Wednesday May 26, 2021
Effective March 12, 2021
1. Information We Collect and How We Use It
ASHHRA collects information from several sources. Our Web server automatically collects the domain name and Internet Protocol (“IP”) address for each visitor to our websites. We collect information about the usage of our websites. In addition, we may request or require you to provide personally identifiable information and/or create an account in order to access certain services or engage in certain activities on a website. The information collected depends on how you choose to use our services and our websites, as detailed below.
a. Commonly Accepted Practices
Information collected may be used for commonly accepted practices, including:
- Product service fulfillment, such as the use of addresses for shipping and credit card information for payment;
- Sending electronic publications to online subscribers;
- Administration of our websites and monitoring usage of our websites;
- Internal operations, such as the use of identity-verification technologies, and the review of server logs;
- Legal compliance and public purposes, such as subpoena compliance and credit reporting;
- Registration and participation in ASHHRA products, services, and communities; and
- Marketing of products and services to you by ASHHRA, such as the recommendation of products or the delivery of coupons based upon prior purchases.
b. Information Collected to Create an Account
There are times when ASHHRA may request or require you to create an account with us in order to obtain certain services. In such cases we may collect user name or ID and password information from you. We use this information to verify users’ identities in order to prevent unauthorized access to users’ personal information. ASHHRA allows account holders to elect to have the website remember their login information between visits so they do not have to log in each time. This is done by checking a box labeled “remember me” on the login page. This feature requires the placement of a small text file called a cookie (see next section) on the user’s hard drive. The cookie tells the site that the user has logged in before. As part of registering for some of ASHHRA’s products and affiliates, we may collect contact and demographic information such as your name, address, email address, etc. We may also collect information regarding your personal and professional history, interests, activities, experiences and interests in health care products and services. Certain information may be required in order to complete the registration process.
d. Email Addresses and Mailing Lists
ASHHRA collects and uses the email addresses and mailing addresses of its members (see Section 2. Members’ Information, below) for purposes of providing membership benefits and services to members. In addition, ASHHRA collects email and mailing addresses in connection with registration for and attendance at conferences, webinars and other events, subscriptions for publications, the purchase of products and services, and in other circumstances. We may use your e-mail address or other personally identifiable information to send commercial or marketing messages to you regarding ASHHRA’s products or services. In addition, we may also use your name, mailing address, email address, or other personally identifiable information (i) to send commercial or marketing messages on behalf of our affiliated organizations or on behalf of unrelated third parties, and/or (ii) in a mailing list sold to third parties for the marketing of their products and services. For example, we may share contact information you provide when you register for a conference or webinar with conference exhibitors or webinar sponsors so that they may send you commercial messages. You may opt-out of any or all of such disclosures as provided below.
Our online surveys may ask respondents for contact, demographic and other personally identifiable information. The ways in which such information may be used or disclosed will be described in the survey materials. We also may use contact information from our surveys to send the user information about products and services of ASHHRA, our affiliated organizations and/or unrelated third parties.
f. Information from Other Sources
The information we collect is gathered from several sources. Such sources may include, but are not limited to: membership enrollment; conference, webinar, distance learning and other event registration; website visits; newsletter and magazine subscriptions; and product sales. We may combine the information you submit when using one of our services with information (i) collected from your use of other ASHHRA services, (ii) collected by ASHHRA affiliated organizations, or (iii) obtained from third parties. The combined information may be used in a similar manner to any other information we collect.
2. Members' Information
a. Public Profiles
Some or all of the information ASHHRA collects from you as part of registrations of certain products and affiliates may be maintained in your account profile. This account profile will be visible to third parties accessing the Web Site except as set forth herein. We may make tools available for you in your account settings that will enable you to limit some of the data that will appear to third parties in your account profile.
3. Third Party Advertisers and Analytics
These third parties may view, edit, or set their own cookies. They may also collect non- personal and personal information concerning your online activities over time and across different websites. The information they may collect includes the other sites you have visited or applications that you have downloaded to your mobile device, and other information about you or your device in order to help analyze and serve targeted advertising on the Web Site and elsewhere. For more information about third party ad servers and your ability to opt-out of targeted advertising from such third parties, please visit the Network Advertising Initiative and/or the Digital Advertising Alliance Self-Regulatory Program for Online Behavioral Advertising.
ASHHRA does not provide any personally identifiable information to these third party ad servers or ad networks without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out.
4. How We Respond to “Do Not Track” Signals
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” from a visitor’s browser. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
5. Social Media Interactions and Third Party Links
ASHHRA’s websites and publications contain many links to other websites. In addition, ASHHRA and its affiliates may maintain a presence on third-party sites such as Facebook® or Linked-In®. These other websites may send their own cookies to users, collect data or solicit personal information. ASHHRA is not responsible for the privacy practices or the content of these other websites. Please check with the other sites to review their privacy policies and how they may collect or use information.
6. Information Sharing
In the unlikely event that ASHHRA or one of its affiliated organizations is acquired, or substantially all of the assets of ASHHRA or one of its affiliated organizations are acquired, by a third party either in a sale, bankruptcy court proceeding or otherwise it is possible that personal information of website users and customers would be one of the assets transferred. In such an event, ASHHRA would take reasonable steps to require the third party to maintain our privacy policies and practices.
In addition, ASHHRA may disclose personally identifiable information to third parties, but only:
- to contractors we use to support our business, provided they only use the personally identifiable information for ASHHRA purposes;
- to respond to law enforcement requests, where required by applicable laws, court orders, warrants, subpoenas (whether civil or criminal) or governmental regulations.
- in situations involving threats to the physical safety of any person;
- in connection with joint ventures with third parties; or
as necessary to enforce our rights in connection with the Web Site.
7. Information Security
Please understand that no one can give an absolute assurance that information intended to be maintained as private, whether transmitted via the Internet or otherwise, cannot be accessed inappropriately or unlawfully by third parties. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a computer. We have taken and will continue to take reasonable steps to ensure the secure and safe transmission of your personal information.
8. Children's Privacy
The ASHHRA website is not intended for children under eighteen (18) years of age. ASHHRA does not knowingly solicit or collect personal information from or about any such children, and ASHHRA does not knowingly market its products or services to any such children. If ASHHRA becomes aware that it has inadvertently received personal information from a User under the age of eighteen (18), it will delete such personal information from its records.
9. Consent to Transfer
ASHHRA is based in the United States and the information we collect is governed by United States law. By accessing or using the Web Site or providing us with any information, you consent to the transfer, processing and storage of your information in and to the United States and other countries, jurisdictions in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
IF FOR ANY REASON ASHHRA WOULD LIKE TO USE THE INFORMATION YOU HAVE SUBMITTED FOR SUBSTANTIALLY DIFFERENT PURPOSES OTHER THAN THOSE OUTLINED AT THE TIME YOU ORIGINALLY SUBMITTED YOUR INFORMATION, ASHHRA WILL AFFIRMATIVELY REQUEST PERMISSION FROM YOU TO USE SUCH DATA FOR THOSE SUBSTANTIALLY DIFFERENT PURPOSES PRIOR TO USING THE DATA.
11. Accessing and Updating Personal Information
You may request access to your personal information, corrections and/or deletions of the same by using the Contact Information set forth below. We will use reasonable, good faith efforts to promptly address your concerns, subject to legal retention obligations and legitimate business needs.
When making a request, individual users are asked to identify themselves and the information requested to be accessed, corrected or removed. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. Correcting or removing data is done free of charge to the user unless doing so requires a disproportionate effort. After deleting your information from active servers, copies may remain in our backup system.
12. Marketing Emails and Mobile Messages
You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Web Site or other ASHHRA services, such as administrative and services announcements. These transactional account messages may be unaffected if you choose to opt out from marketing e-mails.
If you sign up to receive SMS or MMS messages from ASHHRA, you may unsubscribe from any SMS or MMS messages received by replying “STOP”.
13. Contact Information and Opt-Out Requests
By email at ASHHRA@ashhra.org
By phone at 312-422-3720
By mail at American Society for Healthcare Human Resources Administration
c/o Compliance Officer
233 S. Wacker Dr., Suite 4400
Chicago, IL 60606
We also welcome users’ requests not to receive certain forms of communication from ASHHRA and third parties and not to have certain information shared with nonaffiliated third parties. If you prefer that we not disclose your personally identifiable information to nonaffiliated third parties, you may request us not to make those disclosures (except as required by law) by contacting us as described above. If you elect to opt out of certain disclosures, we may not be able to offer you certain services and products. Please note that personally identifiable information does not include publicly available information that is lawfully made available to the general public from federal, state or local government records, widely distributed media or disclosures to the general public required by law.
14. LISTSERV® Email Lists and Social Media Sites
ASHHRA may offer opportunities to its members and others to share information and participate in social networking on ASHHRA websites or ASHHRA may participate in social media sites maintained by others. Please consult the Social Media Policy applicable to the particular website before participating in any social networking or content sharing activity.