Privacy Statement Updated May 25, 2018.

Welcome to Global Healthcare Resources (GHR) and its affiliated organizations. GHR is the leading global authority in the field of healthcare, medical travel, wellness, benefits, and insurance.

In Part I of this Privacy Statement we set forth GHR’s Privacy Policy as to personal information which we collect online through www.globalhealthcareresources.com or other GHR websites which link to this Privacy Statement from their site (collectively, “GHR Websites”).

In Part II of this Privacy Statement we set forth GHR’s Privacy Policy as to personal information which we collect other than through GHR Websites.

“Personal information”, is any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you. Personal information includes “sensitive personal information” and “pseudonymised personal information” but excludes anonymous information or information that has had the identity of an individual permanently removed.

Your use of the GHR Websites and/or provision of your personal information or sensitive personal information to GHR constitutes your consent to the use, storage, processing and transfer of that information in accordance with this Privacy Statement.

For the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”) the data controller is Global Healthcare Resources with an office 8845 N. Military Trail, Suite 200, Palm Beach Gardens, FL 33410. GHR is an organization based in the United States. Where your data is being collected and used by Global Healthcare Resources, all references to GHR herein shall mean GHR or affiliated companies or associations GHR manages.

QUESTIONS

If you have any questions or complaints regarding this Privacy Statement, please contact us at info@globalhealthcareresources.com.  If you have any questions about the GHR Websites, please contact us at info@globalhealthcareresources.com, by phone at 561-791-2000, or send a letter to:

Global Healthcare Resources

8845 N. Military Trail, Suite 200

Palm Beach Gardens, FL 33410

CHANGES TO THIS PRIVACY STATEMENT

We will update this Privacy Statement from time to time, so please check back periodically.

If at any point we decide to use personal information in a manner that is materially different from that stated at the time it was collected, we will endeavor to notify you of such changes (e.g., we will post a revised Privacy Statement with a new effective date, display the word “updated” next to the Privacy Policy link on each page on the GHR Websites, or otherwise), prior to implementing them.

PART I – GHR WEBSITES PRIVACY POLICY

Throughout GHR Websites, there are forms for visitors to request information, products, and services. We use personal information from these forms to provide the products, promotional materials, or memberships that you request.

Forms on the GHR Websites that request financial information do so in order to bill you for products or services ordered. Unique identifiers (specifically, your GHR or association member number) are collected from website visitors to verify the user’s identity for access to restricted content or features on the GHR Websites.

This Privacy Policy discloses GHR’S privacy practices and contains detailed information about the following:

  • What information do we collect?
  • What are “cookies” and how does GHR use them?
  • Do we share information with third parties?
  • How do we use the information we collect?
  • How can you review and modify your personal information?
  • What is the opt-out policy for GHR Websites?
  • Your California privacy rights
  • Your European privacy rights
  • What types of security procedures are in place to protect against the loss, misuse or alteration of your information?
  • How do GHR Websites use bulletin boards, discussion lists, and moderated chats?
  1. What information do we collect?
    GHR Websites collect the following personal information about site visitors:
  2. a)    Site Use Information

GHR collects technical information relating to each time a visitor comes to a GHR Website, including IP address, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform type (e.g. Internet Explorer browser on a Windows platform).

We may also collect information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Gathering this technical information helps us to learn what browsers we need to support and helps us determine what sections of GHR Websites are most popular and how many visitors come to our site(s). You do not have to register with GHR Websites before we can collect this information.

  1. b)    Information You Give Us

You may provide personal information to us which may include your name, home and/or work email address, postal address, phone number and/or fax number, your employer and job title, demographic information about you including birth year, certification designation, etc., and if you are making a purchase, your credit card information. You are only required to provide such information if you want to take advantage of optional products and services provided through GHR Websites.

GHR collects personal information in the following ways from different parts of the GHR Websites:

  • GHR or Association Membership Applications: You are sharing personal information with us when you join a GHR managed association or renew your membership through the GHR Websites. GHR or association members will have GHR or association membership log-in credentials which enable members to take advantage of restricted content and features on GHR Websites.
  • Other Registration: When registering for specific services we may ask for the same type of personal information. For example, if you subscribe to an e-mail newsletter, we will ask you to provide your e-mail address.
  • Online Purchases: When you make a purchase using the GHR store(s) or when you subscribe to a GHR publication through the GHR websites we may also ask for the same type of personal information. The number and variety of useful services on GHR Websites that may require the collection of personal information about you will continue to grow in the future.
  1. What are “cookies” and how does GHR use them?

A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer. This unique number identifies your web browser to GHR computers whenever you visit GHR Websites.

The use of cookies is an industry standard, and cookies are currently used on most major websites. Most web browsers are initially set up to accept cookies. If you prefer, you can reset your browser to notify you when you have received a cookie. You can also set your browser to refuse to accept cookies altogether.

While GHR does not require you to use cookies, keep in mind that certain services will not function properly if you set your browser to refuse all cookies. To help serve you better, GHR generally uses cookies to:

  • Identify return visitors. Cookies let us remember your web browser so we can provide personalized member services such as My GHR and GHR search agents. Cookies also allow us to identify GHR or association members who are returning to the site.
  • Display advertisements. GHR uses an outside ad company to display GHR approved ads on our website and other websites. While we use cookies on other parts of our website(s), the cookies received with banner ads are collected by our ad company. These cookies allow GHR to manage the delivery of ads.

For more information about how we use cookies on the GHR Websites, please see our Cookie Policy.

  1. Do we share information with third parties?

Personal information collected through GHR Websites is generally collected and maintained solely by GHR or its contracted vendors.

We may share personal information in the following ways:

  1. a)    Information You Give Us
  1. Personal information provided when you register for services or products. When you provide personal information about you on GHR Websites to register for a service, buy a product, or take advantage of a promotion GHR reserves the right to sell or otherwise provide to selected third parties, mailing/information lists derived from such registrations.If you wish to opt out of such list sales/distribution at any time, you may do so by following the directions in Item 6 below. We will not share personal information relating to individuals based in the EU unless you have provided your opt in consent.  
  1. Information provided when joining or renewing membership in a GHR managed association. If you join GHR or a GHR managed association or renew your membership through the GHR Websites, you provide personal information about you on the membership application. GHR reserves the right to sell or otherwise provide mailing/information lists concerning members to selected third-parties.If you wish to opt out of such list sales/distributions at any time during your GHR membership, you may do so by following the directions in Item 6 below. We will not share personal information relating to individuals based in the EU unless you have provided your opt in consent.GHR does not sell to third-parties, e-mail addresses obtained from member applications or renewals (except that GHR will rent a member e-mail address if that member has expressly opted in to allow such rentals).

    Sensitive Personal Information. GHR does not share with third parties, sensitive personal information such as passcodes, social security numbers, credit card numbers, felony conviction information, or health information except as necessary to complete transactions requested by you and under strict confidentiality and security protections; nor does GHR publish such sensitive personal information.

  1. b)    Site Use Information

We disclose to third-party sponsors/advertisers aggregate statistics (i.e., impressions and click-throughs on a company’s advertisement).

In addition, we may share aggregate website statistics with the media or other third parties. We do not disclose personal information to these sponsors/advertisers or other third parties as part of this process, only information in an aggregate form.

  1. c)    GHR Subsidiaries

We also allow our subsidiaries, Free Health Inc, WMT&GHC Inc and others, to use the information which you may provide when you register for services or products or when you join or renew membership in GHR, to the same extent as GHR may use such information under this Privacy Policy, and fully subject to the same limits as GHR is subject to on the use of such information under this Privacy Policy.

  1. How do we use the information we collect?

We use your personal information according to the terms of the Privacy Policy in effect at the time of our use. We will only process your personal information, including sharing it with third parties, where (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party (including your membership agreement with us), (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate commercial interests, provided your interests and fundamental rights do not override those interests.

We use personal information for the following purposes:

  1. a)    Information You Give Us

We use the personal information you give us:

  1. to carry out our obligations arising from your membership and any other agreement entered into between you and us
  2. to update and renew your membership as required
  3. to provide you with the information, products and services you request from us
  4. to arrange and deliver conferences, events and programming relevant to your job and subjects of interest
  5. to respond to your questions and provide related membership or customer services
  6. to improve the GHR Websites
  7. to send you GHR publications, information about member benefits and special offers, and other information that GHR believes is relevant and useful to its members, where you have not opted out of receiving such information
  8. to send you third party information that GHR believes is relevant and useful to you, where you have given your consent
  9. to notify you about changes to your membership or related services or to ask you to provide feedback
  10. to enable you to partake in a prize draw, competition or complete a survey
  11. to administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  12. to comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities
  1.  in matters involving a danger to personal or public safety, or to protect the rights, property or safety of GHR, our members, customers, certificants or others GHR may voluntarily provide information to appropriate governmental authorities
  2.  in some cases members may receive products or services, which are paid for by their government employer, and as a result of payment by the government employer, the record must be open for public access pursuant to applicable law, such as the Florida Public Records Act, and GHR will share such information pursuant to those laws

 

  1. b)    Site Use Information

As mentioned above, GHR uses the aggregate, anonymous data collected to let our sponsors/advertisers know the number of impressions or views and the number of “click throughs” on their advertisement(s).

GHR also uses this aggregate, anonymous data to perform statistical analyses of the collective characteristics and behavior of visitors to GHR Websites; to measure user interests regarding specific areas of GHR Websites; and to analyze how and where best to use our resources.

Without such data, we would not know which parts of GHR Websites are the most popular, and we would not be able to change and update the content and services appropriately.

  1. c)    Information Collected in Connection with Certification and Recertification

If you register for certification or recertification services, or for any other GHR credential or certificate (e.g. Certified Corporate Wellness Specialist®), GHR uses any personal information you may provide doing so in the same manner as we do when you register for other GHR products and services. Without limitation of the foregoing, GHR (and/or GHR’s certification or credential-related vendors) may use and disclose personal information, certification exam performance information, and/or assessment information related to any other GHR credential or certificate in connection with (the following is a non-exclusive list of examples):

  1. Listing all individuals who have achieved a GHR certification in the GHR Online Certified Directory
  2. Sending notifications/reminders on the status of certification or other credential or certificate, information on professional development and recertification opportunities, and other news and communications of interest to the certified community or those holding any other GHR credential or certificate
  3. The scheduling and administration of exams
  4. The preparation, review, updating, validation, accreditation and/or administration of the exams and exam preparation materials
  5. Publishing information regarding a candidate/certificant/credential-holder/certificate-holder against whom disciplinary action has been taken and the reason for that action.

 

Examples of how GHR will not share a candidate’s/certificant’s/credential-holder/certificate-holder’s personal information, certification exam performance information, or assessment information related to any other GHR credential or certificate are as follows:

  1. GHR will not share the names of candidates who do not pass the exam with the general public.
  2. GHR will not share information about an examinee’s performance on individual exam items with any person or entity.
  3. GHR will not disclose any personal information related to requests for reasonable accommodation under the ADA, or under similar Non-US requirements, other than as reasonably necessary to review and/or provide that accommodation.

However, GHR may disclose the above information as reasonably necessary in relation to the administration of the exam and exam program (e.g. to communicate ADA accommodations to our exam testing centers as necessary); to comply with the law, regulation, pursuant to court order or other legal process; in connection with the preparation, review, updating, validation, accreditation and/or administration of the exam or exam preparation materials; or to protect the rights, property or safety of GHR, our members, certificants or others.

  1. d)    Exceptions           

On occasion GHR collects personal information through GHR Websites with the intent to afford a greater degree of privacy for such information than is otherwise set forth in this privacy policy.

In those relatively rare situations where GHR does so it will clearly disclose to you at the time it collects such information, what degree of privacy will be afforded to the personal information collected at such time; and GHR will follow a process to assure that the specifically disclosed degree of privacy is in fact afforded to such information.

For example, GHR may collect survey information through a survey where GHR’s use of any personal information from that survey is more limited than the general GHR Privacy Statement would otherwise allow; in such a case, GHR will disclose the stricter privacy policy governing that survey information at the time such personal information is collected from the survey respondent.

  1. How can you review and modify your personal information?

You have the following options for modifying or causing to be deleted personal information or demographic information previously provided by you to GHR.

  1. E-mail info@globalhealthcareresources.com
  2. Send mail to the following postal address: GHR, 8845 N. Military Trail, Suite 200, Palm Beach Gardens, FL 33410: Customer Care Department.
  3. Call: 561-791-2000.
  1. What is the opt-out policy for GHR Websites?

GHR provides members and customers with the opportunity to opt-out of receiving communications from us and our partners. If you no longer wish to receive specific communications or services, you have the following options:

  1. You can send an e-mail to: info@globalhealthcareresources.com
  2. You can send mail to the following postal address: GHR, 8845 N. Military Trail, Suite 200, Palm Beach Gardens, FL 33410: Customer Care Department.
  3. You can call the following telephone number: +561-791-2000.

Instructions for opting out of any GHR e-mail newsletter you receive are included with each e-mail.

  1. Your California Privacy Rights

For California Residents Only.  GHR may disclose your personal information to our subsidiaries or other third parties who may use that information to market directly to you.  As a California resident, you have the right to opt-out of having your personal information licensed to such third parties.  We will not share your information after we have received your notification that you are opting out. If you wish to opt-out you have the following options:

  1. You can send an e-mail info@globahhealthcareresources.com
  2. You can send mail to the following postal address: GHR, 8845 N. Military Trail, Suite 200, Palm Beach Gardens, FL 33410: Customer Care Department.
  3. You can call the following telephone number: +561-791-2000.
  1. Your European Privacy Rights

For European Residents Only. If you are based in the EU, in certain circumstances, you have rights under the GDPR in relation to your personal information.

  • Request access to your personal information.  You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
  • Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.
  • Request erasure of your personal information. You may have the right to request that personal information held about you is deleted.
  • Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information.
  • Request transfer of your personal information. You may have the right to request transfer of personal information directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligations under this Privacy Policy or European data protection laws, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

If you wish to exercise your European data subject rights, you have the following options:

  1. You can send an e-mail to: info@globalhealthcareresources.com
  2. You can send mail to the following postal address: GHR, 8845 N. Military Trail, Suite 200, Palm Beach Gardens, FL 33410: Customer Care Department.
  3. You can call the following telephone number: +561-791-2000.
  1. What kinds of security procedures are in place to protect against the loss, misuse or alteration of your information?

GHR Websites have security measures equal to or better than those reasonably expected in the industry, such as firewalls, in place to protect against the loss, misuse and alteration of your personal information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we take reasonable precautions to prevent such unfortunate occurrences. Certain particularly sensitive information, such as your credit card number, collected for a commercial transaction is encrypted prior to transmission.

You are ultimately responsible for the security of your GHR or affiliate login credentials. You may not share your GHR or affiliate login credentials with colleagues or friends so they can access content or features that are restricted to GHR or association members only. You should log out of your browser at the end of each computer session to ensure that others cannot access your personal information and correspondence, especially if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.

  1. How do GHR Websites use bulletin boards, discussion lists, and moderated chats?

GHR Websites make bulletin boards, discussion lists, and moderated chats available to its members. Any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information. Although users may post messages that will appear on the message boards anonymously, GHR does retain a record of who posts all notes.

PART II – GHR PRIVACY POLICY FOR INFORMATION COLLECTED OTHER THAN THROUGH GHR WEBSITES

If you submit personal information to GHR through any channel other than GHR Websites, the same privacy rules set forth at Part I above for GHR Websites will be applied to such personal information you submit through channels other than GHR Websites (including without limitation your opt-out rights at Part I, Section 6 above), except as follows:

  1. The “cookies” and other tracking devices used by GHR Websites and described in Part I above do not apply to personal information gathered through channels other than GHR Websites.
  2. Hardcopy personal information provided to GHR which is not converted to electronic media and hosted by GHR will be subject to different security procedures than will stored electronic personal information. GHR has security measures equal to or better than those reasonably expected in the industry, in place to protect against the loss, misuse and alteration of your hardcopy personal information under our control.
  3. When GHR collects personal information through channels other than GHR Websites it may in some instances apply a different privacy policy to such information; but where it does so it shall conspicuously disclose to you at the time of collection what privacy policy will apply to such information.  For example, GHR may collect survey information through a survey where GHR’s use of any personal information from that survey is more limited than the general GHR Privacy Statement would otherwise allow; in such a case GHR will disclose the stricter privacy policy governing that survey information at the time such personal information is collected from the survey respondent.

Privacy Policy Effective May, 25, 2018