Last Updated and Effective: July 26, 2023
2. Who We Are
The Service is operated by HIRC, a trade association as described in Section 501(c)(6) of the Internal Revenue Code of 1986 with offices at 4446 Arcon Lane NW, Rochester, MN 55901.
3. Collection of Personal Information
Personal Information We Collect
To provide Our Service, We may collect and process information that is defined as personal information under applicable privacy laws (“Personal Information”). We collect and process the following categories of Personal Information (note, specific Personal Information elements are examples and may change):
Audio/Visual Data – Audio/video files and records, such as webinar recordings and voicemails.
Contact Data – Personal Information about you and used to contact you, e.g. email address, physical address, or phone number.
Device/Network Data – Personal Information relating to your device, browser, or application e.g. device identifiers, IP address, identifiers from cookies, session history and Service navigation metadata, and other data generated through applications and browsers, including via cookies and similar technologies.
Financial Data – Information such as bank account details or payment card information and relevant information in connection with a financial transaction.
General Location Data – Non-precise location data, e.g. location information derived from IP addresses.
Inference Data – Personal Information We create or use as part of a profile reflecting your preferences, characteristics, aptitudes, market segments, likes, favorites or interests.
Usage Data – Data about your activity on and use of Service, such as site performance data, browsing metadata; device and software interactions; user navigation flows; clickstream data; software and device crash data, performance and other diagnostic data; and other device connectivity data.
User Content – Personal Information included in content provided by users of the Service in any free-form or unstructured format, such as in a “contact us” box, free text field, file, document, or message to us.
How We Collect Personal Information
We collect Personal Information from various sources based on the context in which the Personal Information will be processed:
Data We collect from you – We collect Personal Information from you directly, for example, when you input information into an online form, or contact Us directly.
Data collected automatically – We may collect certain Personal Information automatically. For example, We collect Device/Network Data automatically using cookies and similar technologies when you use Our Service, access Our Service, or when you open Our communications.
Data We receive from service providers – We receive Personal Information from service providers performing services on Our behalf.
Data We receive from members, collaborators, partners, and sponsors – We receive Personal Information from HIRC members, collaborators, partners, or sponsors who seek to collaborate on and/or support HIRC initiatives.
4. Use of Personal Information
When you use Our Service, We automatically collect and process Contact Data, Usage Data, and Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through Our Service, such as delivering pages, logging activities for security purposes, etc. We may also process this Personal Information for Our Business Purposes (described below).
Posts and Forums
We process Inference Data, Usage Data, Contact Data, and the User Content you post (e.g. comments, forum posts, etc.) on Our Service. We process this Personal Information for Our Business Purposes (described below).
Posts may be public, or reposted on Our Service. Content you provide may be publicly available when you post it on Our Service, or in some cases, sent to other members via informational email notifications.
Account and Membership
When you create an account with Us and/or sign up for a HIRC membership, We may collect Contact Data, Device/Network Data, Usage Data, and User Content. If you become a paid member, We process Financial Data. We process this Personal Information to open and maintain your account, provide you with information relevant to your account, and otherwise provide the features and services you request. We may use your Personal Information to respond to any emails or other communications you send to us, to advise you of any changes to Our Service, or to advise you of any problems with Our Service. In addition, subject to applicable law, we may also enroll you in informational or promotional communications, e.g. with information regarding services in which we believe you may be interested. You may opt-out of receiving our marketing communications by contacting us directly at [email protected], by following the “unsubscribe” process at the bottom of the email. We may also use this Contact Data, and Device/Network Data collected in this context for Our Business Purposes and Commercial Purposes. For more information, please review the HIRC Membership Agreement.
Informational or Promotional Emails
We may process Device/Network Data, Usage Data, and Contact Data in connection with email communications relating to Our Service, or if We send you communications. You may receive such email communications if you contact us, choose to receive them, or interact with Us in way that allows Us to send you those communications. We may also automatically collect Device/Network Data when you open or interact with those communications so that We can better understand engagement with Our communications. We may also process this Personal Information for Our Business Purposes and Commercial Purposes (described below).
We may process Audio/Visual Data, Contact Data, and General Location Data when you attend an information event, such as a workshop or webinar. We may also process Audio/Visual Data if an informational event is recorded.
We use this Personal Information as necessary to provide educational resources and services to Our members and to support Our mission of solving for a more transparent and resilient supply chain. We may also process this Personal Information for Our Business Purposes and Promotional Purposes.
When you contact Us though the Service using a contact us box or via email, We process Personal Information such as Contact Data, Device/Network Data, and any Personal Information contained within any User Content. We use Contact Data and User Content as necessary to communicate with you about the subject matter of your request and related matters. We may also process this Personal Information for Our Business Purposes (described below).
Cookies and Similar Tracking Technologies
- for “essential” purposes necessary for Our Service to operate (such as maintaining user sessions, content delivery, and the like);
- for “functional” purposes, such as to enable certain features of Our Service (for example, to allow a customer to maintain a logged-in session);
- for “analytics” purposes and to improve Our Service, such as to analyze the traffic to and on Our Service (for example, We can count how many people have looked at a specific page, or see how visitors move around the Service when they use it, to distinguish unique visits/visitors to Our Service, and what website they visited prior to visiting Our Service, and use this information to understand user behaviors and improve the design and functionality of the Service); and
We may also process this Personal Information for Our Business Purposes.
We may also work with third-party marketing companies that help deliver online marketing to you. See your Rights & Choices for information regarding opt-out rights for cookies and similar technologies and in relation to Online Advertising.
5. Purposes of Processing
In addition to the uses described above, We generally process Personal Information for several common purposes in connection with Our business (“Business Purposes”). Please see below for more information regarding the purposes for which We process your Personal Information.
Operate Our Service and Fulfill Obligations – We process any Personal Information as is necessary to provide the Service, and as otherwise necessary to fulfill Our obligations to you, e.g. to provide you with the information, features, and services you request.
Internal Processes and Service Improvement – We may use any Personal Information We process through Our Service as necessary in connection with Our improvement of the design of Our Service, understanding how the Service are used or functions, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to Service use, and for ensuring the security and stability of the Service. Additionally, We may use Personal Information to understand what parts of Our Service are most relevant to users, how users interact with various aspects of Our Service, how Our Service performs or fails to perform, etc., or We may analyze use of the Service to determine if there are specific activities that might indicate an information security risk to the Service or Our users.
Analytics – We process Personal Information as necessary in connection with Our creation of analytics relating to how Our Service is used, the pages and content users view, and the creation of other reports regarding the use and performance of Our Service and other similar information and metrics.
Corporate Events – Your Personal Information may be processed as part of routine corporate operations, as part of corporate reorganizations, or any business transition, such as a merger, acquisition, liquidation, or sale of assets.
Other Processing of Personal Information – If We process Personal Information in connection with Our Service in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated when you provide it.
We and certain third parties process Personal Information to further Our commercial or economic interests (“Commercial Purposes”) depending on the context of collection and your rights and choices.
Marketing Communications – We may send you marketing and promotional communications if you sign up for such communications or with your consent after you register for an account or membership. These communications may be personalized based on your user profile
6. Data Sharing
Information We collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific Business Purposes, as described below.
Service Providers and Volunteers – In connection with Our general business operations, service improvements, enabling certain features, and other lawful business interests, We may share Personal Information with service providers, subprocessors, and volunteers who provide certain services to Us or process data on Our behalf. For example, We may use third party hosting providers to host Our Service or Content, and We may disclose information as part of Our own internal operations, such as security operations, internal research, etc.
Corporate Events – Your Personal Information may be disclosed to a third party in the event that We consider or go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of Our assets. For example, Personal Information may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
Partners and Affiliates – To streamline certain business operations and develop services that better meet the interests and needs of Our customers, We may share your Personal Information with any of Our current or future affiliated entities, subsidiaries, and parent companies.
Advertisers and Sponsors – We may share certain Personal Information with advertisers and sponsors in support of Our Business Purposes and Commercial Purposes. We may allow these third parties to operate through Our Service.
7. Your Rights & Choices
Applicable law may grant you rights in your Personal Information. These rights vary based on your location and state/country of residence, and may be limited by or subject to Our own rights in your Personal Information. You may submit requests to exercise rights you may have by contacting Us at [email protected].
All rights requests We receive directly must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Information. For example, We may require that you verify that you have access to the email on file in order to verify your identity. If an agent is submitting the request on your behalf, We reserve the right to validate the agent’s authority to act on your behalf.
Note: We are able to fulfill rights requests regarding Personal Information that We control or process. We may not have access to or control over Personal Information controlled by third parties. Please contact the third party directly to exercise your rights in third party-controlled information.
You may have the following choices regarding the Personal Information We process, to the extent required under applicable law:
Changing Your Information – To change Your information, please contact us at [email protected].
Closing Your Account – If the email account associated with Your email address is not active, We may remove it from Our system without notice. To close Your account, please email us at [email protected].
Consent – If you consent to Our processing of Personal Information, you may withdraw your consent at any time. You may be required to close your account to withdraw consent where your consent is necessary to perform essential aspects of Our Service.
Email Marketing – You have the choice to opt-out of or withdraw your consent to email marketing communications. You may exercise your choice via the links in Our communications.
Do-Not-Track – Your browser or device may offer You a “Do Not Track” option, which allows You to signal to operators of websites, web applications, mobile applications, and services (including behavioral advertising services) that You do not wish such operators to track certain of Your online activities over time and/or across different websites or applications. The Service does not support Do Not Track requests at this time, which means that We or Our analytics providers or other third parties with which We work may collect information about Your online activity both during and after Your use of the Service.
We implement a variety of security measures to protect the safety of Your Personal Information when You enter, submit, or access Your Personal Information. Please keep Your account password secure to help ensure the safety of Your Personal Information.
While We take certain measures to protect the information You submit via the Service against loss, theft, and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through the Service may not be secure. You should use caution whenever submitting information through the Service and take special care in deciding with which information You provide us.
We cannot guarantee that transmissions of Your Personal Information will be fully secure and that third parties will never be able to defeat Our security measures or the security measures of Our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.
If you use the Service outside of the United States, You consent to having Your data transferred to the United States, where it may be accessible to law enforcement of other authorities pursuant to lawful request.
9. Data Retention
We retain information for so long as it, in Our discretion, remains relevant to its purpose, and in any event, for so long as is required by law or regulation. We may maintain anonymized, pseudonymized, or aggregated data, including usage data, for analytics purposes. We may retain and use Your information as necessary to comply with Our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information We have collected may be required for the Service to function properly.
10. Links to Other Websites or Applications
Our Service is neither directed at nor intended for use by people under 18 years of age or minors under the age of majority in a relevant jurisdiction. Further, We do not knowingly collect Personal Information from such individuals. If We learn that We have inadvertently done so, We will promptly delete it.
12. International Transfers
We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Information may be processed in the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Information in other countries.
13. Changes to Our Policy
We may change this Policy from time to time. Please visit this page regularly so that you are aware of Our latest updates. Your use of the Service following notice of any changes indicates acceptance of any changes.
14. Contact Us
Feel free to contact us with questions or concerns at [email protected].
15. Your Nevada Privacy Rights
The Nevada Revised Statutes (NRS 603A.300 et seq.) permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. If You are a Nevada consumer, You may submit a request pursuant to this directive by emailing us at [email protected]. We will provide further information about how We verify the authenticity of the request and Your identity.
16. Your California Privacy Rights
Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of Personal Information the business has shared with third parties for those third parties’ direct marketing purposes, and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. If You are a California resident, You may make one request each year by emailing Us at [email protected], or by writing Us at Healthcare Industry Resilience Collaborative, 4446 Arcon Lane NW, Rochester, MN 55901.