Picis Clinical Solutions, Inc. and QuadraMed Affinity Corporation (hereinafter referred to as “Harris Affinity”)
is committed to protecting the privacy and security of the personal information we receive or collect from you. We also believe in transparency and are committed to informing you about how we treat your personal information.
This Policy does not apply to information you may provide to us offline or through means other than through this Website.
Our Role in Protecting the Privacy and Security of Your Personal Information
Harris Affinity (collectively Picis Clinical Solutions, Inc. and QuadraMed Affinity Corporation, or “we”, “us”, “our”) is responsible for adhering to applicable data protection principles and laws and to safeguarding the personal information that you provide to us through the Website. Harris Affinity does not sell personal information and we have not sold personal information nor shared personal information for commercial purposes in the preceding 12 months.
If you are a user in in the European Union (the “EU”) or European Economic Area (“EEA”), Harris Affinity will be the controller of the personal information we collect from you for purposes of the E.U. General Data Protection Regulation, 2016/679 (the “GDPR”).
What Personal Information We Collect and Why
The types of information we collect (and have collected in the previous 12 months) include:
|Category||Types of Data and Purpose|
|Contact Information||When you visit our Site or ask for services, we may ask you for your name, address, telephone number, email address or other contact details (and have collected in the previous 12 months) in order to respond to your requests or inquiries about our Site or services.|
|User Account Information||When you create an account, we collect your contact information, other identifying information (e.g., age, date of birth, photo), username and password, and other registration information, including payment information necessary to enable us to fulfill your account registration request and maintain your account profile. You may edit or update your user account information at any time.|
|Conference Registration Information||When you register for a conference or seminar hosted by us, we collect your contact information and other details necessary for processing the registration, including payment information.|
|Business Information||When you seek services from us in the course of contractual or customer relationships between you, your organization, and Harris Affinity, we collect business contact information and other personal information in order to provide you with the services you have requested.|
|Financial and Payment Information||When you purchase goods or services from Harris Affinity, we may collect your bank account and other information necessary to process payments, including credit card numbers, security codes, expiration dates, and other related billing information.|
|Location Information||When you use our Site, we may collect information about your use of our Site and services for advertising, analytics, and content development purposes and to maintain and improve the security of our Site and services. Location information collected may include your Internet Protocol (IP) address, internet tags, GPS, Wi-Fi, cellular technology, Radio-frequency identification (RFID), Bluetooth or other beacon technology or other similar location-tracking technologies.|
|Cookies||When you visit our Site, we [our affiliates or third parties] may collect cookies and use similar technologies to, among other things, provide you with a more personal and interactive experience on our Site, improve our marketing efforts, and provide usage analytics for our Site (e.g., page response times, download errors, length of visit, webpages visited, etc.). Please see our Cookies and Similar Technologies Policy for more information. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.|
|Automated Information||When you visit our Site, we [our affiliates or third parties] automatically collect information from your browser or your mobile device, which may include Internet Protocol (IP) address or unique device identifier, cookies, and data about which pages you visit in order to allow to operate and provide the Site and our services. This information is used to maintain and improve the security of our Site and services, to analyze and improve the quality of our Site and services, understand how you interact with the Site, and provide advertising and a more personalized experience to you. To learn more about our collection of technical data, please visit our Cookies and Similar Technologies Policy.|
|Email Interconnectivity||If you receive email communications from us, we may use certain tools to capture data related to when you open our message, click on any links, or banners it contains and make purchases. We use this information to enhance our marketing efforts.|
|Employment||If you apply for a job, or become an employee, we collect personal information necessary to process your application or employment. This may include, among other things, your contact information, your social security number, employment history, etc.|
|Feedback/Support/Inquiries||If you provide us with feedback or contact us for support or ask us questions, we will collect your name, email address, other contact information and other information needed to respond to your feedback, request for support, or answer your question.|
|Mailing List||When you sign up for one of our mailing lists, we collect your contact information, including your email address and postal address.|
|Order Placement||When you place an order with or purchase goods or services from us, we collect your name, billing address, shipping address, email address, and contact details, shipping preferences, and payment information.|
|Sensitive Personal Information||When necessary in order to respond to your requests for services or employment, we may collect information regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, financial information, or data concerning your sex life or sexual orientation. Harris Affinity will only collect this sensitive personal information with your express consent or as otherwise permitted by applicable law.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources.
How Will We Use Your Personal Information?
In addition to the uses described above, Harris Affinity uses the personal information collected in an effort to improve your experience on the Site, to provide services to you, and to communicate with you about the information you have requested. Harris Affinity may also use personal information to help target specific offers to you and to help Harris Affinity develop and improve our Site and services. Additionally, Harris Affinity may use your personal information in the following ways:
- To provide you with services you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection and taking other steps necessary to the performance of our business relationship with you;
- To present and improve Site contact and functionality;
- To determine user interests, needs and preferences;
- To provide notice of changes to our Site or the services we offer or provide through it;
- To conduct research and analysis;
- To develop new products and services;
- To manage and maintain the security of our Site and services;
- To market our services to you. We will only provide you with marketing related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time. We do not sell or distribute this information to third parties or use it for any other purpose.
- To comply with our legal and compliance obligations, including maintaining records, performing compliance audits, etc.
- For insurance purposes;
- To exercise and defend our legal rights, or to comply with court orders;
- For any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your personal information was provided to us;
- In any other way we may describe when you provide the information; and
- For any other purpose to which you have consented or for which we have a legitimate basis under the law.
We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
- because it is necessary to perform the services you have requested, to comply with your instructions or requests, or other contractual obligations between you and Harris Affinity;
- to comply with our legal obligations as well as to keep records of our compliance processes;
- because our legitimate interests, or those of a third party recipient of your personal information, makes the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
- because you have chosen to publish or display your personal information on a public area of the Site, such as blog or comment area;
- because it is necessary to protect your vital interests;
- because it is necessary in the public interest; or
- because you have expressly given us your consent to process your personal information in a particular manner.
We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above.
Disclosure Of Your Personal Information
We may share your personal information in the following contexts:
|Subsidiaries and Acquisitions||We may share your personal information with our corporate subsidiaries and affiliates. If another company acquires Harris Affinity, we will share your personal information with that company.|
|Disclosures With Your Consent||We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent.|
|Public||Some areas of our Site may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publicly available.|
|Directories||You may consent through account or conference/seminar registrations to having your contact information shared with other account holders or conference/seminar registrants.|
|Third Parties||Harris Affinity may provide personal information about you to third parties that offer products and services specifically requested by you.|
|Service Providers||Harris Affinity may share your personal information with our service providers. Among other things, service providers may help us to administer the Site, support our provision of services requested by you, provide technical support, send marketing, promotions and communications to you about our service, payment processing and other legitimate purposes permitted by law.|
How Long Do We Store Your Personal Information?
Harris Affinity will retain your personal information as needed to fulfill the purposes for which it was lawfully collected. Harris Affinity also will retain and use your personal information as long as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, provide our services, and enforce our agreements.
When we no longer have a purpose to retain your personal information, we will destroy your personal information in accordance with applicable law and our policies.
Security of Your Personal Information
Harris Affinity has put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized manner, altered, or disclosed. While our security measures seek to protect your personal information in our possession, no security system is perfect and Harris Affinity cannot promise that your personal information will remain absolutely secure in all circumstances.
The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.
If a security breach causes an unauthorized intrusion into our Site or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by law.
Updating Your Personal Information
If any of the personal information you have provided to us changes, please let us know. For instance, if your email changes, you wish to cancel any request you have made of us, or if you become aware of inaccurate personal information about you, contact us at email@example.com to update your information. You may also edit your account details if you have a user account through our Site.
We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal data that you provide to us.
Your Rights to Access and Control Your Personal Information
Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy.
Right of Access. If required by law (e.g., under the GDPR), upon request, we will grant reasonable access to the personal information that we hold about you.
Accuracy. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or changes.
Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to processing of your personal information. If you would like us to stop using or wish to restrict our processing of your personal information, please contact us and we will let you know if we are able to agree to your request.
Right to Erasure and Deletion of Your Personal Information. You may have a legal right (for instance, if you are located in the EU or EEA under the GDPR) to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed. All deletion requests should be sent to the address noted in the Contact Us section of this Policy.
We may decide to delete your personal information if we believe it is incomplete, inaccurate or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases and our Site, but it may remain archived when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Right to Withdraw Consent. If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partially withdraw your consent. To withdraw your consent, in full or in part, please notify us using the information in the Contact Us section of this Policy and you may follow opt-out links on any marketing communications sent to you.
Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
Right to Complain. If you wish to file a complaint with us about our privacy practices, you may do so by contacting us using the information provided in the Contact Us section of this Policy and we will do our best to respond to and, if possible, resolve your complaint. If you believe that your rights relating to your personal information have been violated, you have a right to lodge a complaint with the applicable enforcement authority, or seek a remedy through the courts.
Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions.
California Residents. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing. If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the Contact Us section of this Policy.
European Union or European Economic Area Residents. If you are located in the EU or EEA and believe we have not processed your personal information in accordance with applicable provisions of the GDPR, you may file a complaint with your local data protection or supervisory authority.
Cross Border Transfers of Personal Information
Harris Affinity is located and established in the United States and therefore, your personal information may be transferred to, stored or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the security and privacy of your personal information. By using our Site or requesting services from us, you understand and consent to the collection, storage, processing and transfer of your personal information to our facilities in the United States and those third parties with whom we share it as described in this Policy.
Residents of the EU / EEA. We rely on recognized legal bases to lawfully conduct cross-border transfers of personal information outside of the European Union (EU) and European Economic Area (EEA), such as your express informed consent (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between Harris Affinity and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.
Links to Other Sites
This Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties over which we have no control or supervision. If you click on an embedded third-party link, you will be redirected away from this Site to the external third-party website. You can check the URL to confirm that you have left this Site.
Harris Affinity cannot and does not (i) guarantee the adequacy of privacy, security, practice content or media provided by third parties or their websites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site.
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the internet. Our Site and the services are not directed to children aged 16 or younger, nor is information knowingly collected from children under the age of 16. No one under the age of 16 may access, browse, or use the Site or provide any information to or on the Site. If you are under 16, please do not use or provide any information on this Site. If we learn that we have collected or received personal information from a child under the age of 16 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it.
For more information about COPPA, please visit the Federal Trade Commission’s website at: www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we treat your personal information or in response to changes in law. We will post any changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will notify you through a notice on the website home page as well. The date this Policy was last revised is identified at the top of this Policy.
If you have questions or comments about this Policy, wish to access personal information we hold about you; believe the personal information we have about you is incorrect, or wish to lodge a complaint with us about how we have handled your personal information, please contact us using the contact details below and we will do our best to assist you:
- Send an email to: firstname.lastname@example.org
- Call us at: 1-888-847-7747
- Write to us at:
2300 Corporate Park Drive
Herndon, VA 20171