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Privacy Policy and Data Protection – Wisethink Health Solutions
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Privacy Policy and Data Protection

Introduction

WiseThink Consulting LLC dba WiseThink Health Solutions (“WiseThink”) respects the privacy of its employees, its customers, and visitors to its website, and is committed to protecting the privacy of the Personal Information (defined below) that you share with us.  This Privacy Policy outlines the type of personal information that is collected by WiseThink when you contact us, visit our web site or in the employment context, and how we use and protect it. This Policy also tells you what to do if you do not want your Personal Information collected and how you can change information you have already provided to us.
Your consent:  By using our website, you consent to the collection, use and disclosure of information as described in this Policy.

Scope

This Policy applies to WiseThink, and all of its wholly-owned subsidiaries and affiliates.  References to “WiseThink” in this policy refer to WiseThink., and all of its wholly-owned subsidiaries and affiliates.  “Personal Information” means any information or set of information that identifies or can reasonably be used to identify an individual (the “Identifiable Person”). Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with nonpublic, personal information.  “Sensitive Personal Information” is data that pertains to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation or any other data that is identified as “sensitive” by the Identifiable Person.

Purposes of Collection of Personal Information

WiseThink’s collection and use of Personal Information in the employment context is essential in connection with the conduct of WiseThink’s human resources and business functions. Examples of the purposes for which WiseThink collects and uses Personal Information include, without limitation, recruitment, payroll, and personnel management, such as compensation, promotion, evaluation, benefit administration and succession planning, and designing and implementing employment-related education and training programs, and maintaining facility and employee security, health, and safety.  Unless required by applicable law, WiseThink does not request or record Sensitive Personal Information.
To the extent practical and appropriate, WiseThink collects Personal Information directly from the Identifiable Person. In those cases where WiseThink collects Personal Information from other persons, it takes measures to respect the privacy preferences of the Identifiable Person. Examples of when WiseThink may seek information from others include, without limitation, evaluating employees, recruiting, benefit administration and succession planning. WiseThink also collects Personal Information from contacts made through its website.  When Personal Information is supplied at an WiseThink website, we will use it for the express purpose for which it was collected, or for other purposes disclosed at the time when the Personal Information is supplied.  See “Information Collected on our Websites” below for additional information.  WiseThink also collects personal information, including health information, about EU individuals who use WiseThink products, for medical device reporting, warranty and product support purposes.

U.S.-European Union and Swiss Safe Harbor Programs

WiseThink as a Third Party Distributor of CRF Inc. (www.crfhealth.com) complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  WiseThink has certified that is adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view CRF Inc’s certification, please visit http://export.gov/safeharbor/index.asp.

Notice

At the time that WiseThink collects Personal Information from you for any of the purposes identified above, we will inform you of the purpose for which the Personal Information is being collected and used, and how to contact WiseThink with any questions or complaints, or to update your Personal Information.  WiseThink will not disclose Personal Information to third parties except in accordance with this Policy and as disclosed at the time of the collection of the Information.

Choice

WiseThink will offer you the opportunity to choose whether your Personal Information is to be (a) disclosed to a third party or (b) used for a purpose other than that for which the Personal Information was originally collected or subsequently authorized by you.
WiseThink will not disclose Sensitive Personal Information to a third party or use it for any purpose other than that for which it was originally collected or subsequently authorized by you, except as required by law, court order, or subpoena.

Security

WiseThink will take reasonable precautions to keep your Personal Information secure. All personally identifiable information is subject to restricted access to prevent unauthorized access, modification or misuse.

Data Integrity

WiseThink will not process your Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. To the extent necessary for those purposes, WiseThink will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate, complete and current.

Access

WiseThink will provide you with reasonable access to your Personal Information collected or recorded by WiseThink, and will undertake reasonable steps to effect any correction or amendment of Personal Information that you demonstrate to be incorrect or incomplete.

Transfer to Third Parties

Before WiseThink transfers Personal Information to a third party that is acting as an agent, it will ascertain that the third party safeguards Personal Information consistent with this policy, has itself made a Safe Harbor certification, or is subject to the EU Data Protection Directive. Where WiseThink has knowledge that an agent is using or disclosing Personal Information contrary to this policy, WiseThink will take reasonable steps to prevent or stop the use or disclosure.

Enforcement

WiseThink will conduct periodic internal audits to our ongoing adherence to this Policy, and will promptly seek to remedy any instances of noncompliance brought to its attention.

Dispute Resolution

We encourage individuals covered by this Policy to raise any concerns that they have about the way that we protect and process their Personal Information by contacting info@WiseThinkHealth.com or Privacy Compliance Director, WiseThink Health Solutions., 2451 Cumberland Parkway Suite 3675, Atlanta GA 30339, and we will do our best to resolve them.  WiseThink will investigate your concerns promptly, and will respond to your correspondence within sixty (60) days after we receive it.  WiseThink will provide you with a clear explanation of any decisions made with respect to your request.

Information Collected on Our Websites

When you supply Personal Information at an WiseThink website, we will use it for the express purpose for which it was collected (e.g., to enter you in a sweepstake or to send you a sample). It may also be used by us to send you information and/or offers about our goods and/or services which we believe may be of interest to you, or to invite you to participate in market research. At any time, however, you may opt out of such future contact by writing us at info@WiseThink.com or Privacy Compliance Director, WiseThink Health Solutions., 2451 Cumberland Parkway Suite 3675, Atlanta GA 30339 .
At times we may retain third parties to process or analyze data we collect on our web sites, including Personal Information. In addition, if you order a product or service from us, we may share Personal Information with suppliers and other third parties to allow delivery of such product or service. These suppliers and other third parties are not authorized by us to use your Personal Information in any other way.

WiseThink may use “cookies” to collect other information during an individual’s visit to our web sites, such as the particular site areas visited and the services utilized through our web site. We collect this information to better tailor our site and our products to your interests and needs. Cookies may also be used to help speed up your future activities at our site. For example, a site can recognize that you have provided Personal Information to use and refrain from requesting the same information a second time. Most browsers are initially set to accept a cookie. Cookies may be disabled by the individual visitor, although refusal of cookies at the site may result in an inability to visit certain areas of the site or to receive personalized information when visiting the site.

In addition we are constantly trying to improve how we promote our web site. To help us do this, we may measure the effectiveness of our web presence by determining when you accessed the web site, and what you clicked on within our site. Site measurement statistics may be used to personalize your web site experience, as well as to evaluate – anonymously and in the aggregate – statistics about usage of the web site. Information about your computer, such as your IP address (a number assigned to your computer whenever you surf the Internet), the type of Internet browser you are using and the type of operating system you are using may also be collected and linked to your Personal Information. This is to ensure that our web site presents the best web experience for visitors, and that they are effective information resources.

Some of the pages an individual visits may also collect information through the use of pixel tags (also called clear gifs) that may be shared with third parties which directly support WiseThink’s promotional activities and web site development. For example, web site usage information about visitors to our web sites may be shared with our third party advertising agency in order to better target Internet banner advertisements on WiseThink web sites. The information collected through the use of these pixel tags is not, however, personally identifiable, although it could be linked to an individual’s Personal Information.
Finally, we may supplement the Personal Information that an individual website user provided us with other information we hold or that we receive from third parties. We do this for marketing purposes in order to provide more targeted products and service to meet site visitors’ needs.

Limitation on Scope of Principles

Please note that we will release your Personal Information if required to do so by law, or by search warrant, subpoena, or court order.

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