The methods that may be used on the Services to collect Usage Information include:

• Log Information: Log information is data about your use of the Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.

• Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Services or e-mails, including information about your browsing and purchasing behavior.

A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Services and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Services, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Services may not work.  A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them.  To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Services may associate some or all of these types of cookies with your devices.

Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Services, to monitor how users navigate the Services, and to count content views.

• Embedded Scripts

An embedded script is programming code designed to collect information about your interactions with the Services. It is temporarily downloaded onto your computer from MHM’s web server, or from a third party with which MHM works, and is active only while you are connected to the Services, and deleted or deactivated thereafter.

• In-App Tracking Methods

There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. 

MHM is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.

C. Information MHM Collects From Other Sources.

MHM may also obtain information about you from other sources, including our clients, Service Providers and Third-Party Services, and combine that with MHM-Collected PI.  Notwithstanding anything to the contrary, except (i) for Client-service PI and Client-service PHI (both defined below), and (ii) to the extent such data is combined by or on behalf of MHM with MHM-Collected PI, this Privacy Policy is not intended to limit MHM’s activities regarding such third-party-sourced, or non-Services-sourced information (including Personal Information), and such data will only be treated as MHM-Collected PI to the extent it is combined with MHM-Collected PI. MHM is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.  Personal Information we receive from a client in the course of performing Professional Services for the client that is designated as confidential or proprietary to the client is “Client-service PI.”

2. HOW WE USE THE INFORMATION WE OBTAIN.

MHM may use information about you, including MHM-Collected PI, Client-service PI and other Personal Information, for any purposes not inconsistent with MHM’s statements under this Privacy Policy, Additional Privacy Notices or otherwise made at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

• Facilitate, manage, personalize, and improve your online or other Services experience;

• Allow you to participate in the features and service offerings we make available on or via the Services;

• To perform Professional Services for clients
• Process your registration, manage your account and/or upload your User Generated Content (“UGC”). (For more information on how UGC is treated under the Services’ Terms of Use click here. For more on the public nature of UGC, see Section 5;

• Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content, and send you notices;

• Our marketing (as permitted by applicable law) and other purposes;

• Improve the Services, and our other services, and for any other internal business purposes;

• Tailor our content and offers (as permitted by applicable law);

• Fulfill other purposes disclosed at the time you provide Personal Information, or at the time we receive Client-service PI or Client-Service PHI whether or not from you directly, or otherwise where we are legally permitted to do so and doing so is not inconsistent with an express privacy commitment we have made; and

• Prevent and address fraud, breach of policies or terms, and threats or harm and to comply with applicable law, and law enforcement or other legal processes, and government requests.

3. INFORMATION WE SHARE WITH THIRD PARTIES.

As permitted by applicable law, MHM may share non-Personal Information, and Personal Information that is not deemed MHM-Collected PI hereunder, or Client-service PI or Client-service PHI, provided that we are not aware of restrictions on our use or sharing, with third parties for any purpose.  However, MHM’s sharing of MHM-Collected PI,Client-service PI, and Client-service PHI is subject to the following:

• Marketing:  Subject to your communications choices explained in Section 11, and the rights of California residents explained here, we may use your Personal Information to send you marketing communications.  MHM will not share your MHM-Collected PI with third parties, for their own direct marketing purposes, except with our Affiliates and in connection with Corporate Transactions (defined below), absent your consent (which may be by means of third party interaction described in the next bullet point). Your HIPAA PHI will be used or disclosed for marketing purposes only in accordance with the requirements of HIPAA and our Protected Health Information Notice of Privacy Practices and your non-public personal financial information that is governed by the federal Gramm-Leach-Bliley Act or state insurance or financial services privacy laws will be used or disclosed for marketing purposes only in accordance with the requirements of those laws and our Financial Services Privacy Statement.
• Your Disclosure or Consent:  As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, and Analytics), your activities on the Services may, by their nature, result in the sharing of your MHM-Collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties.  Such third party data receipt and collection is subject to the privacy and business practices of that third party, not MHM. 
• Additional Privacy Notices: If governed by an applicable Additional Privacy Notice, then subject to the terms and conditions of that Additional Privacy Notice.

MHM may also share any information about you (including, without limitation, MHM-Collected PI) for any purposes not inconsistent with this Privacy Policy, an applicable Additional Privacy Notice, or otherwise not prohibited by applicable law, including, without limitation:

• Clients, in connection with our Services to them that you use or access or that relate to you;
• MHM’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including, without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on MHM’s behalf, provided however, (i) your Client-service PHI will remain subject to any applicable requirements of HIPAA and state health information privacy laws; (ii) your non-public personal financial information that is governed by the federal Gramm-Leach-Bliley Act or state insurance or financial services privacy laws will remain subject to any applicable requirements of those laws; and (iii) MHM does not authorize its Service Providers to use MHM-Collected PI, Client-service PI or Client Service PHI provided by MHM to the Service Providers to send you direct marketing messages other than related to MHM absent your consent.  For more information on choices Service Providers may offer you click here.
• To comply with the law, law enforcement or other legal process, and in response to a government request; and

• If MHM believes your actions are inconsistent with MHM’s terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of MHM, the Services or its clients or users, or any third party.

MHM may share your Client-service PI, Client Service PHI and MHM-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of MHM assets, or transfer of all or a portion of MHM’s business to another company (“Corporate Transactions”).

In addition, in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity).  Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.

4. PROTECTED HEALTH INFORMATION (“PHI”).

Notwithstanding anything in this Privacy Policy to the contrary, when we receive PHI in the course of performing services for a HIPAA covered entity or an entity subject to state health information privacy laws (“Client-service PHI”), we treat and protect the Client-service PHI consistent with our obligations under HIPAA, applicable state health information privacy laws and our contractual obligations to the covered entity (e.g., a group health plan).

5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.

The Services may permit you to post or submit UGC including, without limitation, comments and other content, including Personal Information and PHI.  If you choose to submit UGC to any public area of the Online Services (e.g., blog posts and comments to blog posts), your UGC will be considered “public” and will be accessible by anyone, including MHM.  Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Information and PHI included in UGC is not subject to MHM’s usage or sharing limitations, or other obligations, regarding MHM-Collected PI, Client-service PI, Client-service PHI, or other Personal Information under this Privacy Policy or otherwise, and may be used and shared by MHM and third parties to the fullest extent not prohibited by applicable law.  MHM encourages you to exercise caution when making decisions about what you disclose in such public areas.  For more information on how UGC is treated under the Services’ Terms of Use click here. California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Online Services.

6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, AND ANALYTICS.

The Services may include hyperlinks to, or include on or in connection with, the Services (e.g., apps, software, and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you. 

For example, certain functionalities on the Services permit interactions that you initiate between the Services and certain Third-Party Services, such as third party social networks (“Social Features”).  If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Services (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Services (e.g., by using a hashtag associated with MHM in a tweet or status update), your post may be used on or in connection with the Services or otherwise by MHM.  Also, both MHM and the third party may have access to certain information about you and your use of the Services and any Third-Party Service.

MHM may use Google Analytics, Adobe Analytics or other Service Providers for analytics services.  These analytics services may use cookies and other Tracking Technologies to help MHM analyze Service users and how they use the Services.  Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Services’ activity, and providing other services relating to Services activity and other Internet usage. 

Except to the extent we combine information we receive from Service Providers, Third-Party Services, or other third parties with MHM-Collected PI, in which case MHM will treat the combined information as MHM-Collected PI under this Privacy Policy (see Section 1(c), data obtained by MHM from a third party, even in association with the Services, is not subject to MHM’s limitations regarding MHM-Collected PI under this Privacy Policy, however such data remains subject to any restrictions imposed on MHM by the third party, if any.  Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with MHM, the types of information shared, and your choices on what is visible to others on Third-Party Services. 

Except as required under applicable law and/or our contractual commitments to covered entities with regard to Client-service PHI or to our clients regarding Client-service PI, MHM is not responsible for and makes no representations regarding the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Services, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.  See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding analytics.

7. DATA SECURITY AND MONITORING.

MHM takes reasonable measures to protect MHM-Collected PI (excluding public UGC), Client-service PI and Client-service PHI, from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and MHM cannot guarantee the security of your information collected through the Services.

To help protect you and others, and as permitted by applicable law, MHM and its Service Providers may (but make no commitment to) monitor use of the Services, and may collect and use related information including MHM-Collected PI and other Personal Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the Services; ensure compliance with the Terms of Use (and applicable Additional Terms) and this Privacy Policy (and Additional Privacy Notices); investigate violations of or enforce these agreements; and otherwise to protect the rights and property of MHM, its clients, third parties, and other users.  Monitoring may result in the collection, recording, and analysis of online activity or communications through our Services.  If you do not consent to these conditions, you must discontinue your use of the Services.

8. INTERNATIONAL TRANSFER.

MHM is based in the U.S. and the information MHM and its Service Providers collect is governed by U.S. law.  If you are accessing the Services from outside of the U.S., please be aware that information collected through the Services may be transferred to, processed, stored, and used in the U.S.  You expressly acknowledge and agree that your use of and access to any Services is governed by and subject to U.S. law.  Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy. 

9. CHILDREN'S PRIVACY.

The Services is intended for a general audience and not directed to children less than thirteen (13) years of age. MHM does not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA.  If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. 

Any California residents under the age of eighteen (18) who have registered to use the Services, and who posted content or information on the Online Services, can request removal by contacting MHM here, detailing where the content or information is posted and attesting that you posted it.  MHM will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that MHM does not control.

10. ACCESSING AND CHANGING INFORMATION.

MHM may provide web pages or other mechanisms allowing you to delete, correct, or update some of the MHM-Collected PI, and potentially certain other information about you (e.g., profile and account information).  MHM will make good faith efforts to make requested changes in MHM’S then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from MHM’S databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter.  Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

11. CHOICES:  TRACKING AND COMMUNICATION OPTIONS.

A. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.  Browsers offer different functionalities and options so you may need to set them separately.  Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies.  For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Services may not work and that when you revisit the Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.