Phase to Phase Strategy, LLC Privacy Policy

Phase to Phase Strategy, LLC (P2P) understands how important the privacy of personal information is to our customers. P2P is committed to honoring your privacy, and to offering special protections for any personal health information you choose to share with us. The document you are reading is our privacy policy for our web site, which is accessible by consumers, and it describes what information we may collect about you, what uses we may make of it, how you can tell us what to do with your information, and what precautions we take against unauthorized access or use of your information.

Web Site Covered

This privacy policy only applies to You should read the privacy policy at each web site that you visit after you leave We are not responsible for how other web sites treat your privacy once you leave our site.

Policy Changes

If our privacy policy changes in a significant way, we will make every effort to notify you of the changes. Minor changes to the policy may occur that will not affect our use of individually identifiable information. If the privacy policy changes in a way that significantly affects the way we handle personal information, we will not use the information we have previously gathered without obtaining consent from the appropriate individuals. We will post privacy policy changes on our web site in a timely manner.

Unregistered Visitors

Visitors to our web site can access the web site's home page, and browse some areas of the site, without disclosing any personally identifiable information. We do track information provided to us by your browser, including the web site you came from (known as the "referring URL"), the type of browser you use, the time and date of access, and other information that does not personally identify you.

Registered Visitors

Customers registering for services on our web site are asked to provide us with identifying information, such as name, gender, contact information, and other identifying information. On our registration screen, we clearly label which information is required for registration, and which information is optional and may be given at your discretsion. You will also be given a choice about whether or not you want to receive promotional information.

Identity Verification

We may also collect information about physicians or other healthcare professionals who register on our web site from other sources in order to verify their licensure status and identity. In some cases we may ask customers for information, such as credit card information, after they register. Where necessary (for example, to process an order for a purchase), our web site may contact financial or credit organizations to confirm customer credit cards.

Other Information

Discussion Boards: When you are using a discussion board on our web site, you are posting a message and your user name is available for all registered users to see. When you are posting publicly, any user of our web site can see your message. Any information you want to keep private should not be posted to a discussion board or other public forum on our web site.

Additional Forms and E-mails: We may also ask you to provide additional information after you register if you want to obtain additional services or information or to resolve complaints or concerns. In addition, we gather information about you that is automatically collected by our web server, such as your IP address and domain name. P2P may use this information to personalize its offerings and presentations to you, facilitate your movements throughout our web site, provide personalized services, and to communicate with you individually.

Continuing Medical Education

When you register for a Continuing Medical Education ("CME") activity through our web site, we collect certain personally identifiable information from you such as your name, e-mail address, and mailing address. In addition to personally identifiable information, we collect aggregated non-personally-identifiable information about the activities undertaken by our users. We use the information that we collect through CME activities in several ways:

Commercial supporters of CME activities on our web site will receive only aggregated data about CME activities that are relevant to their nterests and/or the courses they support;

P2P and our customer support staff will have internal access to files containing personally identifiable information, including evaluation forms and aggregated CME participant information. These files can be accessed in order to respond to your questions or comments. Our staff may also use personally identifiable information, including registration information and evaluation data, in assessing educational needs and planning marketing activities.

We may use the information we collect as otherwise permitted in this Privacy Policy.

Technology Used

"Cookies" is a technology used by the P2P web site to identify a user as the user moves through the web site. Your browser allows us to place some information on your computer's hard drive that identifies the computer you are using. We use cookies to personalize our web site and to track your usage. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, web sites that are cookie-enabled will not recognize you when you return to the web site, and some web site functionality may be lost. The Help section of your browser will tell you how to prevent your browser from accepting cookies. Although cookies do not normally contain personally identifiable information, if you are a registered user we may associate your registration information with cookies our web site places on your computer's hard drive. Associating a cookie with your registration data allows us to offer increased personalization and functionality.

Marketing and Advertising

We may target our advertising or marketing depending on information we have about you. For example, a user who we know is a Cardiology Specialist may receive advertising for programs targeted to their needs or interests. We also create aggregate data about visitors to our web site for product development and improvement activities. We also use it for market analysis. We may provide information from our web site in aggregate form, with identifying information removed, to third parties. For example, we may tell a healthcare partner what percentage of our registered users resides in a particular geographical area. When aggregated health information is provided, we pool it from many individual records and strip it of any data that could be used to identify an individual before it is used. Any third party that receives aggregated healthcare data must agree not to attempt to re-identify the people it belongs to.

Information Sharing

In addition to aggregate information, we may share some kinds of information with third parties as described below. Companies and People Who Work for Us: Because we are a large company, we contract with other companies and individuals to help us provide services. For example, we may host some of our web sites on another company's computers, hire technical consultants to maintain our web-based health tools, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, if you are a healthcare professional, we may validate your licensure status and other information against available databases that list licensed health care professionals. In order to perform their jobs, these other companies may have limited access to some of the personal information we maintain about our users. We require all such companies to comply with the terms of our privacy policies, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us. We use our best efforts to limit the use of other companies in areas where personally identifiable healthcare information may be involved.

Business Transfers: If we transfer a business unit (such as a subsidiary) or an asset (such as a web site) to another company, we will require them to honor the applicable terms of this privacy policy.

Legal Requirements: We may release account and other personal information when we believe release is required to comply with law. We may release personal health information, including information from a medical record, if, in our judgment after review by an attorney, the release is compelled by law or regulation, or if the release is necessary to prevent the death or serious injury of an individual.

When we share information with third parties, we ask that they agree in writing to abide by P2P’s privacy policies.

If we discover that a third party inadvertently disclosed personal information about any of our customers, we will take immediate action to prevent further occurrences. Other than the cases described above, P2P will not release personally identifiable information to a third party without the customer's consent. Also, if we ask your consent to release personal healthcare information to a third party, we will use our best efforts to clearly define and limit the scope of your consent.

Protection of Information

In this section of our privacy policy, we discuss the security measures we take to protect information that we have collected about you.

Information Security

We have implemented technology and security policies, rules, and other measures to protect the personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. We also protect your information by requiring that all our employees and others who have access or are associated with the processing of your data respect your confidentiality.

P2P uses security methods to determine the identity of its registered users, so that appropriate rights and restrictions can be enforced for that user. Reliable verification of user identity is called authentication. P2P uses both passwords and usernames to authenticate users. Users are responsible for maintaining their own passwords.

P2P Team Members (Employees and Freelancer Project Staff)

P2P team members are required to keep customer information private, as a condition of their engagement with the company. Only selected, authorized P2P employees are permitted to access your personal information.

Privacy Questions

For privacy questions or concerns about the P2P web site, please contact

Revision date: This policy was last updated on November 23, 2009.

Phase to Phase Strategy © 2009

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