Privacy Policy

Last Updated: June 20, 2017

PRIVACY NOTICE

Welcome. The information below explains how Zitter Health Insights, Inc. (the “Company”) collects, uses, and discloses information collected by us through our market research surveys, as well as our use and disclosure of information provided to us by third-parties or through your use of our website located at www.zitter.com (the “Website”). Please take a moment to read the following privacy notice (this “Privacy Notice”) to learn how we handle your personal information.

The Company (“we” or “us” or “our”) understands that individuals with whom we conduct business and who share their information with us value their privacy. We are committed to taking reasonable steps to both protect your privacy online and manage your information responsibly.  This Privacy Notice is intended to notify you of our online privacy practices, the type of information that may be collected and stored, how the information is used, with whom the information may be shared, what choices are available to you regarding the collection, use and distribution of the information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, and who to contact with questions or concerns.

This Privacy Notice does not apply to other companies, or third-party vendors who provide services to us, or persons who might be listed as third-party contacts on the Website, each of which may be governed by their own privacy policies.  This Privacy Notice also does not apply to websites you may link to through your use of the Website or our services.  The Company is not responsible for the privacy policies or notices on any other websites you might visit, whether or not linked to or referenced by the Website.  Therefore, we recommend that you review the privacy policy or notice on each website you visit.

By using or accessing the Website, engaging in survey research with us and/or by contacting us or providing any information (personal or otherwise), you consent to the collection, transfer, storage, disclosure and use of information by us in accordance with this Privacy Notice.  If we decide to change our Privacy Notice, we will post those changes on this page.

Why We Collect Information:

We collect personal information from you because it helps us deliver our products and services, and design and deliver meaningful insights/feedback to our clients.

How We Collect Information:

We collect information in two primary ways:

You Give Us Information

We collect information from you when you submit it to use through the Website or otherwise submit it to us through participation in our surveys or through an alternative collection mechanism (e.g., phone survey or other third-party website or mechanism).

Please do not submit any sensitive personal information or data to us, including but not limited to your: (i) racial or ethnic origin; (ii) political, philosophical or religious beliefs, including membership in a political party or trade union; (iii) physical or mental health, biometric details or genetic makeup; or (iv) sexual orientation or preferences. If any such information is submitted to us, it is at your own risk.

We Collect Information Automatically

We automatically collect certain types of information when you visit our Website. For example, we automatically collect various types of technical information when you use our Website as otherwise described in this Privacy Notice.

We Collect Information from Other Sources: We may obtain information about you from outside sources.  For example, we may obtain commercially available information about you from third parties or purchase e-mail lists from third parties for advertising and marketing purposes or fraud detection/prevention.   We may also receive information from third-parties who provide services for us through web-beacons and other technologies as otherwise discussed in this Privacy Notice.

What Information We Collect:

We may collect, store and use the following kinds of personal and or sensitive data:

Managed Care Advisors: Information you provide to us directly or via third-parties, including but not limited to your email address, position/job title and information regarding your professional experience in connection with pharmacies, physicians, biopharmaceutical companies and other medical providers and covered entities;
Patients: Information you provide to us directly or via third-parties, including but not limited to your email address, medical condition, medications and information regarding your interactions with pharmacies, physicians, and other medical providers and covered entities;
Information collected through any market research surveys you agree to participate in, and other information that you otherwise provide to us such as for the purpose of data collection for the designated research you consent to participating in.
We may supplement information that you provide with information received from third parties or other organizations to create segmentations. We use your demographic and profile data to build these segments. This segment data is used to enhance your survey experience or for data analysis purposes. We share this data with trusted third parties on an anonymous summary or an aggregated and de-identified group basis.

General Browsing:

Even if you do not submit personal information through the Website, we gather navigational information about where visitors go on or through the Website, what materials or advertisements or links they “click” or access, and information about the technical efficiencies of our Website and services (i.e., time to connect to the Website, time to download pages, etc.). This information allows us to see which areas of our Website are most visited and helps us better understand the user experience. This information also helps us improve the quality of the Website by recognizing and delivering more of the features, areas, and services our visitors prefer. In this process of gathering information, we may collect personally identifiable and non-personally identifiable information (for example, domain type, browser type and version, service provider and IP address, referring/exit pages, operating system, date/time stamp, and click-stream data). We may also create and use electronic records to compile statistics about how our visitors collectively interact with our Website.  We may also supplement this information with information from publicly available or commercial databases.

Mobile Browsing:

If you are accessing the Website via a mobile device, information about your use of the Website, as well as your mobile device type, carrier and location, may be communicated to us, and such information may be shared with your mobile carrier or access provider.

Use of Cookies:

Cookies are bits of electronic information that a website may transfer to a visitor’s computer to identify specific information about the visitor’s visits to the website. The Website uses a browser feature known as a cookie, which assigns a unique identification to your computer. Cookies are typically stored on your computer’s hard drive and are used to help track clicks as you go through the pages within our Website. We may also use cookies to tell us whether you have previously visited the Website. We also use cookies which may be set by third-parties with whom we have entered into agreements which may enable us to obtain analytics information about the use of our Website. You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies which may have been placed onto your computer. Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your computer that are not removed through normal browser management tools. We will not use FLASH cookies in a manner inconsistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service.

Use of Web Beacons, Clear-GIFs, Pixel Tags and JavaScript:

We also may use “web beacons” (also called “action pixels,” “pixel tags” or “clear gifs”) and/or JavaScript plug-ins, placed on our Website and in our emails to you. These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message which are used for such things as recording webpages and advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online behavior and measure the effectiveness of our website and our marketing. We also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these devices on the Website and/or in emails to use information obtained from them such as pages viewed, items purchased, emails opened and items upon which you may click in emails. These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you.

Server Logs:

We may use web server logs.  A web “server log” is a record of activity created by a computer that delivers certain webpages to your browser. Certain activities that you perform on our Website may record information in server logs. For example, if you enter a search term into a search box located on the Website, the server log may record the search term, the link you clicked on to bring you to our Website and/or information about your browser, such as your IP address and the cookies set on your browser.

Search Queries on Our Website:

We may provide you with options to search for information on the Website. If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.

Surveys:

From time to time, the Company may engage your expertise/professional knowledge by requesting you to participate in data collection or market research surveys to better inform our clients and conduct market analytics. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether to disclose any of your personal information. Information requested may include contact information, which may be used to provide you with financial remuneration for participation (such as email address and phone number), demographic information (such as postal code, age level, gender, etc.) and other personal information pertaining to your role and responsibilities in a healthcare organization. The aggregate, non-personally identifiable information collected from all survey respondents may be shared with third-parties (clients) who sponsor such surveys. If your information gathered via a survey will be used in a manner different from that described in this Privacy Notice, such use will be detailed in the survey instructions.

The Company will use reasonable efforts to protect your personal information and responses from disclosure other than as set forth herein. In this role, you understand and allow that your responses will be associated with your respective parent organization but respective name or title will never intentionally be made available to research sponsors. To protect advisor anonymity, at no time will a query be performed which would give both title and organization name to a sponsor. Only queries aggregated by organization or aggregated by title will be performed. As part of the client’s engagement, we endeavor to have each client agree to not share any information from this survey outside of its organization and to never refer to, copy, and/or distribute any information from this survey.  However, the Company cannot be, and is not, responsible for its clients’ compliance with any contractual or legal obligations; therefore, the Company does not guarantee same.  However, the Company will use reasonable efforts to obtain such compliance.

By agreeing to participate in survey research with the Company, you further agree to not share “Confidential Information” that may be shared with you as part of the survey. Confidential Information as used herein means (a) information with respect to any of the Company’s or the Company’s clients’ existing or contemplated products, marketing plans, processes, techniques or know-how, sales data or any information or data developed pursuant to the performance of the consulting services contemplated hereunder, (b) information transmitted in writing or other tangible form and clearly marked “Confidential,” or (c) information which is promptly reduced to writing and clearly marked as “Confidential” if first transmitted orally.  Your confidentiality obligations shall extend for five (5) years from the date of disclosure of such Confidential Information to you.  However, your confidentiality obligation shall not apply to such Confidential Information which is or which subsequently may become within the knowledge of the general public or which may be demonstrated to have been known to you at the time of receipt thereof or at a later date from a source which was under no obligation to maintain as confidential.

As a participant of survey research with the Company, you, the advisor, agree to notify the Company immediately for any change in your position, responsibilities, and/or organization. The Company will determine if change is appropriate to survey data collection and we will terminate your participation as deemed appropriate. The Company shall have the right to terminate survey research participation for any reason upon written notice to you.

Applicability of HIPAA to the PHI Collected by the Company

The Company uses information that it receives for research and analysis, which may be shared with the Company’s partners and customers pursuant to appropriate agreements and applicable law. In addition, the Company may receive “PHI” from “Covered Entities” to create aggregate or de-identified information. Please note that HIPAA will not apply to any “Individually Identifiable Health Information” that you submit to us, unless such information is PHI and is submitted to us by a Covered Entity, or we administer a survey on a Covered Entity’s behalf.  Notwithstanding, the Company will make reasonable efforts to ensure the privacy and security of all Individually Identifiable Health Information of users of the Website which is created, received, maintained, or transmitted by the Company. Accordingly, Company will endeavor to use appropriate administrative, physical and technical safeguards to protect the confidentiality, integrity, and availability of all such Individually Identifiable Health Information under our care and control.

Definitions

As used in this Privacy Notice, the following terms are defined as follows:

“Business Associate” means a person or entity who performs functions or activities on behalf of, or certain services for, a Covered Entity that involve the use or disclosure of Protected Health Information, and as further defined at 45 C.F.R. § 160.103.

“Covered Entity” means either (1) a health plan, (2) a health care clearinghouse, or (3) health care providers who electronically transmit any health information in connection with transactions for which the U.S. Department of Health and Human Services has adopted standards, and as further defined at 45 C.F.R. § 160.103.

“HIPAA” means the Health Insurance Portability and Accountability Act of 1996, as amended, as well as its implementing regulations.

“Individually Identifiable Health Information” is any information about the health status, provision of health care, or payment for health care that can be linked to a specific identifiable individual.

“Protected Health Information” or “PHI” means Individually Identifiable Health Information which is received, transmitted or maintained by a Covered Entity.

If HIPAA Applies To Your PHI

If your PHI is governed by HIPAA, you may have certain rights in and to the information you provide, including the right to request amendments to your PHI, review an accounting of the disclosures of your PHI, and to have that PHI made available to you. Please see the applicable Covered Entity’s notice of privacy practices for more information regarding the privacy and security of your PHI.

If HIPAA Does Not Apply To Your PHI

If your PHI is not governed by HIPAA (i.e., if it is submitted to us independently of a Covered Entity), the Company will still take reasonable efforts to ensure the privacy and security of Individually Identifiable Health Information we receive from you, and we will only intentionally use such Individually Identifiable Health Information in de-identified and aggregate form.

How We Use the Information We Collect:

We do not sell data we collect in any individualized form – period.

We use the information we collect in a variety of ways.  Generally, using all of the above mentioned, and similar type tools, we may collect, aggregate, and use information from or about you such as data about the type of browser and operating system used, your geographical location, which webpages you view, the time and duration of your visits to our site, the search queries you may use on this site and any other submissions you may make, whether you clicked on any items or links on the site, whether you have clicked on any links in any emails sent from us, or third-parties on our behalf, whether you have chosen to opt-out of certain services or information sharing, and whether you have viewed or ordered certain products or services.

We use the information we collect internally in our business for many business purposes, such as to: (i) provide the Website and conduct surveys; (ii) analyze trends and conduct research, including providing aggregate data and trends to our customers; (iii) provide support and respond to questions from users and Website visitors; (iv) improve our Website, products or services; (v) learn about users’ needs; (vi) contact users for research, informational, and marketing purposes, including customizing our Website for you based upon your information and browsing habits; (vii) track traffic patterns and site usage; (viii) provide customer service and technical support; (ix) correlate information with other commercially available information to identify demographics and preferences to assist us in our research and marketing efforts; (x) provide specific relevant marketing, promotional, or other information to you; (xi) address information security and/or privacy practices, network functioning, engineering, and troubleshooting issues; (xii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiii) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website, our partners or customers, or the public; and (xiv) process or engage in a sale of all or part of our business or our assets, or if we go through a reorganization or merger.

We may also share personally identifiable information and non-personally identifiable information externally with our affiliates and business partners, as well as with other third-party service providers who help us provide operational services for the site and our business, which might include, but is not necessarily limited to: business entities that provide e-mail address management and communication contact services, retargeting services, network equipment and application management providers and hosting entities, credit and debit card payment gateways and processors and the issuing and acquiring banks involved in the funds settlement procedures necessary to charge your cards or financial accounts, entities which obtain information such as demographic information which might be aggregated with information we have about you, entities that allow us to personally identify visitors to the website, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Notice.

We may also use your personally identifiable information to contact you in ways other than e-mail or regular mail, such as via telephone contact or facsimile. All use of personally identifiable information will be as permitted by applicable law.

Business Transfers

If Company or substantially all of its assets were acquired, or in the unlikely event that Company goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Company may continue to use your personal information as set forth in this Privacy Notice.

Your Choices about the Information We Collect

The Company retains your information for if it deems appropriate based upon its business, contractual and legal needs and requirements.  If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us.  If you do not wish to receive emails about market research survey opportunities from us, please contact us to opt-out.  Contact information set forth below to opt-out is below.  If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be.  Please note that while we will never share Personally Identifiable Health Information with our partners, de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct any opt-out request (specifying explicitly what you seek to opt out of, and including your name, address and e-mail address) to the following contacts, including the phrase “OPT-OUT REQUEST” in ALL CAPS in the subject line:

Email Address:

contact@zitter.com

Postal Address:

Zitter Health Insights

290 W. Mt. Pleasant Avenue, Suite 2210

Livingston, NJ  07039

Your California Privacy Rights

We collect various types of personal information about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.

If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below with the phrase “CALIFORNIA RIGHTS” in ALL CAPS in the subject line. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third Party Direct Marketing Opt-Out Form so you may request that your personal information not be disclosed to third parties for their direct marketing purposes.

Email Address:

contact@zitter.com

Postal Address:

Zitter Health Insights

290 W. Mt. Pleasant Avenue, Suite 2210

Livingston, NJ  07039

 

Privacy of Children Who Visit the Website

We recognize the importance of children’s safety and privacy. The Website is not designed to attract children, and our services are not intended for use by any children under the age of 13. We do not request, or knowingly collect, any personally identifiable information from children under the age of 13. If you have reason to believe that we have collected information pertaining to children under the age of 13 please contact us at contact@zitter.com .

Visitors to the Website Outside of the United States

If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Website will be created on servers located in the United States, and all information you provide will be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be as those in your country.  By using this Website and/or submitting information to us, you specifically consent to the transfer of your information to the United States to the facilities and servers we use, and to those with whom we may share your information.

Updating Personal Information

We prefer to keep your personal information accurate and up-to-date. If you would like to change your contact information, please update your profile or send an email to contact@zitter.com.

Links

For your convenience, the Website may contain links to other websites.  We are not responsible for the privacy practices, advertising, products, or the content of such other websites. None of the links should be deemed to imply that we endorse or have any affiliation with the links.

Security

We believe in providing a safe and secure experience for all of our online visitors and survey respondents. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information, and to protect you against the criminal misuse of that information.

While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure.  No security measures are perfect or impenetrable.  We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the Website will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

Questions / Changes in Notice

If you have questions or concerns with respect to our Privacy Notice, you may contact us at contact@zitter.com. We may elect to change or amend our Privacy Notice; in such event, we will post the notice changes in our Privacy Notice on the Website.