PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE REGISTERING OR SUBMITTING ANY INFORMATION TO THE SITE

Face to Face Health, Inc., a Colorado corporation (“FacetoFace,” “we,” “us,” and “our”) operates FacetoFace.com (the “Site”).  This Face to Face Privacy Policy (“Privacy Policy”) describes the types of information we collect from Site members and visitors and how we use and share that information.  This Privacy Policy will explain the choices you have about how your information is used and how we handle that information. We urge you to read this Privacy Policy carefully.

We intentionally ask for very little personal information, and we STRONGLY encourage you to use common sense on our Site. Do not submit or reveal home addresses, phone numbers or anything else that you wouldn't want a stranger to have. Please be aware that all information that you post in public areas of the Site and all information that is contained in your FacetoFace profile or health diary and flagged as “public” can be seen by every registered user of the Site (“Member”) and by non-registered users of the Site (“Visitor”).

1.  Application of this Privacy Policy; Cross Border Data Transfers; User Consent

Application: This Privacy Policy applies to the FacetoFace Site; it does not apply to any third party sites that support our Site, in any capacity. 

The Site contains links to other sites. It is important for you to understand that once you enter another Web site (whether through an advertisement, service, or content link), FacetoFace is not responsible for the privacy practices of these other sites.  You should carefully review the privacy policies of every Web site that you visit through a link or advertisement on the FacetoFace Site

You can access certain limited functionality on the Site without registering.  If you use the site without registering, the only information we collect will be non-personally identifiable data that we collect through the use of cookies and the collection of IP addresses, as described below.

To use most of the functionality of the Site you must register.  To register, you will be required to submit certain personally identifiable information, as described below.

Additionally, to create your profile, your health diary, or perhaps while participating in a public or semi-public forum on the site, you may voluntarily submit other personal information to the Site, including personally identifiable information and health information.  You are entirely responsible for deciding what information to submit and whether that information is made available to other Members and Visitors in public, friends only and private areas on the Site.

Cross Border Data Transfers.  FacetoFace is based in, maintains principal offices in, and administers the Site from, Louisville, Colorado, in the United States of America. The Site is intended for users who are United States residents.  We may process and store your personal information on servers located in countries (including the United States) where laws regarding processing of personal information may be less stringent than the laws in your country.

FacetoFace makes no assurances or warranties that the site meets the legal requirements for privacy of PII in jurisdictions outside of the United States.  It is entirely your responsibility and you bear the entire risk for compliance for access from outside the United States.

Your Consent:  By submitting personal information through our site, you agree to the terms of this Privacy Policy and you expressly consent to the processing, use and transfer of your information, including your personally identifiable information, according to this Privacy Policy.  If you do not consent to such processing, use and transfer, you may not use this site. 

2. Personally Identifiable Information You Provide to Us

“Personally identifiable information” or “PII” means information that can be traced back to a specific individual.  Personally identifiable information includes information such as your complete name, email address, home address, telephone number, driver’s license number and Social Security number.  Also, if other information becomes linked to PII, that other information can also become PII. For example, if you are participating in a forum under your username, and you give out your phone number, then your username becomes PII when linked with your phone number.

Information We Require.  When you register to become a Member of our Site, we require you to provide your e-mail address, a user ID that you choose and a password that you choose (collectively, “Registration PII”).  No other information is required to register and use the Site.  You are responsible for providing an accurate email address and for keeping it current because that it is how we communicate with you.  Inaccurate information will affect our ability to contact you as described in this Privacy Policy. 

We encrypt the Registration PII that you provide and store and process it on our servers in Louisville, Colorado.  We use the Registration PII that you provide to respond to your questions, provide you with Site services you select, send you emails about Site maintenance and updates, inform you of features on the site, and inform you of material changes to our Terms of Use and this Privacy Policy.

Other information that you submit to the Site is linked to your user ID and email address for site administration purposes.  Unless you reveal your email or any other personally identifiable information in a public or semi public area of the site, other users of the Site will not have access to your Registration PII.  We do not knowingly share your email address with our advertisers and other partners without your consent.

Information You Voluntarily Submit.  The FacetoFace Site is a social site that allows members to directly connect to each other to find solutions to their healthcare problems.  Our Site is designed to inform the healthcare consumer, by providing access to real world information from real people about similar conditions, medications, facilities, and health plans.  To enhance your experience on the Site, you may want to voluntarily submit personal information, including health information and personally identifiable information, by adding information to your profile, creating a health diary, creating and/or sharing information with friends, forums or user-defined groups.  You may enter as much or as little of your personal information as you like.

We do not take any measures to protect the privacy or security of any additional personal information you voluntarily submit unless you mark the information “private.”  Any information you mark as “private” will not be available to other users of the site.  Any personal information that you submit to the site and mark as “public” will not be protected; it will be visible to other Members and Visitors to the Site, and will be available to Internet search engines such as Google.  Additionally, any information that you submit and mark as “friends” will be visible to anyone you designate as a “friend.” 

You control your personal information on the Site, including all PII.  It is your responsibility to decide what information you submit, how you mark that information and whether it is made available to other users of the Site.  You can add, edit or remove your personal information at any time.  You can change how your information is marked (private, public or friends).  You can also control access to your “friends” information.  You can remove anyone from your “friends” list by clicking the ‘remove as a friend’ link on their “friends” page.  To protect your privacy, you should not submit personally identifiable information to the Site.

HealthMatch.  If you chose to use our automatic HealthMatch Service, our proprietary algorithm will automatically match those characteristics you designate to other Members with similar characteristics.  HealthMatch uses information in your health profile that you designate for matching by setting “use for matching” in your health profile, and all information in your health diary, your forum entries and elsewhere on the Site you submit information.  You also can create custom searches in HealthMatch in addition to using our automatic matching feature.

Emails to Other Members.  One of the useful features of the Site is the ability for Members to contact other Members by email.  When these emails are sent, the sender cannot see the real email address of the intended recipient and the recipient cannot see the real email address of the sender.  When the email is sent, it is temporarily stored on our server, and then deleted.  We do not encrypt emails during transmission or storage.  One of the important features of the FacetoFace Site is the ability of Members to establish direct contact with other users enabling them to share and learn directly from each other.  It is important for you to understand that when you use the email feature on the Site to send an email to another Member, that Member will “see” your real email address in the message they receive.  If you do not wish to have your email address revealed to other Members, do not use this email feature.

3. Non-Personal Information We Collect

Even if you do not register with the Site, we collect non-personally identifiable data about your use of the FacetoFace Site. “Non-personally identifiable data” is information that is not traceable back to any individual and cannot be used to identify an individual. The non-personally identifiable data that FacetoFace collects in these ways is accessible by certain FacetoFace personnel as well as third-party agents that are involved from time to time in design, administration, maintenance and/or hosting of our Site.  FacetoFace uses all non-personally identifiable data that we collects internally and together with its designers, administrators and other agents in order to improve your experience on the Site.

Cookies.  “Cookies” are small text files that are placed on the hard drive of your computer by a Web page server.  Every computer that accesses our Site is assigned a different cookie.  We collect non-personal information about your use of our Site and your use of the Web sites of selected partners and advertisers through the use of Cookies.  We use Cookies to identify your Internet browser, store your preferences, track usage, determine whether you have authority to access certain content or services on the FacetoFace Site, and for security purposes.  We also use Cookies to facilitate a Member’s log-in. For example, if you check a box to ask that we store your user ID on your computer so that you don't have to enter it each time you visit the site, it's stored in a Cookie on your computer.  Data in FacetoFace Cookies may be read by the FacetoFace Site to authenticate user sessions or provide Member services, but cannot be read by any other Web site.  Cookies can contain pieces of personally identifiable information (PII). FacetoFace encrypts any PII it stores in its Cookies.

Third party advertisements displayed on the Site may also contain cookies set by Internet advertising companies or advertisers (known as “third party cookies”).  FacetoFace does not control these third party cookies and users of the FacetoFace Site should check the privacy policy of the Internet advertising company or advertiser to see whether and how it uses Cookies.  A Cookie placed on your computer by an advertiser may be accessed by any site on which that same advertiser has a presence.  

You can set your computer to warn you each time a Cookie is being sent or block all Cookies. However, by blocking all Cookies you may not have access to certain functions and conveniences on the FacetoFace Site.  But you do not have to accept our Cookies in order to use our Site. We do not link non-personal information from Cookies to personally identifiable information without your permission. 

IP Address.  We also collect your Internet Protocol (IP) address and browser type.  An IP address is a number that is assigned to your computer when you use the Internet. The IP address data that we collect does not contain any personally identifiable information about you. This data is used to manage and improve the FacetoFace services, track usage, and for security purposes.

4.  Information We Share with Others

One of the benefits of the FacetoFace Site is our ability to collect, analyze and share a broad range of healthcare related data.  So that others can learn from your experiences, all of your personal information, including health information, that you submit to the Site is added to our data base.  Members and Visitors to the site can review all information you mark as “public,” and Members you designate as “friends” can see your “friends” information.

Additionally, your personal information, including information you have marked “private” may be de-identified (stripped of any personally identifying information), aggregated with others’ information, and made available to other Members or to our business partners in the form of reports, charts or other analytics.  We or our partners may analyze the data and produce a report for public distribution.  We also may use the de-identified and aggregated information for our email campaigns or we may sell that information to our partners for their use in research, marketing, product development or the like.  We may also develop algorithms leveraging all information in the FacetoFace database for such purposes as network analysis, reputation scoring, or spam and fraud prevention.

Use of Information in Terminated Accounts.  When you terminate your account, or if we terminate your account because of abuse or breach of our Terms of Use, your access to your personal information will immediately cease.  Upon termination, we remove your email address, username and password from our servers.  Any other personal information you have submitted to the Site will remain on our servers, but the information will no longer be active on the Site or accessible to other Members or Visitors to the Site.  We may use the information for reporting various analytics to our partners, but it will no longer be linked to your email address or identifiable with you unless you voluntarily submitted personally identifiable information on the Site.

Other Uses.  We reserve the right to use and disclose any information on the Site, including PII, in connection with litigation, to stop abuse, or similar needs.  Additionally, if we participate in a corporate transaction where a third party acquires our assets or, we may transfer all information in our database, including PII, to another party.

5.  Member Communications

From time to time we communicate with our Members via email using the email address they provided at registration or in a later update.  You should be aware that email communications are not secure, we do not encrypt emails that we send or that are generated from our Site.

Administrative Email Communications.  You cannot opt out of certain email services.  When you register on the Site, we send an email to welcome you and confirm your registration.  When you contact us through any of the links on the Site, we will respond via email. We will send you an email to notify you of material changes to the Terms of use or this Privacy Policy, to notify you of changes in fees for premium services, a service interruption or planned suspension, a corporate transaction or other notices we may decide to send in connection with Site administration.  So long as you are a Member of the Site, you will not be able to opt out of these administrative communications

Informational and Promotional Email Communications.  After you register to use the Site, you may receive recurring informational/promotional materials via email from us or directly from our third party partners.  Among other things, we may use these emails to notify you about new services or new partners.  If at any time you no longer desire to receive this service, you can opt out by clicking on the "unsubscribe" link at the bottom of any email newsletter or promotion. An email to our automated unsubscribe service will be created on your computer. Click the "send" button. You will then be unsubscribed from that newsletter within two to three business days.  If you experience difficulties with our automated unsubscribe service, please use our “Contact Us” form, and we will manually unsubscribe you from that newsletter/service in two to three business days.  In some cases, when you click on a link or an advertisement on our site, in an e-mail or a newsletter, your browser may be momentarily directed to the website of a third party which, acting on behalf of FacetoFace, notes or "counts" your response to the advertisement, e-mail or newsletter before re-directing your browser to your selected destination; this re-direction process may not be apparent to you.

6.  Security Measures

Password and User ID.  Your user ID and your password are encrypted when you transmit them to us from your profile page on the Site.  If you transmit them in any other manner we cannot assure you they will be encrypted.  Your user ID and password are also encrypted in our database. 

You can change your password at any time from your profile page on the Site.  If you forget your password, you can retrieve it from the log-in page by using the “I forgot my password” link.  Type in your email address and if it matches the email address in your account you will receive email with further instructions on how to reset password.

As further security, your passwords must have at least 6 characters.  Your registration will not be accepted if you submit a password with fewer characters.  You are urged to combine letters and numbers in your password for enhanced security.

Database Information.  We only encrypt your userID and password in our database.  No other information you submit to the Site is encrypted when it is stored in our database.  While we do not warrant that your information will not be lost, we do employ backup measures to try to minimize data loss due server malfunctions

7.  Children’s Privacy

FacetoFace does not knowingly collect personally identifiable information from any children under age 13.

8.  Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect changes to our Site or changes in the law, our information collection and use practices, the features of the Site, or the technology we use, and those modifications will be effective when they are posted on the Site.  Your continued use of the Site after we post a revised Privacy Policy signifies your acceptance of the revised Privacy Policy.  It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes.  Please terminate your use of the Site immediately if you do not agree to the terms of this Privacy Policy or any revised policy.

Material Changes.  A “material change” to this Privacy Policy is a change that expands the permissible uses or disclosures of personally identifiable information allowed by the prior version of the Privacy Policy.  We will inform you by email if there is a material change to the Privacy Policy. Your continued use of the FacetoFace Site will indicate acceptance of the changes. You may of course choose not to continue using the Site.

Non-Material Changes.  We may make non-material changes to the Privacy Policy, in which case we may not notify you of the non-material changes.

9.  Questions About This Privacy Policy

If you have questions about this Privacy Policy please let us know through the “Contact Us” link on the Site.  Alternatively, you can contact us via U.S. mail at:

Face to Face Health, Inc.

Attention- Privacy Policy

357 S. McCaslin Blvd., Ste. 200

Louisville CO 80027.

This Privacy Policy was last updated October 6, 2008.