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Your Privacy is Important to Us

Privacy Policy

Thank you for visiting this web site (each, a "Site") owned and operated by Berkeley Analytics, Inc. (dba Turnaround Health). ("Turnaround Health"). This Privacy Policy details certain policies implemented throughout Turnaround Health governing Turnaround Health's use of personally identifiable information about users of our Site and the programs available on or through the Site.

We hope that reading our Privacy Policy helps you understand how we collect, use and disclose information about you.

General Description of Information that We Collect

While you may use some of the functionality of the Site without registration, many of the specific tools and services on our Site require registration. If you use our Site without registering, the only information we collect will be Non-Personal Information through the use of Cookies. If you choose to register with our Site for certain Interactive Tools or other services, we require you to submit certain Personally Identifiable Information. Depending on the tool or service you have selected, we may also collect Personal Health Information. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to Turnaround Health. Inaccurate information will affect the information you receive when using our Site and tools and our ability to contact you as described in this Privacy Policy. For example, your email address should be kept current because that it is how we communicate with you.

Non-Personal Information We Collect About You.
The Site may track Non-Personal Information that will be maintained, used and disclosed in aggregate form only and which will not contain your Personally Identifiable Information. For example, without limitation, we may collect the total number of visitors to our Site, a user's IP address, the number of visitors to each page of our Site and/or how many users clicked on a certain promotion. We may analyze this Non-Personal Information for trends and statistics in the aggregate, and we may use such Non-Personal Information to administer the Site, track users' movement, and gather broad demographic information for aggregate use.

Cookies.
We collect Non-Personal Information about your use of our Web Site through the use of Cookies. Every computer that accesses a Turnaround Health Web site is assigned a different Cookie by Turnaround Health. The information collected by Cookies helps us improve the overall Site experience for our users.

Most browser software can be set to reject all Cookies. Most browsers offer instructions on how to reset the browser to reject Cookies in the "Help" section of the toolbar. If you reject our Cookies, certain of the functions and conveniences of our Site may not work properly, but you do not have to accept our Cookies in order to productively use our Site. We do not link Non-Personal Information from Cookies to Personally Identifiable Information without your permission and do not use Cookies to collect or store Personal Health Information about you.

Personally Identifiable Information We Collect About You and How We Use Your Information.
We collect Personally Identifiable Information, including your name, email address, and zip code, and Protected Health Information you provide to us when you register as a member of our Site or services and/or when you update your member profile as well as any other Personally Identifiable Information that you elect to provide to us when you contact us or include such information in a response to us. We use the Personally Identifiable Information and Protected Health Information that you provide to respond to your questions, provide you the specific services you select, and send you the Alive-PD program by email, and sometimes by telephone and through printed mailings.

When you register for use of Alive-PD service you will receive messages and services via email from our Alive-PD program. These emails may contain information such as the Alive-PD program goal you are working on (e.g. increase fruits/vegetables). You can unsubscribe or Opt-Out from our Alive-PD program emails, printed mailings or phone calls by clicking the associated checkbox on the email or on the Contact Information tab of your Alive-PD program home page.

If you have difficulties with our unsubscribe or subscribe service, please contact us and let us know about your problem. Turnaround Health Customer Service will use its commercially reasonable efforts to manually unsubscribe you from that newsletter in two to three business days from receipt of your request.

Emails You Send to Turnaround Health.
Any content, business information, ideas, concepts or inventions that you send to Turnaround Health by email are not protected under this Privacy Policy.If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them to Turnaround Health.

Tell A Friend
If you use our Tell a Friend service to tell a friend about our Site or the Alive-PD program, we will ask you for your name, your email address and your friend's email address. We will automatically send your friend a one-time email inviting him or her to register for the Alive-PD program.  Turnaround Health does not use your name, your email address or your friend's email information that you submit to our Tell a Friend service for any other purpose. We will only use the information you provide to send the email you request.

Third Party Websites, Communities, Blogs and other Public Forums
The Site may contain links to other websites. Once you enter another website (through a content link), be aware that Turnaround Health is not responsible for the privacy practices of these other websites. We encourage you to look for and review the privacy statements of each and every website that you visit through a link or advertisement on the Site.

If you visit a Turnaround Health feature or community area on a third party website such as Facebook and Twitter where users can share information and support one another, your use of that feature or community area is governed by that third party's privacy policy and terms of use.

Any information you shared in any online community area (including Personally Identifiable and Personal Health Information) like a chat room, blog, or online discussion is by design open to the public and is not private. You should think carefully before posting any Personally Identifiable or Personal Health Information in any public forum. What you post can be seen, disclosed to or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, Bing etc. Third Party Websites, Communities, Blogs and other Public Forums The Site may contain links to other websites. Once you enter another website (through a content link), be aware that Turnaround Health is not responsible for the privacy practices of these other websites. We encourage you to look for and review the privacy statements of each and every website that you visit through a link or advertisement on the Site. If you visit a Turnaround Health feature or community area on a third party website such as Facebook and Twitter where users can share information and support one another, your use of that feature or community area is governed by that third party's privacy policy and terms of use. Any information you shared in any online community area (including Personally Identifiable and Personal Health Information) like a chat room, blog, or online discussion is by design open to the public and is not private. You should think carefully before posting any Personally Identifiable or Personal Health Information in any public forum. What you post can be seen, disclosed to or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, Bing etc.

Website Registration and Interactive Tools on Turnaround Health
After you have registered as a member of the Alive-PD program and completed the questionnaires, you may choose to use certain Alive-PD program interactive content and tools that may display information about yourself on the Site including Personal Health Information. Some of the tools (like certain quizzes or calculators) do not retain your Personal Health Information, while others (like the Simulator Tool) store your Personal Health Information for the purpose of providing you with the Alive-PD program.

Children
Neither the Site nor any of its services are designed or intended to attract children under the age of 13. We do not collect Personally Identifiable Information from any person we actually know is under the age of 13. A parent or guardian, however, may use the Site to establish an Alive-PD account for a minor. The parent or guardian is solely responsible for providing supervision of the minor's use of Turnaround Health content. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through Site for the minor.

Disclosure of Your Information
Except as described in this Privacy Policy below or as specifically agreed to by you, Turnaround Health will not disclose any Personally Identifiable or Personal Health Information it gathers from you on our Site. We may release Personally Identifiable or Personal Health Information to third parties: (1) to comply with a legitimate governmental agency investigation, law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In the event that we are legally compelled to disclose your Personally Identifiable or Personal Health Information to a third party, we may attempt to notify you unless doing so would violate the law or court order. In addition, we may disclose Personally Identifiable Information or Personal Health Information as described below.

Turnaround Health may share your Personally Identifiable Information or Personal Health Information with its subsidiaries, but your Personally Identifiable Information and Personal Health Information will remain subject to the terms of this Privacy Policy. Additionally, we may transfer your Personally Identifiable Information or Personal Health Information to a successor entity upon a merger, consolidation or other corporate reorganization in which Turnaround Health participates or to a purchaser or acquirer of all or substantially all of Turnaround Health's assets to which this Site relates.

Turnaround Health contractors sometimes have limited access to your Personally Identifiable Information or Personal Health Information in the course of providing products or services to Turnaround Health. These contractors include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of our Site. We also contractually require that our contractors 1) protect the privacy of your Personally Identifiable Information consistent with this Privacy Policy, and 2) not use your Personally Identifiable Information for any purpose other than providing us with products and services as required by law.

How Turnaround Health Handles Privacy and Security Internally
Turnaround Health may use the following security measures that are reasonably designed to help protect your privacy: username and password protection, firewalls, Secure Socket Layer, limiting the number of Turnaround Health employees who have potential access to your Personally Identifiable Information, and requiring all Turnaround Health employees to abide by our Privacy Policy.

Despite Turnaround Health's reasonable efforts to protect your Personally Identifiable Information and Personal Health Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.

Updating Your Information and Contacting Turnaround Health

A. Updating Your Personally Identifiable Information

Turnaround Health tools that collect and store self-reported data allow you to correct, update or review information you have submitted by going back to the specific tool, logging-in and making the desired changes. Turnaround Health may store user submitted data (PII and/or PHI) in an active database for a period of nine (9) months. After nine (9) months, user submitted data, including PII and/or PHI may be held in an active database or on an inactive back-up medium for a period of six (6) years.

B. Removing your Personally Identifiable Information

If you have a complaint or problem, please contact us. Our customer service department will forward your complaint to the appropriate internal Turnaround Health department for a response or resolution. We try to answer every email within 48 business hours, but may not always be able to do so. If you want to (1) delete your Personally Identifiable Information or Protected Health Information from our systems, (2) update the Personally Identifiable Information or Protected Health Information that you have provided to us, or (3) change your preferences with respect to marketing contacts or other activities, select the privacy option on our Contact Us form.

If you do not receive adequate resolution of a privacy related problem, you may write to Turnaround Health's Privacy Office at:

Turnaround Health, 15 Shattuck Square, Suite 288, Berkeley, CA 94704

We will use commercially reasonable efforts to notify you within 30 days of receipt of your letter to confirm your Personally Identifiable Information or Protected Health Information have been removed from our active databases. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to Turnaround Health from our servers.

Changes to This Privacy Policy
Due to the Internet's rapidly evolving nature, Turnaround Health may need to update this Privacy Policy from time to time. If so, Turnaround Health will post our updated Privacy Policy on our Site along with notice that the Privacy Policy has been changed. Turnaround Health may also send registered users of the Site e-mail notifications notifying such users of any changes to the Privacy Policy. Turnaround Health encourages you to review this Privacy Policy regularly for any changes. Your continued use of this Site and/or continued provision of personally identifiable information to us after we post our updated Privacy Policy and change notice on the Site will be subject to the terms of the then-current Privacy Policy.

Notice to European Users
The information you enter on this Site or otherwise provide to Turnaround Health may be transferred outside of the European Union to the United States of America which does not offer an equivalent level of protection to that required in the European Union. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union's Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his consent to the transfer of personal information, regardless of the third country's level of protection. By agreeing to this Privacy Policy, you consent to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in the European Union and to the processing of that information by Turnaround Health on its servers located in the United States of America as described in this Privacy Policy.

Last Updated: November 8, 2011
Date Effective: November 8, 2011

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