Privacy Policy & Policy on Cookies

The ASHP Research and Education Foundation (“Foundation” “we,” “us,” or “our”) has created this Privacy Policy to demonstrate its firm commitment to privacy.  This Privacy Policy will help you understand how your Personally Identifiable Information (as that term is defined below) is collected on any website or mobile application owned and operated by the Foundation, including, but not limited to, ashpfoundation.org, and how that information may be shared.  This Privacy Policy also describes the choices available to you regarding the Foundation’s use of your Personally Identifiable Information and how you can access and update this information.  The following discloses the information gathering and dissemination practices for the Foundation.

YOUR USE OF ANY FOUNDATION WEBSITE OR ANY FOUNDATION MOBILE APPLICATION CONSTITUTES YOUR ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY.  If you do not agree to the terms of this Privacy Policy, you should not visit or use any Foundation website or Foundation mobile application.

Introduction
In this Privacy Policy we use the term “Personally Identifiable Information” to describe information that can be associated with an individual and can be used to identify that individual.  We do not consider Personally Identifiable Information to include information that has been anonymized or aggregated so that it does not identify an individual.  You represent that if you give us Personally Identifiable Information on behalf of someone else, the person providing the Personally Identifiable Information to you gave you consent to provide that person’s individual information to the Foundation.  If someone else gives us Personally Identifiable Information on your behalf, you represent that you gave that person consent to provide your Personally Identifiable Information to the Foundation.
This Privacy Policy applies when you:

  • Visit or utilize a website on which this Privacy Policy is posted;
  • Create a Foundation online user account (either through a Foundation website or through a Foundation mobile application);
  • Download any Foundation mobile application to your mobile device;
  • Otherwise interact with the Foundation online, offline, or through any Foundation mobile application.

Notification of Changes to Privacy Policy
The Foundation may update this Privacy Policy at any time to reflect changes to the Foundation’s privacy practices.  Users can find out about changes in this Privacy Policy by visiting this page.  Your continued use of any Foundation website or any Foundation mobile application (the “Foundation Platforms”) constitutes acceptance of any such changes.  We encourage you to periodically review this page for the latest information on the Foundation’s privacy practices.  This Privacy Policy was last revised in May 2018.  We also encourage users to read this Privacy Policy thoroughly and use it as a point of reference for the future.

Personally Identifiable Information
The Foundation Platforms collect Personally Identifiable Information from various locations. The Personally Identifiable Information collected includes:

  • Name;
  • Title;
  • Year of birth;
  • Home address;
  • Business address;
  • Educational information
  • Practice demographics;
  • Email address; and
  • Billing information such as debit or credit card number, expiration date, security code (if applicable), and billing address.

When you use any Foundation Platform, we may automatically record information such as browsing activity and data displayed or clicked on (such as UI elements, ads, and links), and we may collect other information, including, but not limited to, the type of device you use, browser type, operating system version, IP address, data and time of access, and device identifier. 
The Foundation uses Personally Identifiable Information to send orders, email news services, newsletters, and event announcements, and to request donations. The non-financial information we collect is sometimes shared with other organizations to help them contact consumers for marketing purposes.  Users may choose to decline receiving future mailings by following the instructions in the “Opting Out” section below.  Aggregated demographic information may also be compiled and shared, but will not identify the individual user.

Location Information
We may collect information about the location of your device, including GPS location, for purposes of enhancing or facilitating our services.  We may also use information about the location of the device you are using to help us understand how our Foundation Platforms and other services and functionality are being used and to deliver more relevant marketing.  You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.  Please note that your location may be derived from your WiFi, Bluetooth, and other device settings.  See your device settings for more information.

Cookies
The Foundation and our service providers and advertising partners use cookies and tracking technologies on Foundation Platforms. Cookies are small data files that are sent from a website’s server and are stored on your device’s hard drive to enable us to recognize repeat visitors, facilitate your use of the site, and to track access to and use of Foundation Platforms.  Foundation Platforms use both “session cookies” and “persistent cookies”.  A session cookie disappears after you close your browser.  A persistent cookie remains on your device’s hard drive after you close your browser and may be used by your browser on subsequent visits to Foundation Platforms.

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.  You may also change your cookie settings through preferences options in our products and/or services, where applicable.  If you elect to browse the website with the cookies option turned off, you may not be able to access restricted content and the shopping cart may not perform correctly.  For more details on the use of cookies in Foundation Platforms, please visit the Policy on Cookies.

Web Beacons
Our web pages contain electronic images known as web beacons (sometimes called single-pixel gifs), which are used along with cookies to compile aggregated statistics to analyze how our website is used and may be used in some of our emails to let us know which emails and links have been opened by recipients.  This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

Log Files
We may collect information to analyze traffic on Foundation Platforms.  Such information includes, but is not limited to, browser type, IP address, access time, and files accessed are collected in log files.  Aggregate information generated from the log files is sometimes shared with advertisers.

Links
Foundation Platforms may contain links to other third party websites. The Foundation is not responsible for the privacy practices or the content of other websites.  If you submit Personally Identifiable Information to those websites, your information is governed by those websites’ privacy statements.  Please carefully read the privacy statements of the websites to which we link, as their privacy practices may differ from those of the Foundation.

Survey Information
Personally Identifiable Information is optional in our online surveys and would be used only to contact a user for clarification purposes.  Demographic and profile data that are collected may be analyzed and shared with advertisers on an aggregate basis.

Email
Throughout Foundation Platforms, users are provided the opportunity to communicate with the Foundation via email.  We read every message and try to reply promptly to everyone.  This information is used to reply directly to your questions or comments. 

Opting Out
Our Foundation Platforms provide users the opportunity to opt out of receiving certain communications from the Foundation and any third parties at the point where the information is submitted. 
Choosing to opt out of emails currently means you will NOT receive ANY email from the Foundation.  Likewise, opting out of emails and mailings means you will receive no announcements about upcoming program offerings, events, meetings, trainings, announcements and promotions.
Users who do not want to receive mailings or emails from the Foundation can also contact the Foundation by the following means and request to be excluded:

Email: foundation@ashp.org

Postal mail:
ASHP Research and Education Foundation
4500 East-West Highway, Suite 900
Bethesda, Maryland 20814
Telephone: (301) 664-8612

Changing Information
Users have the ability to change information previously provided such as name, address, telephone, and e-mail address.  Please contact the Foundation by the following means to make or request the change:
Accessing Change of Address
Email: foundation@ashp.org
Telephone: (301) 664-8612

THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

The GDPR is a European regulation concerning the use and processing of personal information. We are committed to processing the information of European Union (EU) visitors to our sites in compliance with the GDPR upon its effectiveness on May 25, 2018.

The applicable legal basis for which we process your information includes the following:

  • We have a legitimate interest in communicating with you and managing our interactions with your regarding our products and services.
  • In specific circumstances, we may need to process your information to comply with an applicable law or regulation.  Where we process your information to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations.

We will use reasonable efforts to timely respond to any requests by you to exercise your rights under the GDPR:

  • You have the right to see and get a copy of information, including an electronic copy, that we have about you;  
  • You have the right to ask us to make any corrections to inaccurate or incomplete personal data we have about you;
  • You can also request that we erase your personal data when it is no longer needed for the purposes for which you provided it;  
  • You may ask us to restrict how we process your personal data to certain limited purposes where erasure is not possible;  
  • In certain circumstances you may be able to request that we send a copy of your personal data to a third party of your choosing;
  • You can object to processing of your personal information based on the Foundation’s legitimate interest (or those of a third party) to use this information 

To exercise any of these rights, please contact us at:

Email: foundation@ashp.org

Postal mail:
ASHP Research and Education Foundation
4500 East-West Highway, Suite 900
Bethesda, Maryland 20814
Telephone: (301) 664-8612

You also have the right to lodge a complaint with the supervisory authority where you believe that your rights have been violated. You may consult a list of data protection authorities.

We hold your information and use it as described in this Privacy Policy and will use reasonable measures to ensure that your personal information is only transferred to third parties who also maintain at least the standard of protection required under the GDPR.

Foundation Platforms are owned and operated in the United States. Your use of any Foundation Platform will result in the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.  If you are visiting this site from a country other than the United States, your information will cross an international boundary.  The level of protection for your information in the United States may not be the same as the level of protection in your country. 

Security
Maintaining the integrity of data collected on the Foundation’s websites is of utmost importance to the Foundation. Credit card information is transmitted in encrypted form. Personally Identifiable Information is stored behind password protection.  The Foundation has a prudent password rotation policy that is clearly communicated to all staff.  Routine backups are made and stored securely.
We follow generally accepted best practices to reasonably protect the information submitted to us, both during transmission and once we receive it.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, we cannot guarantee its absolute security.
We will retain your information for as long as your online user account is active or as needed to provide you services.  If you wish to cancel your online user account or request that we no longer use your information to provide you services contact us as set forth in the “Questions” section, below.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Children’s Online Privacy
Foundation Platforms are not intended to be used by anyone under the age of 13 and, as such, the Foundation does not knowingly collect Personally Identifiable Information from anyone under the age of 13.  If you are under the age of 13, please do not submit any Personally Identifiable Information to the Foundation or create an online user account.  If a parent or legal guardian becomes aware that his or her child under the age of 13 has provided us with Personally Identifiable Information without parental or legal guardian consent, the parent or legal guardian should contact us and we will delete such information from our files.

Questions
If you have any questions about this Privacy Policy, the Foundation’s privacy practices, or your use of any Foundation Platform, please contact us.

Policy on Cookies

The ASHP Research and Education Foundation (the “Foundation,” “we,” “us,” or “our”) and our service providers and advertising partners use cookies and tracking technologies on the Foundation’s websites and mobile applications (“Foundation Platforms”).  Cookies are small data files that are sent from a website’s server and are stored on a visitor’s device’s hard drive to enable us to recognize repeat visitors, facilitate your use of the site, and to track access to and use of Foundation Platforms.  Foundation Platforms use both “session cookies” and “persistent cookies”.  A session cookie disappears after you close your browser.  A persistent cookie remains on your device’s hard drive after you close your browser and may be used by your browser on subsequent visits to Foundation Platforms.

We collect cookies on Foundation Platforms:

  • for sign-in authentication;
  • to capture and collect demographic data that helps us track which other websites have linked visitors to our site;
  • to advertise what pages of our site are used by and are of interest to those visitors;
  • to link to information those visitors provide to the Foundation when they join, make a purchase, register for meeting or make a donation; and
  • to improve the functionality of Foundation Platforms and the experience for those who use our site.

We receive data that includes visitors’ IP addresses, browser types, date/time stamps, donations, and names and sign-up information. This information is anonymous and is used by the Foundation for internal purposes only - to deliver the most effective content to our visitors. The Foundation does not require that you accept cookies; however, some functionality on Foundation Platforms, including our may be disabled if you decline to accept cookies.  You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.  You also may change your cookie settings through preferences options in our products and/or services, where applicable. If you choose to e-mail us and provide personally identifiable information about yourself, we will use this information only to respond to your inquiry. We will not sell, rent or otherwise disclose that information to third parties unless such disclosure is necessary for the purposes set forth in this policy, by law or a policy or notice contained or associated with a specific Foundation product or service.

Analytics
Similar to many operators of websites, the Foundation works with third-party service providers to enhance and improve Foundation Platforms, products, and services.  These providers supply tools for traffic monitoring, interest-based advertising, surveys, social media advertising, and email marketing.  For example, ASHP uses Google Analytics and the DoubleClick cookies for this purpose.  The Foundation monitors site traffic and technical performance for research and development of new products and services, and to administer Foundation Platforms, improve our visitors’ experiences, evaluate site usage, provide site security, and provide localized content based on geographic location. We collect device identifiers, such as IP address, for this purpose.  Foundation Platform visitors may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or they may opt out of Google Analytics by visiting the Google Analytics opt-out page.  Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions.  Foundation Platforms containing other programs run by us or other third parties may contain information as to how cookies are used on those sites.

Most web browsers provide controls that allow you to block or delete cookies.  You can prevent the setting of such cookies by changing your settings within your browser.  Furthermore you can adjust your browser so that the browser asks you for permission before each cookie is dropped on your device.  Also you can delete all your cookies on your device within your browser.  You can find more information about cookies, browser settings and cookie deletion on http://www.allaboutcookies.org/.  Generally, you can also go to the Help section on your internet browser and see instructions for blocking or deleting cookies.

Please note that certain features that we use on our Foundation Platforms depend on cookies.  If you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.

Responding to Do Not Track Signals
Some browsers provide the ability to send a Do Not Track signal to websites.  Foundation Platforms do not respond to these signals or similar mechanisms.

Interest Based Advertising
The Foundation does not collect tracking information but uses third parties that belong to recognized industry digital advertising initiatives to track and/or deliver ads. These industry associations allow consumers to better control interest based ads.  We have listed some of these associations below and provided links to their site.  The Foundation and its service providers place web beacons, cookies, and other tracking technologies on our and other sites to track users by device identification.  Ads are then presented to visitors based on their online behaviors and their actual or presumed commercial interests as indicated by those online behaviors.  The service providers that the Foundation works with do not collect or access information that directly identifies you (such as your name or email address).

We also use email to send you marketing messages and to request donations.  The Foundation uses web beacons to collect data about what content you viewed in an email.  If you would like to opt-out of these types of emails, you can do so by clicking on the link provided in each marketing email we send, if applicable, or contacting us directly at:

Email: foundation@ashp.org

Postal mail:
ASHP Research and Education Foundation
4500 East-West Highway, Suite 900
Bethesda, Maryland 20814
Telephone: (301) 664-8612

Please also note that the Foundation or its advertising providers may use web beacons on its or third party websites to allow us to count users who have visited certain web pages and to generate statistics about how Foundation Platforms are used.  Web beacons, unlike cookies, cannot be declined.  However, setting your browser to decline cookies or prompt you for a response will keep most web beacons from tracking your activity.

Sharing Information with Advertising Providers
In certain countries, we work with advertising providers, such as Facebook, Twitter, LinkedIn and others, and receive audience based data (such as pixel traffic and conversion data) from them based on non-identifiable information such as IP addresses.  These providers may collect additional information from you, such as your IP address and information about your browser or operating system, may combine information about you with information from other companies and may place or recognize their own unique cookie on your browser.  These cookies may contain demographic or other data in de-identified form.  Cookies used by third party advertising technology providers and how these companies use the information gathered from the cookies will be governed by the respective company’s privacy policy.  To block or limit this activity, see the information below and the Foundation Privacy Policy.

Advertising Choices
You may opt out of receiving interest based advertising by visiting the following sites:

As some of the tracking data for interest based advertising is also used for other necessary purposes (such as analytics and fraud detection), opting out of interest based advertising does NOT stop that data from being collected.  You also will continue to receive non-interest based advertisements and may not necessarily see fewer ads.

May 2018

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