“Personal Information” or “Information” means information that (1) is transferred from the European Economic Area (“EEA”) or Switzerland to the United States or maintained in the United States; (2) is recorded in any form; (3) is about, or pertains to, a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
Collection and Use of Personal Information
In connection with the access and use of Global Conferencing Solutions Services, we may ask you to provide us with Personal Information when, among other things, you register on the Global Conferencing Solutions website, use one of our Services, fill out a survey, make a request for information, or enter a sweepstakes or contest through the Global Conferencing Solutions website. We may also capture your telephone number when you use our conferencing Services. Please be aware that any information you choose to share on any publicly available portion of the Services or with third parties, including without limitation your personal page, chat messages, forum posts, blogs, resumes, job applications, business cards, or any other information that you provide to Sponsors or other attendees, may be collected and used by others without restriction. We will use the Personal Information you provide us in these circumstances to operate the Global Conferencing Solutions website, to the extent required for the delivery of the Global Conferencing Solutions Services, to satisfy Global Conferencing Solution’s legitimate business interests (such as customer analysis and internal marketing study and analysis), and to provide information you request from the Global Conferencing Solutions website (“Primary Use”).
Unless you instruct us not to do so, Global Conferencing Solutions may also use the Personal Information you provide us to contact you regarding additional or new services and features offered by Global Conferencing Solutions, special offers by Global Conferencing Solutions, or important information regarding Global Conferencing Solutions (“Global Conferencing Solutions Secondary Use”). In addition, with your permission, we may provide your Personal Information to other companies who may contact you regarding products, services, and offers that may be of interest to you, but that are not directly related to Global Conferencing Solutions or the Global Conferencing Solutions website (“Third Party Secondary Use”).
Global Conferencing Solutions may provide your Personal Information to vendors that assist Global Conferencing Solutions in processing such Information or in case you purchase services of Third Parties from Global Conferencing Solutions (“Third Party Services”). Global Conferencing Solutions requires such vendors to enter into agreements with Global Conferencing Solutions prohibiting disclosure of the information to others and restricting its use to providing the contracted services of Global Conferencing Solutions.
As we noted above, we will not use your Personal Information or Sensitive Personal Information for any Third Party Secondary Uses unless you affirmatively choose to participate in such Secondary Uses. You may also stop delivery of informational or promotional mail from us by following the instructions included in the informational or promotional mail itself.
When you register to use any of the Services offered by Global Conferencing Solutions, Global Conferencing Solutions will send you a confirmation of your registration showing the Personal Information we obtained from your registration. Also, we will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated.
International transfers and the U.S.-E.U. Safe Harbor and the U.S.-Swiss Safe Harbor
Unless you have already consented to such disclosure, prior to disclosing Personal Information to a third party, Global Conferencing Solutions shall notify you of such disclosure and allow you to opt out of such disclosure. Global Conferencing Solutions shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
Global Conferencing Solutions shall take reasonable steps to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Personal Information we collect from you is stored in operating environments that employ reasonable security measures and that are not available to the general public. Global Conferencing Solutions is not responsible for unauthorized access to such Information by hackers or others that obtain access through illegal measures, in the absence of negligence on the part of Global Conferencing Solutions. Further, the other websites you may access through the Global Conferencing Solutions website may have different security practices and you should familiarize yourself with those practices. Global Conferencing Solutions cannot guarantee the security of Information transmitted via the Internet.
You are responsible for the confidentiality and security of passwords Global Conferencing Solutions issues to you. If you believe a third party has obtained your password in an unauthorized manner, please notify us promptly.
Global Conferencing Solutions shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Global Conferencing Solutions shall take reasonable steps to ensure the Personal Information is accurate, complete, current and reliable for its intended use.
Disclosure for Legal Purposes
We may disclose Personal Information if required to do so by law or in the good-faith belief such action is necessary: (a) to conform to the edicts of the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or those of our customers and their users; (c) to protect the personal safety of our customers and their users or the public; or (d) in connection with a merger, consolidation or sale of substantial assets of Global Conferencing Solutions. As we continue to develop our business, we might buy or sell assets related to our business. In such transactions Personal Information generally is one of the transferred business assets. Also, in the event Global Conferencing Solutions or substantially all of its assets are acquired, Personal Information will be one of the transferred assets.
Please understand, in addition to collecting Personal Information, Global Conferencing Solutions will also gather information that does not personally identify you regarding your use of the Global Conferencing Solutions website (“Anonymous Information”). The Anonymous Information we collect regarding your use of the Global Conferencing Solutions website may be used by us to measure the effectiveness of marketing efforts on the Global Conferencing Solutions website, for improving the services we offer to you, or to improve the Global Conferencing Solutions website. Generally, you will not be aware when such Anonymous Information is being collected about you. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access our website.
Venturing off the Global Conferencing Solutions website
The Global Conferencing Solutions website may contain hyperlinks that can take you to websites run by third parties (“Third-Party Websites”). Any hypertext or other links to Third-Party Websites from the Global Conferencing Solutions website are provided solely as a convenience to you. If you use these links, you will leave the Global Conferencing Solutions website. Global Conferencing Solutions has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, Global Conferencing Solutions does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked to the Global Conferencing Solutions website, you do this entirely at your own risk.
If at any time you believe Global Conferencing Solutions has not followed the above Policy, or if you have questions, comments, or complaints regarding Global Conferencing Solution’s Policy, please contact us via e-mail at [email protected]. By mail, we can be contacted at:
Global Conferencing Solutions, Inc.
ATTN: Safe Harbor Support
2825 Cottonwood Parkway, Suite 500
Salt Lake City, UT 84020
HIPAA PRIVACY NOTICE
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Global Conferencing Solutions and its affiliates are required by law to maintain the privacy of “protected health information.” “Protected health information” includes any identifiable information we obtain from you or others that relates to your physical or mental health, the health care you have received, or payment for your health care.
As required by law, this notice provides you with information about your rights and our legal duties and privacy practices with respect to the privacy of protected health information. This notice also discusses the uses and disclosures we will make of your protected health information. We must comply with the provisions of this notice, although we reserve the right to change the terms of this notice from time to time and to make the revised notice effective for all protected health information we maintain. You can always request a copy of the most current privacy notice from our Privacy and Security Official.
PERMITTED USES AND DISCLOSURES
The affiliates of Global Conferencing Solutions (“GCS”) listed above are Business Associates of Covered Entities with which you may do business. These Covered Entities would include, for example, your insurance company, your dentist, your pharmacy, etc. In the capacity of Business Associate, the Covered Entity you use may provide access to a portion of your protected health information to GCS. We intend to use or disclose your protected health information for the purposes of fulfilling our obligations to the Covered Entity. These uses or disclosures may include, but are not limited to, the following categories and examples:
Treatment – We may use protected health information provided to us by your Covered Entity to inform you of approaching events related to your healthcare. For example, we may notify you a prescription is coming up for refill; or, we may call you because it has been a while since you have ordered supplies for a medical condition and it is time to reorder.
Payment – We may use protected health information provided to us by your Covered Entity to inform you of issues related to payment for your healthcare. For example, we may notify you of a past due payment on a medical bill.
Healthcare operations – We may use protected health information provided to us by your Covered Entity to assist your Covered Entity in serving you better. For example, we may provide conference capabilities for your physician to consult with other medical staff; we may provide customer service on behalf of your insurance carrier to assist you with your insurance benefits; or, we may provide recall notifications for a recalled medical device you may use.
OTHER USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION
We may contact you, on behalf of your Covered Entity, to provide appointment reminders or information about health-related benefits and services that may be of interest to you.
We may disclose your protected health information at the direction of your Covered Entity and only as permitted by applicable law. This may include disclosure of your protected health information to your family or friends or any other individual identified by you when they are involved in your care or the payment of your care. We will only disclose the protected health information directly relevant to their involvement in your care or payment. We may also use or disclose your protected health information to notify, or assist in the notification of, a family member, a personal representative, or another person responsible for your care of your location, general condition or death. If you are available, we will give you an opportunity to object to these disclosures, and we will not make these disclosures if you object. If you are not available, we will determine whether a disclosure to your family or friends is in your best interest, and we will disclose only the protected health information that is directly relevant to their involvement in your care.
When permitted by law, we may coordinate our uses and disclosures of protected health information with public or private entities authorized by law or by charter to assist in disaster relief efforts.
We may contact you on behalf of your Covered Entity as part of their marketing efforts as permitted by applicable law.
Except for the special situations set forth below and the general uses and disclosures described above, we will not use or disclose your protected health information for any other purposes unless you provide a written authorization to your Covered Entity.
Worker’s Compensation – We may disclose your protected health information to the extent authorized by and to the extent necessary to comply with laws relating to workers’ compensation or other similar programs established by law.
Public Health – When required or permitted by law, we may disclose your protected health information to public health or legal authorities responsible for preventing or controlling disease, injury or disability or performing other public health functions. In addition, we may disclose your protected health information in order to avert a serious threat to health or safety.
Specialized Government Functions – We may disclose your protected health information for military and veterans’ activities, national security and intelligence activities and similar special governmental functions as required or permitted by law.
Health Oversight Agencies – We may disclose your protected health information to an appropriate health oversight agency, public health authority or attorney involved in health oversight activities.
Law Enforcement – We may disclose your protected health information for law enforcement purposes as required or permitted by law or in response to a valid subpoena, court order or other binding authority.
Judicial and Administrative Proceedings – We may disclose your protected health information for judicial or administrative proceedings as required or permitted by law or in response to a valid subpoena, court order or other binding authority.
Food and Drug Administration (“FDA”) – We may disclose to the FDA, or an entity subject to FDA jurisdiction, your protected health information for public health purposes related to the quality, safety or effectiveness of an FDA-regulated product or activity for which that person has responsibility. For example, your information may be disclosed in connection with the reporting of an adverse event, product defect, product tracking or to provide post marketing surveillance information.
Disclosures Required by Law – We may use or disclose your protected health information as required by law provided such use or disclosure complies with and is limited to the relevant requirements of such law.
YOUR RIGHTS REGARDING HEALTH INFORMATION ABOUT YOU
You have a right to expect your protected health information will be kept secure and used only for legitimate purposes.
You have a right to understand how your protected health information may be used and disclosed by GCS.
You have a right to access this privacy notice that tells you how your protected health information may be used or disclosed.
You have a right to ask questions about any health privacy issue and have those questions clearly and promptly answered.
You have a (limited) right to know who has seen your health information, and for what purpose. If you make additional requests for such an accounting during any 12-month period, we may charge you a reasonable, cost-based fee.
You have a right to see, and to keep a copy of, all of your health records except psychotherapy notes and information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding. Your request for a copy of your record must be in writing.
You have a right to ask for correction or inclusion of a statement of disagreement for anything in your records you feel is in error. Your request must be submitted in writing and include supporting documentation.
You have a right to authorize, or refuse, additional uses of your protected health information, such as for fundraising, marketing, or research.
You have a right to request extra protections for protected health information you consider especially sensitive, and to request we communicate with you by alternative means.
If you believe your privacy rights have been violated, you should immediately contact our Privacy and Security Official. We will not take any action against you for filing a complaint. You may also file a complaint with the Secretary of Health and Human Services.
If you have any questions or would like further information about this notice, please contact [email protected]