HEMOPHILIA.COM PRIVACY POLICY

Version 2.1. Last Revised: 09/24/2014

This Privacy Policy is provided by Accredo Health Group, Inc. (“Accredo”, “we”, “us” or “our”) to all visitors (“you” or “your”) who use the available pages of the Hemophilia.com website located at http://www.Hemophilia.com/ (the “Site”). This Site is provided to you as a service to share information regarding Accredo’s services to support hemophilia care.

We are firmly committed to protecting the confidentiality and security of your Personal Information. The term “Personal Information” means any information which can be used to identify a person including by way of example, but not limitation, name, date of birth, mailing address, home phone number, mobile phone number, e-mail address, credit card information, and/or Social Security number.

COLLECTION AND USE OF NON-PERSONAL INFORMATION


How We Collect Non-Personal Information

General Tracking Information

When you visit the Site, and during your interactions with the Site, we may collect Non-Personal Information from you. "Non-Personal Information" means a data element or collection of data elements that by itself cannot ordinarily be associated with a specific individual. Non-Personal Information includes by way of example but not limitation, the Internet browser or computer operating system you are using, the pages of the Site and other sites that you access, the amount of time spent on various portions of the Site, and certain Site data captured through your interactions with the Site and other sites. Non-Personal Information may be collected on an aggregated, anonymous basis through web server logs, cookies, ad servers, tracking pixels, web beacons, and similar Internet tracking devices (collectively “Tracking Mechanisms”). Web servers automatically collect Non-Personal Information, including your IP address, when you request pages of the Site or other sites. Based on certain interactions with the Site, mailings, and third-party sites, and other communications with us, certain Non-Personal Information may be associated with your Personal Information such that your Non-Personal Information is identifiable with you. You may be able to opt-out of certain third-party associations by following customization and/or opt-out options as described below.

How We Use Non-Personal Information

The Tracking Mechanisms and the Non-Personal Information collected through their usage may be used by us and our affiliated companies for a variety of analytic and developmental purposes including to improve and enhance the Site and our products and services, to create new products and services, to customize your experience on the Site and other sites that you visit on the Internet, and to identify and/or offer products, services and website functionality that may be of interest to you.

We may use two kinds of cookies – session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, to determine ways to improve the Site, Site content, and the services offered through the Site. These cookies are deleted from your hard drive when you close your browser session. Persistent cookies are used to collect non-personally identifiable information such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp and number of clicks.

You may set your browser to accept cookies, warn you when a cookie is sent or turn off all cookies (except Flash cookies). Check your browser’s help menu or your mobile device settings to find out how. Some mobile devices store cookies not only in areas connected to the browsers but all in app-specific area, so you may have to check your app settings options to determine how to manage or delete cookies stored in these other areas. If you do not accept cookies, some features, services or activities available through the Site may not function correctly and you may be unable to access certain content.

We may embed tracking pixels within various pages of the Site to enable use of site analytics. The site analytics enable us to determine the usage frequency of various areas of the Site and identify areas of the Site for enhancement. While you are visiting and after you leave the Site, we may use web beacons to notify you of areas of the Site and other aspects of our organization and its affiliated companies in which you may be interested. Certain tracking pixels and web beacons may be cleared or reset through configuration of your web browser such as by clearing your cache. We may use ad servers to provide you with offers of possible interest.

We use your IP address so that we can send data (such as the pages you request) to you and collect Non-Personal Information during the process. We aggregate this Non-Personal Information with similar Non-Personal Information collected from other users to track overall visitor traffic patterns and help us understand Site usage and preferred and most frequently used pages, products and services, to provide you with better service, to improve Site use and functionality, and to provide you with information on other products and services that may be of interest to you.

We may analyze Non-Personal Information in the aggregate to study outcomes, costs, and provider profiles, and to suggest benefit designs for employers or health plans. These studies may generate Aggregate Data (described below) which we may utilize for a variety of purposes.

We may perform statistical analyses of the traffic patterns, Site usage, and behaviors associated with the Site. We may use these analyses to generate Aggregate Data from the original Non-Personal Information. “Aggregate Data” is summary level data, such as the number of web visitors in a specific geographic area. Aggregate Data does not contain information that can be used to identify or contact you, such as your name, address, telephone number or e-mail address, and does not reflect the original form of the Non-Personal Information collected from you.

Third-Party Usage

We may use third parties to (a) operate and maintain the server(s) on which the Site operates, (b) provide Tracking Mechanism(s) that we embed in or use with the Site, (c) provide advertisements and other information to you about the Site, products, and services through a third-party site based on a prior visit to the Site, (d) analyze communications with us and interactions with the Site, (e) collect Personal Information from you, and (f) collect Non-Personal Information on your interactions with the Site. The third party will then share the Personal Information, Non-Personal Information, Aggregate Data, and/or other data with us.

COLLECTION AND USE OF PERSONAL INFORMATION


Access to Patient Education Materials

Various patient education materials are available to you at no cost. You can access and download these materials through the Site by providing certain Personal Information. As described in greater detail on the Site, your Personal Information can be submitted to us through e-mail or through a user interface on the Site. Once received, you will be provided with access to these materials.

Providing us with your Personal Information to access the patient education materials is optional and is not necessary to access the Site. By submitting us your Personal Information, you agree to receive a one-time communication from us with information that may be of interest to you. You may receive additional e-mails or other communications from us by so indicating in response to the one-time communication.

Social Media

When you communicate with us through social media, or provide a comment directed as us through social media, we may use social media to communicate with you. We may also promote content of interest to you through social media. You may opt out or configure your social media account settings to limit promotion of such content.

Analytics

We may use certain in-house or third-party functionality to analyze your communications with us and interactions with the Site. These third parties will be required to protect any Personal Information in accordance with this Policy. Third parties will not capture, be provided with access to, nor utilize Personal Health Information as part of their analysis. Other analytics capabilities are reflected above in the description of Non-Personal Information.

How We Use Your Personal Information

We will not use or disclose your Personal Information in a manner inconsistent with applicable law or this Privacy Policy. Examples of our uses and disclosures include:

  • We will use your Personal Information to make a one-time communication with you regarding your interest in the Site, Accredo, downloaded education materials, and the like.
  • We may share your Personal Information with other Express Scripts companies (i.e., entities which are controlling, controlled by, or under common control with Express Scripts) to provide you with more personalized and enhanced services.
  • We may disclose your Personal Information to relevant third parties such as site technicians, auditors, lawyers, or other professional advisors.
  • We may communicate with you via e-mail, facsimile, letter, text message, mobile phone, and similar mechanisms.
  • We may send you promotional offers or marketing information that may be of interest to you.
  • We may use third-party agents for purposes of communicating with you
  • Statements here and elsewhere on the Site concerning the treatment of your Personal Information may not apply with respect to information already in our possession.

In certain circumstances, we may be legally compelled to release your Personal Information in response to a court order, subpoena, search warrant, or law or regulation.

“Do No Track” Signals and Similar Mechanisms

Our Site does not respond to web browser “do not track” signals and similar mechanisms. However, you may control certain Tracking Mechanisms as described above.

TRANSFER OF PERSONAL INFORMATION AND NON-PERSONAL INFORMATION

All Personal Information and Non-Personal Information obtained through our Site is owned by us. Accordingly, if we are acquired, merge with another entity, or divest one or more of our businesses, affiliates or subsidiary companies, the Sites, and any Personal Information and Non-Personal Information obtained through them, may be transferred to an applicable entity for the purpose of continuation of services, in accordance with applicable law.

USAGE BY CHILDREN

Our Site is neither intended for nor designed to attract users who are under the age of 18. We are committed to preventing the unintentional collection of Personal Information from children under the age of 13. Any Personal Information of a child under 13 that is provided to us must be provided by a parent or legal guardian, and not by a child under the age of 13 who is using the Site.

If you are the parent or legal guardian of a child under the age of 13 whom you have reason to believe has provided his or her own Personal Information to us, you have the right to request the removal of that child's Personal Information from our database. In order to request such removal, please send an e-mail to privacy@express-scripts.com. You will be required to verify your identity as the child’s parent or legal guardian in order to have their Personal Information removed.

LINKING POLICY

Our Site may contain hyperlinks allowing our users to connect to other websites owned by us and our affiliated companies and websites owned by our third-party vendors, distributors, and providers (“Linked Sites”). You may also access our Site through a hyperlink embedded in a Linked Site. We provide hyperlinks to the Linked Sites to enable you to conveniently access websites that may be of interest to you. Please note that once you click on a hyperlink that transfers you from our Site to a Linked Site, you have left our Site, and this Privacy Policy will immediately cease to apply to any subsequent activity on the Linked Site. We are under no obligation to notify you when you have left our Site and have accessed a Linked Site. Use of any Linked Site will be governed by the privacy policy, terms of use, and/or other policies (if any) on the Linked Site. You may, at your option, participate in surveys or provide other information to our affiliates that control a Linked Site, and that information may be shared with us or with others subject to the privacy policy terms set forth on that Linked Site. Certain Non-Personal Information that you choose to provide through a Linked Site (such as comments) that is subsequently provided to us by the Linked Site provider in connection with a service engagement may be identifiable to us as your Personal Information.

SECURITY STATEMENT

We are committed to protecting the privacy and security of this Site. We take reasonable technical and procedural precautions to protect the information received by us. Our Internet infrastructure is protected using industry recognized commercial security products, including current encryption technology, and best practice procedures for maintenance of the website. In addition, our infrastructure is monitored 24 hours a day, seven days a week.

No method of transmission over the Internet or storage of data on an Internet server is 100% secure. Although we use commercially acceptable and reasonable precautions to protect your information, we do not guarantee its absolute security.

YOUR ACCEPTANCE OF THIS PRIVACY POLICY

You are deemed to have assented to the terms and conditions contained in this Privacy Policy when you use the Site. You are deemed to have accepted this Privacy Policy each time you access the Site. If you do not agree to the terms of this Privacy Policy, please do not use the Site. The terms and conditions contained in this Privacy Policy are subject to and may be superseded by applicable Federal and State laws.

CHANGES IN OUR PRIVACY POLICY

We use Non-Personal Information and Personal Information collected from you only within the scope of use described in this Privacy Policy. However, we reserve the right, from time to time in our sole and absolute discretion, to change, to modify, or to add terms or remove terms from this Privacy Policy without advance notice to you. Changes to this Privacy Policy will be reflected when we post a new version number and updated revision date. The version number includes a major number, a decimal point, and a minor number. A change to the major number reflects a significant change to the policy, while a change to the minor number reflects a less significant change to the policy. Examples of significant changes include additional provisions that reflect new Site functionality, significant modifications to existing provisions, and more significant changes to Site functionality that cause provisions to be modified, added, or removed. Examples of less significant changes include additional provisions that clarify current Site functionality, minor modifications to existing provisions, and less significant changes to Site functionality that cause provisions to be modified, added, or removed.

We recommend that you check the version number and revision date prior to using the Site, and that you review this Privacy Policy on a frequent basis. Your continued use of the Site after this Privacy Policy has been updated, as shown in the version number and revision date, indicates your agreement and acceptance of this Privacy Policy, including all changes made as of the date of your use of the Site.

HOW TO SEND US YOUR COMMENTS

We welcome your comments. For technical assistance with the Site, please contact our technical support by calling 1-877-ACCREDO (222-7336). If you have general feedback regarding this Privacy Policy, please e-mail us. Upon submission, any suggestions you make regarding the Site become our property, and we shall have the right to use any of your comments or suggestions without further permission from or notice to you.

Specific questions regarding the enforcement of this policy should be directed to privacy@express-scripts.com.