Privacy policy.

Our central philosophy is that your personal information belongs to you, not us, and that your personal health information is a very private matter that you want specially protected. You should have control over who has access to it and if you share it with us then we have the responsibility for protecting it and making it secure. We are passionate about such protection. By “Personal Information” we mean information about you that is personally identifiable, like your name, address, e-mail address, or phone number, as well as other non-public information that is associated with this personal information.

The Fundamentals:

1. We do not sell, rent or lease your email address, identity or any other personal information about you to anyone else.

2. We do share this information with our subsidiaries and affiliated companies who provide data analysis or processing for us and are bound within the terms of this privacy policy. We do not share it with anyone else.

3. If it is in your interest and if you give us informed permission we may need to discuss your personal health information with a provider of health care or a health insurance company who already has that information and has your permission to talk to us. We will not disclose new private information to that third party without your specific informed consent. By “informed consent” we mean that we have verified with you your understanding of the implications of us disclosing that information, and also understand that we have no control over that third party’s privacy policy.

4. You control how, when and where you wish to receive information from us, and/or be contacted by us. This is an opt-in policy (e.g. for email contact) which you may change at any time. We will not contact you through another person, whether a relation or not, without your express authority.

5. We will want to collect personal information and personal health information about you but only with your explicit and informed permission. We believe it is in your best interest for us to understand your circumstances as best we can – so that we can offer advice, support and services that are specific to you and the specific situation you are in. We may want to gather this information in a number of ways:

a. You provide it to us directly (e.g. by registering with us or answering one of our life, health or financial questionnaires). All data and responses to our questionnaires that you fill out on our site are security protected and accessible only through passwords.

b. We collect it from someone else (e.g. from your health care provider or insurance company). We may need to verify certain information or to obtain new information about you that you have given us authority to obtain on your behalf. We keep this information in the same way that we keep the information you provide directly.

c. We analyze how you use our services (e.g. which of our on-line sites you access). This helps us understand how you and people like you use the site so that we can serve you better. The data analyzed is anonymous – without any personal identification – just like counting cars and types of cars at a freeway intersection and where they go next, but not who is driving or the plates. We do not use permanent “remember me” cookies but temporary ones that remain only while you are signed in to make things smoother for you. We do not use or analyze IP addresses or web logs.

6. You may provide us with information that you later want to add to, change, erase or edit in some way. This is your right, since it is your information, not ours. We will let you know what impact if any this action may have on the advice, support or services we provide you with. In particular, updating your information, adding new medical facts or telling us of recent personal events may change the advice we had previously given you.

7. If you purchase a service or product from us, and use a credit card, we will collect your credit card information for that transaction, but we do not store that information.

8. Whatever information you allow us to keep about you and your circumstances, we will store as securely protected as is technically possible. We will maintain state of the art technology for this. We keep our own personal data there as well, so we too want it kept securely and private.

9. We can only control our own website, so if you click on a link that takes you to another website, please read their privacy policies which may differ from our own. We will always let you know when you leave our website for another one.

10. Children under the age of 13. We conform to the Children’s Online Privacy Protection Act [COPPA]. This means that we will never knowingly request personally identifiable information from anyone under the age of 13 without the consent of one parent. Even with that consent, we will not share their personally identifiable information with third parties.

11. Business Transition. In the event that we undergo a business transition such as a merger, being acquired by another company, or selling a substantial portion of its business assets, users’ personal information may become part of the assets managed under the new corporation.

12. Disclosure required by law. We may also disclose information if we have a good faith belief that access, use, preservation or disclosure of such information is necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable or Terms and Conditions, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues or (d) protect against imminent harm to our rights, property or safety, ours users or the public as required or permitted by law.

13. Data transport. If your personal data has to be transported to a third party, we will not have control over their use of it and may not have control over how it is transported if it is over an open network, (e.g. the Internet or email). In every case we will seek to protect and make secure your data, and warn you beforehand of the risk involved, but we cannot guarantee its confidentiality when transmitted over an open network.

a. When disclosing any personal information via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. A third party may therefore be able to trace an existing bank account or relationship or one that is subsequently created.

b. Even if both the sender and recipient are located in the same country data may also be transmitted via such networks to other countries regularly and without controls, including to countries that do not afford the same level of data protection as your country of domicile.

c. Regardless of the security precautions taken by you or by us, “perfect security” does not exist on the Internet. For certain services, we use strong encryption to transfer your data. In these cases you will be told separately about the treatment of this data and about the details of encryption.

d. Your data may be lost during transmission or may be accessed by unauthorized parties. We do not accept any liability for direct or indirect losses as regards the security of your data during its transfer via Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.