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GLOBAL
MED-NET, INC.
PRIVACY POLICY
Global MED-NET, Inc. ("Global MED-NET")
respects individual privacy and values the confidence of its customers.
Global MED-NET strives to collect, use and disclose Personal information
in a manner consistent with state and federal privacy laws, as they
apply, and has a tradition of upholding the highest ethical standards
in its business practices. This Privacy Policy (the “Policy”)
sets forth the privacy principles that Global Med-Net follows with
respect to transfers of personal information anywhere in the United
States.
I. ENFORCEMENT
Global MED-NET has a Chief Privacy Officer who is responsible for
Global MED-NET's compliance with and enforcement of this Policy
and data security issues. Global MED-NET educates its employees
concerning compliance with this Policy and has self-assessment procedures
in place to assure compliance. Global MED-NET's Chief Privacy Officer
is available to any of its valued customers who may have questions
concerning this Policy or data security practices. Relevant contact
information is provided herein.
II. SCOPE
This Policy applies to all Personal information received by Global
MED-NET in any format including electronic, paper or verbal.
Global MED-NET collects and processes Personal
information concerning its potential customers manually and through
its Internet site. As an integral part of its business, Global MED-NET
collects and processes Personal information and Sensitive Personal
information from its customers in a variety of ways, including manually,
via telephonic means (including facsimiles), electronic mail, the
Internet or its Intranet site.
Global MED-NET is the sole owner of Personal
information it collects from its customers. Global MED-NET will
not sell or share this information with third parties in ways different
than what are disclosed in this Privacy Policy. On a national basis,
Global MED-NET will, and will cause its affiliates and business
partners to, establish and maintain business procedures that are
consistent with this Policy.
Personal information and Sensitive Personal
information collected by Global MED-NET from prospective customers
and customers may be maintained at its Operations Center in Naperville,
Illinois, or at its other sites. Global MED-NET collects Personal
information and Sensitive Personal information for, among other
things, legitimate business reasons such as customer service, meeting
governmental reporting and records requirements, maintenance of
accurate accounts payable and receivable records, internal marketing
research, safety and performance management, financial and sales
data, and contact information. All Personal information and Sensitive
Personal information collected by Global MED-NET will be used for
legitimate business purposes consistent with this Policy.
III. DEFINITIONS
For purposes
of this Policy, the following definitions shall apply:
"Agent" means any third party that
uses Personal information provided by Global MED-NET to perform
tasks on behalf of or at the instruction of Global MED-NET.
"Global MED-NET" means Global MED-NET,
Inc., its predecessors, successors, subsidiaries, parent company,
divisions and groups.
"Personal information" means any
information or set of information that identifies or could be used
by or on behalf of Global MED-NET to identify an individual. Personal
information does not include information that is encoded or anonymized,
or publicly available information that has not been combined with
non-public Personal information.
"Sensitive Personal information"
means Personal information that reveals race, ethnic origin, religious
or political beliefs, or that concerns health or sex life. In addition,
Global MED-NET will treat as Sensitive Personal information any
information received from a third party where that third party treats
and identifies the information as sensitive.
IV. PRIVACY
PRINCIPLES
(1) DATA INTEGRITY:
Global MED-NET will use Personal information only in ways that are
compatible with the purposes for which it was collected or subsequently
authorized by the individual. Global MED-NET will take reasonable
steps to ensure that Personal information is relevant to its intended
use, accurate, complete, and current.
(2) TRANSFERS TO AGENTS: Global MED-NET
will obtain assurances from its Agents that they
will safeguard Personal information
consistently with this Policy. Where Global MED-NET has knowledge
that an Agent is using or disclosing Personal information in a manner
contrary to this Policy, Global MED-NET will take reasonable steps
to prevent or stop the use or disclosure. Global MED-NET holds its
Agents accountable for maintaining the trust its employees and customers
place in the company.
(3) ACCESS AND CORRECTION: Upon request,
Global MED-NET will grant individuals reasonable access to Personal
information and Sensitive Personal information that it holds about
them. In addition, Global MED-NET will take reasonable steps to
permit individuals to correct, amend, or delete information that
is demonstrated to be inaccurate or incomplete. Any customer who
desires to review, correct or delete their information can do so
by contacting Global MED-NET, Inc., Membership Services, 1751 West
Diehl Road, Suite 400, Naperville, Illinois 60563, verifying their
identity and providing their membership number.
(4) SECURITY: Global MED-NET will take
reasonable precautions to protect Personal information and Sensitive
Personal information in its possession from loss, misuse and unauthorized
access, disclosure, alteration and destruction. Security is designed
to prevent unauthorized access to database equipment and hard copies
of Personal information and Sensitive Personal information and monitors
access to its servers to provide protection from hacking or other
unauthorized access. Global MED-NET limits access to Personal information,
Sensitive Personal information and data to those persons in Global
MED-NET's organization, or agents of Global MED-NET, that have a
specific business purpose for maintaining and processing such information
and data. Individuals who have been granted access to Personal information
or Sensitive Personal information are aware of their responsibilities
to protect the security, confidentiality and integrity of that information.
(5) ENFORCEMENT: Global MED-NET will
conduct compliance audits of its relevant privacy practices to verify
adherence to this Policy. Any employee who Global MED-NET determines
is in violation of this Policy will be subject to disciplinary action
up to and including termination of employment.
V. DISPUTE RESOLUTION
Any questions or concerns regarding the use or disclosure of Personal
information or Sensitive Personal information should be directed
to the Global MED-NET Privacy Inquiries Office at the address given
below. Global MED-NET will investigate and attempt to resolve complaints
and disputes regarding use and disclosure of Personal information
and Sensitive Personal information in accordance with the principles
contained in this Policy.
VI. INTERNET PRIVACY
Global MED-NET sees the Internet, Intranets and the use of other
technologies as valuable tools for communicating and interacting
with consumers. Global MED-NET recognizes the importance of maintaining
the privacy of Personal information collected through web sites
that it operates. Visitors on the Web may elect to voluntarily provide
Personal information via Global MED-NET web-sites but are not required
to do so. Global MED-NET collects information from visitors to the
web-sites who voluntarily provide Personal information by filling
out and submitting on-line questionnaires concerning feedback on
the web-site or requesting information on products or services.
In general, the Personal information voluntarily provided by web-site
users is contact information limited to the user's name, home and/or
business address, phone numbers and e-mail address. Global MED-NET
collects this information so that it may answer questions and forward
requested information. Global MED-NET does not sell this information
nor share this information with non-agent third parties. In addition,
Global MED-NET may offer customers the ability to subscribe as members
over the Web and/or to provide additions or corrections to their
information. In such event, customers will be required to provide
Sensitive Personal information to Global MED-NET, and Global MED-NET
may share this information with third parties in order to provide
its emergency medical storage and forwarding information services
to its customers in accordance with its membership program.
Global MED-NET may also collect anonymous
information concerning web-site users through the use of "cookies".
"Cookies" are small files that web-sites place on users’
computers to identify the user and enhance the web-site experience.
Visitors may set their browsers to provide notice before they receive
a cookie, giving them opportunity to decide whether to accept the
cookie. A visitor can also set their browser to turn off cookies.
If visitors do so, however, some areas of Global MED-NET web-sites
may not function properly.
Global MED-NET web-site users have the
option to request that Global MED-NET not use information previously
provided, correct information previously provided, or remove information
previously provided to Global MED-NET. Those who would like to correct
or suppress information they have provided to Global MED-NET should
forward such requests to Membership Services. The requests should
include the individual's name, address, and other relevant contact
information (phone number, e-mail address). Global MED-NET will
use all reasonable efforts to honor such requests as quickly as
possible.
Global MED-NET web-sites may contain
links to other "non-Global MED-NET" web-sites. Global
MED-NET assumes no responsibility for the content or the privacy
policies and practices of those web-sites. Global MED-NET encourages
all users to read the privacy statements of those sites; their privacy
practices may differ from those of Global MED-NET.
VII. CONTACT INFORMATION
Persons
who wish to obtain access to their Personal information or Sensitive
Personal information for purposes of correction or deletion should
contact the following:
| ACTION |
CONTACT |
MAILING ADDRESS |
| Access, Correct or Delete Personal
Information |
Membership Services |
Global MED-NET, Inc., Membership
Services
1751 West Diehl Road, Suite 400, Naperville, IL 60563
E-mail: membership@globalmednet.net |
Persons who wish to resolve a dispute
with Global MED-NET over its Privacy Policy should contact the following:
| ACTION |
CONTACT |
MAILING ADDRESS |
| Dispute Resolution |
Privacy Inquiries |
Global MED-NET, Inc., Privacy Inquiries
1751 West Diehl Road, Suite 400, Naperville, IL 60563
E-mail: privacyofficer@globalmednet.net
Attention: Chief Privacy Officer |
VIII. CHANGES TO THIS PRIVACY
POLICY
The practices described in this Policy are current as of April 1,
2002. Global MED-NET reserves the right to modify or amend this
Policy at any time consistent with state and federal privacy laws,
as they apply. Appropriate public notice will be given concerning
such amendments.
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