This policy applies to personal information in the following circumstances:
- Personal information submitted from our website at www.ilumhealthsolutions.com or any other website owned and controlled by ILÚM on its own behalf (each, a “ILÚM site”).
- Personal information submitted from web pages ILÚM controls under the ILÚM name on third party social media websites such as Facebook or LinkedIn (“social sites”).
This policy does not apply to personal information in the following circumstances:
- Personal information collected directly from our current, former or prospective clients, employees, contractors or vendors, regardless of how the personal information is collected
- Personal information collected or submitted via any hard copy communications.
- Personal information collected or submitted via oral (eg, telephone) or audiovisual (eg, YouTube or Skype) communications.
- Personal information collected from other offline resources and communications, except in cases where such personal information is consolidated with personal information collected by ILÚM online
- Personal information collected from third-party online resources to which an ILÚM site may link, where ILÚM does not control the content or the privacy practices of the resources
Please note that personal information that is not subject to this policy may be protected by applicable laws, rules and regulations (collectively, “regulations”). Regulations are constantly evolving, so ILÚM works hard to ensure that all personal information is maintained in compliance with current regulations, whether or not the regulations are expressly addressed in this policy.
Examples of personal information
Examples of personal information include but are not necessarily limited to user identifications, passwords, complete or partial names, social security numbers, dates of birth, postal addresses, electronic mail addresses, telephone numbers, and other information that identifies particular individuals.
Who will have access to personal information?
Personal information will be accessible to ILÚM, including its associates on a need to know basis, and to individuals and organizations that use personal information solely for and at the direction of ILÚM. Uses and disclosures of personal information by outside individuals and organizations acting on ILÚM’s behalf are governed by agreements that require personal information to be protected appropriately. Personal information only will be used and disclosed by ILÚM and individuals and organizations working on its behalf in a manner consistent with this policy, other applicable privacy notices, and as permitted or required by regulations.
The location of personal information
Information collected through an ILÚM site may be transferred, used, and stored in the United States and in foreign jurisdictions in which ILÚM, its users, clients, or agents are located now or at any time in the future. Anyone who accesses an ILÚM site consents to the capture, storage, transfer, use, and processing of personal information in and between all of those jurisdictions. The data protection and other laws in some countries and jurisdictions are not as comprehensive or stringent as the privacy laws in other countries and jurisdictions.
Sharing personal information with third parties
In general, ILÚM does not sell or share personal information except as described in this policy and other applicable privacy notices. However, circumstances may arise where ILÚM may, for business reasons, decide to reorganize or divest all or portions of its business through sale, merger or acquisition. In these circumstances, personal information may be shared with actual or prospective purchasers. ILÚM will obtain written assurances that personal information will be protected appropriately in these circumstances. ILÚM reserves the right to disclose personal information, including email addresses, for reporting to government authorities, to parties in relevant legal proceedings as authorized by a court or tribunal, and otherwise to the extent required or explicitly authorized by applicable regulations.
How does ILÚM secure personal information?
ILÚM takes reasonable steps to protect personal information as it is transmitted from a person’s computer to our online resources and servers. ILÚM also takes reasonable steps to protect personal information in its possession from unauthorized access, disclosure, alteration or destruction. ILÚM reminds individuals that they should also take reasonable steps to protect their personal information by securing copies of user identifications, passwords, and related access codes for our online resources.
How individuals may access and correct personal information about them?
Any individual who would like to gain access to a copy of his or her personal information ILÚM has collected pursuant to this policy may contact us at the ILÚM privacy address stated below.
We may also allow individuals to update their personal information by modifying information previously entered into forms or data fields on an ILÚM site. Where permitted by law, an individual’s ability to access and correct personal information will be limited where access and correction would limit ILÚM’s ability to comply with a regulation, legal or ethical obligation, limit ILÚM’s ability to investigate, make or defend legal claims, result in disclosure of personal information about a third party, or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to ILÚM or a third party.
How personal information is used?
Personal information may be used by ILÚM to respond to requests for information about ILÚM’s business and the services offered by ILÚM to its clients, as well as for any other purpose permitted by regulations.
Information collected from computers or other electronic devices
Some of the ILÚM sites and other online resources use tracking technologies, such as cookies and single-pixel tags, to provide additional functionality that enables individuals to use these resources more effectively. ILÚM uses tracking technologies in ways to collect nonpersonal information, such as to track accurately numbers of users or referring sites or advertisements to our online resources, or to remember whether an individual identified himself or herself as a healthcare professional or a resident of a particular country. We also may collect nonpersonal information about the devices used to connect to an ILÚM site, such as the type of device (eg, computer, tablet, mobile telephone), device identification, usage information about the device, and how the device uses the ILÚM sites and other resources.
A cookie is a small data file that is sent by web servers to a device’s hard drive or other memory where the individual’s browser files are kept. Cookies enable websites to store small bits of information on a computer or other device and retrieve that information at a later time.
ILÚM uses two types of cookies: Session cookies, which are temporary cookies that are erased from the device’s memory when the Internet browser is closed or the device is turned off, and persistent cookies, which exist on device’s hard drive or memory until the persistent cookies expire. Both session cookies and persistent cookies may be erased or deleted by an individual.
Single-pixel tags, also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible because of their small size. They are used to collect nonpersonal information, such as web pages viewed, the site the individual visited before, an advertisement clicked on by an individual, and whether promotional or other commercial email messages are opened.
Choices about how ILÚM collects, uses and discloses personal information
Individuals often have up to four categories of choices on ILÚM sites about personal information collection and use. These include:
1. No personal information collection
An individual may choose not to provide any personal information to ILÚM online by electing not to enter any personal information into a form or data field on an ILÚM site and by not using any personalized services provided by our online resources. However, some of our online resources are available only to individuals who provide personal information or who use personalized services.
2. Limitations and options regarding uses and disclosures for other purposes
Some ILÚM online resources may request permission to use and disclose personal information in order to add the individual to our contact lists and to identify and offer additional services and promotions that we believe the individual might find interesting. Each individual may limit the use of his or her personal information by checking or unchecking options provided at the time the individual enters that information or that ILÚM may offer in the future.
3. Limitation and options on tracking
ILÚM online resources that use tracking technologies, such as cookies, to store personal preferences and selections also enable individuals to choose whether they want ILÚM to use such technologies to remember the individual, or to provide additional services, by checking or unchecking options provided during registration, or at the time that the individual enters personal information into forms or data fields. ILÚM’s online resources do not limit nonpersonal uses of tracking technologies for individuals.
4. Email communications
Individuals may choose to receive optional email and other communications from ILÚM by signing up for or subscribing to these communications on our ILÚM sites and other online resources. An individual may later opt-out of communications by visiting the ILÚM site or other online resources where the individual subscribed, where available, and update email communication selections, or by using the unsubscribe or opt-out instructions in the ILÚM email communications. An individual also may opt-out by contacting ILÚM at the privacy address stated below. Individuals may opt out of email communications tracking by opting out of receiving those email communications altogether using one of the approaches described above. In some cases, ILÚM will not be able to turn off email tracking and may still send communications.
Protection of Social Security numbers
ILÚM requires that Social Security numbers be appropriately secured, in accordance with their sensitivity, from loss, misuse, and unauthorized access, disclosure, alteration or destruction.
ILÚM does not knowingly collect personal information from children less than 13 years of age, nor does ILÚM authorize children less than 13 years of age to use any ILÚM site. If ILÚM learns that it has inadvertently collected personal information from a child under the age of 13, upon receipt of notice from the child or the child’s parent or guardian, ILÚM will use reasonable efforts to delete that child’s personal information from ILÚM’s systems.
California privacy rights
A California resident who has provided personal information to a business with whom she or he has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed her or his personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.
California Customers may request further information about our compliance with California’s privacy law by contacting us as stated below. Please note that we are only required to respond to one request per customer per year, and we are not required to respond to requests made by means other than through this email address.
ILÚM’s contact address for privacy questions
Individuals may contact ILÚM at the email address firstname.lastname@example.org Anyone who has questions about this policy or ILÚM’s information collection, use, and disclosure practices, may contact us at these addresses. When contacting ILÚM, please note or provide the name of the ILÚM site or other online resource to which the individual provided personal information, as well as the nature of any information provided. ILÚM will use reasonable efforts to respond promptly within twenty business days to requests, questions or concerns regarding access to an individual’s personal information collected online or ILÚM’s use of personal information. ILÚM may contact individuals to followup and share your inquiry with other individuals within ILÚM or an affiliated entity or working for ILÚM that are responsible for functions related to the subject of an inquiry. Except where required by law, ILÚM cannot ensure a response to questions or comments regarding topics unrelated to this policy or ILÚM’s privacy practices.
ILÚM may update this policy