PRIVACY POLICY

SNP Veterans Medical Center & Health Systems Ltd. (“SNP”), an entity held in Kolonia, Pohnpei, Federated States of Micronesia 96941, authorized as a PEO Provider by VRN Program Consultants Ltd. and Veterans Recovery Network PBC, held in the State of Colorado, United States of America. SNP operates under its business license using the website address is: https://www.snphealth.org.

This Website Privacy Policy (“Privacy Policy”) and additional policies linked below explain how we collect, use, protect, and treat your personal information and user data. The Website is operated by SNP (“SNP” or “we”) at https://snphealth.org (“Website”). This Privacy Policy covers only information and data collected or processed through the Website and not any other information or data collected or processed by third parties who provide products and services on the Website (“Service Providers”) or affiliated organizations (“Affiliates”), third party web pages, or websites, products, or services to which we link that do not display a direct link to this Privacy Policy. We are not responsible for the content or privacy practices of other websites, or online or mobile services. By using our Website, you signify your consent to the data practices described in this Privacy Policy.

I. INFORMATION WE COLLECT.
The information we collect about you includes:

A. Personally Identifiable Information:
Our Website and our Service Providers only collect personally identifiable information (“PII”) with your consent. Collection of PII occurs if you register for an appointment on the Website, subscribe to a newsletter, tweet to us, or use other features and resources on the Website. You may visit our Site anonymously, but that may prevent you from engaging in certain Website features or Services. The PII we may collect includes the following:

First Name
Last Name
Telephone Number
Email address
Caller ID information (if available)

B. Non-Personally Identifiable Information:
Our Website and Service Providers may collect non-personally identifiable (anonymous) information (“Non-PII”) from visitors. Non-PII cannot identify a specific individual unless combined with Personally Identifiable Information. Examples of Non-PII that may be collected by the Website or required to provide the Services, including:

ZIP code
Cookies
“Cookies” are short computer codes known as cookies, web beacons, and other technologies that collect Non-PII and are stored on your browser when you visit our Website or share Website content through a social media account. The following are examples of Non-PII third party service providers collect with cookies:

Browser type and operating system
Date and time of visit
Referring web page
Links that connected you to the Website
IP address
Mobile Device ID
Medical condition or symptoms

C. Online Personal Privacy:
1.We or our Service Providers may drop a Cookie on the browser of Website visitors. We do this to continue to market our Services to you after you leave our Website. The Website does not employ technology to override the privacy settings in your web browser.

2. Our Service Providers may track Website visitors across multiple websites to retarget Website visitors to continue to market our Services to prospective patients after they leave our site. Users logged in to social media programs may be tracked by Service Providers who track such users across multiple websites and who may disregard the privacy settings in your web browsers.

D. Canadian and European Union Users
We do not intend to collect PII from Canadian and European Union users. If you are from the European Union or Canada, do not provide us with PII, use our Services, or the Website. If we learn that we collected PII from a user from the European Union or Canada, we will promptly delete that information.

E. Children
We do not intend to collect PII from children under 13. If you are under the age of 13, do not provide us with PII, use our Services, or the Website. If we learn that we collected PII from a child under 13, we will promptly delete that information.

F. Information about You from Other Sources:
We and our Affiliates and Service Providers may collect personal information about you on the Website and from other sources, including commercially available sources. All the information we collect about you may be combined to personalize your experience, provide you and our clients with Services, to improve our Website and Services, to provide relevant advertising to users, and for other marketing efforts.

II. HOW WE USE YOUR INFORMATION.
Non-PII that we or our Service Providers collect is used to improve marketing and sales efforts, better connect Website visitors with SNP services/providers, and connect SNP services/providers with potential patients. If you elect to provide PII, we may utilize such data to better connect you with an appropriate physician practice group.

A. Visitors who Request Services via the Website
Visitors who volunteer PII on our Website consent to be contacted by us, physician practice groups, or a call center Service Provider. A Service Provider may contact you by telephone and may, among other things, verify your self-reported PII and interest in services or speaking with a physician. We may contact you by telephone even if you have opted into the National Do Not Call list, or any State Do Not Call list

IF YOU DO NOT CONSENT TO BEING CALLED BY A SNP REPRESENTATIVE DO NOT ENTER YOUR PII INTO FORMS ON OUR WEBSITE.

If you do not wish to be contacted again by a SNP representative with respect to your inquiry, you should specifically request that the SNP representative not contact you again. Please note that we may maintain the PII you provided whether you elect to use the Services.

B. Mobile Visitors and Click-to-Call Services
Mobile users who initiate calls by clicking on a telephone number on a mobile Website consent to contacting a SNP representative to verify your PII and connect you with appropriate SNP service/provider.

C. Email Communications and Promotional Offers
If you sign up for one or more of our newsletters, you may receive email communications from us. We may send you email, contact you, or engage you in other communication mediums that relates to your use of the Website and Services. If, at any time, you do not wish to receive email communications about the Website or our newsletters, please use the “UNSUBSCRIBE” link at the bottom of our email.

D. Aggregate or Anonymous Information
We may share Non-PII with Service Providers and other third parties.

E. With Consent
Except as set forth above, you will be notified when PII may be shared with third parties, and will be able to prevent the sharing of this information.

III. HOW WE PROTECT AND RETAIN YOUR INFORMATION.
We take security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include secure socket layers, firewalls and encryption, internal reviews of our data collection, storage and processing practices, and security measures, as well as physical security measures to guard against unauthorized access to systems.

If we retain PII on our systems, we restrict access to PII to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Website and Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.

IV. HOW TO CONTROL AND CORRECT YOUR INFORMATION.
We or our Service Providers may retarget users who view https://snphealth.org. You may elect not to provide user data to us or our Service Providers by following the opt-out procedures set forth below, but our Website may not work properly and/or some of our Services.

A. Learn More about Cookies, Web Beacons, and other Technologies

You can accept or decline Cookies. Most browsers automatically accept Cookies. To learn more about Cookies, including how to refuse Cookies on your computer by adjusting web browser settings, follow these links:

All About Cookies
Google
Google Chrome
Microsoft Internet Explorer
Microsoft Edge
Mozilla Firefox
Flash

B. Opting Out of Cookies:
To opt-out from collection and use of your Web Browsing Data by the Website, use this: NAI opt-out tool provided by the National Advertising Initiative.

To opt-out from tracking by our display advertising, click here. Some of our Service Providers’ cookies do not have an “opt-out” option, but you always have the option of blocking the use of cookies by changing a setting in your Internet browser.

C. Privacy Rights:
A patient (or authorized representatives of a patient) who have an established business relationship with us have the right to request that we provide certain information regarding the disclosure of their personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may contact the SNP directly to request such information. SNP shall hold compliance on Date Protect (Collection & Processing) under Sections 349 and 350 of Title 21 of the FSM Code, and 21 F.S.M.C. 349.

V. REVISIONS TO THE PRIVACY POLICY.
Please be aware that our Privacy Policy may be changed by updating this page. If we collect personal information or data from or about you, we will use it according to the Privacy Policy in effect at the time the data is gathered. This Privacy Policy, together with the Website’s Terms of Use, contains the entire agreement between you and Company with respect to the Website and any services provided by the Website. You should review this Privacy Policy periodically to ensure you are in agreement with any updates or changes. Your continued use of our website following any changes will mean you accept such changes.

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