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SHP Privacy Policy

Updated 1/14/2020

If you are a California resident, please click here for more information about your specific privacy rights.

We at Strategic Healthcare Programs, LLC (“SHP”, “we,” “us,” or “our”) have created this Privacy Policy because we know that you value how the information and data you provide to us is used and shared. This Privacy Policy applies to: (i) the personal information we gather on our website at www.SHPdata.com website (the “site”); (ii) the way we use personal information internally; and (iii) our policy regarding sharing your personal information with others. Your visit to the site is also subject to our Terms of Use, which is located on the site.

We are committed to processing your information in accordance with all applicable data protection laws and data protection codes of conduct including the California Consumer Privacy Act ("CCPA"). We have implemented the practices set out in this Privacy Policy for our website, https://www.shpdata.com/ and dependent pages (the "Site"). We have instructed our website administrator to include information regarding these privacy practices anywhere on the Site where Personal Information is collected.

This policy addresses our privacy practices relating to our employees, job applicants, visitors to the Site and registered users of the Site. For purposes of this Privacy Policy, "Personal Information" means any information that, by itself or in combination with other information, identifies or can reasonably be used to identify an individual or household, such as name, email address, IP address, telephone number, address, billing information or date of birth. Personal Information does not include information that is anonymized.  The term “Processing” means any operation or set of operations which is performed on Personal Information, whether or not by automated means, such as collection, use, organization, storage, alteration or destruction, disclosure, or transfer.

We may revise any portion of the Site, including this Privacy Policy, from time to time to keep up with technical innovation, new types of site content, and for other reasons. All revisions to this Privacy Policy will be effective upon notice given by means of posting the revised Privacy Policy on this site, with a new effective date posted at the top. If the Privacy Policy changes in a way that materially affects how we handle personal information, we will not use the personal information we previously gathered in the manner described in the new policy without providing notice and/or obtaining your consent, as appropriate. Your continued usage of the site after any revision(s) to this Privacy Policy will constitute your acceptance of the revised Site Privacy Policy. We encourage you to refer to this Privacy Policy frequently, and to regularly check the effective date shown at the top.

Our Site may contain links to third-party websites, advertisers or services that are not owned or controlled by SHP. If you click on those links and provide personal information to those third-parties, be sure to read such third-party websites’ Privacy Policies. SHP is not responsible for how these websites operate or treat the personal information that you provide to them.

Declaration of Consent

By submitting Personal Information and other information to the Site, you consent to the Processing of such information in accordance with the terms of this Privacy Policy.

You may withdraw this consent at any time by filling out this contact form, calling us at (805) 963-9446, or by writing to Strategic Healthcare Programs, L.L.C., ATTN: Privacy Officer, 510 Castillo Street, Santa Barbara, CA. 93101.

Collecting Information

Generally, you may browse the Site without directly providing any Personal Information (though we may automatically collect certain non-sensitive information as described further below, such as IP Address and log information). However, we may ask that you provide information, including, without limitation, Personal Information, at various times and locations through the Site. For example, we collect personal information when you register for an account, or request a demo or product and service information. We also collect personal information when you fill out a form to contact us, to subscribe to email lists, or to access educational content. We may collect and store any Personal Information you input into the Site.

Protecting Personal Information

We take commercially reasonable steps to protect your Personal Information when you transmit it from your computer to the Site and to protect such information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them.

Personal Information We Collect

We may collect the following information about you:

  • Contact and account information, such as name, email address, telephone number, and physical address.
  • Employer information, such as company name, business address, phone number, email address, or other professional information.
  • Employment applicant information, such as name, email address, contact information, professional information, employment and education history, and characteristics of protected classifications under California or federal law (such as race or gender).
  • Technical information, such as IP address, browser type, device, operating system, and Internet Service Provider.
  • Activities on the Site such as pages and files you view, referring webpages, search queries you entered to reach the Site, links you click, and time and duration on the Site. Activities external to the Site such as clicks on links in email newsletters or ads.
  • Demographics information such as geolocation, gender, and age.
  • Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences

Ways We Collect Information

We may collect information about you in several ways, including:

  • Information you provide to us directly through the Site or third-party sites, such as when you fill out a form to receive educational material, register for a webinar, take a survey, subscribe to an email list, request information about our services, apply for a job, or to contact us.
  • Information you voluntarily provide to us via verbal or written communication such as speaking with sales representatives at trade shows or calling or emailing us.
  • Information collected or inferred from your use of the Site, such as information automatically collected from third-party vendors such as analytics or advertising partners, using cookies, beakons, pixel tags or other technologies,  when you participate with the Site.
  • Through the purchase of customer or prospect lists from third-party vendors.
  • Receipt of trade show attendee lists. 

How We Use Personal Information

We may combine information that we receive from the various sources described in this Privacy Policy with Personal Information and use or disclose it for the purposes identified below. We may use the information collected and provided, individually or in an aggregate form, in order to:

  • contact you about the Site;
  • notify you about important changes to the Site;
  • deliver what you request;
  • evaluate products or services we could offer to you;
  • monitor or improve use of the Site;
  • analyze and otherwise use data collected for any purpose including consulting, research and marketing;
  • customize any advertising and content you see on the Site;
  • provide specific information to you from us and/or our affiliates;
  • send you promotional material from us and/or our affiliates;
  • show you ads on third-party sites, this may include personalized ads based upon your activities; and
  • review and assess your qualifications for employment based on an application you submitted.

Log Files

We maintain a log file of all actions that are initiated or facilitated using the Site, to capture, record and store data concerning the transaction. Access to this data is restricted to those who administer our network and public website, except that we may use and disclose this information to third parties in response to legal process or law enforcement inquiries, abuse of our website, or violation of any applicable Terms of Use or contractual provision you may have with us.

Email Communications

You should know that e-mail is not necessarily secure against all forms of interception. If your communication includes sensitive information about you or your company and you would prefer not to transmit this information in this fashion, please contact us by post or telephone rather than e-mail.

You may opt-out of receiving promotional or marketing emails at any time by notifying us as a reply to any unwanted e-mail, by using the unsubscribe function in our communications, through this contact form, calling us at (805) 963-9446, or by writing to us at Strategic Healthcare Programs, L.L.C, ATTN: Privacy Officer, 510 Castillo Street, Santa Barbara, CA. 93101. Requests to unsubscribe from SHP’s e-mails may take 5 business days to process. You may also opt-out of receiving postal mail or telemarketing communication using the contact methods above.

Cookies

A cookie is an element of data contained in a text file, that a website asks your browser to store on your device. Some cookies are set for one session only and disappear when you close your browser, some are persistent and remain on your browser for subsequent visits. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. The Site uses both first party cookies, which are set by us, and third-party cookies which are set by services with external domains, and are subject to the privacy policy of those external services.

There are 4 main types of cookies the Site uses:

Strictly necessary cookies
These cookies are set by us and are essential for the website to function.These are usually only set in response to actions made by you which amount to a request for services, such as filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Functional cookies.
These cookies enable the Site to provide enhanced functionality and personalization. The most common use is to remember preferences or login information. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Performance cookies
Also known as 'analytical' cookies, these cookies collect aggregate information on how our visitors use the Site so that we can measure and improve performance of the Site. Performance cookies track information such as, which parts of the website have been visited and for how long, identify repeat visits, how people found the Site, what links have been clicked, and if any errors have occurred. We may use this data to help optimize the Site and make it easier for you to navigate and find popular content. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not be able to monitor and improve usability of the Site.

Targeting cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they don’t track the user. Because standard “Do Not Track” technology is not yet finalized, and not all browsers support DNT, the Site’s information collection and disclosure practices, and the choices that it provides to consumers, may continue to operate as described in this Privacy Policy, whether or not a DNT signal is received. We do not honor “do not track” signals from website browsers at this time. For more information about DNT, see http://donottrack.us/.

Personal Information Retention

Personal Information will be stored for as long as the information is required to fulfill our legitimate business needs or the purposes for which the Personal Information was collected, or for such period as is required by law.

Disclosing Personal Information to Third Parties

We do not sell Personal Information about you in exchange for any monetary consideration. However, we do share your information for other purposes that could be deemed a “sale” as defined by the CCPA. We may share your Personal Information with the categories of recipients described below:

  • SHP’s divisions, holding companies, subsidiaries, and affiliates.
  • Third-party service providers or other entities that are involved in the operation of the Site, help us provide you with our products and services, and that otherwise support our relationship with you (such as shipping or direct mailing organizations).  In such cases, our agreements with these third parties do not permit them to use or disclose Personal Information for purposes other than fulfilling those services.
  • Law enforcement, government agencies, or other regulators to comply with law or legal requirements, to enforce our agreements, and to protect our rights and the property or safety of SHP, our users, or third parties.
  • Transactional parties if we, or some or all of our assets, are acquired by another entity, including through a sale or in connection with a bankruptcy.
  • Your employer or coworkers if you receive our products or services in connection with your employment.
  • Third-party ad servers and ad platforms.

We may also share Personal Information that has been anonymized or aggregated with third parties for any purpose.

Third-Party Sites

The Site may contain links to other third-party  sites. When you click on one of these links you are visiting a website operated by someone other than us and the operator of that website may have a different privacy policy. We are not responsible for their individual privacy practices, so we encourage you to investigate the privacy policies of such third-party  operators.

The Site includes Social Media Features, such as the Facebook Like button and Share this button. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third-party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

Some of our pages utilize framing techniques to serve content to/from third-party sites while preserving the look and feel of our website. Please be aware that you are providing your personal information to these third parties and not to the Site.

Third-Party Analytics Partners

We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google's practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Third-Party Advertising Partners

We may work with third-party advertisers such as Google Ads, Facebook, and LinkedIn, that use cookies and similar technologies to show you ads on network sites that we think may interest you. To provide this 'interest-based advertising', the parties combine non-personal data about your online activities acquired over time, which help cater advertising that we deliver to you.  Such tools are created and managed by parties outside our control. As such, we are not responsible for what information is actually captured by such third parties or how such third parties use and protect that information. Please refer to their respective privacy policies for more information. We use data from these third parties to measure the efficiency of our ads.

Many third-party advertisers and ad networks are members of the Network Advertising Initiative (NAI) and follow the Digital Advertising Alliance (DAA) Self-Regulatory Principles for Online Behavioral Advertising. You can opt out of receiving these personalized ads by visiting the opt-out pages on the NAI websites and DAA websites. Opting out may make the ads you see across the internet less relevant to you.

You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager. You may opt-out of Facebook ads by visiting the Facebook Ad Preferences Manager. You may opt-out of receiving LinkedIn by visiting the LinkedIn Ad Preferences Manager

Individual Rights of California Residents

Commencing on January 1, 2020, if you are a resident of California, you may have additional rights as required by the California Consumer Privacy Act (CCPA).

With certain legal exceptions and limitations, you may exercise the following rights. We will not discriminate against you in any manner prohibited by applicable law for exercising these rights.

  • Access. You have the right to request information about the categories and specific Personal Information we have collected about you, the sources of Personal Information, the purpose for collecting the Personal Information, the categories of third parties to whom we have sold your Personal Information or shared it for a business purpose and the types of Personal Information sold or shared. You may also request information about any third parties with whom we have shared your Personal Information for those third parties’ direct marketing purposes.  You may request this information at the contact information above.
  • Deletion. You may request that we delete your Personal Information.
  • Correction. You have the right to ask us to correct your Personal Information 
  • Opt-out of sale of information. You have the right to opt out of the sale of your personal information as defined in the CCPA

You may exercise these rights by contacting us through this contact form, calling us at (805) 963-9446, or writing to us at Strategic Healthcare Programs, L.L.C ATTN: Privacy Officer, 510 Castillo Street, Santa Barbara, CA. 93101.  We will respond to any such requests within 30 days of receipt.

Children

Our website is not intended for children under 13 years of age. No one under age 13 may provide any information to us through the Site. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not access, use, or provide any information on the Site or on or through any of its features. If we learn we have collected or received Personal Information from a child under 13 without parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us by filling out this contact form, calling us at (805) 963-9446, or writing to us Strategic Healthcare Programs, L.L.C, ATTN: Privacy Officer, 510 Castillo Street, Santa Barbara, CA. 93101.

Data Breaches

While every effort and measure is taken to reduce the risk of data breaches, we have dedicated controls and procedures in place for such situations, along with the procedures that are required to make notifications to the relevant Supervisory Authority and data subjects (where applicable).

Other terms and conditions

In addition to this Privacy Policy, your use of the site is governed by the site’s Terms of Use which are available on the site. Please read them carefully. These Terms of Use are fully incorporated and made a part of this Privacy Policy by this reference, and they include terms governing choice of law, and other matters that are of importance to the construction and application of this Privacy Policy.

Comments and Questions

We welcome comments and questions regarding this Privacy Policy. Any such questions should be directed via this contact form or calling us at (805) 963-9446. Additionally, you may make your request in writing to Strategic Healthcare Programs, L.L.C, ATTN: Privacy Officer, 510 Castillo Street, Santa Barbara, CA. 93101.