Privacy Policy

This Privacy Policy was last updated on August 30, 2016. Prior versions of the Privacy Policy are available here.

MOTIVATION SCIENCE, INC.
PRIVACY POLICY

General Statement

Motivation Science, Inc., a Delaware corporation (the “Company”, “we”, “us” or “our”), provides the website located at www.validic.com (the “Website”) to support healthcare application or website providers by providing their end users with access to certain third party applications, programs, and/or devices that the end users may elect to connect to using the Website (collectively, the “Service”).

This privacy policy (“Privacy Policy”) applies to the Website and to the Service and describes the information we collect, how we use it, with whom we share it, our compliance with the U.S. – EU and U.S. – Swiss Privacy Shields, and other related matters.

The Company controls, owns, and manages the information collected on the Website and by and through the Service and may use the information to build and grow our business in the manner as described in this Privacy Policy.

The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance.

The Information We Collect

In this section, we provide you with details about some of the information we currently collect about users of our Website and of our Service (collectively, “User Data”).

  • User Key. Your healthcare application or website (each, a “healthcare portal“) provides us with a user key (the “User Key”) that identifies you as a registered member of the healthcare portal. This allows us to verify that we are authorized to provide you with the Service.

  • Personal Information. We may collect information by which you may be personally identified, such as name, address, e-mail address and/or telephone number, and information required for the payment of goods or services that you order from us, including credit card numbers, security codes and other financial information (“Personal Information”).

  • Program Data. We will collect user data produced by your use of, or uploaded by you to, certain integrated third party applications, programs and/or devices that you may elect to use in connection with the Website and/or the Service (“Programs”). We provide you with information about Programs that connect with the Service. These Programs typically have features that collect and store data and/or other information about you and/or permit you to upload the same to your user account with the Program. When you choose to integrate these Programs with the Service, they will be able to provide us with access to some or all of that data and/or other information (the “Program Data”).You should review information from the Programs, including their privacy statements and terms of use, prior to using them or allowing them access to any information about you. These Programs are not sold, designed or manufactured by the Company. All support for these Programs is provided by the Program provider. The Company does not warrant and is not responsible for the quality, use or operation of the Programs and your use of any such Programs is governed by separate terms of use and privacy statements by the Program provider. We then share the Program Data with your healthcare portal provider.

  • Cookie Information. “Cookies” are small files that a site or its service provider transfers (if you allow) to your computer, mobile phone or other device with a web browser and data storage capability that enables the sites or service provider’s systems to recognize your browser and capture and remember certain information. Most web browsers will accept cookies by default, but they can be set to reject cookies, either from all websites or from specific sites. You can also manually delete cookies from your web browser. These options are generally set through a “Privacy” setting in your browser setup, but you should know that in some cases blocking, rejecting or deleting cookies may impact your ability to use the Website or the Service. We use cookies to help remember you as a user. We may also use cookies in the future in other ways to provide and to improve the Service, to make the Website easier to use, or for other similar purposes.

  • Navigational Information. We may collect and use information and data from you when you are using the Service and/or Website through the standard operation of our Internet servers. Information collected from you may include user Internet Protocol (IP) addresses, browser type and version, domain names, referring/exit pages, devices, operating system, date/time stamp, click stream data and anonymous statistical data regarding your use of the Service and/or Website. For example, we can tell which Internet Service Provider our users use, but not the names, addresses or other information that would allow us to identify particular users. We use this information to analyze trends, to administer and to improve the Service and Website, to track users’ movements around the Website and to gather demographic and other aggregate information (as described in more detail below) about our user base as a whole.

  • Clear Gifs. We may also employ a software technology called “clear gifs” (also known as “web beacons” or “web bugs”) that helps us better manage content on the Website by providing us feedback as to 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 users. In contrast to cookies, which are stored on your web enabled device’s hard drive, clear gifs are embedded invisibly on a website page, web-based document or email message and are about the size of the period at the end of this sentence. Clear gifs may be used in our HTML-based emails to confirm receipt of, and response to our emails, including those that you forward to other recipients.

  • Site Information. Due to communications standards on the internet, when you visit the Website we typically automatically receive the URL of the site from which you came and the site to which you are going when you leave our Website. We also receive the internet protocol address of your computer (or the proxy server you use to access the Internet), your computer operating system and type of web browser you are using, email patterns, your mobile device and mobile operating system, as well as the name of your ISP or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have enabled.

  • Site Analytics. We may analyze your use of the Website and/or Service with third party software that allows us to monitor and record your navigation and usage activities, in order to better customize and improve our Website, Service and other products.

  • Aggregated User Data. In an ongoing effort to better understand and serve the users of the Website and the Services, we may conduct research on demographics, interests, behavior and other topics based on User Data of our end users, including you, that is provided to, collected by or otherwise available to us. We use the User Data from you and other users and reformat, supplement, compile, analyze and/or aggregate these datasets together to create what we term “Aggregated User Data.” We may share certain components of this User Data and/or Aggregated User Data with our affiliates, agents and business partners as described below.

How We Use the Information We Collect

We use the information we collect to continually try to improve our Service and to provide a safe, efficient, and customized experience. In particular, we may use your User Data to do any of the following:

  • To manage and improve our service. We use the information we collect to provide our Service and other services and features and to measure and improve the Website, the Service and other services and features provided by us. We may also use User Data, including Aggregated User Data, to develop proprietary technology or services (including through the filing of patents or other forms of intellectual property protection) to be used in the Service and/or other related services. We may also use the information we collect to enforce our Terms, which are available at http://validic.com/legal/terms. We also use a variety of technological systems to detect and address anomalous activity, some of which require the use of User Data.

  • To create backup files. We create backup copies of the Program Data we provide to your healthcare portal provider.

  • To describe our services. We may also disclose certain Aggregated User Data in order to describe the Service and our other services and capabilities to current and prospective business partners, researchers, service providers and to other third parties for other lawful purposes.

  • To comply with law. We may use any of your User Data as necessary in order to comply with any applicable laws, regulations or court orders. We may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

How the Information We Collect May be Shared

  • Sharing with Healthcare Portal Providers. We share the Program Data we collect from the Programs with your application provider.

  • Outside Contractors. We may employ independent contractors, vendors, suppliers and other third parties to support our services and products (including the Website and the Service), such as hosting, monitoring and maintaining the Website and/or the Service, administering or monitoring emails, analyzing our users’ preferences, developing or improving applications for the Website and the Service and providing other related services. These parties may sometimes have limited access to User Data, in the course of providing products or services to us. Access to your User Data by these parties is limited to the information that we determine, in our sole discretion, to be reasonably necessary in order for them to perform their function for us. While we will seek to require outside contractors to protect the privacy of your User Data under privacy policies or confidentiality agreements that are at least as protective of your User Data as this Privacy Policy, and will not authorize them to use your User Data except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of these parties.

  • Business Transfers. We may also disclose and/or transfer your User Data to third parties in connection with a corporate transaction, such as a merger, acquisition by another company or sale or other transfer of all or a portion of our business or assets.

  • Onward Transfer. In cases of onward transfer to third parties of data of EU or Swiss Individuals received pursuant to the EU-US and Swiss-US Privacy Shields, the Company is potentially liable.

Reviewing, Updating and Deleting Your Information

EU individuals have the right to access their personal data. We provide your healthcare portal provider with the capability to review, update and delete your User Data. We require your permission before any of your User Data is accessed, retrieved or made available to your healthcare portal provider. In addition, we provide your healthcare portal provider the ability to allow you to revoke permission to access your User Data.

Links and Advertising

We do not advertise on our Website or through the Service and do not provide any User Data to advertisers or otherwise to third parties for the purpose of advertising or marketing. From time to time, the Website may contain hyperlinks (“Links”) to third parties, including third party providers of certain Programs. Such Links are for your reference only, and we neither control the privacy policies of such linked websites nor are we liable or responsible in any way for the use of any personally identifiable information that you may provide such sites. We recommend that you remain aware when you leave the Website and review the terms of use and privacy policies of each and every linked website.

You should also be aware that if you voluntarily disclose personally identifiable information in an email or other communications with any third party listed on the Website or in other materials, that information, along with any other information disclosed in your communication, can be collected and correlated and used by such third parties and may result in your receiving unsolicited messages from other persons. Such collection, correlation, use and messages are beyond our control.

Security

  • Steps we take to keep your information secure. The security of your User Data is important to us. We have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure User Data from unauthorized access, including as set forth in more detail in our Company Security Policy available at http://validic.com/legal/data-security (the “Security Policy”).

  • Risks inherent in sharing information. Notwithstanding our commitment to protect your information, you should be aware that there is always some risk involved in transmitting information over the internet. In addition to the risk that the employees, contractors and others subject to our Security Policy may fail to follow required procedures, there is also some risk your or our network and/or security systems could be circumvented or breached, including by third parties who use our Website or Service in order to do so. As a result, while we strive to use commercially reasonable means to protect your User Data, we cannot ensure or warrant the security and privacy of your User Data or any other information you transmit to us, or of your or our network and/or security systems. If you have any questions regarding the security of the Website or the Service you can contact our privacy team at the email address set forth above.

Children’s Policy

The Website and the Service are for general audiences and neither is directed toward those under 18 years of age. We do not knowingly collect Personal Information from children under 13 without parental consent. If you become aware that a child has provided us with Personal Information, please contact our Privacy Officer at the email address in the Contact Information section. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to remove such information and terminate the child’s account.

Enforcement

We regularly review our compliance with this Privacy Policy. Please let us know of any questions or concerns you have regarding this Privacy Policy or our compliance with this Privacy Policy by contacting our Privacy Officer at the email address in the Contact Information section. When we receive formal written complaints, it is our policy to contact that complaining user regarding his/her concerns. We will cooperate with the appropriate regulatory authorities to resolve any complaints regarding the transfer of personal data that cannot be resolved between the Company and an individual or entity.

Please remember that your use of the Website and the Service is also governed by our Terms, which are available at http://validic.com/legal/terms.

U.S.-EU and U.S. – Swiss Privacy Shields

The Company complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. The Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, the Company commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact the Company at:

Motivation Science, Inc.
Ben Clark, Privacy Officer
300 W. Morgan Street, Suite 1200
Durham, NC 27701
privacy@validic.com

The Company has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

The Company is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. When we do so, we will revise the “Updated” date at the top of this Privacy Policy. Any such change will be effective immediately upon posting on the Website. You are responsible for checking the Privacy Policy for such changes.

Contact Information

If you have questions or complaints regarding this Policy or our practices, please contact the Company at:

Motivation Science, Inc
Ben Clark, Privacy Officer
300 W. Morgan St., Ste. 1200
Durham, NC 27701
privacy@validic.com

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