Privacy Policy for the Heritage Health Prize Competition Website

Effective: April 4, 2011

Last Updated: April 4, 2011

This privacy policy ("Privacy Policy") applies to information collected on http://www.heritagehealthprize.com (the "Site") in connection with the Heritage Health Prize Competition (the "Competition") sponsored by Heritage Provider Network, Inc. ("HPN", "we" or "us"). The Site is operated and managed by Kaggle Pty Ltd. ("Kaggle").

Except where otherwise expressly indicated in this Privacy Policy or on the Site, this Privacy Policy applies only to information collected on the Site and does not apply to information collected outside of the Site. Before using or submitting information to the Site, please review this Privacy Policy carefully.

Certain areas of the Site contain information intended only for users who register to participate in the Competition ("Registered Users") and HPN reserves the right to limit those areas to Registered Users. This Privacy Policy addresses HPN’s privacy practices relating to general use of the Site, as well as use of the Site by Registered Users.

A. Information HPN Collects

HPN collects the following types of information from users of the Site:

1. Personally Identifiable Information

HPN may receive and store any information that you enter on the Site in connection with the Competition or provide to HPN in any other way on or through the Site that would allow HPN to identify you or contact you (collectively "Personally Identifiable Information"). The Personally Identifiable Information that you provide will be used by HPN only in accordance with this Privacy Policy. Examples of Personally Identifiable Information HPN may collect from you are name, e-mail address, telephone number and address if you are a Registered User and the names and e-mail addresses of those who communicate with us by e-mail.

You may choose not to provide HPN with certain Personally Identifiable Information but then you may not be able to take advantage of certain features of the Site.

2. Automatic Information

HPN may receive and store certain types of technical information whenever you interact with HPN through the Site. We may automatically receive and record your browser information, operating system information, IP address, the page you requested and the page the directed you to the Site. This allows HPN to enhance your experience and better support your needs. This information is not stored in a manner that is personally identifiable with you and may include the following:

(a) Aggregate Information In connection with your visit to the Site, HPN may automatically collect usage information, such as the numbers of users and frequency of use. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies as discussed below.

(b) Cookies HPN uses "cookies" to help you access and navigate the Site more efficiently and to statistically monitor how many people are using the Site. A "cookie" is a small file or tool stored on your hard drive containing information that allows HPN to deliver customized information to you. If you become a Registered User, HPN may use cookies to store your e-mail address, password and other technical information related to the Site so that HPN can identify you when you return to the Site, track your use of the Site and customize the Site for you. You may set your browser to notify you of or decline the receipt of cookies. Certain features of the Site may not, however, function properly or be available if your browser is configured to disable cookies.

HPN uses both "session" and "persistent" cookies on the Site. Session cookies are temporary bits of information that are erased once you exit your web browser or turn off your computer. Persistent cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of reasons, such as retrieving certain information you have previously provided (i.e., email address and password) and helping to determine what areas of the Site you find most valuable. Many companies offer programs that help you to visit web sites anonymously and HPN wants you to be aware that these programs are available, but use of such programs may block your access to certain features of the Site.

(c) E-mail Communications When you send an e-mail to HPN, HPN may retain your e-mail address and the contents of the e-mail that you send. This Privacy Policy does not apply to content, business information, ideas, concepts or inventions that you send to HPN by e-mail. Please refer to HPN’s Terms of Use for HPN’s policy with respect to such information. If you want to keep the information in your email(s) private or proprietary, please do not send such information in an e-mail to HPN.

B. How HPN Uses Information

When you provide HPN with your Personally Identifiable Information, HPN may use it to manage HPN’s registry of Registered Users for the Competition, facilitate communication between HPN and you and/or provide you with information about the Competition. HPN also may use the information to enforce the Competition Official Rules and HPN’s agreements with you, to prevent fraud and other prohibited or illegal activities and for other legally permissible purposes. These uses of your Personally Identifiable Information may include, without limitation, the following:

1. Public Areas

The Sites feature a public comment area where Registered Users can share information and post questions ("Public Areas"). Other visitors to the Sites may view information posted in Public Areas but cannot share information or post questions. By using the Public Areas, each Registered User hereby acknowledges and agrees that any information shared in a Public Area (including, without limitation, Personally Identifiable Information) is available to the public and may be used by others in ways neither you nor HPN are able to control or predict, including, without limitation, to contact you for unauthorized purposes.

2. Registered User Areas

Certain areas of the Site are accessible only to Registered Users ("Registered User Areas").

If you register to become a Registered User of any Site, the registration information that you provide to HPN may be stored in a profile. Your profile, or a portion thereof, may be viewed by Registered Users and other visitors to the Site.

HPN may use the Personally Identifiable Information that you provide when registering to become a Registered User to send you information about the Competition and also may use, or may permit Kaggle to use, your Personally Identifiable Information to send other information that HPN believes is relevant and useful to Registered Users. HPN does not sell mailing lists (names and mailing addresses) and e-mail addresses of Registered Users to third parties.

3. Aggregate Information

The aggregate information collected via the Site includes anonymous statistical demographic information but no Personally Identifiable Information. This aggregate information is used to determine trends and needs and enhance the Site experience for Competition participants and visitors to the Site.

4. Emails and Newsletters

From time to time, HPN may use your Personally Identifiable Information to send you important administrative information regarding the Competition and Site. HPN also may provide your Personally Identifiable Information to Kaggle so that it may contact you with administrative information regarding the Competition and Site.

C. With Whom HPN Shares Information

HPN will not give, share, sell, or trade your Personally Identifiable Information to or with any third parties other than Kaggle in any way, other than under the following circumstances:

1. Third-Party Service Providers

HPN may retain other companies and individuals to perform functions on HPN’s behalf, such as Kaggle and web hosting companies. HPN may share your Personally Identifiable Information with such third-party service providers to perform these functions consistent with this Privacy Policy.

2. Compliance with Law and Fraud Protection

HPN may disclose any information, including without limitation Personally Identifiable Information, that HPN deems necessary, in its sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. HPN also may exchange information, including without limitation Personally Identifiable Information, with other companies and organizations to protect the rights, property of safety of HPN and its agents, employees or affiliates or others. HPN reserves the right to disclose a user’s Personally Identifiable Information if HPN believes the user is in violation of HPN’s Terms of Use and/or the Competition Official Rules, even without a subpoena, warrant or other court order.

3. Sale or Transfer of Information

In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets of HPN or the Site, Personally Identifiable Information and/or other information collected about you via the Site may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of HPN or the Site in order to permit the party to continue the operation of the Site, including the Registered User Areas. By using the Site, you consent to the sale and transfer of your information as described in this paragraph.

D. Important Disclosures, Practices and Contact Information 1. Accessing, Updating or Deleting your Personally Identifiable Information

If you are a Registered User and would like to review, update or delete your registration information, please use the "Contact Us" link page on the Site.

2. Opting Out

HPN respects the privacy of your Personally Identifiable Information. If you tell HPN that you do not wish to have this information used as a basis for further contact with you, HPN will respect your wishes. You also may choose not to provide HPN with certain information, but that may result in your inability to use certain features of the Site. To remove your Personally Identifiable Information from HPN’s database, please contact us via the "Contact Us" page on the Site.

3. Third Party Links

The Site may contain links to third-party websites. Please be aware that HPN cannot control and is not responsible for the information collection practices of such websites, which may differ from those of HPN. HPN encourages you to review and understand the privacy policies of these other websites before providing any information to them.

4. Data Security

HPN maintains a variety of commercially reasonable physical, electronic and procedural safeguards designed to protect your Personally Identifiable Information from unauthorized access and disclosure. For example, HPN uses accepted tools and techniques to protect against unauthorized access to HPN’s systems. Please note that HPN has no control over the security of other websites on the Internet that you might visit or with which you might interact even when a link may appear to another site from the Site. Although HPN takes steps to secure your information, HPN does not promise, and you should not expect, that your personal information, searches or other communications will always remain secure. In the event of a breach of the confidentiality or security of your information, including your Personally Identifiable Information, HPN will notify you as necessary and if possible so you can take appropriate protective steps. HPN may notify you under such circumstances using the e-mail address that HPN has on record for you.

5. Children

The Site is a general audience site and is not intended for children under 13. HPN requires that only persons who are the age of majority or older in their place of residence use the Site. By using the Site, you hereby represent that you are at least the age of majority or older in your place of residence. HPN does not knowingly market to, solicit information, accept service or collect information from children under the age of 13. When the Site has actual knowledge that it collects information from children or offers a service directed toward children, it will comply with applicable laws, including the U.S. Children's Online Privacy Protection Act.

6. Changes to this Privacy Policy

At any time without prior notice, HPN may update this Privacy Policy to reflect changes in HPN’s practices. When HPN posts changes to this Privacy Policy, HPN will revise the "Last Updated" date at the top of this page. If HPN makes any material change to this Privacy Policy, HPN will notify each Registered User by sending an e-mail to the e-mail address provided to HPN in a Registered User’s account and/or by prominently posting notice of the changes on the Site. HPN encourages you to bookmark this Privacy Policy and to periodically review it to inform yourself of changes to it or any of HPN’s other policies. Any changes to HPN’s Privacy Policy will become effective upon HPN’s posting of the updated policy. Use of the Site constitutes your acceptance of the terms of this Privacy Policy then in effect.

7. California Privacy Rights Under California Civil Code Section 1798.83

If you are a resident of California ("California Users"), in addition to the rights set forth in this Privacy Policy, you generally have the right to request information from HPN regarding the manner in which HPN shares certain categories of Personally Identifiable Information with third parties for their direct marketing purposes.

Under the law, however, a business is not required to provide this information if it adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying California Users of their rights to prevent disclosure of personal information and providing a cost free means to exercise that right. As stated above, HPN does not share such Personally Identifiable Information with third parties for their direct marketing purposes unless you have requested HPN to do so or have otherwise consented and then subject to your right to opt-out of sharing your personal information for third party marketing purposes.

Please note that whenever you opt in to receive future communications from a third party, your information will be subject to the third party's privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as HPN has no control over how third parties use information. You should always review the privacy policy of any party that collects your information to determine how it will handle your information.

Please note that HPN is only required to respond to one request per user per year.

8. Users From Outside the United States

By visiting the Site, submitting information or using any of HPN’s products or services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and processed in the United States. If you do not agree to this Privacy Policy, please do not use the Site.

The Site is controlled and operated by HPN from the United States. HPN does not represent or warrant that the Site or any part thereof is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk and are responsible for complying with all local laws, rules and regulations. You also are subject to United States export controls in connection with your use of the Site and are responsible for any violations of such controls, including, without limitation, any United States embargoes or other federal rules and regulations restricting exports. HPN may limit the availability of the Site, in whole or in part, to any person, geographic area or jurisdiction that HPN chooses, at any time and in HPN’s sole discretion.

9. No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

10. Contacting HPN

Please contact us via email by visiting the "Contact Us" page.