The INRTracker website at www.inrtracker.com (the "Site") is a personal health management web site. Our goal is to provide a platform for users who want to improve their health.
What kind of information we collect
Some of the information that Members enter into certain fields when registering to use or using the Site will not be shared except in rare instances ("Restricted Data"). The type of Restricted Data that Members may submit at the Site may include:
- Password, as collected as part of registration or in a Member’s Account Information. Protected Data
This is data that we will not share unless you opt in and allow us to share it with our "Partners".
- Insurance Provider
- Messages through the contact form
- Medical Conditions/Medical Devices information, e.g. atrial fibrillation, pacemaker
- Treatment information (e.g. treatment start dates, stop dates, dosages and notes)
- Logged information (e.g. INRs and Exercise)
- Device identifier (such as a the Controller Number for Members who have a ReliantHeart Inc. Medical Device)
- Patient identification number (such as the Patient ID for Members who have a ReliantHeart Inc. Medical Device)
Some of the information that Members provide about themselves may be shared with Partners. Examples of Shared Data that Members may submit at the Site, including through their account details ("My Account"), may include:
- Phone Number
- Biographical information (e.g., Name, Gender, Birth Year, Country, Time zone, Speaking Language)
- Profile Picture
- Sign up date
- Site Usage (as defined below)
- Activity initiated on the discussion board (e.g., posts, comments and survey responses)
In the course of using the Site, Members may share information that could be used to reasonably identify them ("Personal Information"), including name and email address. When a Member chooses to share Personal Information via a free text field (i.e., the discussion boards), the information shall become and be treated as Shared Data.
How your data is used in general
Members should expect that every piece of information they submit (even if it is not currently displayed), except for Restricted Data and Protected Data, may be shared with Partners, advertisers, service providers and other Members. Protected Data may be shared with Partners on an aggregate basis (i.e., that which does not identify an individual Member or his or her Site Usage).
There are instances where Shared Data and Protected Data, including Personal Information, may be used, shared and disclosed including, but not limited to, the following:
- INRTracker uses Shared Data and Protected Data, including Site Usage internally, as needed, for research, for maintenance and operation of the Site, and to create the best possible tools and functionality for users.
- INRTracker may use a Member’s data, including Restricted Data and Protected Data, in the case of an emergency or other circumstance that we determine requires a member of the management team to directly contact the Member. Such information may be provided to law enforcement if, in the reasonable judgment of INRTracker, necessary or appropriate.
- INRTracker may share or disclose a Member’s Shared Data, Restricted Data and Protected Data where required by law or to comply with legal process.
- In the event INRTracker goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of its assets, the Shared Data, Protected Data and Restricted Data, including Personal Information, might be among the assets transferred. Members will be notified via this Site of any such change in ownership or control of Personal Information.
How Protected Data is Used
Protected Data is not automatically shared with, sold to, or displayed for other Members or Partners. Specific instances where Protected Data may be used include, but are not limited to, the following:
- If a Member agrees to participate in a media interview (as arranged by INRTracker), INRTracker will share the contact information the Member provides (i.e. name, email, telephone) with the reporter for the purpose of arranging and conducting an interview
- If a Member explicitly opts in to have their Protected Data shared with a Partner, INRTracker will share the information as consented to by the Member (e.g. remote INR self testing with an independent diagnostic testing facility)
How Shared Data is used
Shared Data is viewable via My Account and through aggregated reports that are made available to other INRTracker Members. In some instances, this Shared Data is also viewable to those not registered to join INRTracker ("Non-members"). We report publicly Shared Data in aggregate, such as the number of users on a particular treatment or the number of users experiencing a particular symptom.
In addition to serving the individual needs of our Members, INRTracker and its Partners are interested in better understanding the patient experience and improving treatment options and health outcomes for everyone.
INRTracker provides Shared Data, in individual and aggregate format, to Partners and other third parties for use in signing users up for services (e.g. remote INR self testing), scientific research, market research and general advertising purposes. When selling this information, INRTracker removes Members’ Restricted Data and Protected Data. As stated previously, Protected Data will not be transferred, sold or shared on a non-aggregate basis unless you opt-in to allowing us to share it with our Partners.
INRTracker may also periodically ask Members to complete short surveys about their experiences (including questions about products and services). Survey responses are analyzed, combined with Members’ Shared Data and shared with and/or sold to Partners, advertisers and service providers. Member participation in these surveys is not required, and refusal to do so will not impact a Member’s experience on the Site.
INRTracker, like most Internet communities, is a public forum, and Members acknowledge and accept that any information shared through free text features or images might be connected to Members’ Shared Data (which may be shared with, sold to, or displayed for others, including non-Members). For example, if a Member puts his or her name (or other Personal Information) into a free text field like the discussion board, the Member should know this information may be included in what is shared with, displayed for, or sold to others, including Partners.
A cookie is a small data file that often includes an anonymous, unique token, which is sent to your browser from a website’s computers and may be stored on your computer’s hard drive. Two types of cookies are required to use the Site:
- Session Cookies are temporary cookies that remain only until you log out of the website or exit your web browser. Session Cookies do not store any Personal Information, only a unique visitor ID number that may be used to ensure Members are properly authenticated and can view site information.
- Persistent Cookies remain in the cookie file of your browser for much longer, even after you leave the Site. Persistent Cookies also do not store any Personal Information. Persistent Cookies store preferences that should persist from visit to visit, like "Remember Me," and a unique token to enable us to understand how Members use the Site ("Site Usage").
- "Web Beacons" (a.k.a. clear GIFs or pixel tags) are tiny graphic image files imbedded in a web page or email that may be used to collect anonymous information about your use of the Site and other services we or our Partners provide. The information collected by Web Beacons allows us to analyze how many people are using the Site, using a Partner’s website or opening our emails, and for what purpose, and also allows us to enhance our interest-based advertising.
- We may use third-party website analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the Site. These website analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across websites which do not use their services. We use the information collected from these services to help make the Site easier to use.
Other security issues
INRTracker cannot guarantee the identity of any other Members with whom a Member may interact in the course of using the Site or who may have access to a Member’s Shared Data. Additionally, we cannot guarantee the authenticity of any data that Members may provide about themselves.
Finally, Members should know that INRTracker takes commercially reasonable technical precautions to help keep Member data secure.
Risks and benefits
While our goal is to help users improve health outcomes, there are no certain benefits to using this website. However, keeping track of personal well-being, treatments, and symptoms has been shown to be helpful in improving overall health. Any use of this website is at the Member’s risk.
Members should understand that anyone can register at INRTracker and view Shared Data. There is a possibility that users may feel uncomfortable sharing information online. It is possible that a Member could be identified using information shared on INRTracker (and/or in conjunction with other data sources). A Member could be discriminated against or experience repercussions as a result of the information shared. For example, it is possible that employers, insurance companies, or others may discriminate based on health information.
In using the Site, Members are free to skip any non-required questions or data fields that make them feel uncomfortable. Members are also free to stop using this service at any time. If a Member chooses to deactivate his/her account, INRTracker will not display or sell the data in that account as of the date of deactivation. However, the Member’s data will remain in the system for auditing purposes, and research conducted prior to the deactivation of a Member’s account will still include the Member’s data.
The Site is hosted in the United States and is intended for visitors located within the United States. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Site. By providing any information, including personal information, on or to the Site, you consent to such transfer, storage, and processing.
Changes and Updates to this Policy
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