References to "you" mean you, the assigned user, or someone authorized by you to act on your behalf.
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1 MNG Direct Privacy Policy THIS POLICY DESCRIBES HOW MNG DIRECT MAY USE AND DISCLOSE THE PERSONAL INFORMATION THAT YOU PROVIDE IN CONNECTION WITH YOUR USE OF THE MNG DIRECT SOLUTIONS, AND ALSO HOW YOU MAY ACCESS THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. I. Introduction This section of the Privacy Policy includes some key information that we think is important for you to understand prior to your use of the MNG Direct Solutions, however, this is only an introduction. By using the MNG Direct solutions, you signify your acceptance of this Privacy Policy. If you do not accept this Privacy Policy, do not use the MNG Direct Solutions. Certain capitalized terms used in this Privacy Policy are defined at the end of this Privacy Policy. MNG Direct may send you personalized s or electronic messages, including news, reminders, and opportunities, pertaining to healthcare education using the MNG Direct Solutions. If after receiving such s or multimedia messages, you prefer not to receive them in the future, you may opt out of this service by following the directions as described below in the Personalized s/Messages section of this Privacy Policy. II. MNG Direct's Commitment to Privacy Protection MNG Direct is committed to protecting your privacy. The purpose of this Privacy Policy is to describe our privacy practices regarding the information you provide to us. In particular, this Privacy Policy describes: What Personal Information we may collect from you; What "cookies" and "web beacons" are and how they are used; How we use your Personal Information; Your privacy choices as a user of the MNG Direct Solutions; How we protect your Personal Information; Links to Other Websites Changes to the MNG Direct Privacy Policy. Information We Share Glossary How to Contact Us References to "you" mean you, the assigned user, or someone authorized by you to act on your behalf. III. "Cookies" and "Web Beacons" and How They Are Used The MNG Direct Solutions use "Cookies" and "Web Beacons." MNG Direct collects Personal Information about your use of the MNG Direct Solutions through the use of Cookies and Web Beacons. We collect certain information by automated means, such as cookies and web beacons, when you visit our websites. The information we collect in this manner includes IP address, browser type, operating system, referring URLs, information on actions taken on a website, and dates and times of website visits. A "cookie" is a text file placed on a computer's hard drive or your mobile device's memory by a web server. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. Every computer is assigned a different Cookie by MNG Direct. The information collected by Cookies and Web Beacons (i) helps MNG Direct dynamically generate content on web pages or in newsletters, (ii)
2 allows MNG Direct to statistically monitor how many people are using the web site, (iii) allows MNG Direct to determine how many people open our s, and (iv) helps MNG Direct determine for what purposes these actions are being taken. MNG Direct may use Cookie information to determine the popularity of certain content. Cookies are also used to facilitate your login and serve as navigation aides and session timers. Cookies used by the MNG Direct Solutions are also used to restrict use of the MNG Direct Solutions by people who are not approved for viewership. Our Web Beacons are not used to track your activity outside of our web sites. You may set your browser to reject Cookies and/or Web Beacons, but if you do so, you will limit the usefulness of the MNG Direct Solutions. IV. Data MNG Direct may use Information from users to create data such as reports that may be disclosed to third parties. V. Data Warehouse Analysis MNG Direct may send your Information to a data warehouse for analysis of trends and effectiveness of NexGen solutions. VI. Sponsored Programs From time to time, MNG Direct may offer you the opportunity to engage in industry-sponsored informational programs consisting of sponsor-selected materials. Examples of Sponsored Programs include custom-developed on-site information resources featuring branded or unbranded commercial content, interactive programs that provide information about medical conditions, treatments and products, multi-media presentations including video featuring a key opinion leader and safety and regulatory information resources. When you choose to engage in a Sponsored Program, you may be asked to provide personally identifiable information (e.g., postal address, telephone number, address, etc.) which may be used to supplement information about you that we have already received during the opt-in process. In addition, we may collect information in connection with a transaction that you have requested (e.g., sample request, sales rep visit, etc.) or responses to Sponsored Program questions. Even if you do not provide us with personally identifiable information, we collect non-personally identifiable information about your use of Sponsored Programs through cookies and web beacons, as described above. The personally identifiable information that you provide when you engage in a Sponsored Program will be used to provide the services you have requested or authorized, respond to your questions, provide you the specific services you select and to send you s about new programs and selected information from our sponsors as it relates to your specialty or area of clinical practice. You may also receive invitations to engage in other Sponsored Programs from the same sponsor. If you engage in a Sponsored Program, e.g., access a sponsored information resource or video presentation, open a Sponsored Program , or interact with a Sponsored Program advertising module, we may identify you by name to the sponsor of the Sponsored Program and/or its agent(s) on the sponsor's behalf. We may also provide the sponsor with your personally identifiable information, based on your registration profile. You should read the privacy policy of the applicable sponsor and familiarize yourself with how such sponsor will treat your information. We are not responsible for how the sponsor and its agents use your information and manage your privacy. Further, we may use personally identifiable information for research purposes, and we may provide this information to third parties. If we discover that a third party inadvertently disclosed personally identifiable information about any of our users, we will take immediate action to prevent further occurrences.
3 VII. Third Party Web Sites Certain content and services offered to you through the MNG Direct Solutions are served on web sites hosted and operated by a third party, sometimes accessed through links within content in the MNG Direct Solutions ("Third Party Web Sites"). MNG Direct does not disclose your Information to these Third Party Web Sites without your consent, but you should be aware that any information you disclose once you access these other web sites is not subject to this Privacy Policy. Once you click on a link to a Third Party Web Site, and leave a MNG Direct website, that site's privacy policy, rather than this Privacy Policy, governs your activities on that site MNG Direct does not endorse and is not responsible for the privacy practices of the Third Party Web Sites. You should review the privacy policy posted on each of these web sites to understand how that Third Party Web Site collects and uses your Personal Information. VIII. How MNG Direct Protects Your Information In order to protect the security of Information, MNG Direct employs the following security procedures: We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We use SSL encryption on a number of our websites from which we transfer certain personal information. In certain limited circumstances MNG Direct may release your Information, to third parties in response to (i) a court order, search warrant, subpoena or other legal action that we reasonably deem to be valid; (ii) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights; or (iii) in connection with a corporate transaction or proceeding resulting in a transfer of the assets or line of business relating to such data. In the event that MNG Direct is legally compelled to disclose such Information to a third party, MNG Direct will attempt to notify you unless doing so would violate the law or court order. IX. Links To Other Websites Our websites may provide links to other websites for your convenience and information. These websites may operate independently from MNG Direct. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by MNG Direct, we are not responsible for the sites' content, any use of the sites, or the privacy practices of the sites. X. Changes to the MNG Direct Privacy Policy MNG Direct reserves the right to change, modify, add, or remove portions of this Privacy Policy, or any of its supplemental policies, at any time. You are responsible for checking this policy from time to time for updates. Non-Material Changes MNG Direct may make non-material changes to the Privacy Policy that do not expand the permissible uses or disclosures of Information. We may not notify you of such non-material changes. MNG Direct will inform you of a material change to the Privacy Policy that affects its use of your Information. Your continued use of the MNG Direct Solutions indicates your acceptance of these
4 changes. If you do not accept the changes to the Privacy Policy, you should stop using the MNG Direct Solutions. XI. Information We Share We do not sell or otherwise disclose personal information we collect about you, except as described here in or otherwise disclose to you at the time the data is collected. XII. Glossary Aggregate Information or Data: As a web site gathers individual pieces of Personal Information (see definition below) from its users, it may combine similar data from one, many, or all users of the website into one batch. Data can also be linked to other information on specific users to create additional aggregate data. This sort of statistical information is called aggregate data because it reflects the habits and characteristics of a group of users. Aggregate data can be shared with business partners and integrated with other data. Cookie: Means small amounts of information passed between a web site and the web browser on the user s computer that allow a user s browser to remember that specific information later during visits to that web site, and that the web server can later retrieve. Non-Personal Information: Information that is not traceable back to any individual and cannot be used to identify an individual. Opt In: Means you are actively indicating your preference to participate in a program, , feature, tool, or enhancement on a web site. Typically, if you opt in, you must provide certain information, usually Personal Information, to the web site or otherwise actively indicate your choice or preference to participate in the web site program. Opt Out: Means that if you do not take some action you are indicating your preference to participate in a program, , feature, tool or enhancement on a web site. Typically, if you opt out, you must uncheck a box next to a stated preference or otherwise take some action to indicate your preference not to participate in a program. Personal Information: Information that can be traced back to an individual (contrast with Non-Personal Information and Aggregate Information). Examples of Personal Information include your name, and viewership information. Third Party: Means any entity other than MNG Direct. Third Party Contractor Web Site: Means a Third Party that serves content and/or services on this Portal that is served on web sites hosted by a company other than MNG Direct. Third Party Site: Means a web site operated by companies other than MNG Direct that is not a Third Party Contractor Web Site. Web Beacons: Means an electronic file that allows a web site to access certain cookies or to count users who have visited a particular page.
5 XIII. Questions or Concerns about Our Terms of Use For questions or concerns about these terms of use, please contact MNG Direct at: 3331 Street Road, Suite 200 Bensalem, PA Last Updated: September, 2015 Copyright MNG Direct, LLC All rights reserved.
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