PDR Network, LLC Privacy Policy (Version 7.0)
Effective Date:   October 24, 2014


This Privacy Policy will inform you how PDR Network, LLC (“PDR Network”, “we” or “our”) collects, uses and secures personal information from healthcare professionals and other individuals and businesses in connection with PDR Network’s products and services.  It describes how PDR Network handles your personal information collected via the www.pdrnetwork.com Web site, the www.pdr.net Web site, other Web sites that link to this Privacy Policy, online registration, off-line PDR surveys, PDR mobile applications, and through your use of PDR BRIEF and other PDR products which are enabled in your electronic health records (“EHR”) systems, if applicable. By visiting our Web sites or using any of PDR Network’s products and services, you indicate your acceptance of our Privacy Policy.  

Site Ownership, Scope, and Applicability of this Privacy Policy:    
This Privacy Policy applies only when you are within the PDR Network-branded environment and only to information that PDR Network collects.  Our Web sites may provide direct links to various sponsor, marketing partner and other third party Web sites.  This Privacy Policy does not describe the practices or privacy policies of these third parties. Before disclosing personal information to any third party, you should read the privacy policy associated with that Web site, as PDR Network has no control over personal information submitted by you to, or collected by, such third parties.    

Other PDR Network Web sites (including consumer-focused sites such as www.pdrhealth.com and www.pdrbookstore.com) and services (such as the bookstore) are controlled by their own privacy policies.  These can be obtained by clicking on the Web site privacy policy link for such Web sites or contacting customer service at the number listed in the section of this Privacy Policy called “How to Contact Us with any Questions or Comments”.  

Information that We Collect:
If you want to interact with PDR Network on-line and take advantage of the materials available on the PDR Network Web site for qualified professionals (such as the annual PDR® Physicians Desk Reference book and FDA-approved PDR Drug Alerts), you may register and join the PDR Network professional community.  Registration is voluntary and free to qualified healthcare professionals.  Your email address and/or fax number will be used to send and administer Drug and Device Alert services, FDA-approved drug labeling information, and other clinically-relevant PDR services or information including but not limited to general or targeted promotional messaging, and patient adherence and pharmacy discount card information.  Our ability to provide products and services on behalf of our commercial clients allows us to provide our products and services free to you and other users.

In addition to Web site registration, PDR Network uses a variety of sources to keep our physician e-mail list up to date, including fielding physician surveys, alliances with medical societies, recruiting events and licensing from third parties which are authorized to license such emails.  When you join the PDR Network professional community through any of these means we collect contact information (such as name, office address, office phone and fax numbers, and e-mail address), and other personal information (such as information about your professional background, licensure, practice, and areas of specialization) as well as any other personal information that you choose to provide us.  

We will tailor the materials we provide you based on the information in your profile, such as your specialty. Please note that certain products (such as the PDR® Physicians Desk Reference book, FDA-approved PDR Drug Alerts, and pharmaceutical product sampling services) may only be available to qualified, credentialed professionals, so you may not receive access to all of the services we offer if we cannot confirm your qualifications for them.  

If you are a user of PDR Network products and services, we will also collect and use activity statistics so we can understand the ways in which our sites and services are being used and so that we can offer our users relevant and personalized experiences. For example, we will record information about the PDR activities in which you participate, newsletters you subscribe to, and Web sites, tools and other services that you use.  This activity-related data may also be shared with business partners and other third parties, on an identified or a de-identified basis.  

We may collect additional information about you from third party sources in order to assist us in providing our products and services, and we may combine them with the information that we collect directly from you or our interactions with you.   For example, if you are a physician, we will compare your name, medical school and other information with the American Medical Association database to help verify the accuracy of our subscriber database.

Children:
None of our sites or services are directed at children, and to our knowledge we do not collect any information about children.  We make every reasonable effort to ensure that we do not accept personal information from persons under 13 years of age.  

How We Use Your Personal Information:   
In general, we use the information we collect from you in order to:  
-           respond to your requests for information
-           provide you with PDR products and services and improve our products and services on an on-going basis  
-           determine if you are eligible to receive certain products or services  
-           provide customer service
-           better understand you so that we may tailor our communications and services based on your interests, preferences, needs and specialties  
-           provide you with additional services or information that we believe to be relevant and of interest to you, including marketing and educational
            materials from us and our sponsors, marketing partners and other third parties  
-           send you invitations via email and text messaging to participate in market research surveys and industry-sponsored or client-sponsored programs  

If you purchase a product from us (such as a book or newsletter subscription), you may provide us with a credit card number. This credit card number may be stored but will only be used and disclosed as needed to process your purchase. We will not disclose credit card numbers to any third party for any other purposes.  

When We Share Your Personal Information with Others:
We work with sponsors, marketing partners and other third parties to provide high quality products and services. We may provide your personal information to third parties as needed to fulfill your requests for products and services or to facilitate the delivery of appropriate notices to you.  For example, if you choose to participate in complimentary pharmaceutical product sampling programs, we will provide your information to the third party which is fulfilling such sampling, in accordance with the terms of the sampling program.   Unless you tell us not to (i.e. ‘opt-out’), we may provide information about you or your practice to third parties. We share our lists with selected business partners so that they may offer products or services which may be relevant and of interest to you.  For example, we may provide our commercial clients, such as pharmaceutical companies, with your identifiable information when you engage with such clients’ promotional content through our services and information about the type of engagement (e.g. whether you viewed, interacted with or requested information about such promotional content). However, we do not share or sell your e-mail addresses or fax numbers for third party marketing purposes.

We may also share your information with third party vendors, consultants and other service providers with whom we contract to help us provide our products and services (e.g. Web site hosting services).  Such companies are prohibited from using your personal information for their own purposes, and may only use your information to fulfill their responsibilities to PDR Network.

We may provide syndicated data services, custom market research services and/or data analytics to third parties that are based on aggregated, de-identified data from you and the many other physicians and healthcare providers with whom PDR Network interacts on a regular basis.   

We may also provide services based on your personally identifiable data, such as targeted marketing campaigns, and we may match your personal information with information we receive as a result of your activities while interacting with any of our PDR products or services, such as your use of PDR mobile applications or the drug look-ups you conduct in PDR BRIEF in your electronic health record systems to the extent that we are permitted to do so under our contracts with the providers of such EHR systems.

Special Note Regarding Protected Health Information You May Provide to PDR for Adverse Drug Event Reporting:  
PDR Network provides a service called RxEvent (found in various locations including www.RxEvent.org) which collects Adverse Drug Event reports.  In some cases, the reports provided by users of this service may include “Protected Health Information" or “PHI” as those terms are defined in 45 C.F.R. Sections 164.501 and 160.103.  PDR Network's policies and obligations to receive, store and communicate such PHI are governed by law and are set forth at https://rxevent.org/Tos.html.

Special Note Regarding Personal Information You Provide to PDR for Market Research and Industry-Sponsored or Client-Sponsored Programs:  
PDR Network, acting on its own or with third parties, provides highly targeted interactive content and opportunities for healthcare providers to participate in market research studies and industry-sponsored or client-sponsored programs. From time to time we may invite you to participate in sponsored or non-sponsored market research studies. When participating in our surveys, in addition to providing your responses to the survey questions, you may be asked to provide additional personal information. This feedback will only be shared in an aggregate manner (e.g. not in a manner that is correlated to your personally identifiable information), unless specifically stated otherwise as to individual surveys. 

We may also invite you to participate in industry-sponsored or client-sponsored programs, such as but not limited to pharmaceutical sampling programs, e-detailing, and sponsored education programs.  By participating, you agree that your name, location, specialty, profession, the content you read, the answers you provide, and other personal information can be shared with the industry sponsor and/or its agents on the sponsor's behalf. You may be asked to provide personal information and we may collect information in connection with a transaction that you have requested (e.g. requests for information, sales rep visit, etc.) or responses to sponsored program questions, which, along with your identity, will be provided to the program's sponsor. Even if you do not provide us with personal information, we collect non-personally identifiable information about your use of sponsored programs through cookies, as described in the " Cookies and Web Site Information" section of this Privacy Policy.  When engaging with sponsored content, you should read the privacy policy of the applicable sponsor and familiarize yourself with how such sponsor will treat your information. We are not responsible for how the sponsor and its agents use your information and manage your privacy.   

You May Choose to Opt-Out of Various PDR Network Communications:  

We use good faith efforts to respect your preferences about our use and disclosure of your information. We only want to send you information if you want to receive it. We want to communicate with you in the manner that works best for you – whether that is via e-mail, phone, fax, text or direct mail. You may change your communication preferences at any time by doing any of the following things:    
-           updating your profile through the profile link on a PDR Network Web site homepage to opt-out of specified types of communications
-           opting-out of e-mails, or specific types of e-mails, by using the “unsubscribe” feature on the e-mail communication
-           contacting our customer service department by e-mail at customerservice@pdr.net or by phone at 1-800-232-7379 and requesting the desired
            change (e.g., opting in or out of faxes)  

You can also tell us at any time after you register that you do not want us to disclose your information to unaffiliated third parties for their own use by updating your profile through the profile link on the PDR Network Web site homepage, or by contacting our customer service department.  

Accessing and Updating Your Personal Information:   

We strive to provide you with a reasonable opportunity to access and update your profile information. If you have disclosed information to us via on-line registration or by updating your profile, you may access and update this information by following the link on the PDR Network Web site homepage to your account profile. Our customer service department can also assist you with other reasonable requests related to information about you that may be maintained by us.  

Additionally, if you have registered with PDR Network previously but have not provided information needed to qualify to receive the PDR® Physicians Desk Reference book, FDA-approved PDR Drug Alerts, or other services that require credentialing, you may add information to your profile to enable us to qualify you and provide the additional products and services.  

Cookies and Web Site Information:
We use standard "cookie" technology as well as web beacons and web server logs to collect information about how our Web site is used. Cookies are small pieces of data that are stored by your web browser on your hard drive. The cookies allow our web servers to recognize the computers used to access our Web sites. Cookies allow you to move from page to page on the Web site, by remembering the information about the entire session.  

Web beacons are transparent pixel images that are used in collecting information about Web site visitor activities and e-mail response and tracking. For example, if we send you an e-mail message, we (or third parties providing services on our behalf) may collect information through web beacons to determine whether you have opened the e-mail message or clicked on links located within the e-mail message.  

Information gathered through cookies, web beacons and by our web server logs may include your IP address, the date and time of visits, the pages viewed, time spent at our Web site, and the Web sites visited just before and just after our Web site.

We may use third-party advertising entities to serve ads when you visit our Web site or when you receive email newsletters and communications from us. This company may use information about your visit to this Web site in order to provide advertisements about goods and services that may be relevant and of interest to you. In the course of serving advertisements to this Web site, our third-party advertisers may place or recognize a unique cookie on your browser. You may view, delete or block cookies by adjusting your web browser preferences.  If you disable cookies, you may still use our Web site, but this may interfere with some of its functionality.  

How We Secure Your Information:   
We have implemented reasonable technical, physical, and administrative controls to help prevent the loss, misuse, and alteration of the information under our control. For example, when we ask users to provide any information during the registration or profile update process, the data is protected using Secure Sockets Layer (SSL) or other encryption technology.     

Use of Mobile Devices and Applications; Responsibility for Third Party Fees:   
PDR Network may deploy mobile marketing campaigns and may allow you to register for services that involve text messages and/or e-mails being sent to your mobile device. You are responsible for obtaining access to the mobile device services, and that access may involve third-party fees, including mobile carrier, text messaging, or data downloading and usage charges. You are solely responsible for those fees, including any and all fees associated with the delivery of the messages, e-mails or other materials to your mobile device. Please consult your mobile service provider's pricing plan prior to registering for any such services to determine the charges for sending and receiving messages or data from or to your mobile device.   If you use any PDR mobile applications, this Privacy Policy will apply to your use of such applications and any personal information we collect resulting from such use.

PDR May Disclose Your Personal Information to Comply with Certain Legal Requirements:   
PDR Network may need to disclose certain information about you or from you for a variety of legal reasons, such as: (i) to comply with a law, regulation, court order, subpoena, or search warrant, in the course of a legal proceeding or in response to a law enforcement agency request or a regulatory or client audit, (ii) when we believe it is necessary to protect and/or enforce rights, property or safety interests, or (iii) when we deem necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce our Privacy Policy. If there is a change of control in PDR Network’s business (whether by merger, sale, or otherwise) or a sale or transfer of its assets, your information could be sold or transferred as part of that transaction and your information could potentially be used by the purchaser, but any such use remains subject to this Privacy Policy unless and until it is changed.  

You acknowledge that PDR Network is located in the U.S. and will process and store your information in the U.S., and that as a result, U.S. governments, courts or law enforcement, or regulatory agencies may be able to obtain disclosure of your information through the laws of the U.S.  

Special Notice to California Residents:  
Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about them or their family for marketing purposes during the previous calendar year, and a description of the categories of personal information shared.  To make such a request, please send an email to customerservice@pdr.net and include the phrase “California Privacy Request” in the subject line, and provide us with your name, address and email address.  We will respond to you within thirty days of receiving such a request.  

Do Not Track  

PDR supports Do Not Track with respect to its products and services. Do Not Track (DNT) is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, visit donottrack.us

Changes to this Privacy Policy:   
If we make changes to our Privacy Policy, we will post the updated policy, and we will also notify you via e-mail or take other reasonable steps to give you an opportunity to re-visit your permissions to determine if you would like to opt-out of any of our uses of your personal information.  The date this Privacy Policy became effective will always appear at the top of this Web page, and we encourage you to periodically review our Privacy Policy for the latest information on our privacy practices.  

How to Contact Us with Any Questions or Feedback:   
If you have any questions about this Privacy Policy or your interactions with PDR Network, or if you would like to provide comments, please contact us at customerservice@pdr.net, or by phone, toll-free, at 1-800-232-7379 within the United States.  

Legal Disclaimer; Governing Law:
  
Unfortunately, no data protection method or combination of methods can be guaranteed to be 100 percent secure. We take reasonable steps to protect your personal information as described throughout this Privacy Policy, but we cannot ensure or warrant our ability to do so. As a result, you use PDR Network Web sites and PDR Network content, products and services at your own risk. PDR Network disclaims any liability for disclosures of your personal information due to errors in transmission or unauthorized acts of third parties.   This Privacy Policy, and any transactions or disputes to which it applies, will be governed by the laws of New Jersey without regard to any conflicts of laws.