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CMEPipeline.com Privacy & Ethics Statement

Rievent Technologies is committed to protecting your privacy and following pharmaceutical industry best practices and regulations regarding continuing medical education.

This privacy statement covers the site CMEPipeline.com and is effective on/since October 03, 2002.

In addition to this privacy statement, this Web site is compliant with ACCME guidelines for Internet-based CME programs (ACCME policy 2002-A-11). CMEPipeline.com is not a pharmaceutical company Web site, advertising is not permitted, there are no links to pharmaceutical Web sites, and each program contains an agreement and privacy policy prior to entering the program. Hardware and software required to participate in each program is indicated in the program's menu.

The privacy policy of this Web site is strictly enforced.

CMEPipeline.com is a licensee of the TRUSTe eHealth Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.CMEPipeline.com. Because this Web site wants to demonstrate its commitment to our users’ privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If users have questions or concerns regarding this statement, they should first contact Rievent Technologies, LLC CMEPipeline.com Support by completing the support request form or in writing by writing to the address listed in the Contact Information section of this privacy policy. If they do not receive acknowledgment of their inquiry or their inquiry is not satisfactorily addressed, they should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process ( http://www.truste.org/consumers/watchdog_complaint.php ). TRUSTe will serve as a liaison with the Web site to resolve users concerns.

Information Collection and Use

Registration / Profile
In order to use this Web site, a user must first complete the registration form. During registration, a user is required to give contact information (such as name and email address). We use this information to contact the user about services on our site for which he has expressed interest.

It is necessary to collect personally identifiable information in order to manage continuing education credits and to award certificates. If a user does not provide personal information, they will not be able to participate in continuing education programs.

Information Use

Under strict pharmaceutical industry regulations, the sponsor of the educational program uses the information collected during an educational program in aggregate only. No personally identifiable information is used during aggregate data collection. Aggregate data is used to analyze the effectiveness of the educational program and contribute to the success of future research and programs. The education provider is granted access to an individual user’s data such as test grades and survey results. This is required so the education provider can certify successful program completion and award continuing medical education credits.

This site does not retain or track personally identifiable health record information.

Profile
This profile is used to tailor a user’s visit to our Web site, and is not used for marketing promotions. We do share your profile with the education provider, but your profile is not accessible to the education sponsor. We may use your profile to keep you informed of new programs that correlate to your profession or specialty (see the section on Communications from the Site for more information).

Cookies
A cookie is a piece of data stored on the user’s computer tied to information about the user. We use session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. The session cookie is linked to the user's account information and is required to access password protected sections of the site. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions.

By setting a cookie on our site, users would not have to log in a password more than once when this feature is available, thereby saving time while on our site. If users reject the cookie, they will be unable to log in to the site since a session cookie is used to maintain application state. No third party business partners use cookies on our site (for example, advertisers).

The web site will not work without the use of non-persistent cookies which are required for session tracking to facilitate log in and access control.

Third Party Advertising
Third party advertising is prohibited on CMEPipeline.com under ACCME guidelines. CMEPipeline.com has no advertising.

Log Files
Like most standard web site servers, we use log files. These include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track a user’s movement in the aggregate, and gather broad demographic information for aggregate use.

Clear Gifs (Web Beacons/Web Bugs)
We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs) that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller (about the size of the period at the end of this sentence). Third party clear gifs are not permitted or used on this site.

In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and of our marketing campaigns. If users would like to opt-out of these emails, they can do so by following the instructions in the Choice/Opt-out section.

Use of technology to block clear gifs may affect the layout and presentation of the site or emails since clear gifs are often also used for spacing and layout. Permitting clear gifs are not required to use the site or view emails sent from CMEPipeline.com.

Communications from the Site

Service Announcements
On very rare occasions it is necessary to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

Continuing Education Program Announcement E-mail Notifications
We may use your profile to keep you informed of new programs that correlate to your profession or specialty. When new CME offerings are added to the site, an email is sent to relevant registered users selected by profession or specialty. Users may choose to opt in or out of these communication. (see the section on Choice/Opt-out for more information).

Customer Service
We communicate with users to provide requested services and in regards to issues relating to their account. We reply via email or phone, in accordance with the users’ wishes. Established members will occasionally receive information on new programs, service announcements, and a newsletter. Out of respect for the privacy of our users, we present the option to not receive these types of communications. Please see the Choice/Opt-out section.

Sharing

Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or a legal process served on our Web site.

Aggregate Information (non-personally identifiable)
This site conforms to pharmaceutical industry regulations regarding information released under unrestricted educational grants. The sponsor of a program may see information in aggregate form only as defined by pharmaceutical and accreditation body standards related to unrestricted education grants.

Personally Identifiable Information
The education provider for a specific continuing education program has access to personally identifiable information for the purpose of certifying participation and will retain records of the user's attendance according to the accreditation body’s policies (ACCME, ACPE, or others).

Third Party Intermediaries
We occasionally use an outside shipping company to ship orders. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.

Business Transitions
In the event Rievent Technologies goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the transferred assets. Users will be notified via prominent notice on our Web site prior to a change of ownership or control of their personal information. If, as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection, the users will be given a choice consistent with our Notification of Changes section.

Choice/Opt-out

Users who no longer wish to receive our promotional communications related to continuing education programs may opt-out of receiving these communications. Users with an account who have not set their communication preferences will be included in announcements related to educational programs. The announcements are correlated with the user's profile (profession and specialty) to provide emails only to relevant clinicians.

User's may set their site communication preferences using the link available from their MyCME page or by clicking on this link: https://www.cmepipeline.com/notifications

Continuing education programs present an opt-in agreement regarding correspondence beyond the scope of an education program and the CMEPipeline.com web site. Many programs on this site present an opt-in statement to the user during the program regarding a post-impact analysis study to be conducted some period of time after program completion. If a user chooses to opt-in to their party (education provider) correspondence defined by the program's opt-in agreement, they will need to contact the provider directly in order to opt-out if they no longer wish to receive further communications.

Since the education provider shares your record of attendance in education programs, if you receive promotional materials related to a program that you participated in, then it is necessary to contact the education provider directly to be removed from their correspondence list.

Links

This Web site contains links to other sites. Please be aware that we, Rievent Technologies, are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.

Surveys

Our site requests information from users via surveys (in addition to required educational program evaluations). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site and its medical education content. Survey information requested during an educational program is provided in aggregate to the sponsor of a program. The education provider has access to granular survey information including contact information. Both the sponsor and provider are bound by ACCME, ACPE, or other continuing education accreditation body regulations regarding the use and disclosure of information collected. All survey information collected is in compliance with ACCME, ACPE, or other continuing education accreditation guidelines for that specific program.

Tell-A-Friend

A Tell-A-Friend link is occasionally available on select email announcements. If a user elects to use the referral link for informing a friend about the announcement, we ask them for the friend’s name and email address. Rievent Technologies will automatically send the friend a one-time email inviting them to visit the site. Rievent Technologies does not store this information.

Security

This Web site takes every precaution to protect our users’ information. When users submit sensitive information via the Web site, their information is protected both online and off-line.

When our registration/order form asks users to enter sensitive information (such as credit card number and/or social security number, DEA number, etc.), that information is encrypted and is protected with the best encryption software in the industry – Secure Sockets Layer (SSL). While on a secure page, the lock icon on the bottom of web browsers (such as Netscape Navigator or Microsoft Internet Explorer) becomes locked, as opposed to unlocked, or open, when users are just “surfing.”

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information off-line. Only employees who need the information to per