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PRIVACY POLICY

Effective Date: August 16, 2012

Overview

You should read this entire Privacy Policy, but here are some high points further detailed below:

–   We ask you for, and use technology to detect, information about you. Some of this
    information is shared with others.

–   If location services are enabled, your Device location may be tracked.

–   Survey results provided to sponsors will be de-identified (i.e., your Personal Information
    will not be linked to your survey results in what the sponsor receives).

–   By downloading our apps or using our sites, you consent to our practices detailed below.

–   Click here for an index of topics covered below. You may click on any topic to go to the details.

Introduction

Welcome! You have arrived at www.caligninc.com, our Soapbox and Soapbox Rx mobile survey, or another site or app owned and operated by Calign, Inc. (“Company” or “we,” “our” or “us”). This “Privacy Policy” governs your use of our web sites and mobile applications that post a link to this Privacy Policy (including, without limitation, both mobile and online versions), and also applies to your use of interactive features, widgets, applications, content or downloads that we own or control that interact with such sites and applications, or that post this Privacy Policy (collectively, the “Sites/Apps”) regardless of how you access or use them, whether via personal computers, mobile devices or otherwise. It does not apply to third party interactive features, widgets, applications, and content or downloads that we do not own or control even if they are accessed by or interact with our Sites/Apps. It also does not apply to data we receive from such third parties, or any other third parties, except to the extent we combine such data with Personal Information (defined below) that we have ourselves collected via our Sites/Apps under this Policy.

You can use our Sites/Apps to register for and take surveys for our survey sponsors. The survey results we share with the sponsors will never tie your responses back to your personal identity. In other words, we do not link your Personal Information to your survey results when we give the survey results to a survey sponsor.

This policy does not apply to our data collection activities offline or otherwise outside of our Sites/Apps (unless otherwise stated below). To the extent we provide you notice on our Sites/Apps of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Sites/Apps’ Terms of Service , which governs your use of the Sites/Apps. By using our Sites/Apps, you consent to our Privacy Policy and Terms of Service and our collection, use and sharing of your information and data, and other activities (including regarding Tracking Technologies (defined below), as described below.

Table of Contents

It is important that you read and understand the entire Privacy Policy before using the Sites/Apps. However, this table of contents further highlights key issues and points and you can click on the headings to be taken to the full explanation.

1. What Information Do The Sites/Apps Collect?

(a) Information You Provide To Us

You may give us Personal Information and Demographic Information, such as when you
register or contact us. More

(b) Information We Collect As You Access And Use The Sites/Apps

Tracking Technologies collect Usage Information based on your Device Identifier. More
Interactions with Third Party Sites/Apps. More

(c) Information Third Parties Provide About You

We may obtain information about you from third parties. More

2. How Do We Use The Information Collected?

We use your Personal Information, Demographic Information and Usage Information for a variety of purposes. More

3. How and When Do We Disclose Information To Third Parties?

We will not give a survey sponsor your survey results linked to your Personal Information. However, we may provide other of your information to third parties under various other circumstances. More
These include:

(a) When You Agree To Receive Information From Third Parties

(b) Third Parties Providing Services on Our Behalf

(c) Administrative and Legal Reasons

(d) Business Transfer

(e) Co-branded Areas

(f) Sweepstakes, Contests And Promotions

(g) Your Connecticut Privacy Rights

4. Do Third Party Content And Links To Third Party Sites/Apps Appear on The Sites/Apps?

We are not responsible for your interaction with third party content or locations. More

5. How Do I Change My Information And Communications Preferences?

You may change certain account information and preferences. More

6.What About Transfer of Information To The United States?

Data may be transferred to the United States. More

7. What Should Parents Know About Children?

We do not intend to collect Personal Information from children. If you think we have, let us know. More

8. What About Security?

No data security is absolute, but we take reasonable steps to secure data appropriately. More

9. What About Changes To The Privacy Policy?

We may change this Privacy policy as explained here.

10. What if I have a question or complaint?

Contact us here.

The Full Detailed Privacy Policy

1. What Information Do The Sites/Apps Collect?

(a) Information You Provide To Us

Personal Information and Demographic Information. On the Sites/Apps, including via surveys, we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, Social Security or Tax Payer ID number, if healthcare professional – license and medical education numbers, e-mail address, and home address (“Personal Information”); and (2) demographic information, such as information about your gender, your type of business, gender, marital status, income or revenues, education level, and occupation (“Demographic Information”). We may collect this information through various forms and in various places on the Sites/Apps, including surveys, account registration forms, contact us forms, or when you otherwise interact with the Sites/Apps. If we associate Demographic Information we collect directly from you on the Sites/Apps with your Personal Information, we will treat the combined data as Personal Information under this Privacy Policy.

(b) Information We Collect or Store As You Access And Use The Sites/Apps

In addition to any Personal Information or other information that you choose to submit to us via our Sites/Apps, we, our third-party service providers, and other third parties may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Sites/Apps (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, laptop, tablet or mobile phone (a “Device”) whenever you visit or interact with our Sites/Apps. Usage Information may be non identifying or may be associated with you. If we associate Usage Information we collect directly from you on the Sites/Apps with your Personal Information, we will treat the combined data as Personal Information under this Privacy Policy.

This Usage Information may include:

  • Your IP address or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Sites/Apps, and our computers identify your Device by its Device Identifier;
  • Your Device functionality (including browser, operating system, hardware, mobile network information);
  • The areas within our Sites/Apps that you visit and your activities there, including remembering you and your preferences;
  • Your Device location;
  • Your Device characteristics; and
  • Certain other Device data, including the time of day, among other information.

We may use various now and later developed methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies.   A cookie is a data file placed on a Device when it is used to visit the Sites/Apps. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Sites/Apps may not function properly, and that when you revisit our Sites/Apps your ability to limit cookies is subject to your browser settings and limitations.

Web Beacons.  Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Sites/Apps’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites/Apps, to monitor how users navigate the Sites/Apps, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts.   An embedded script is programming code that is designed to collect information about your interactions with the Sites/Apps, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Sites/Apps, and is deactivated or deleted thereafter.

ETag, or entity tag.   A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and HTML5 cookies.

We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary.  We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Sites/Apps, including Tracking Technologies required to prevent fraudulent activity, improve security or allow you to make use of shopping cart functionality.

Performance Related.  We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Sites/Apps, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Sites/Apps.

Functionality Related.   We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Sites/Apps, including identifying you when you sign in to our Sites/Apps or keeping track of your preferences, including in terms of the presentation of surveys made available via our Sites/Apps.

There may be other Tracking Technologies now and later devised and used by us in connection with the Sites/Apps. Further, third parties may use Tracking Technologies with our Site. We may not control those Tracking Technologies and in such event, we are not responsible for them, even if the third party provides us with data or services. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Sites/Apps and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties and you will look solely to those third parties in connection with their Tracking Technologies and their activities.

(c) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on our Sites/Apps with outside records from third parties such as survey sponsors, for various purposes, including to enhance our ability to serve you, to target relevant surveys to you, to tailor our surveys to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with Personal Information we collect on the Sites/Apps, the combined data will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties.

2. How Do We Use The Information Collected?

Use of Information by Us. We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy: (1) to provide you with information or services or process transactions that you have requested or agreed to receive including facilitating your completion of surveys, to send you electronic communications, or to provide you with the opportunity to participate in new surveys; (2) to enable you to participate in a variety of the Sites/Apps’ features such as online entry sweepstakes, contests or other promotions; (3) to process your registration with the Sites/Apps, including verifying your information is active and valid; (4) to improve the Sites/Apps or our services, to customize your experience on the Sites/Apps, or to serve you specific surveys and other content that is relevant to you; (5) to contact you with regard to your use of the Sites/Apps and, in our discretion, changes to the Sites/Apps and/or Sites/Apps’ policies; (6) for internal business purposes; and (7) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Please note that information submitted to the Sites/Apps via a “contact us” or other similar function may not receive a response; we will not use that information so provided to contact you for marketing purposes unrelated to your inquiry unless you agree otherwise.

3. How and When Do We Disclose Information to Third Parties?

We may share non-Personal Information, such as aggregated user statistics, including without limitation anonymized survey results (i.e., where responses are not linked to Personal Information) and Demographic Data with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information linked to your survey responses with survey sponsors. We may, however, share your Personal Information with sponsors under other circumstances, such as with respect to the operation of sweepstakes, contests and promotions as described in Section (f). In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy.

(a)     When You Agree To Receive Information From Third Parties. You may be presented with an option on our Sites/Apps to receive certain information and/or marketing offers directly from third parties. If you choose to do so, your Personal Information will be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties. We are not responsible for such third party privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communications from one of these third parties, you will need to contact that third party directly.

(b)     Third Parties Providing Services on Our Behalf. We may use third party vendors to perform certain services on behalf of us or the Sites/Apps, such as hosting the Sites/Apps, designing and/or operating the Sites/Apps’ features, tracking the Sites/Apps’ activities and analytics, and enabling us to send you survey or other offers or perform administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third party analytics service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them.

(c)      Administrative and Legal Reasons. Subject to applicable law, we may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Sites/Apps’ Terms of Service or other policies applicable to the Sites/Apps, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Sites/Apps or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d)     Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Sites/Apps or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e)       Co-branded Areas. Certain areas of the Sites/Apps may be provided to you in association with third parties (“Co-Branded Areas”) such as [sponsors], [charities] and [political organizations] and may require you to disclose Personal Information to them. Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of you information. If you elect to register for products and/or services, communicate with such third parties or download their content or applications, at Co-Branded Areas, you may be providing your information to both us and the third party. Further, if you sign-in to a Co-Branded Area with a username and password obtained on the Sites/Apps, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area. We are not responsible for such third party’s data collection or practices and you should look to such third party privacy policies for More information.

(f)      Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Sites/Apps that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing us and the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

(g)      Your Connecticut Privacy Rights. Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

4. Do Third Party Content And Links To Third Party Sites/Apps Appear on the Sites/Apps?

The Sites/Apps may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Sites/Apps are served to you. In addition, when you are on the Sites/Apps you may be directed to other Sites/Apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their Sites/Apps. For example, if you “click” on a link, the “click” may take you off the Sites/Apps onto a different site, even if we have a presence on that third party site (e.g., to our Facebook page). These other Sites/Apps may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Sites/Apps and to review the third party privacy policies of all third party locations and exercise caution in connection with them.

5. How Do I Change My Information And Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Sites/Apps may allow you to review, correct or update Personal Information you have provided through the Sites/Apps’ registration forms and “Contact Us” links, your account registrant page or otherwise, and you may provide registration updates and changes by contacting us at info@caligninc.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. With respect to our mobile applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace.

Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit or delete your Personal Information, or change your preferences on the Sites/Apps, information that you change or remove may nonetheless persist, or be retained, internally for our administrative purposes.

You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your Site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. If you subscribe to text messages from us, you can terminate a particular text message subscription by reply texting “STOP.” Subsequent or different subscriptions will be unaffected.

Please note that we reserve the right to send you certain communications relating to your account or use of the Sites/Apps, such as administrative and services announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving marketing communications.

If you have any questions about: your Privacy Policy or practices describe in it, you should contact us in the following ways: Postal Mail: 1223 Wilshire Blvd., Suite 466, Santa Monica, CA 90403; By e-mail: privacy@caligninc.com

6. What About Consent To Transfer Information To The United States?

Our Sites/Apps are operated in the United States and intended only for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Sites/Apps or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

7. What Should Parents Know About Children?

The Sites/Apps are general audience web Sites/Apps and we do not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us at privacy@caligninc.com.

8. What About Security?

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Sites/Apps and provide us with your information at your own risk.

9. What About Changes To The Privacy Policy?

We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. However, we will not use your Personal Information in a manner materially different than promised at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
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