COMPLIANCE WITH LEGISLATION
OUR COMMITMENT TO YOUR PRIVACY
Affinity is committed to protecting your privacy. We adhere to the following principles to protect your privacy:
- All Personal Information that you provide will be protected in accordance with industry standard protocols and technology.
Affinity has a designated Privacy Officer to respond to any complaints or inquiries with regards to how we use your Personal Information. The Privacy Officer is responsible for overseeing our compliance with applicable legislation. You may contact our Privacy Officer by sending an email to firstname.lastname@example.org.
Affinity’s Client Support Portal has been created to enable clients and visitors to create new software support tickets for Affinity products, and to track these tickets. Accordingly, you will enter, and Affinity will store, specifics of individual software issues. In conjunction with this, Affinity will also store your name, telephone number, email address, products being used, nature of the problem and document attachments.
The Affinity Community provides a common, shared site in which the buyer and merchant partner communities can share information, conduct e-commerce and create new solutions for healthcare management issues. Being part of the Affinity Community necessarily means that you will be sharing information about yourself with Affinity and other partners and Members and communicating with them. The following are the two main types of Personal Information disclosed on the Affinity Community Website:
Information about yourself that you share. This is the Website profile that your contacts and other users see about you. You have control over what you share and who can see this information, and you can update this information at any time.
Communication. We help and encourage you to communicate with Affinity support personnel, contacts and other users through messaging, blogs, files, pages, discussions, applications and other methods. Some of this is one-to-one, some of it is in groups, and some of it is public discussion. You decide how much or how little you wish to communicate to individuals or groups and you also decide whether or not you wish to remain anonymous.
By using our Website, you are providing implied consent for us to collect your Personal Information such as your name, phone number, and certain contact information.
When dealing with certain legal, medical, or security issues, we may be required by law to disclose your Personal Information without seeking or obtaining your consent.
COLLECTION OF INFORMATION
“Personal Information” is information about an identifiable individual. It includes such things as name, age, gender, educational background and performance, occupation, contact information, financial information and other information which can be linked to an individual’s identity. It does not apply to the information of non-individuals, such as corporations and other business entities and, generally speaking, to business contact information of individuals.
In order for you to properly use our Website you may be required to provide certain Personal Information and other information to us pertaining to yourself and / or your business. In doing so, we may collect the following information: first and last name, email address, telephone number, your mailing address and transactional data.
We collect your Personal Information in the following ways:
3. Contact Information In order to connect with others, you may use the Website to send invitations either to their Affinity profile (if they are Members) or to email addresses of people you know if they are not Members. The names and email addresses of people whom you invite will be used to send your invitations and reminders. Please note that when you send an invitation to another Member, that Member will have access to your email address because it is displayed in the invitation. Your contacts will also have access to your email address. You may not invite anyone you do not know and trust to connect with you.
4. Using Website and its Applications We receive information when you interact with and use the Website and its applications. For example, we are notified when you join groups, share pages and other resources, create a blog, etc.
6. Log files, IP Addresses and information about your computer and mobile device
An internet protocol (“IP”) address is a number that is automatically assigned to your computer whenever you are surfing the internet. Web servers (computers that “serve up” web pages) automatically identify your computer by its IP address. When Members, clients or visitors request pages from our Website, our servers typically log their IP addresses. Your IP address may personally identify you depending, in part, on the naming standards followed by your internet service provider (“ISP”). You may wish to ask your ISP about its policies and practices regarding naming standards.
We reserve the right to use IP addresses to identify a visitor when we believe it is necessary to enforce compliance with the following: (a) to fulfill a government request; (b) to conform with the requirements of applicable law or legal process; (c) to protect or defend our legal rights or property, our Website, or its users; or (d) in an emergency to protect the health and safety of our Website’s users or the general public.
Due to the communications standards on the internet, when you visit the Website we automatically receive the Uniform Resource Locator (URL) of the website from which you came and the website to which you are going when you leave the Website. Affinity also receives the IP address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, your mobile device (including your Unique Device Identifier (UDID)) and mobile operating system (if you are accessing the Website using a mobile device), as well as the name of your ISP or your mobile carrier. This information collected can include, among other things:
- the internet domain and IP address from which a Member or visitor accesses our Website,
- the type of browser used (e.g., Internet Explorer, Firefox, Safari, etc.),
- the third party website, if any, from which the visit originated,
- the operating system that the Member, client or visitor is using (e.g., Windows 7, Vista, Windows XP, Macintosh OS, etc.),
- the domain name of the client or visitor’s Internet service provider,
- the search terms that a Member, client or visitor uses on our Website,
- the specific web pages and/or content visited on our Website, and
- the date, time and duration of visits.
The link between your IP address and your Personal Information is not shared with third parties without your permission, except as described above.
7. Client Support Portal
Affinity’s Client Support Portal [insert link to portal] has been created to enable clients and visitors to create new software support tickets for Affinity products, and to track these tickets. Accordingly, you will enter, and Affinity will store, specifics of individual software issues.
USE OF PERSONAL INFORMATION
Affionity uses the information collected on our Website to manage and improve our business operations, to provide our services and products to you, to measure and improve those services and products, to enhance visitor experience on our Website, to permit access to our Client Support Portal [insert link to portal], to track the statistical usage and technical information of those who visit our Website, and to provide visitors and clients with customer support.
We may also use the information collected to contact you from time to time with product or service-related announcements including information about upgrades, new versions and new product offerings.
Uses of Personal Information:
1. Consent to Affinity Processing and Analyzing Information About You
We will communicate with you through email, notices posted on the Website, messages to your inbox, or through other means available through the Website. We may send you a series of emails that help inform new Members about the Website’s features, and we may also send you service messages relating to the functioning of the Website.
You can change your e-mail and contact preferences at any time by logging into your account and changing your settings related to your email notification choices.
Please be aware that you cannot opt-out of receiving service messages. Also, if we send communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand that you are responsible to pay any service fees associated with your receipt of messages on your mobile device (including text messaging charges).
3. Member Communications
Many communications you initiate through the Website (e.g., an invitation sent to a non-Member) will list your primary email address and name in the header of the message. Messages you initiate may also provide aggregate information about Website your profile and contacts (for instance how many people are in your contacts list), but will not list the people to whom you’re directly connected. Other communications that you initiate through the Website, like a request for an introduction, will list your name as the initiator but will not include your personal email address contact information. Your contact information will only be shared with another Member if both of you have indicated that you would like to establish contact with each other.
4. Customized Content
We use information you provide to us to customize your experience on our Website. For example, when you login to your account, we will display the names of new Members who have recently joined your network or recent status updates from your connections.
5. Sharing Information with Third Parties
Member information can be made public by the creator of the information. This allows Members to publish portions of their Website profile and other contributions to the public internet. This public Website profile will be crawled by and displayed through search engines when someone searches for your name or related search terms. You may remove such public access from your resource by editing resource settings. However, Affinity does not control how often third-party search engines will update their caches, which may contain old public profile information.
Content distributed through the Website sharing features may result in displaying some of your information publically. For example, when you post content to a group that is open for public discussion, your content, including your name as the contributor, may be displayed in search engine results.
We may provide aggregated anonymous data about the usage of the Website to third parties for purposes that we deem, in our sole discretion, to be appropriate, including to commercial and government funders of Affinity.
6. Affinity External Developers
We collaborate with and allow third parties to develop Website applications and functionality in conjunction with and outside of Affinity. These third parties are either partners with whom we have negotiated an agreement to provide services or developers who have agreed to our developer terms and conditions in order to build applications. Both the negotiated agreements and our developer terms and conditions contain restrictions on access, storage and use of your Personal Information. However, we cannot guarantee that any developer or third party will abide by their contractual obligations.
Despite our agreements and technical steps taken to restrict access to and avoid possible misuse of information, we may not screen or audit all services and applications. You agree that your use of our Website is on an “as is” basis and without any warranty.
If you use any Website application or service, the abovementioned developers and third parties may have access to and share certain information about you, such as non-public profile information and information visible only to your groups or contacts. We make contractual and technical efforts to restrict this information to the minimum necessary to successfully develop and test such applications, but again we cannot guarantee that any developer or third party will abide by their contractual obligations.
7. Polls and Surveys
Polls and surveys may be conducted by Affinity, Members or third parties. As a Member, you may be invited to participate in polls and surveys from the Website. Your selection may be random, or it may be based on your non-Personal Information, such as job title, geography, company size and/or industry. Whether or not you decide to participate in a poll or survey is completely up to you.
We will not disclose your Personal Information to any third parties in connection with the conduct of any polls or surveys. Your consent to use your Personal Information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.
We offer search services to help find information and learn more about other Members and resources. We use information from user profiles and contributions to groups, Affinity Website pages, and answers to inform and refine our search service.
9. Blogs, Discussion Posts and other Services
If you post to any blog or discussion group you should be aware that any Personal Information you choose to provide there can be read, collected, and used by other Members, as well as developers and other third parties, and could be used to send you unsolicited messages. Affinity is not responsible for the information you choose to submit, including whether it is copyright protected. It is your responsibility to only post information to which you have copyright or other legal authority to use. Also, some discussion group content may be public and searchable on the internet if the group owner has opened the group for public discussions. You can delete your posts at any time. However, please note that ideas you post and information you share may be seen and used by other Members, and we cannot guarantee that other Members have not made copies of or used the ideas and information that you have shared.
10. Links to Third Party Websites
DISCLOSURE OF PERSONAL INFORMATION
Disclosures Necessary to Provide a Service
We may disclose your Personal Information where it is necessary to enable any of our staff, employees, agents, contractors, suppliers or commercial partners to provide a service to us or to perform a function on our behalf.
Disclosures to Others as the Result of a Change in Control or Sale of Affinity
We may disclose your Personal Information and other information you provide, to third parties in connection with a change in control or sale of Affinity. Such third parties will have the right to continue to use your Personal Information and other information that you provide to us.
Compliance with Legal Process
Outside of USA
Keeping in mind the purpose of its use, Affinity will make every reasonable effort to keep your Personal Information as accurate and complete as possible.
SAFEGUARDING PERSONAL INFORMATION
Your Personal Information is kept in strict confidence. Affinity utilizes appropriate security safeguards to keep your Personal Information confidential and secure. Only authorized personnel have access to your Personal Information; we do not release your Personal Information to third parties other than those third parties that are necessary to satisfy the purposes for which the Personal Information was collected, including third party service providers, or in accordance with privacy legislation. We require third party service providers to safeguard your Personal Information by implementing privacy policies and procedures equivalent to or greater than our own.
ACCESS TO PERSONAL INFORMATION
You have a right to access, modify, correct and eliminate the data you supplied, subject to some exceptions set out in applicable legislation. For example, we are required to refuse to provide access to information that would reveal Personal Information about another individual. If access is refused, in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide the requesting individual with the remainder of the record.
UNSOLICITED EMAILS AND TELEPHONE CALLS
Please do not share/send your Personal Information (and particularly financial/credit card information) in response to any unsolicited e-mail or telephone call that appears to come from Affinity or its affiliated brands. We will not contact you and ask for such information; such information is only submitted when accessing our Website or when speaking with an authorized representative of Affinity.
YOUR INFORMATION CHOICES
1. Accessing and Changing Your Account Information
You can review the information you provided to us and make any desired changes to the information you publish, or to your settings including your email and contact preferences, at any time by logging in to your account. Please be aware that even after your request for a change is processed, Affinity may, for a time, retain residual information about you in its backup and/or archival copies of its database.
2. Default Settings
Because Members may use and interact with Affinity in a variety of ways, and because those uses may change over time, we designed our settings to provide our Website users with granular control over the information they share. We encourage our Website users to review their account settings and adjust them in accordance with their preferences.
3. Closing Your Account
You can close your account by emailing a request to Affinity support at email@example.com. If you close your account, we will remove your name and other Personal Information from our publicly viewable database. If you close your account, we have no obligation to retain your information, and we may delete any or all of your account information without liability. However, we may retain certain data contributed by you if Affinity believes it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. Affinity may also retain and use your information if necessary to provide the services to other Website users. For example, similar to when an email you may send to another person through an email service provider resides in that person’s inbox even after you delete it from your sent files or close your account, messages you send to other Members, as well as your contributions to groups, may remain visible to others after you have closed your account. Similarly, other information you have shared with others, or that others have copied, may also remain visible. Affinity disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information or any obligation not to delete the information. Affinity does not control when search engines update their cache, which may contain certain public profile information that has since been removed from the publicly viewable data.
4. Memorializing Accounts
If we learn that a Member is deceased, we may memorialize the Member’s account. In these cases we may restrict profile access, remove messaging functionality and close an account if we receive a formal request from the Member’s next of kin or other proper legal request to do so.
As a Member, you have certain obligations to Affinity, other Members and the public at large. Some of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members such as the Affinity Community . These include the following:
- You must not download or otherwise disseminate any information that may be deemed to be injurious, violent, offensive, racist or xenophobic, or which may otherwise violate the purpose and spirit of Affinity and its community of Members.
- You must not provide Member information that you believe might be injurious or detrimental to your person or to your professional or social status.
- You must keep your username and password confidential and not share it with others.
Headings are for reference purposes only and have no legal effect.
Copyright© 2019 Harris Affinity. All rights reserved. Any rights not expressly granted herein are reserved.
QUESTIONS REGARDING COMPLIANCE
If you have questions or concerns about our privacy practices or wish to make a request in respect of your Personal Information please contact our Privacy Officer at firstname.lastname@example.org, our corporate office at 1-888-847-7747 or if you prefer by writing us at:
Harris Affinity. c/o Privacy Officer
2300 Corporate Park Drive