CareSpeak Communications, Inc. (“CareSpeak”) understands that your health is a very personal matter, and we want you to feel as comfortable as possible when visiting CareSpeak.com (“Website”) and using our services. We urge you to read this Privacy Policy carefully so that you understand clearly how we may collect and use information (“Privacy Policy”).

This Privacy Policy is in addition to our general Terms & Conditions of Use which we urge you to read. By using our site, you agree to be bound by the terms of this Privacy Policy and by our general Terms & Conditions of Use. We may change this Privacy Policy at any time by posting revisions to this web site. At such time we will notify you of the changes to the e-mail address you provide us when you register.  If you do not agree to the terms of this Privacy Policy, please exit the Website immediately.

INFORMATION THAT WE COLLECT

1.     Personal Information

When you visit our Website, we collect information that can be used to identify or contact you (“Personal Information”). You provide to us your Personal Information in the following three ways:

·         (1) When you register as a user and/or when you update your MyAccount page,

·         (2) When you subscribe to use one or more of CareSpeak’s services, and

·         (3) When you opt-in to participate in marketing and/or promotional e-mails and/or surveys, or send emails directly to CareSpeak.

We collect Personal Information for statistical analysis of user behavior, product improvement and development, content improvement and development, fulfillment of a requested transaction or record keeping, editorial and feedback, and marketing and promotional purposes.

CareSpeak may collect or track (1) the e-mail addresses of visitors that communicate with CareSpeak via e-mail, and (2) information knowingly provided by the visitor in online forms, registration forms, surveys, e-mail, and other online avenues (including, without limitation, demographic and personal profile data). CareSpeak also may collect or track (3) the home server domain names, e-mail addresses, type of client computer, files downloaded, search engine used, operating system, and type of web browser of visitors to the Website, and (4) aggregate and user-specific information regarding which pages Website visitors and users access.

You may use our Website without singing-up or submitting any Personal Information. In that case, the only information we collect will be non-personal information collected through the use of cookies and/or other web tracking technologies. However, in order to have access to certain services and content available on our site (e.g., MediM Alerts), you are required to register. We use the Personal Information that you provide through registration to provide you with our service and/or to respond to questions from you and/or inform you of significant changes to this Privacy Policy. If you opt-in during the register process, we may also use this information to send you emails with special promotions or newsletters with content that we think may be of interest to you. The information we collect in the register process set forth below. Required information is indicated by an asterisk*. Provision of all other information is optional.

2.     Cookies

If you choose “Remember Me” during the log-in process, we will place Internet "cookies" on your hard drive. Internet cookies save data about an individual user, such as the user’s name, password, user-name, shopping cart, screen preferences, and the pages of a Website viewed by the visitor. When the user revisits the Website, CareSpeak may recognize the user by the Internet cookie and customize the user’s experience accordingly. Your browser software can be set to reject all cookies. Most browsers offer instructions on how to reset the browser to reject cookies in the "Help" section of the toolbar. If you reject our cookie, certain of the functions of our Website may not work properly but you do not have to accept our cookie in order to productively use our Website. While it may be possible to link non-personal cookie information to Personal Information collected in other ways, we want you to know that if you accept our cookie we will not, without your consent, link the cookie information we collect to Personal Information you provide to us on our Website.

3.     E-mails and Newsletters

We collect anonymous, non-personal information about your use of e-mails and newsletters that we send to you. In some cases, when you click on a link or an advertisement in an e-mail or newsletter, your browser may be momentarily directed to the site of a third party which, acting on CareSpeak’s behalf, notes or "counts" your response to the e-mail or newsletter before re-directing your browser to its proper destination; this re-direction process will not be apparent to you.

When you use CareSpeak’s "Tell a Friend" application, CareSpeak emails the content you designate to your friend's email address and lists your email address as the sender. CareSpeak uses the friend's email address only for the purpose of sending your friend the email you requested and for no other purpose unless otherwise disclosed to you at the time you send the email.

4.     Searches

When and if a visitor performs a search within the Website, CareSpeak may record information identifying the visitor or linking the visitor to the search performed. CareSpeak may also record limited information for every search request and use that information to solve technical problems with the services available directly or indirectly in connection with the Website and to calculate overall usage statistics.

5.     Emails to CareSpeak

This Privacy Policy does not protect you when you send any type of business information, ideas, concepts or inventions to CareSpeak by email. If you want to keep any or all business information, ideas, concepts or inventions private or proprietary, do not send them in an email to CareSpeak. We try to answer every email in a timely manner, but are not always able to do so.

6.     Privacy of Minors and Children

The Children's Online Privacy and Protection Act of 1998 ("COPPA") defines a "Child" as anyone under the age of 13. CareSpeak strictly adheres to COPPA. We will not register or otherwise collect Personal Information from persons who identify themselves as being under the age of 13 during the registration process without the prior verifiable consent of that person's parent or guardian.

DISCLOSURE OF INFORMATION THAT WE COLLECT

We will not disclose to third parties any of your Personal Information unless: (1) you expressly tell or permit us to disclose such information, or (2) we believe in good faith that we must do so to comply with legal requirements such as a laws, regulations, search warrants, subpoenas or court orders.

1.     Disclosure to CareSpeak Operations and Maintenance Contractors

CareSpeak operations and maintenance contractors sometimes have limited access to your Personal Information in the course of providing products or services to CareSpeak. These contractors include vendors and suppliers that provide us with technology, services, and/or content related to better operation and maintenance of our Website. If you opted-in to receive emails and newsletters from CareSpeak, these contractors also may have access to your email address to send newsletters or special promotions to you on our behalf or to send emails to you for purposes such as conducting market research on our behalf. Access to your Personal Information by these contractors is limited to the information reasonably necessary in order for the contractor to perform its limited function for CareSpeak. We also contractually require that our operations and maintenance contractors 1) protect the privacy of your Personal Information consistent with this Privacy Policy, and 2) not use or disclose your Personal Information for any purpose other than providing us with products and services.

2.     Disclosure to Linked Sites

There are links to Websites operated by companies other than CareSpeak ("Third Party Websites") that are not contractors who provide content or services through our Website. These links may be found in advertisements, referenced within content, or placed beside the names or logos of sponsors. CareSpeak does not disclose your Personal Information to these Third Party Websites without obtaining your consent. CareSpeak does not endorse and is not responsible for the privacy practices of these sites. If you choose to link to one of these Third party Websites, you should review the privacy policy posted on this other site to understand how that Third Party Website collects and uses your Personal Information.

3.     Disclosure of Aggregate Information

CareSpeak may provide to third parties non-personal information about you that does not allow you to be identified or contacted and that is combined with the non-personal information of other users ("Aggregate Information"). For example, we might inform third parties regarding the number of users of our site and the activities they conduct while on our site. Depending on the circumstances, we may or may not charge third parties for this Aggregate Information. We also may not limit the third parties' use of the Aggregate Information, except that we do require third parties to whom we disclose Aggregate Information to agree that they will not attempt to make this information personally identifiable by combining it with other databases or otherwise.

4.     MyAccount Page

CareSpeak collects the Personal Information you voluntarily store in MyAccount. The information MyAccount currently is designed to store includes but is not limited to the following categories: (1) Patient Contact Information; (2) Medications; (3) Condition or Illness Information; (4) Doctor or Health Professional Information; (5) Pharmacy Information; (6) Caregiver Information; (7) Any other information you voluntarily store.

CareSpeak does not use the Personal Information stored in MyAccount for any purpose except to provide members with the service that you sign up for (e.g. MediM Alerts). The only entities that will have access to MyAccount Personal Information are CareSpeak itself and any third parties hired by CareSpeak to assist us in operating, maintaining, and improving the site. These third parties are required by us to hold your information in the strictest of confidence and may not use or disclose it except to fulfill the service we hired them to perform. CareSpeak will not share any of the Personal Information that is stored in MyAccount with any other third parties without your express permission.

5.     Security

CareSpeak has implemented numerous security features designed to prevent the unauthorized release of or access to personal information. We have taken a number of steps to safeguard your privacy:

• Access to CareSpeak.com requires register registration. During sing-up we ask you to select a username and password, which will be required each time you log-in. To ensure privacy of your data, never share your username and password with anyone unless you want them to have access to your data. You may change your username and/or your password at any time by logging on and selecting the MyAccount tab.
• When you log-in at CareSpeak.com a session ID is generated for the duration of your log-in. This session ID ends as soon as you log-out. In addition, you session ID will automatically time out after a period of 15 minutes if you are not active on the site. CareSpeak does not use cookies unless you choose the “Remember Me” option at the time you log-in.
• CareSpeak.com is a secure site using SSL 256-bit encryption with identity certified by GeoTrust, a VeriSign Company.

Please be advised, however, that the confidentiality of any communication or material transmitted to or from CareSpeak via this Website or e-mail cannot be guaranteed. Accordingly, CareSpeak is not responsible for the security of information transmitted via the Internet. Instead of communicating with CareSpeak via e-mail or the Internet, visitors can contact CareSpeak by mail, phone, or facsimile at the address or numbers set forth at the end of this Privacy Policy.

UPDATING PERSONAL INFORMATION AND CONTACTING CARESPEAK

You can always contact us in order to (1) delete your Personal Information from our systems, (2) update the Personal Information that you have provided to us, and (3) change your preferences with respect to marketing contacts or other activities, by e-mailing us. Such changes will not have any effect on other information that CareSpeak maintains. We try to answer every email in a timely manner but are not always able to do so.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to CareSpeak from our servers. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personal Information may exist in a non-erasable form that will be difficult or impossible for us to locate. Nevertheless, we promise that upon receiving your request, all Personal Information stored in the databases we actively use for research and daily business activities, and other readily searchable media, will be deleted.

Revised: April 2007

CareSpeak Communications, Inc.

E-mail: cs@carespeak.com

Phone: +1 (732) 993-3590

Fax: +1 (732) 432-9513