What Information Do We Collect?
- Information We Receive From Third Parties: We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information, joint marketing partners, social media platforms, people with whom you are connected on social media platforms, and other third parties.
What Information Do We Collect Automatically From Your Device and How Do We Use It?
We and our third-party service providers may collect information automatically from your device in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
- Using pixel tags and other similar technologies: We may use pixel tags (also known as web beacons and clear GIFs) to, among other things, track the actions of users of the Services and our email recipients, measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs“)) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
- Precise Real-Time Location Information: We may collect precise, real-time information about the location of your mobile device. We may use your device’s location to provide you with personalized location-based services and content, including marketing communications. You may be permitted to allow or deny the use of your device’s location by managing your location services preferences through your device settings.
How Do We Use Your Information?
In addition to using your information to deliver the programs, services, products, or information you request, and for the purposes described above, we may also use it:
- to provide customer support;
- to provide you with information about the Services, our other products, programs, or services, your accounts, and notices;
- to deliver marketing communications that may be of interest to you;
- to permit you to participate in polls, surveys, promotions, or other interactive features, such as chat features;
- to personalize your experience and better tailor content to you;
- to facilitate social sharing functionality;
- to allow you to send messages to another person through the Services;
- to help us, our subsidiaries, affiliates, and business partners better understand our audiences, evaluate user interest in the Services, improve the Services, and perform other market research activities;
- for our business purposes, such as data analysis; audits; monitoring and prevention of fraud, infringement, and other potential misuse of the Services; modifying the Services; determining the effectiveness of our promotional campaigns; and operating and expanding our business activities; and
- as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We may use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable law. We may combine, aggregate, or anonymize any of the information we collect from you with information we may collect from or about you from any other online or offline source.
When and to Whom Do We Disclose Your Information?
The information we collect from and about you may be disclosed:
- to third parties that provide services to us, such as fulfilling requests for information, answering calls, administering programs or projects, assisting in research and development, or delivering advertisements or other communications;
- to business partners who offer products or services jointly with us or with our subsidiaries or affiliates;
- to permit a third-party business partner to deliver marketing communications or products that may be of interest to you, subject to any choices you have expressed;
- to identify you to any person to whom you send messages;
- to any person you direct us to contact, such as your designated caregiver(s);
- by you, on message boards, chat, profile pages, blogs, and other services to which you post information and materials. Because any information you post may become public, we urge you to be very careful when deciding to disclose any information on or through the Services;
- as required by law, such as to law enforcement, to health authorities to report possible adverse events, during government inspections or audits, as ordered or directed by courts or other governmental agencies, or in order to comply with a subpoena or other legal process;
- when we believe in good faith that disclosure is necessary to protect legal rights or the security or integrity of the Services; protect your safety or the safety of others; investigate fraud, a breach of contract, or a violation of law; or respond to a government request; and
- to third parties, advisors, and other entities to the extent reasonably necessary for development of or to proceed with the negotiation or completion of a corporate or commercial transaction, including a reorganization, merger, acquisition, joint venture, sale or other disposition of all or a portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings.
We may disclose information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable law.
Where you have elected to participate in one of our programs or services or to receive marketing communications from us, we may offer you the ability to discontinue your participation or to opt out of receiving those communications in the communication itself, or you can visit our Contact Us page https://www.epmip.com/contact-us/.
We use appropriate technical, administrative, and physical safeguards to protect the information collected through the Services. Unfortunately, no organization can guarantee the absolute security of information, especially information transmitted over the Internet.
We do not knowingly collect personal information online from a child under the age of 13 without obtaining prior parental consent, other than to inform the child that we must have parental consent before collecting personal information.
Accessing and Updating Your Information
We encourage you to update the personal information you provide to us to help us continue to provide information that best meets your needs. You may be able to update this information through Services, or visit our Contact Us page https://www.epmip.com/contact-us/. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
Links to Third Party Websites
The Services may contain links to third-party services that are not under our control. We are not responsible for the collection and use of your information by such services, and we encourage you to review their privacy policies. In addition, we are not responsible for the information collection, use, disclosure, or security practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to such other organizations through or in connection with the Services.
How to Contact Us
Additional State-Specific Information for United States Residents
Some states (including but not limited to California, Nevada, and Texas), have state specific rights for their residents, see State Privacy Notices below.
State Privacy Notices
Effective March 1, 2020
For the notices below, capitalized terms as well as “we” or “us” have the same meaning as set out above.
California Residents Under Age 18: If you are a resident of California under age 18 and a registered user of the Services, you may ask us to remove content or data that you have posted to the Services by writing to firstname.lastname@example.org. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
California Consumer Privacy Act Notice
Last Updated: March 1, 2020
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we provide the following details regarding the categories of Personal Information about California residents (excluding business-to-business data) that we have collected or disclosed within the preceding 12 months:
- We collected the following categories of Personal Information:
- 1.1 Identifiers, such as name and government-issued identifier (e.g., Social Security number);
- 1.2 Personal information, as defined in the California safeguards law, such as contact and financial information;
- 1.3 Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status;
- 1.4 Commercial information, such as transaction information and purchase history;
- 1.5 Biometric information, such as fingerprints and voiceprints;
- 1.6 Internet or network activity information, such as browsing history and interactions with our websites;
- 1.7 Geolocation data, such as device location;
- 1.8 Audio, electronic, visual and similar information, such as call and video recordings;
- 1.9 Professional or employment-related information, such as work history and prior employer;
- 1.10 Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
- 1.11 Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
We collect this Personal Information directly from California residents themselves, as well as from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, caregivers, companies and other third parties that help us screen and onboard individuals for hiring purposes, and other third parties.
We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment purposes, and to otherwise accomplish our business purposes and objectives. Our business purposes and objectives include, for example, developing, improving, repairing, and maintaining our products and services; personalizing, advertising, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.
- We disclosed the following Personal Information to our affiliates and third parties, such as our service providers, for our operational business purposes:
- 2.1 Identifiers, such as name and government-issued identifier (e.g., Social Security number);
- 2.2 Personal information, as defined in the California safeguards law, such as contact and financial information;
- 2.3 Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status;
- 2.4 Commercial information, such as transaction information and purchase history;
- 2.5 Biometric information, such as fingerprints and voiceprints;
- 2.6 Internet or network activity information, such as browsing history and interactions with our websites;
- 2.7 Geolocation data, such as device location;
- 2.8 Audio, electronic, visual and similar information, such as call and video recordings;
- 2.9 Professional or employment-related information, such as work history and prior employer;
- 2.10 Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
- 2.11 Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
- We have not “sold” Personal Information for purposes of the CCPA.
For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
If you are a California resident, you may request that we:
- Disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we otherwise shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.
- Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us at email@example.com. In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
Nevada Residents as Covered by Nevada Privacy Law
We do not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact firstname.lastname@example.org.
Pursuant to the Texas Health and Safety Code, Sec. 181.154, please be advised that if we receive any data that identifies you and relates to your past, present or future physical or mental health, healthcare or payment for your healthcare, such data may be subject to electronic disclosure by such means as file transfers or email.