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HCP Navigator
Privacy Policy

Effective Date: September 6, 2017
Last Updated: December 4, 2018 

Introduction
Thank you for using HCP Navigator, LLC (collectively referred to herein as “HCP Navigator”, “we”, “our” or “us”). HCP Navigator has adopted this Privacy Policy which governs the collection and use of personal information collected through our corporate website, www.HCPNavigator.com (the “Site”) and personal information we received from our customers through their use of our platform and services (the “HCP Navigator Platform”). Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; and (5) the choices we offer, including how to access and update information.

This Privacy Policy is organized into two sections:

  1. The first section applies to information we collect through the Site.
  2. The second section applies to the information we collect through our platform and services (the “HCP Navigator Platforms”).

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@HCPNavigator.com.

When this Privacy Policy Applies
Our Privacy Policy applies to all of the services offered by HCP Navigator and its affiliates, and services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms of Use
By accessing or using the Sites in any manner, you also agree to be bound by HCP Navigator’s Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites and Services.

Section 1: Data Collection via the Site
By using the Site, or by interacting with us through Third Party Sources, you consent to the collection, use and disclosure of information by HCP Navigator as specified in this Section 1.

Information We Collect
The Services comprise a platform through which you can access data specific to your selected Service. In using the platform, you may complete forms and provide us with personal information, such as when you:

  • Request a demo;
  • Access or use the Site and/or Services; and
  • Communicate with HCP Navigator.

We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, address, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

  1. Information You Give to Us

You may choose to provide us with Personal Information about yourself, including your first and last name, email address, company name, title, phone number, and state by completing forms on our platform. You may also provide us with Personal Information about yourself when you report a problem or have a question about our Services.

The Sites offer interactive and social features that permit you to submit content and communicate with other users. You may provide Personal Information to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other users.

Please note that if you do not provide us with Personal Information, your ability to use certain aspects of our products and services may be limited.

  1. Information We Obtain from Your Use of Our Site

When you use our services, either through your internet browser or the platform, we collect certain information automatically, such as your operating system version, browser type, and internet service provider. When you use our Services, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; MAC address; and cookies that uniquely identify your browser.  We may also collect and process information about your actual location, including general information (zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the platform or specific features of the platform).  The information we collect automatically is statistical data and may or may not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties.

  1. Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit or use our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google, LinkedIn, SalesFusion, Pardot and similar partners. We may use this technology to deliver or help our Partners deliver certain advertising through mobile applications and browsers based on information associated with your mobile device.  If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the “Your Ad Choices” section below.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

In some circumstances, we may work with third parties to provide services on our Sites. For example, we use analytics services supported by third party companies who generate analytics cookies on our behalf. We may not have access to these cookies, although we may use statistical information arising from the cookies provided by these third parties to customize content and for the other purposes described above. These companies may also transfer this information to other parties where required to do so by law, or where such other parties process the information on their behalf.

Web Beacons. Pages of our Services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

Mobile Device Identifiers and SDKs. A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services or analytics to be performed.

How We Use Information We Collect
We use your personal information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

  1. To present, operate or improve the Site, including analysis of Site activity;
  2. To provide you with Services and Products;
  3. To improve our Services and Products;
  4. To maintain your profile and make it available to recruiters through our products and services as described below in “Information We Share.”
  5. To supplement your profile with publicly available information.
  6. To maintain a record of the jobs you view or apply to on our Sites.
  7. To inform you of relevant job postings that may be of interest to you based on your interests as expressed previously through your job search behavior and preferences.
  8. Provide administrative notices or communications applicable to your use of the Sites.
  9. To manage your participation in our events and other promotions, where you have signed up for such events and promotions.
  10. To authorize access to our Sites and Services;
  11. To analyze trends and statistics regarding visitors’ use of the Site;
  12. To respond to technical problems;
  13. To respond to, process and deliver your communications, requests, surveys, or contest entries;
  14. To contact you to request feedback about your experience with our products and services or learn about your demographics, preferences or interests;
  15. To communicate with you about new contests, promotions or rewards, upcoming events, trade shows or conferences, changes to the Site or our products or services, or other news about products and services (whether offered by HCP Navigator or our partners);
  16. To process job applications;
  17. To customize or personalize your online experience, for example to pre-populate forms, or to display or provide you with relevant content, advertising or communications;
  18. To improve our customer service;
  19. To comply with all applicable legal requirements;
  20. To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users; or
  21. To otherwise fulfill the purpose for which the information was provided.

We use the information we collect from our Sites to provide, maintain, improve and optimize them, to develop new services, and to protect our Company and our users.

We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. We may use your Personal Information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it.  We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Information We Share
We share Personal Information with companies, organizations and individuals outside of HCP Navigator in the following circumstances:

  • With your consent. We may share Personal Information with companies, organizations or individuals outside of HCP Navigator when we have your consent to do so.
  • Recruiters and Enterprise Customers. When you create a profile or apply for a job with a company through the Sites, the information supplied by you or shared through HCP Navigator products and services may become part of a recruiter or enterprise customer’s database. Similarly, if your HCP Navigator profile is downloaded by a recruiter or enterprise customer, your information may become a part of their database.  In these instances, the use of such information by the recruiter or enterprise customer will be subject to the privacy policy of that company, and we are not responsible for that company’s use of your information.
  • For external processing or service provision. We provide Personal Information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include payment processors, our subsidiaries, affiliates and marketing partners, and an email service provider to send out emails on our behalf, CV and resume parsing software, and similar partners. It is our policy to only share Personal Information with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.  Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information.  Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites.
  • For Legal Reasons.We will share Personal Information with companies, organizations or individuals outside of HCP Navigator if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
    • meet any applicable law, regulation, legal process or enforceable governmental request.
    • enforce applicable Terms of Service, including investigation of potential violations.
    • detect, prevent, or otherwise address fraud, security or technical issues.
    • protect against harm to the rights, property or safety of HCP Navigator, our users or the public as required or permitted by law.

We attempt to notify users about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

  • Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Information about our users is often a transferred business asset. In the event that HCP Navigator itself or substantially all of our assets are acquired, Personal Information about our users may be one of the transferred assets.
  • Non-Personal and Aggregate Site Use Information.We may share non-personal information (including, but not limited to, order and delivery details but not including payment card information) and aggregate, anonymized, or de-identified Personal Information with any third party, without restriction, including through the use of cookies and other automated technologies, in order to promote or describe use of the Sites, for research, marketing, advertising, or similar purposes.

Your Choices and Accessing, Updating or Deleting Your Personal Information
Whenever you use our Services, we aim to provide you with choices about how we use your Personal Information. We also aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you or you may update or correct inaccuracies in that information through your account or by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

  • Changing or Deleting Your Information

You may update or correct information about yourself by emailing us at privacy@HCPNavigator.com.  If you completely delete all such information, then your account may become deactivated.  We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

Wemay contact you to request that you update your Personal Information on a regular basis to ensure its integrity for the purposes of ongoing data management.

  • Our Opt-in/Opt-out Policy

By providing an email address on the HCP NavigatorSites, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to provide you with information about ourServices and similar information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information.

We currently provide the following opt-out opportunities:

1.     At any time, you can follow a link provided in offers, newsletters or other email messages (except for order confirmation or service notice emails) received from us to unsubscribe from the service.

2.     At any time, you can contact us through privacy@HCPNavigator.comor the address provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Information.

Notwithstanding anything else in this Privacy Policy, please note that wealways reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

  • Your Ad Choices

As described above, we or third party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance(the “DAA”) at the DAA consumer choice service. HCP Navigator is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.

The tools provided at the DAA opt-out pageand the NAI opt-out pageare provided by third parties, not HCP Navigator. HCP Navigator does not control or operate these tools or the choices that advertisers and others provide through these tools.

Third Party Links
The Sites may contain links to webpages operated by parties other than HCP Navigator. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the user to take precautions to ensure that whatever links the user selects or software the user downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the user will be subject to upon linking to the third party’s website. HCP Navigator strongly recommends that each user review the third party’s terms and policies.

International Transfer
We may, directly or indirectly through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy. Specifically, the information and Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction. It may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy. By submitting your information and Personal Information using the Sites, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Information we collect on the Sites.

How We Protect Personal Information

HCP Navigator maintains administrative, technical and physical safeguards designed to protect the user’s Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.

If HCP Navigator collects account information for payment or credit, HCP Navigator will use the information only to complete the task for which the account information was offered.

Children
The Sites are not intended for use by children.  We do not intentionally gather Personal Information about visitors who are under the age of 13. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13, please contact us at privacy@HCPNavigator.com. If we learn that we have inadvertently collected the Personal Information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Direct Marketing and “Do Not Track” Signals
HCP Navigator does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of personal information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your personal information with third parties for marketing purposes at any time by submitting a request to privacy@HCPNavigator.com. California users may request further information about our compliance with this law by contacting us at privacy@HCPNavigator.comor by writing to us at the address listed in the “How to Contact Us” section.

Section 2: The HCP Navigator Platforms
HCP Navigator customers (“Clients”) engage us to deliver job candidate databases and digital marketing tools, including job candidate email marketing services. The HCP Navigator, Recruiting Management System, Practice Alert, HealthcareJobFinder, TRM, TrackerPlus, Nurses Alert, DDS Alert, Allied Health Alert and Candidate Email Marketing(collectively, the “HCP Navigator Platforms”) are platforms our customers use to manage their provider relationships and other digital marketing tools. Client Information, Job Candidate Information, Information about our Client’s Contacts and Archival Information (each defined below) are governed by this Privacy Policy, the HCP Navigator Terms of Use and any other services agreements between HCP Navigator and the applicable Client. The HCP Navigator Platform collects the following information:

  • Client Information. We collect information about individuals within our Client’s organization (“Client Information”). Client Information may include information related to the Client’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Client Information to support the Client account, maintain our business relationship with the Client, respond to Client inquiries, or perform accounting functions. Clients may update personal information and password by logging into the HCP Navigator Platform and updating their account. Clients may contact HCP Navigator support in order to delete their personal data. In some cases, we may not be able to delete Client Information, and in such cases we will tell you why.
  • Job Candidate Information. We collect information about job candidates. Information about job candidates may include Personal Information provided directly by the candidate(s), publically available data about job candidates from third party sites and sources, demographic information, including occupation, education, experience and similar data, job search behavior and preferences, and other details that may be included in the information provided to us by third parties.
  • Information about our Client’s Contacts. We collect information about any contacts, such as vendors, practice groups, and others, that may be uploaded into the HCP Navigator Platform for Candidate Email Marketing (“Information about our Client’s Contacts”). Information about our Client’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Client’s Contacts for the purposes of marketing to such contacts. Clients may update or delete Information about their contacts in the HCP Navigator Platform. Clients may also contact HCP Navigator support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.
  • Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our Clients. This information may include emails, texts, websites, social media messages or posts, and other forms of data or electronic communications (“Archival Information”). Archival Information includes data about our Clients and the third parties they correspond with. We do not control or monitor the information our Clients collect and store through our services, or their privacy practices or policies. It is our Client’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Client’s communications and use of our services. Our Client’s privacy policies or practices apply to Archival Information, the purposes for which the Client collects Archival Information, how the Client may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Client in order to correct, amend, or delete their information, or to opt out of any collection, uses or disclosure of their information by our Client.
  • Automatically Collected Information. We collect information automatically about how our Clients use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs or other tracking technologies. We collect this information in order to monitor, support and improve our services or to provide Clients with certain customized features. We may use Automatically Collected Information to tell us how our Clients use our services, to improve our services or develop new products, services or features. We may combine this information with other information we collect.

We treat Client Information, Job Candidate Information, Information about our Client’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our Clients, subject to the terms of the HCP Navigator Terms of Use and any other service agreement between HCP Navigator and the Client. We do not share Client Information, Information about our Client’s Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Client, as may be necessary to provide services to the client, to our advisors, channel partners, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Client, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Client Information, Information about our Client’s Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, clients, channel partners or service providers.

We will retain client information we process on behalf of our Clients for as long as needed to provide services to our Client, or for the period of time requested by a particular Client.

Changes to this Privacy Policy
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Revisions:

How to Contact Us
If you have any specific questions about this Privacy Policy, you can contact us via email or writing to us at the address below:

Send e-mail to: privacy@HCPNavigator.com

Send mail to our address:

HCP Navigator
Attn: Privacy Policy Inquiry
6 Concourse Parkway, Suite 1000
Atlanta, GA 30328
U.S.A.

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