When we refer to ourselves as "we" or "QOL Medical," we mean our entire company, including any company that we control (for example, a subsidiary that we own). We may share information among companies that we own or control, and we may share information with our co-promotion partners, and companies working with QOL Medical but all information we share will always be protected under the terms of this Privacy Policy. QOL Medical is not responsible for how other Web sites treat your privacy once you leave a QOL Medical site.

I. Personal information we collect

Information we collect from visitors

Visitors to each of our Web sites 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. On some of our sites, you must register to access portions of the site. In addition, we gather information about you that is automatically collected by our Web server, such as your IP address and domain name. QOL Medical may use Web server and browser information to individually customize its offerings and presentations if you submit your personal information.

Information we collect when you register

Visitors registering for services on our Web sites are asked to provide identifying information, such as name, gender, contact information, and other identifying information. On the registration screen, we clearly label which information is required for registration, and which information is optional and may be given at your discretion. QOL Medical Web sites obtain visitors' consent before collecting personally identifiable information.

Other information

We also collect information that you voluntarily provide to us through responses to surveys, search functions, questionnaires, feedback, "Tell your story" forms and the like. On some of our Web sites, we offer health assessment tools that ask you to provide self-assessment information. We may also ask you to provide additional information such as your e-mail address, if you want to obtain additional services or information, or to resolve complaints or concerns.

Use of cookies and other tracking systems

Cookies, log files, and pixel-tags (Web beacons) are technologies used by the QOL Medical Web sites to identify a user as the user moves through our Web sites. Your browser allows us to place some information (session based IDs and/or persistent cookies) on your computer's hard drive that identifies the computer you are using. We may use cookies to personalize our Web sites and to track your usage across other QOL Medical Web sites.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. On occasion, we contract with third parties to place cookies on your computer's hard drive. These third parties have entered into an agreement with us that require them to observe our Privacy Policy.Although cookies do not normally contain personally identifiable information, if you have provided us information about you, we may associate your registration information with cookies or other tracking utilities 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. Without cookies, this functionality would not be possible.Some of our business partners may use cookies on our site (for example, links to business partners). We do not want our business partners to use cookies to track our customer's activities once they leave our sites. However, we may not have total control over how our business partners may use cookies on our Web site. If you become aware that a QOL Medical business partner is placing an unwanted cookie on your hard drive, please contact our privacy officer to assist us in resolving the problem.In addition, we may use other tracking systems like Pixel-tags. Pixel tags, sometimes called Web beacons, are similar in function to a cookie. But because of its insignificant size, it is not visible; though, it is used to pass certain information to our servers to personalize our Web sites and to track your usage across other QOL Medical Web sites. In addition, we may also use Pixel tags in our HTML based emails.

II. How we use the information

We gather aggregate data about visitors to our Web sites for product and service development and improvement activities. We also use it for market analysis. We may provide information from our Web sites in aggregate form, with identifying information removed, to third parties. When aggregate 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.

Marketing-Healthcare Messages

We may target our marketing and healthcare messaging depending on information we have about you. We may send information to you that we may believe will benefit you, including information about any QOL Medical product. (See your privacy choices section.) We may also personalize our Web site based on your interests. For example, you may see different articles in different places on our Web site based on information you have shared with us, or information we have gained by reviewing your previous visits, or information we may have gained from your interactions with a third party that shares information with us. When we share information with third parties working on behalf of QOL Medical, we use our best efforts to assure that they agree in writing to abide by QOL Medical privacy policies. If we discover that a third party working on behalf of QOL Medical inappropriately disclosed personal information about any of our visitors, we will take immediate action to prevent further occurrences. Other than as described above, QOL Medical will not release personally identifiable information to a third party without your consent.

III. Protection of information

How QOL Medical handles privacy internally Our commitment to security

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.General policies 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 to or are associated with the processing of your data respect your confidentiality. QOL Medical 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. QOL Medical uses both passwords and usernames to authenticate users. Users are responsible for maintaining their own passwords.

Storage of health information

Personally identifiable health information you share with us is stored on our database servers at QOL Medical data centers or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Policy. We have a firewall and other technology to prevent individuals from accessing information without authorization. Data centers are designed to be physically secure and protected from unauthorized access by unauthorized persons. Information in our data centers is backed up routinely, in order to aid in the recovery of information in the event of accidental damage of information or in the event of a natural disaster. The backup media is stored in a physically secure storage facility.

Third parties

In addition to aggregate information (discussed previously), we may share some kinds of information with third parties as described below.

Companies and people who work for us: 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 sites, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In order to perform their jobs, these other companies may have limited access to some of the personal information we maintain about our users. Other companies may collect information on our behalf through their sites. This occasionally incorporates the use of frames on the site that will not show the URL you are visiting in the browser address window. We require 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 other companies use of personally identifiable or healthcare information.

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 if, in our judgment after review by an attorney, the release is compelled by law or regulation, or if the release may be necessary to prevent the death or serious injury of an individual.

IV. Your privacy choices

When you complete registration of your member profile, you will be given the option of receiving recurring informational/promotional e-mail from QOL Medical and third parties working with QOL Medical. You may opt-out from receiving this e-mail when you provide the information or follow the instructions as mentioned in the email or included in each of our programs we send to you. Customer Service will unsubscribe you from that newsletter or other programs within ten business days.

Choice

You will be given the opportunity to choose whether your personal information is (a) to be disclosed to a third party working with QOL Medical or (b) to be used for a purpose that is different from the purpose originally intended or authorized. In addition, for sensitive information that includes personal information specifying medical or health conditions, you will be given an affirmative or explicit opt-in choice.

Onward transfer (transfers to third parties)

Before we will disclose information to a third party, we will provide you with notice and choice before either personal information or sensitive information is transferred.

V. Updating your personal information and contacting QOL Medical

You can always contact us in order to (i) remove the personal information that you have provided to us from our systems, (ii) update the personal information that you have provided to us, and (iii) change your preferences with respect to marketing contracts by e-mailing us at privacy.officer@Qqolmed.com or if available also logging into your account to update your information.

VI. Children's policy

We are committed to protecting the privacy of children. We do not collect personally identifiable information from any person we actually know is a child under the age of 13.

QOL Medical Inc. Privacy Policy updated May 2006.

QOL Medical Inc
Privacy Officer
5400 Carillon Point,
Kirkland, WA 98033

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