacy Questions
Individuals may contact Telerx at the email address firstname.lastname@example.org or at the following postal address:
Attn: Privacy Matters
Telerx Marketing Inc.
723 Dresher Road
Horsham, Pennsylvania 19044
Anyone who has questions about this policy or Telerx’s information collection, use and disclosure practices, may contact us at these addresses. When contacting Telerx, please note or provide the name of the Telerx site or other online resource to which the individual provided personal information, as well as the nature of any information provided. Telerx will use reasonable efforts to respond promptly within twenty business days to requests, questions or concerns regarding access to an individual’s personal information collected online or Telerx’s use of personal information. Telerx may contact individuals to follow-up and share your inquiry with other individuals within Telerx or working for Telerx that are responsible for functions related to the subject of an inquiry. Except where required by law, Telerx cannot ensure a response to questions or comments regarding topics unrelated to this policy or Telerx’s privacy practices.
Telerx May Update This Policy
This policy was last updated in February, 2017.