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GHX Website Privacy Policy

This website is operated by Global Healthcare Exchange, LLC and its subsidiaries (collectively, "GHX"). GHX is committed to respecting the privacy and security of your personal information. This Privacy Policy describes the information collected on this website and how it is used and protected. This Privacy Policy applies only to this website. Please review the privacy policy of any other GHX site you may visit, including applications offered by GHX and its subsidiaries (including ePay and Vendormate) and the GHX Community on salesforce.com.

By using this website, or by providing your information to us or to our service providers, you consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy and the GHX Terms of Use for this website.

California residents should carefully review the section below titled "Privacy Notice for California Residents."

Collection and Use of Information

The information we receive and how we use it depends on what you do when visiting our website. You may choose to provide GHX personal information using this website, for example by entering that information into data fields on the website or emailing GHX at the email addresses provided on the website. Personal information includes data that specifically identifies you or your household, such as your name, organization and title, email address, mailing address, and telephone number. For example, you may use the website to request a publication, attend a conference, or submit a question.

GHX and its service providers also collect certain data that is specific to you but that does not directly identify you as an individual person. This information tells us about how people use the website so that we can analyze its effectiveness and provide you with a better web experience. We collect and use this information through a variety of technologies, including "cookies" and techniques used to track who is reading a web page or email, when, and from what computer, as discussed below.

Cookies

This website uses several types of cookies to help its operation. A cookie is a small piece of information sent from a web server to a browser to be stored and read back later by the application. Some cookies are set to expire when you end your session on the website. Others last for longer periods unless you reject or disable them. The website uses browser cookies and may use flash cookies (also called local shared objects), which differ in that flash cookies can store more data, store different data, and store data in a different place on your browser. The types of cookies used on the website are described below.

Site Performance Cookies

Site performance cookies collect information about how users navigate the website. These cookies collect only aggregated, anonymized information, and do not collect information that individually identifies users. This information is used to help the website’s performance.

Functionality Cookies

Functionality cookies remember choices you have made to customize your view of parts of site pages (e.g., languages, text sizes, fonts, etc.).

The website may use local shared objects, or flash cookies, to personalize your visit by storing your preferences.

Advertising Cookies:

These cookies are used to present relevant GHX advertising messages to you on other sites.

Alerts, Options, and Disabling Cookies

The website is set to alert you when it first attempts to send a cookie to your computer and allow you to disable the cookie using your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookie settings. You can manage flash cookies using the local settings manager native to your operating system or, for earlier flash player versions, using the online settings manager for the flash player. Please note, however, that disabling or deleting cookies may affect the functionality of some features on the website.

Web Beacons and Site Analytics

Web beacons, also known as web bugs or pixel tags, are tiny graphic images that are unobtrusively placed on a website or in an email. The website may use web beacons together with cookies to help analyze your use of the site. When the code for a web beacon points to the website to retrieve the image, it simultaneously passes information to the site’s servers about your use of the website, including the pages you view, the links you click, and other actions taken in connection with the website. Web beacons can also collect certain standard information that your browser sends to every website you visit, such as your Internet Protocol ("IP") address, browser type and language, access times, referring website addresses, and previously-set cookie values.

Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Inc. ('Google'), with the expansion "anonymizeIp()." Google Analytics uses cookies to help the website analyse how users use the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. In the event that IP anonymization is activated on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other signatory states of the Treaty on the European Economic Area. On an exceptional basis, the full IP address may be transmitted to a Google server in the United States and shortened there. Google will use this information for the purpose of evaluating your use of the website, compiling reports and providing other services to website operators, relating to website activity and Internet usage. Google says that it does not associate the IP address transmitted through Google Analytics by your browser with other data held by Google.

You may use the appropriate settings on your browser software to prevent cookie storage; however, doing so may affect the functionality of some features on this website.

You can opt out of having your data sent to Google Analytics by downloading and installing the Google Analytics opt-out browser add-on available through Google at https://tools.google.com/dlpage/gaoptout. The add-on does not work for mobile devices, for which you can copy and paste the following Java script into your browser: <a href="javascript:gaOptout()">Deactivate Google Analytics</a>.

Location-Enabled Technology

Some electronic devices include location-enabled technology. If you use these devices to access the website, you may be sending the website information about your location. GHX does not use or keep this information, except to provide the services you have requested. Your device may allow you to disable this technology.

GHX and its service providers retain and use your information for as long as needed to provide you services, respond to your communications, comply with legal obligations, resolve disputes, and enforce our agreements. GHX and its service providers may save personal contact information you choose to provide in order to contact you in the future about GHX products and services. This contact may be in the form of telephone calls, emails, or mailings. You may opt out of these future contacts as described in "Review, Modify, or Delete Your Information" below. GHX reserves certain rights with respect to information provided through this website, and requires certain representations about such information, as described in the Website Terms of Use posted on this website.

Sharing and Transferring Your Information

Some materials and features associated with this website may necessarily be available only to users who provide their contact information (e.g., conference registrations, responses to inquiries).

GHX and its service providers may transfer information between them for business purposes. For example, GHX service providers may handle technical support, marketing and market research, data management, email distribution, or information analysis. We furnish our service providers the information they need to perform these and other services, and we work with our service providers to respect and protect your information. We may also provide your information among GHX affiliates and subsidiaries. The entities with which we share information may be located in the United States or other countries.

GHX does not sell your personal information to any third party. We may sell or transfer non-individualized information to third parties, including summary or aggregated, anonymous information about all or sub-groups of users of the website, for purposes such as reporting or marketing.

In the event that GHX or some of our assets are sold or transferred or used as security, or to the extent we engage in business negotiations with our business partners, the information collected on this website may be transferred or shared with third parties as part of that transaction or negotiation. We may also provide information or provide access to information to any of our affiliated businesses or to our business partners.

On rare occasions, we may disclose specific information without your consent and without notice to you as required to comply with laws and regulations, or to comply with court orders, subpoenas, or lawful discovery requests. Information collected from you may also be used or disclosed to authorities or service providers to prevent, detect, investigate, or respond to security breaches or fraudulent or illegal activity

Protecting Your Information

GHX has implemented reasonable physical, technical, and organizational safeguards to help protect your personal information from unauthorized access, acquisition, or disclosure, alteration, or destruction. Although we strive to keep your personal information secure, no safeguards can be guaranteed to be completely secure, so you should exercise caution when transferring personal and other sensitive information over the Internet. Please advise us immediately at the address listed below of any incident involving loss, unauthorized access, or unauthorized disclosure of personal information that is in our custody or control.

Links to Other Sites

The website may contain links to other sites, content, or resources, including links to other sites operated by GHX or other entities. Please note that when you click on one of these links, you will leave this website and will be subject to the policies and privacy practices of the other site, which may differ significantly and be subject to different laws. You should review the policies of other sites you visit. GHX is not responsible for the content, technology, security, or practices of linked sites operated by others, or for your use of linked sites.

Children’s Privacy

The website is not aimed at or intended for children. We do not knowingly collect information from children under the age of sixteen through this website. If we obtain actual knowledge that we have inadvertently collected personal information relating to a child under the age of sixteen, we will delete that information from our records.

International Transfers

This website is hosted and maintained in the United States. If you are visiting this website from a country other than the United States, you should understand that your data submitted through or generated by your use of this website will be transferred to and processed under the laws of the United States, which may not have the same data protection laws as the country in which you are located. This will necessarily result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to the transfer and processing of your data as set out in this Privacy Policy in the United States subject to the laws of the United States. If you do not consent to having your information used in according with this Privacy Policy, you should not provide your personal information and should disable all cookies and other technologies as described above under "Collection and Use of Information."

Review, Modify, or Delete Your Information

We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us or would like to update or change your personal information or preferences, please follow the instructions below to review, modify, or delete your personal information.

To unsubscribe from receiving periodic emails from us, please follow the instructions for unsubscribing that may be found in emails we send you.

If you request that your registration information be deleted or if you unsubscribe from communications, we may maintain information about your transactions or service inquiries for future service and recordkeeping purposes. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide you information, products, or services. In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

If you wish to otherwise view or correct the information GHX has collected about you through this website, or if you wish to be removed from our contact lists, please contact us using the information at the end of this Privacy Policy. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Updates to this Privacy Policy

GHX may update this Privacy Policy and our website at any time without prior notice to reflect material changes in how we collect, use, share, or store your information, to satisfy legal requirements, or for other business purposes. You should review this Privacy Policy when you visit the website to understand our current practices. The date below shows when this Privacy Policy was last updated.

We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current practices. You consent to any changes we make to this Privacy Policy if you continue to use the website after receiving a notice of the change or upon our posting of the new Privacy Policy on this website.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by GHX’s Legal Department. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it means 'including without limitation'.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon GHX any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable country, state, and other privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and applicable privacy laws, this Privacy Policy shall be interpreted, in that case, to give effect to, and comply with, such privacy laws.

Privacy Notice for California Residents

This section supplements the information provided elsewhere in this Privacy Policy and includes information applicable only to "personal information" of California "consumers" as those terms are defined in the California Consumer Privacy Act ("CCPA"). Taken together, the information in this Privacy Policy serves as general notices and instructions for purposes of the CCPA.

The effects of the laws and regulations described below on any particular individual may vary according to the circumstances. This section is provided for general informational purposes only and is not intended as legal advice.

California Consumer Privacy Act (CCPA)

The CCPA has an effective date of January 1, 2020, with certain important exceptions. Among these are exemptions from certain CCPA requirements until January 1, 2021 for personal information collected in the context of (1) employment; or (2) one business providing products or services to another business ("B2B" information). GHX is a B2B business, meaning that it provides products and services to other businesses rather than to individuals directly. If you are using this website in a context that is subject to exemption, many of the individual CCPA rights described in this section may be inapplicable to you unless and until such exemptions no longer apply.

Categories of California Personal Information Collected

In the past 12 months, GHX has collected, used, and disclosed personal information in connection with this website in the CCPA categories listed in the table below. Please refer to the section titled "Collection and Use of Information" for more detail.

CCPA Category Examples
Identifiers and California Customer Records Statute Categories Name, email, mailing address, IP address
Commercial Information Products or services viewed
Internet or similar website activity Information on visitor’s interaction with this website
Geolocation data Physical location*
Inferences drawn from other personal information Profile reflecting a person’s preferences, behavior, etc.

*Please see "Location-Enabled Technology" above.

Categories of Sources

GHX collects personal information in connection with this website from the following sources, as described in more detail in this Privacy Policy:

  • Directly from you (e.g., from forms you complete on this website); and
  • Indirectly from you or your devices (e.g., from your interaction with this website).

Business Purposes of Uses and Disclosures

GHX has in the past 12 months used and disclosed, and continues to use and disclose, personal information for the following business purposes described more fully in this Privacy Policy.

  • Providing information about, analyzing, and helping develop GHX products and services and events;
  • Responding to inquiries and requests;
  • Providing, supporting, personalizing, analyzing, and developing this website;
  • Advertising and marketing;
  • Helping maintain the safety, security, and integrity of this website, and investigating and helping prosecute wrongdoing;
  • Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • To evaluate or conduct a sale or transfer of assets; and
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA

GHX has not knowingly "sold" any personal information collected through this website within the meaning of CCPA during the last 12 months, and does not intend to do so in the future.

Categories of Third Parties Receiving Information

As described more fully above in the section of this Privacy Policy titled "Sharing and Transferring Your Information," GHX may disclose personal information to the following categories of third parties:

  • GHX affiliates;
  • Service providers;
  • Advertising partners;
  • Businesses involved in a sale or transfer of assets;
  • Law enforcement and government authorities.

California Consumer Rights

Subject to the CCPA exemptions described above, CCPA provides or is scheduled to provide California residents certain rights with respect to their data, including:

  • Information about the categories of information and of sources of information collected; the purposes for which it is collected, used, and disclosed; and the categories of third parties with which it is shared (as discussed above);
  • Access to specific information about and portability of their personal information collected;
  • Certain deletion rights; and
  • Freedom from discrimination in connection with their exercise of CCPA rights.

Exercising Personal Data Rights

You may request exercise of your CCPA rights using the information below under "Contact Us." Only you, or someone legally authorized to act on your behalf, may make requests related to your personal information. You may also make request on behalf of your minor child. You may only submit requests for access or data portability twice within a 12-month period.

Any request related to personal information under CCPA must provide sufficient information to:

  • Reasonably verify you are the data subject or an authorized representative.
  • Allow us to properly understand, evaluate, and respond to your request.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and connect the personal information we have collected to you. We may request that you submit information to verify your identity or authority using a form we specify. If it appears your personal information is subject to a CCPA exemption, we may respond to that effect. We will only use personal information provided in a request to verify your identity or authority to make the request.

Do Not Sell Requests

Because GHX does not and does not intend to sell any personal information collected through this website, we do not currently provide a "Do Not Sell My Personal Information" button or option on this website. However, GHX will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a "sale" of your personal information as defined by the CCPA. You can exercise control over browser-based cookies by adjusting the settings on your browser.

Do Not Track Requests

Because there is no current industry standard on responding to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about online activities over time, GHX does not respond to them at this time. Further, we do not understand them to operate in that manner or to indicate a do not sell expression by you, so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals, and we may recognize certain such signals if we conclude such a program is appropriate.

California "Shine the Light" Law

California residents who use this website may request from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the address provided below.

Contact Us

If you have questions or comments about this Privacy Policy or this website, please contact us using the information below.

Email: compliance@ghx.com

Global Healthcare Exchange
Attn: Director, Compliance and Enterprise Risk Management
1315 West Century Drive, Suite 100
Louisville, Colorado 80027
USA
Phone: 1.720.887.7000

Last updated: January 1, 2020