Healthwise Global Privacy Notice

The following is only applicable to legacy Healthwise products and does not apply to any of WebMD Ignite's products or services, nor does it apply to information collected from visitors to www.webmdignite.com; for the privacy policy governing those, please visit www.webmdignite.com/privacy-policy.

Ignite Healthwise, LLC ("we" or "Healthwise") offers evidence-based, medically-reviewed health education resources, including videos, care instructions, post-discharge education, shared decision making tools, and articles on medical conditions, wellness, symptoms, tests, and treatments that are primarily used by health systems, physician groups, care management companies, and health plans to better educate their patients and clients.

When you use our products and services or when you interact with us, you trust us with your Personal Data. We want to keep that trust by being transparent about our privacy practices - including how and why we process (that is, collect, use, store, manipulate, disclose, transfer and share) your Personal Data. We also want you to understand how we support privacy rights and safeguard your Personal Data.

When used in this Privacy Notice, “Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an Individual (as defined below), and includes “personal data” or “personal information” as used in various applicable data protection laws. Data that cannot be associated with you, such as aggregated, de-identified or anonymized information, is not Personal Data.

To make this Privacy Notice easier to understand, we have provided a summary to the left-hand side of each section. We also encourage you to Contact Us if you have any questions or concerns. If you have a disability and need this policy provided to you in a different format, please email privacy@healthwise.org or call customer support at 1-800-706-9646.

1. SCOPE OF THIS PRIVACY NOTICE

This Notice applies to Individuals, anywhere in the world, who interact with us or who use Healthwise products and services. 

Healthwise believes in the importance of privacy rights and has adopted a global perspective on privacy. This Privacy Notice (“Notice”) covers our privacy and information practices and applies to our websites, products, applications, physical facilities, and related services (collectively, “products and services”). 

When you use our products and services or when you interact with us, you trust us with your Personal Data. We want to keep that trust by being transparent about our privacy practices - including how and why we process (that is, collect, use, store, manipulate, disclose, transfer and share) your Personal Data. We also want you to understand how we support privacy rights and safeguard your Personal Data. 

2. YOUR RIGHTS AND PREFERENCES

Healthwise allows you to exercise your privacy rights and manage how we use your information. 

Privacy and data protection laws in different countries and regions around the world give individuals certain rights in relation to their Personal Data. We conduct our privacy practices according to this global Privacy Notice and the relevant and applicable laws of the countries or regions in which we interact with you through our products and services. If you have questions regarding your privacy rights, Healthwise encourages you to visit the Contact Us page and reach out directly through the online form.

3. TYPES OF INFORMATION WE COLLECT

We collect information that relates to you and your interactions with Healthwise.

1. Data You Provide
   
   • When you interact with us, we may collect Personal Data, such as your first and last names, business address, job title, company, interests, email address, phone number, IP address, and account username and password.
   • Providing us with some Personal Data may be required in order for you to interact with us or to use our products and services.
   • You may be invited to provide additional Personal Data to personalize your interactions with us and your use of our products and services.
   • If you work at Healthwise or are applying to work at Healthwise, Personal Data will be required in order for you to apply for, be considered for and maintain employment with Healthwise. Our employment policies and practices, such as our Employment Privacy Notice, provide additional information regarding our privacy practices for application and employment matters.
      
2. Personal Data from Client Users and Third Parties
   If you interact with Healthwise through an entity that has licensed a product or service directly from Healthwise or sublicensed it through an authorized Healthwise sublicensor, such as a healthcare provider organization (“Client User”) or third party, we may receive Personal Data about you from that Client User or third party when these parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us. Some of the Personal Data we may receive from Client Users about “End Users” which include consumers, patients, or other individuals receiving access to Healthwise products and services from a Client User, include:
   
   • First and last names, email address, username and password, birthdate, age, gender, gender identity, patient ID number, team member ID number, occupational information, health information and product and service interaction data.
   • We may use third party services to supplement, validate or increase the accuracy of Personal Data that you give to Healthwise.
   • If you are accessing Healthwise products and services through a website hosted by a Client User or other third party that is not Healthwise, the Personal Data that you share with them is not controlled by Healthwise or covered by our privacy practices. We encourage you to review their policies and privacy settings so that you understand how the Personal Data you share with them may be used or shared with others.
      
3. Automatic Functional Information
   We may automatically collect some usage information when you interact with us. For instance, we use cookies and other tracking technologies to automatically collect technical information, such as URL, cookie data, IP address, device type, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, operating system, and products and services information.
    
4. Derived Information
   Healthwise may use information we have about you to draw inferences and we may then use those inferences to gain a more complete understanding of your preferences. We use preference data in order to offer you potential choices, make recommendations, or to alert you to products or services that may be of interest to you.
    
5. Children’s Information
   Healthwise products and services are intended for and directed to adults, not children. If you are under 16, do not supply any Personal Data to Healthwise. If you are aware that we have unintentionally collected information from someone who is underage, please notify us immediately by emailing us at privacy@healthwise.org.

4. HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Data to develop and provide our products and services to you, and to personalize, improve and promote our interactions with you.

Unless we specifically disclose otherwise, you understand that we may use any of your collected Personal Data for any of the purposes described in this Notice (as permitted by applicable law), including:

1. For Account Registration and Servicing
   
   • We may use your Personal Data to create, maintain, supplement, service, change or delete your customer account with us.
   • If you have a customer account with us, we may collect certain Personal Data for security purposes in order to verify your authorized access to your accounts with us.
   • We may use your Personal Data to resolve customer service questions you may have about our products and services and to follow up with you about your experience.
      
2. To Communicate with You
   
   • We may use your Personal Data to communicate with you about our products and services or your use of them.
      
3. To Improve and Develop New Products and Services
   
   • We may use your Personal Data to personalize your interactions and experiences with us.
   • We may use your Personal Data to improve the quality of and to develop new products and services.
   • We may use any information you give to us in surveys or other forms of feedback.
   • We may use any information you give to us to better understand our products and services and how we may improve them.
      
4. To Provide Our Products and Services and Operate Our Business
   
   • We may use your information to operate our business, including fulfilling your requests and providing you with technical or customer support, and to help us protect our products and services, including to combat fraud and protect your information.
   • We may conduct research using your information alone or in combination with that of other customers. When we share that research outside of Healthwise for research, academic, marketing and/or promotional purposes, we do so in an aggregated or deidentified way such that no individual person or household is identifiable.
      
5. For Your Participation in our Sweepstakes, Contests or Giveaways
   
   • We may use your contact information in connection with any Healthwise sweepstakes, contests or giveaways in which you choose to participate. Healthwise may retain and use contact information you provide in order to contact you if you win a prize in the sweepstakes, contests or giveaways and to send you additional information about our products and services. If you do not wish to provide your contact information, you do not have to enter the sweepstakes, contests or giveaways.

5. HOW WE SHARE YOUR PERSONAL INFORMATION

We will only share your information as we have described in this Notice, and only (i) in accordance with your consent and elections, (ii) to comply with legal obligations, (iii) to protect and defend Healthwise, (iv) as part of a corporate transaction, (v) as de-identified or aggregated information, or (vi) as otherwise legally permitted.

1. Third Party Service Providers
   With your permission or at your direction, we may disclose your Personal Data to third party service providers who we contract with to help us provide our products and services and operate our business. For example, your Personal Data may be shared when you authorize a third-party application to access your account. In correlation with Healthwise’s use of your Personal Data as stated in Section 4 above to fulfill your requests, provide you with technical or customer support, and to help us protect our products and services, including to combat fraud and to protect your information, we may also share your Personal Data with third party service providers for these purposes. If you use our products and services your Personal Data may be shared with the following third party service providers:

   Sub-Processor	Purpose	Primary Location
   Demandbase, Inc.	Market Intelligence	San Francisco, CA USA
   Microsoft Corporation	Cloud Services	Redmond, WA USA
   New Relic, Inc.	Cloud Infrastructure Monitoring	San Francisco, CA USA
   Okta, Inc.	Identity Management	San Francisco, CA USA
   Redox, Inc.	API Exchange	Madison, WI USA
   Salesforce	Customer Relationship Management Tool, Email Campaigns, Web Page Activity Tracking	San Francisco, CA USA
   SendGrid, Inc.	Email Fulfillment	Denver, CO USA
   Twilio, Inc.	SMS Messaging	San Francisco, CA USA

2. Following the Law and Protecting Healthwise
   We may share your information with courts, law enforcement or regulatory agencies, or other government bodies when we have a good faith belief we are required or permitted to do so by applicable law, regulation, or legal process. We may also disclose your information if we believe it is appropriate to protect the rights, property or safety of Healthwise and our products and services, or to protect or assist others as required by law or contract.
    
3. Sale of Our Business
   If we sell, merge, or transfer any part of our business, information about you may be shared, sold or transferred as part of that transaction. We may also share your information with current or future corporate parents, subsidiaries or affiliates.
    
4. De-identified or Aggregated Data
   We may de-identify or aggregate your information, alone or in combination with other Individuals’ information, and share such de-identified or aggregated information, subject to any restrictions in our contract with a Client User, if applicable.
    
5. With your Consent
   Other than as set out above, we may also share your Personal Data and your information for other purposes with your consent or at your direction.

6. DATA TRANSFERS

Healthwise uses appropriate data processing measures to safeguard Personal Data. 

Where permitted by applicable law, we may process your Personal Data in any country or region where we have facilities, business operations, or in which we engage service providers. By using our site or our products and services, you consent to the transfer of your Personal Data to, and the processing of your Personal Data in, countries outside of your country of residence or the point of collection as such may be needed to achieve our disclosed purposes.

Healthwise is based in and operates from the United States, however some of our Client Users or service providers may be based in other countries. Some of those countries may have data protection laws that are different from the laws of the United States or of your country. Healthwise has taken reasonable and appropriate measures to safeguard your Personal Data when it is being processed by us or by our Client Users or service providers.

Please contact us directly using the form on the website to learn more about your rights with respect to data transfers and to request access to, limit the use of, or limit the disclosure of, your Personal Data. If you make a request that involves Personal Data, you will need to provide certain authentication and verification information in order for us to respond to your request.

7. CONNECTING WITH THIRD PARTIES

Healthwise may work with third parties to enhance your experience.

In your interactions with us, it may be necessary for us to sync, link or connect your information with third parties, including providing Personal Data necessary to identify or authenticate your requested interactions. Your consent for these interactions will be required by us, by the third party or by both. We encourage you to review the privacy practices of any third party that you choose to share your Personal Data with, as we are not responsible for the privacy practices of third parties. 

8. MANAGING YOUR DATA AND PRIVACY

You have a choice about the use and retention of information that identifies you, marketing communications you receive from us, and our use of cookies and other tracking technologies.

You can review and change your information in your account settings, but we may retain certain information. While you have the right to select whether you receive promotional messages, you may still receive other non-promotional messages from us. 

1. Managing Marketing Communications From Us
   We will honor your choices when it comes to receiving marketing communications from us. If you have received marketing communications from us that you no longer wish to receive, you may:
   
   • Contact Us to manage your data and adjust your preferences regarding your Personal Data and your interactions with us.
   • Click the "unsubscribe" link in the email or newsletter you received.
   • For SMS messages, reply "STOP" or follow the instructions in the message or settings to discontinue the communications.
   • Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications.
      
2. Updating Your Personal Data
   You may access, update, change, correct or request deletion of your Personal Data by contacting compliance@healthwise.org.
    

3. Cookies and Similar Tracking Technologies
   We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies ("Cookies”) to collect information about you. We use this information to improve your experiences when you interact with us. You have control over some of the data we collect from Cookies and how we use it. For details about these technologies and the information that they collect, use or share, including how you may be able to control or disable these applications, please visit the following websites:

   • Criteo
   • Digital Advertising Alliance
   • Network Advertising Initiative
   • Interactive Advertising Bureau (IAB) Europe
   • Google Privacy and Terms
   • Adobe Privacy

   
   Please note that if you elect not to enable Cookies, some website functionality may be impaired. Also, if you elect to receive Cookies and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your choices.

4. Do Not Track 
   Like most other companies, we are not currently configured to respond to browser "Do Not Track" signals because, at this time, no formal "Do Not Track" standard has been adopted or enabled.
    
5. Social Media Features
   Healthwise or our authorized third parties may use social media features to gather certain information about you. These features may collect your IP address, log which page you are visiting, and may set a cookie to enable the feature to function properly. Your interactions with these social media features are governed by the privacy policies and practices of the providing company.

9. DATA COLLECTION, RETENTION AND YOUR ACCESS RIGHTS.

You may have the right to exercise certain data protection rights, including the right to request the deletion of, amendment of or access to your Personal Data.

These rights may depend on the country or region in which you are resident.

You may always contact your local data protection authority regarding the use of your Personal Data.

Healthwise will not discriminate against you for exercising your privacy rights.

Healthwise has adopted a global view on privacy with the intent of providing our customers with strong privacy rights regardless of where they reside. We believe that privacy is important, and we have attempted to recognize and implement high standards for privacy rights compliance by recognizing the tenets of the California Consumer Privacy Act of 2018 (“CCPA”) as our standard for providing privacy protections to individuals.

1. Data Collection. Collection, Use and Disclosure of Personal Data
   In the preceding twelve (12) months, Healthwise or its customers collected or processed all of the Personal Data in Section 3 of this Privacy Notice about Individuals. Depending on the products and services used by an Individual, Healthwise may not have collected or processed such Personal Data directly from Individuals but through its Client Users or other third parties.
    
2. Right to Opt-Out of Sale of Personal Data
   Healthwise does not sell your Personal Data. We allow you to opt out of sharing your Personal Data. We allow you to change these settings in the following ways:
   
   • by visiting the Contact Us page; or
   • by calling customer support at 1-800-706-9646 for assistance with your opt out settings.
      
3. Right to Access or Delete Personal Data
   Healthwise wants to be transparent about the Personal Data that we collect and process. You may request that we:
   
   • Provide you with a list of the categories of Personal Data we have collected or disclosed about you in the last twelve months; the categories of the sources of the Personal Data; and the categories of the third parties with whom we share that Personal Data.
   • Provide access to and/or a copy of Personal Data that we hold about you.
   • Delete certain Personal Data that we hold about you, unless Healthwise is legally required to retain it.
   • Correct inaccuracies in your Personal Data, or complete incomplete data.
      
4. Submitting a Request Regarding Your Privacy Rights
   
   • Please Contact Us to submit your request via email (preferred), regular mail or telephone.
   • Once you have submitted a request, Healthwise will respond to you using the contact information provided in your request to contact you and will attempt to verify your identity and authenticate your request. This is required in order for Healthwise to fulfill your request.
   • We will respond to properly submitted and verified requests for disclosure, access and deletion within 30 days.
   • You will receive a confirmation by email of either the completion of your request or a return response with your requested data. If we are unable to verify your identity, we will not be able to process access or deletion requests.
   • If you are unable to make a request directly (or in the case of death of the Individual), you may legally designate an agent by providing a notarized authorization, power of attorney or other legally binding designation of assignment of rights. Please provide proof of this agency along with your request and we will process your request as quickly as possible.
      
5. Data Retention
   Healthwise retains and uses your information in accordance with and as permitted by applicable law and regulations:
   
   • We will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business.
   • When you close your account, we may continue to communicate with you about our products and services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have elected to not receive marketing communications from us.
   • We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones.
   • We will retain and use your information as required by applicable regulations and Healthwise's records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.
      
6. Responses from Healthwise
   While your data protection rights may vary depending on the country or region in which you are located, Healthwise will respond to all requests from Individuals regarding the exercise of the following data protection rights:
   
   • Accessing, correcting, updating, or requesting deletion of your Personal Data;
   • Objecting to or asking us to restrict the processing of your Personal Data;
   • Requesting the portability of your Personal Data and providing the same in a timely manner and at no charge;
   • Electing whether or not to receive marketing communications from us;
   • Withdrawing your consent at any time for us to process your Personal Data (noting that such withdrawal will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect otherwise lawful processing).
      
7. Data Controller and Data Processor
   Under various data privacy regulations, Healthwise is considered to be a “controller” of Personal Data that we collect directly for our own processing purposes. We are considered to be a “processor” of Personal Data that is provided to us by some third parties and Client Users. You should contact those third party controllers if you have any questions about how they use your information.

10. SECURITY OF YOUR INFORMATION

We provide reasonable and appropriate security measures in connection with securing Personal Data we collect. 

Keeping your Personal Data safe is important to us. At Healthwise we:

• Constantly work to update our security practices to implement accepted best methods to protect your Personal Data and review our security procedures carefully.
• Comply with applicable laws and security standards.
• Enable secure transmission measures for your sensitive Personal Data.
• Train applicable employees and contractors on data privacy and require them to safeguard your data.

11. CHANGES TO OUR PRIVACY NOTICE

We may make changes to our Privacy Notice or our supporting privacy procedures at any time. 

From time to time we may change or update this Privacy Notice. We reserve the right to make changes or updates at any time and without prior notice to you.

If we make material changes to the way we process your Personal Data, we will provide you notice by posting the most current version of this Notice on our websites and we may also advise you of changes via our products and services information, or by other communication channels, such as by email, newsletters or community post.

If you object to any changes and no longer wish to use our products and services, you may close your accounts and cease use of our products and services. All changes to this Notice are effective immediately upon posting and your continued interaction with us or your use of our products and services after a posting of an updated Privacy Notice shall constitute your consent to all changes.

12. HOW TO CONTACT US

If you have questions or comments about this Notice, you may contact us by email, telephone or direct mail. Email is the fastest and most-preferred way to reach us with your data management or privacy related questions and concerns.

Via Email: privacy@healthwise.org 
Via Telephone: 1-800-706-9646 
Via Direct Mail: Attn: Legal, Ignite Healthwise, LLC 283-299 Market Street Gateway Center 2, 4th Floor Newark NJ 07102