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Safe Harbor

In Touch Health Safe Harbor Compliant Privacy Policy

InTouch Technologies, Inc.®, (DBA InTouch Health®) is committed to protecting the privacy and security of its clients, partners and associates. Therefore, InTouch Health adheres to the Safe Harbor Agreement concerning the transfer of Personal Information from the European Union ("EU") to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the "Principles") with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles take precedence. This privacy policy applies to all Personal Information received by the Company whether in electronic, paper or verbal format.

Please read our Safe Harbor Privacy Policy Statement at the U.S. Dept. of Commerce Safe Harbor Export.gov website regarding categories of Personal Information that we collect, how it's used and how it may benefit our clients, partners and associates.

Definitions

Agent means a third party that processes Personal Information solely on behalf of and under the instructions of InTouch Health.

Personal Information means any information or set of information that identifies or can reasonably be used to identify an individual.

Sensitive Personal Information means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. Information will be treated as Sensitive Personal Information where it is received from a third party that treats and identifies it as Sensitive.

Principles

Notice

InTouch Health will inform individuals about the purposes for which we collect and use Personal Information about them, how to contact us with any inquiries or complaints regarding such, the types of non-agent third parties with whom we may share Personal Information, and any ways that individuals may limit the use and sharing of such data. This notice will be provided when individuals are first asked to provide Personal Information or as soon thereafter as is practicable.

Choice

InTouch Health will offer an individual the opportunity to choose (opt out) whether Personal Information is shared with a non-agent third party or is used for a purpose other than that for which the data was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, we will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than that for which it was originally collected or subsequently authorized by the individual.

Onward Transfer

InTouch Health will ensure that any third party to which Personal Information may be disclosed agrees to follow these Principles in the handling of that information.

Data Security

InTouch Health will take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

InTouch Health will only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, the Company will take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access

InTouch Health will allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Passive Information Collection

While visiting this site, certain anonymous information may be passively collected (i.e., gathered without you actively providing the information) using technologies like cookies or web beacons.

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse or control the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

This website utilizes the services of LeadLander, Inc. When visitors view a page, a tracking operation retrieves data about the page request. This information is forwarded to the LeadLander server via a list of parameters attached to a single-pixel image GIF request, known as a web beacon. The data tracked includes the page viewed, referring page and IP address. This data is then processed and forwarded to InTouch Health.

Collection and Use of Children's Personal Information

InTouch Health does not knowingly collect Personal Information from children under the age of 13.

Enforcement

InTouch Health uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided below and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using EU Data Protection Authorities as a third party resolution provider.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website. For material changes to this Policy, we will notify individuals by placing a notice on the U.S. Dept. of Commerce Safe Harbor Export.gov website.

Contact Information

Questions, comments or complaints regarding the InTouch Health privacy policy or data collection and processing practices can be mailed or emailed to:

Attn: Privacy Department
InTouch Health
6330 Hollister Avenue
Santa Barbara, CA 93117
Privacy@InTouchHealth.com
Last updated: April 22, 2013

Note: As a convenience to our visitors, this Website currently contains links to a number of sites that we believe may offer useful information. The policies and procedures we described here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection and distribution policies.

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