Website Privacy
Policy

Effective Date: October 8, 2020

The Peterson Center on Healthcare (the “Center,” “we” or “us”) is strongly committed to protecting the privacy of visitors to our website (the “Site”) and people who communicate with us. This Privacy Policy seeks to help you understand (i) how we collect and use your personal information; (ii) how we share and protect your personal information; (iii) your choices regarding our use of such information; and (iv) your rights in relation to your personal information.

This Privacy Policy applies when you visit our Site or share your personally identifiable information with us, as discussed below. Please note that this Privacy Policy applies only to the Site, and not to any other website linked to ours. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them. This Privacy Policy does not concern your interaction with the Center in any matter other than your use of, and does not address our privacy practices except with respect to, the Site. Please read the following carefully to understand the Center’s views and practices regarding your personal information.

If you have any questions or comments about this Privacy Policy, you can e-mail us at privacy@petersonhealthcare.org or write to us at Privacy, Peterson Center on Healthcare, 888-C Eighth Avenue, P.O. Box 144, New York, NY 10019.

How We Collect and Use Your Personal Information

General

We collect personal information from you in a number of ways. Personal information that we receive from you, such as your name, telephone number, postal address and e-mail address (or other information that is associated by us with such information), and personal information that we collect about you from the following sources: your social media interactions with us, your submission of an Initial Inquiry Form to the Center in connection with unsolicited grants, your submission of our online forms for employment or internship positions with the Center, and your use of our Site during which we may collect technical information and information about your visit (as set out below in the “Website Visits” section).

We use your personal information for the following purposes:

  • Enhanced User Experience: To understand better how visitors use our Site, to research our visitors' demographics, interests, and behavior, to provide visitors with customized services and information (and to provide online support for any inquiry you may have during your visit to our Site). In relation to these purposes, we will only process your personal information that is necessary for our legitimate interests to provide you with an enhanced and customized experience on our Site. It is also in your interest to benefit from an enhanced and customized visitor experience.
  • Newsletters and Updates: To contact you, through e-mail, postal mail and text messaging to your mobile phone number (if you wish to provide such information to us on our Site), and send you (i) newsletters and updates about the Center and the issues as to which we aim to increase public awareness; (ii) information regarding our affiliates that may be of interest to you; and (iii) information regarding our partners that may be of interest to you. We will only send these communications to you with your informed and specific consent and, where your consent is not required by law, this use of your information is necessary for our legitimate interest to let you know about us, our affiliates and our partners and the issues that you might be interested in. You may choose to opt-out of any such communications at any point and at no cost.
  • User Accounts: If you sign up for a user account, to participate in the Center Blog or in other features we offer, we will collect and process your personal information which you choose to provide to us. Your user account information will be visible to designated staff members of the Center and our third-party website-services vendors, but not to other registered users or Site visitors (except to the extent you voluntarily provide any such information when you post your comments). This processing of any such information that you provide to us is necessary to perform your contract with us for the provision of the services (online user accounts).
  • User Letters and Articles; User Comments and Content: Please be aware that any personal information you provide in connection with comments you contribute to the Center Blog, videos you upload to our Site, or other interactive features we may offer will be visible to other users and Site visitors. This processing of your personal information is necessary for our legitimate interests to establish or maintain a relationship with you and to receive feedback or content in relation to the way we operate so as to improve or look into further initiatives in line with our charitable initiatives.
  • Grants: If you wish to submit an unsolicited grant concept to the Center, we will only process your personal information that is necessary for the purpose of evaluating your application and/or responding to your grant-related inquiry prior to entering into a contract with you.
  • Job Opportunities: You may choose to apply for employment or an internship position with the Center through online application forms we may provide or by sending us, by e-mail or otherwise, a resume and letter (containing personal information). We will only process your personal information in this regard for the purpose of evaluating your application and/or responding to your employment-related inquiry prior to entering into a contract with you.
  • Compliance with Legal and Regulatory Requirements: To respond to or address inquiries or requests from law enforcement bodies, regulators or other public authorities. This is necessary for the purposes of complying with legal or regulatory requirements to which we are subject.

Website Visits

We and our authorized designees collect information through the servers for the Site, cookies and other technologies. In general, we automatically gather certain information about our Site visitors, including the number and frequency of your visits, the URL of the last and next website you visit, your browser and operating system, your IP address, how long you spend on our Site and what pages you view here.

We use cookies to enhance the efficiency of user interaction with the Site, gain insight into and customize our visitors' use of our Site, and help maintain our Site's proper operation. “Cookies” are small files placed on the hard drive of your computer; each website can send its own cookie to your browser if your browser preferences allow it. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You are always free to opt out from cookies at any time by changing your browser settings accordingly, although that may prevent you from using certain features on our Site, and may result in your needing to re-enter your account user name and password frequently when you are participating in the Center Blog. In addition, a number of companies offer utilities designed to help you visit websites anonymously.

We use cookies to track usage on our Site. We use “session cookies” to help us “remember” you until the session times out, or the closing of your browser, which helps ensure that, if you are participating in the Center Blog, you remain logged into your account. Session cookies are automatically deleted from your hard drive after the end of a session. We may also use a “persistent cookie” which “remembers” you every time you come back to our Site, but only if you choose this option. The information collected through cookies and other technologies is not personally identifiable in and of itself.

We use third party service providers to facilitate our provision of the Site and related services. For example, Google Analytics is a service that uses cookies and tracking code to analyze how visitors use our Site. The information collected (including your browser and operating system, IP address, pages visited on our Site and time spent here) is transmitted to and stored by Google. Google uses this information to evaluate visitors' use of this Site in an aggregate manner, compile reports on website activity and provide other related services. We also use the IpMeta Google Analytics plugin. IpMeta uses your browser's IP address to provide Service Provider and Network Domain dimensions for our Google Analytics reporting using WHOIS metadata. Google may transfer this information to third parties that process information on its behalf or as required by law. You can read Google's privacy policy at https://policies.google.com/privacy.

We will not allow third parties other than our affiliates or service providers to place any cookies, web beacons or other similar devices on our Site. We do not control such devices that may be placed on our Site by third parties. We are not responsible for any other websites accessible from or linked to the Site, including their privacy policies or information collection practices.

How We Share Your Information

We may disclose aggregate and anonymized information about our Site visitors and registered users to organizations or individuals that have provided us with funding or with which we have other relationships, for informational purposes.

We may share your personal information in certain circumstances:

  • Service Providers: We may use the services of other companies and individuals to facilitate our services and perform functions on our behalf, such as providing technical and hosting functions for our Site, managing our databases, sending postal mail, e-mail, and text messages, analyzing data, and providing customer service. These companies and individuals may have access to and use your personal information we collect as needed to perform their respective functions, but will not otherwise disclose such information to other third parties, except as may be required by law. We will use our best efforts to ensure that our service providers keep your personal information secure in accordance with applicable data protection laws. We may share your personal information with the following categories of service provider: website services providers, including IT service providers and providers of analytics services; marketing and communication agencies; external advisers (e.g. social media consulting) and cookie analytics providers.
  • Business Transfers: If the Center merges with or transfers substantially all of its assets to another entity, the Center has the right to share your personal information with that entity. We will make reasonable efforts to provide you with notice of such event, and we will request that the new entity follow the practices disclosed in this Privacy Policy or notify you of any changes to it.
  • Third Parties Permitted by Law: We will not otherwise share your personal information, except as required by law, requested by governmental entity or law enforcement authority, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts and privacy) or may expose us to liability, including in relation to the establishment, exercise or defense of legal claims. We can (and you hereby authorize us to) disclose any of your personal information in such circumstances.

Your personal information may be transferred to and processed in the United States or to other countries located outside the European Economic Area (EEA). We will take steps that are reasonably necessary to ensure that your personal information is adequately secured in accordance with this Privacy Policy and applicable data protection laws, including, where relevant, by entering into a valid data transfer mechanism, such as based on the European Commission Standard Contractual Clauses with the party located outside the EEA.

How We Protect Your Personal Information

The security of your personal information is important to us. We employ several different technical, administrative and physical security measures to protect your personal information from unauthorized access or use. You can also read the statements regarding security in the privacy policy of our website services provider, Pantheon Systems, Inc., at https://pantheon.pactsafe.io/legal.html#contract-r1gwog2ui.

You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personally identifiable information. You use our Site at your own risk.

How Long Do We Keep Your Personal Information

We will only retain your personal information for as long as necessary for the purpose for which that information was collected and to the extent permitted by applicable laws. When we no longer need to use your personal information, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

Your Rights and Making Choices About Your Information

We wish to maintain your information accurately, and to allow you to make choices about how we use it.

You have the following rights in relation to your personal information:

  • Access: You have the right to request a copy of your personal information that we process. For your own privacy and security, at our discretion. We may require you to prove your identity before providing the requested information.
  • Rectification: You have the right to have incomplete or inaccurate personal information that we process about you rectified.
  • Deletion: You have the right to request that we delete your personal information that we process, except we are not obliged to do so if we need to retain such information in order to comply with a legal obligation or to establish, exercise or defend legal claims.
  • Restriction: You have the right to restrict our processing of your personal information where you believe such information to be inaccurate; Our processing is unlawful; or that we no longer need to process such information for a particular purpose unless we are not able to delete the information due to a legal or other obligation or because you do not wish for us to delete it.
  • Portability: You have the right to obtain your personal information that we hold in a structured, electronic format, and to transmit such information to another data controller, where this is (i) personal information which you have provided to us, and (ii) if we are processing that information on the basis of your consent or to perform a contract with you.
  • Objection: Where the legal justification for our processing of your personal information is our legitimate interests, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the information for the establishment, exercise or defense of a legal claim.
  • Withdrawing Consent: If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages (such as our e-mail newsletters and updates or text messages) that you receive from us.

You can make a request to exercise any of these rights in relation to your personal information by contacting us as indicated below in the “Contact Us” section.

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Please click here for a list of local data protection authorities in the EEA countries.

Do Not Track

We do not track our visitors over time or across third party websites to provide targeted advertising, and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

Our Policy Towards Children

We are concerned about the safety and privacy of children who use the Internet. Our Site is not designed for or directed to children under the age of 13. Consistent with the Children's Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly request personal information from anyone under 13 (or under the legal age of majority set out under applicable data protection laws) without prior verifiable parental consent. If we become aware that a child under 13 has somehow provided us with personal information without verifiable parental consent, we will use our best efforts to remove such information from our files. If you believe that your child has provided us with such information without your consent, please e-mail us at privacy@petersonhealthcare.org or write to us at Privacy, Peterson Center on Healthcare, 888-C Eighth Avenue, P.O. Box 144, New York, NY 10019, or call us at (212) 542-9200.

International Use

We make no claim that our Site is appropriate or lawful for use or access outside the United States. Furthermore, our databases are located in the United States. If you access this Site from outside the United States, you do so at your own risk. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access. By sending us your data, you consent to its transfer to and storage within the United States.

Changes to Our Privacy Policy

We reserve the right to change our Privacy Policy from time to time including where this is necessary due to changes to our data processing practices or activities. If we decide to change our Privacy Policy we will notify you of these changes via email where we have a direct relation with you and post an alert on the home page of our Site.

Contact Us

If you have any questions about this Privacy Policy, please contact us as follows:

Governing Law/Forum

Other than with respect to those provisions governed by the EU General Data Protection Regulation, this Privacy Policy is governed by New York law and if you have a dispute regarding this policy or your use of this Site, you agree that it shall be resolved solely in the state or federal courts located in the borough of Manhattan, New York City.