Privacy Policy
This Privacy Policy describes how GI OnDEMAND LLC (“GI OnDEMAND,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. You can jump to particular topics by going to the headings below:
Types Of Information We Collect
Patient Health Information
Uses Of Information
Disclosure Of Information to Third Parties
Data Retention
Your Choices
Authorized Agent
How We Protect Personal Information
Other Important Information
Contact Information
While this Policy covers most instances of information collection, use and disclosure, there may be instances where we or a service provider or business partner request particular information from you. In those instances, we may explain different/specific rules concerning that collection, use and potential disclosure of that information. Under such circumstances, the more specific rules will apply to that information.
This Policy applies to patients/users of the GI OnDEMAND site, physicians who use the GI OnDemand site as part of their practice, and allied healthcare professionals who partner with the GI OnDEMAND site.
Types Of Information We Collect
The following provides examples of the type of information that we collect from you and how we use that information.
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Category of Personal Information |
Types of Data |
Primary Purpose for Collection |
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Patient Account Registration/Password Setup |
We collect your name, email address, and the ID of your gastrointestinal (“GI”) professional’s practice when you create an account. We also collect information relating to the actions that you perform while logged into your account. |
We have an interest in providing account related functionalities to our users. |
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Physician/Health Professional Account Registration/Password Setup |
We collect your name, email address, ACG member ID, phone number, and expertise information. We also collect information relating to the actions that you perform while logged into your account. |
We have an interest in providing account related functionalities to our users. |
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Cookies and first party tracking |
We use cookies on our website. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. |
We have a legitimate interest in making our website operate efficiently. |
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Cookies and Third Party Tracking |
We host Google, Double Click, and YouTube cookies on our site. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. |
These cookies are used by Google to facilitate the use of certain videos on our site. |
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Email Interconnectivity |
If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. |
We have an interest in understanding how you interact with our communications to you. |
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Feedback/Support |
If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. |
We have a legitimate interest in receiving, and acting upon, your feedback or issues. |
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Health Data |
You may provide us with information regarding your health. |
We use this information to provide you with relevant resources related to your GI health. Your GI professional may also use this information.
Please note that health information provided to your GI Professional through GI OnDEMAND is addressed below in the Patient Health Information section. |
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Mailing List |
When you sign up for one of our mailing lists we collect your email/postal address. |
We provide information about our services with individuals that consent to receive such information. |
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Partner Promotion |
We collect information that you provide as part of a co-branded promotion with another company. |
We have a legitimate interest in fulfilling our promotions. |
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Surveys |
When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. |
We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization. |
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Sweepstakes or contests |
When you participate in a sweepstakes or contest we collect information about you which includes contact information to notify you if you are selected. |
We have a legitimate interest in operating the sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws. |
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Web logs |
We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. |
We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. |
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, your doctor, our business partners, our affiliates, or publicly available sources.
Patient Health Information
Because some of the services available on GI OnDEMAND involve services to assist your GI professional in providing healthcare to you, we wanted to explain how we handle your “patient health information” more specifically. “Patient health information” is information you are providing to your GI Professional through GI OnDEMAND related to your health status, your health care (for example for diagnosis or treatment), or the payment for your healthcare. We work with your GI professional to protect and use any patient health information that you provide in accordance with your GI professional’s HIPAA Privacy Notice. In these instances, GI OnDEMAND is acting as a service provider/business associate to your GI professional.
Uses Of Information
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our websites.
- To provide products and services.
- To improve our services and offerings.
- To streamline our processes.
- To conduct analytics.
- To respond to inquiries related to support or other requests.
- To send marketing and promotional materials relating to our services or those of our business partners.
- For internal administrative purposes, as well as to manage our relationship with you.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an online order we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
Disclosure Of Information to Third Parties
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates and Acquisitions. We may disclose information to our affiliates (e.g., parent companies, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also disclose information to that company, including at the negotiation stage.
- Other Disclosures with Your Consent. We may ask if you would like us to disclose your information to other unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also disclose your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publically available.
- Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be disclosed with us and with them. Their use of your information is not governed by this privacy policy.
- Service Providers. We may disclose your information to service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
Data Retention
We evaluate the following criteria in determining the minimum length of time that your personal information must be retained: (i) the purposes for which the data was collected; (ii) your reasonable expectations regarding the retention of your personal information; (iii) the risks associated with retaining your personal information; (iv) whether your personal information can be retained in another format (e.g., deidentified); and (v) legal obligations. Following the expiration of an applicable retention period, we may deidentify, aggregate or anonymize data instead of deleting the data where permitted by applicable law.
Your Choices
You can make the following choices regarding your personal information:
- Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we disclose with third parties or affiliates for direct marketing.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. If our website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
- Deletion Of Your Personal Information. You may request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
- Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
Please address written requests and questions about your rights to support@giondemand.com or mail us at GI OnDEMAND, Attn: Legal Department, 8 The Green, #8109, Dover, DE 19901. You may request a copy of the personal information that we hold about you, and exercise other rights as described above, by emailing us at support@giondemand.com.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we may ask for additional information to verify your identity. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
Authorized Agent
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are a business acting as an authorized agent submitting a request on behalf of an individual you must attach proof that you are registered with the Secretary of State to conduct business in California. If we do not receive that information, the request will be denied.
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is perfectly secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
Other Important Information
The following additional information relates to our privacy practices:
- Transmission Of Information To Other Countries. GI OnDEMAND is based in the United States. As a result your information may be processed in the United States where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.
- Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
- Children. Children under 18 cannot directly register with the GI OnDEMAND platform. Instead, a parent or guardian may register for an account in place of a child. If we come to believe that a child has registered for an account independently, we will take appropriate actions.
- Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
- Information for California Residents. California law indicates that organizations should disclose whether certain categories of information are collected, “shared,” “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect, sell, or share here. Please note that because this list is comprehensive it may refer to types of information that we disclose about people other than yourself. If you would like more information concerning the categories of personal information (if any) we disclose to third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the “Contact Information” section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.
Contact Information
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
support@giodemand.com
GI OnDEMAND
Attn: Legal Department
8 The Green, #8109
Dover, DE 19901
T. 833-446-6336
Effective Date: 10/07/2021
Last Update: 10/07/2021
*******Separate page to be linked from the Information for California Residents Section*********
California Information Sharing Disclosure
The California Consumer Privacy Act indicates that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and disclose about people other than yourself. For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our website’s “contact us” page.
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Categories of Personal Information We Collect |
To Whom We Disclose Personal Information for a Business Purpose |
To Whom We Share Personal Information |
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Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. |
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Additional categories of personal information described in the California Customer Records statute – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information. |
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Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc. |
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Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. |
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Inferences drawn from any of the information listed above |
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