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PRIVACY POLICY

Last Updated: 12th July 2011


Hardrada Medica Group's Privacy Policy

Hardrada Medica Group (“HMG”) is committed to protecting your privacy. Please read this Privacy
Policy in reference to the HMG website and services. By using this website or any of Hardrada
Medica Group’s services, you consent to the use by HMG, its affiliates and third-party vendors of any
information or content you submit through the website or pursuant to the provision of services by HMG
in the manner described in this Privacy Policy.

Questions Regarding Privacy Policy

If you have any questions or concerns regarding our current Privacy Policy please email us at info@hmgsolutions.com

Information We Collect From Opt-In's

When you Opt-In to the Hardrada Medica Group's HCP eMail Database we ask for the following identifying information: Title, Primary Specialty, Secondary Specialty, Group Practice Size, Group Practice Specialty, and Type of Facility. You are asked to identify which Market Verticals (Pharmaceutical, Insurance, Medical Device, CME, Publishing, etc.) from which you would like to receive 3rd Party eMail solicitation.

Opt-Out Process

An opt-out page is provided to enable Members of the Hardrada Medica Group HCP database to opt out at any stage from receiving 3rd Party eMail solicitation from any of Hardrada Medica Group's partners. Healthcare Professionals are given the opportunity to indicate if they wish to stop receiving 3rd party eMail solicitation from All Market Verticals or from specific Market Verticals.

How Does Hardrada Medica Group Use the information It Collects?

Hardrada Medica Group may rent, license or sell the following personally identifiable information: eMail Address, Postal Address, Telephone Number, Fax Number, Specialty Information, and Group Practice Information, only from those specific Healthcare Professionals who have actively Opted-In to the Hardarda Medica Group's HCP eMail Database. Hardrada Medica Group will only rent, license or sell personally identifiable information to those specific Vertical Segments that the Healthcare Professional has approved.

Disclosure to Third Parties

Hardrada Medica Group may share some kinds of personally identifiable information with third parties as described below.

Companies and People Who Work for Us:

Hardrada Medica Group contracts with other companies and individuals to help us provide our services. For example, we may host some of our Professional Sites on another company's computers, hire technical consultants to maintain any Web-based health tools, or work with companies to remove repetitive information from customer lists, analyze data or provide marketing assistance (including assisting us in targeting our advertisements as described herein), customer service or fulfillment services.

In addition, if you are a healthcare professional, we may validate your licensure status and other information against available databases that list licensed health care professionals. In order to perform their jobs, these other companies may have limited access to some of the personally identifiable information we maintain about users of the Professional Sites. We require all such companies to comply with the terms of this Privacy Policy, to limit their access to any personal information to the minimum extent necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us.

Promotional Offers:

Sometimes Hardrada Medica Group sends offers to selected users or clients of HMG services on behalf of other businesses. When we do so, we do not give such businesses your name and address. If you do not wish to receive such third party offers, you may contact HMG at the email or postal address below and request removal from these promotional offers.

Assignments:

If Hardrada Medica Group transfers or assigns a business unit (such as a subsidiary) or an asset (such as a web site) to another company, that company will be required to honor the applicable terms of HMG’s then-current Privacy Policy and associated privacy and data handling practices and procedures.

Legal Requirements:

We may release account and other personally identifiable information when we believe release (1) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) is reasonable 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 information to a third party, we will attempt to notify you unless doing so would violate the law or court order.

Consent:

By providing your personally identifiable information through the HMG website or by using HMG services, you consent to HMG’s providing your information to a third party solely for the purposes and subject to the limits described in this Privacy Policy. For example, when you choose to participate in an HMG “Industry Program,” we will provide certain personally identifiable information to the sponsor of such program, as further described above.

Does Hardrada Medica Group Use "Cookies"?

When HMG sends a third party an Iinformational email message on behalf of one of its clients/partners, we may insert a ”cookie” for tracking purposes. The ”cookie” will only be used to determine which healthcare professional has opened or clicked on an informational email message.

How Does Hardrada Medica Group Protect Your Information?

Hardrada Medica Group safeguards the security and accuracy of the data you send us with physical, electronic, and managerial procedures.

These procedures include limiting access to the information in various ways depending on the nature of the information as well as training our employees on the proper handling of subscriber and client information. While we believe we have taken appropriate measures to protect the information that we have received, we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.

When you place orders or access your account information, we offer the use of a secure server. The secure server software (SSL) encrypts all information you input before it is sent to us. Furthermore, we take extra steps to protect this data from unauthorized access, disclosure, alteration, or destruction.

In addition, HMG takes reasonable steps to maintain the accuracy of the information you provide to
us. If you become aware of an inaccuracy in your personal information maintained by HMG, you may
contact us at the email or postal address in this Privacy Policy.

What access does Hardrada Medica Group give you to your personal information?

You may delete or update your personal information and email preferences, at any time.

You have the option of correcting, updating and/or changing contact and demographic information and other information previously provided and stored in our database. If you wish to correct, update or change your information, simply email info@hmgsolutions.com. Alternatively, you may contact HMG at the following postal address:

Hardrada Medica Group
131 Grove Street
Melrose MA 02176

Your California Privacy Rights

As of January 1, 2005, California civil Code Section 1798.83 permits users of the HMG website or services who are California residents to request certain information regarding the disclosure of personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please contact HMG at the email or postal address above.

European Union Data Protection Directive and Swiss Federal Act on Data Protection Safe Harbors:

Hardrada Medica Group adheres to the U.S. safe harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement with respect to both the European Union Data Protection Directive and the Swiss Federal Act on Data Protection, and is registered with the U.S. Department of Commerce's Safe Harbor Programs for both. Information regarding the Safe Harbor Program can be found at the program’s website: http://export.gov/safeharbor/. If you have questions about our compliance with the safe harbor privacy principles, you may contact us at info@hmgsolutions.com or at the postal address above.

Is This Privacy Policy Subject to Change?

Yes. The Hardrada Medica Group Privacy Policy is subject to change at any time.

By using our website and/or our services, you consent to the collection and use of this information by Hardrada Medica Group for the purposes disclosed in this Privacy Policy. If we decide to materially change our privacy practices, we will post a prominent notice of those changes on the HMG website so that you are always kept informed of what data we collect, how we use it, and under what circumstances we disclose it. Please check the HMG website for changes from time to time to make sure you are aware of our latest privacy practices.

 International Email Marketing Regulations
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21/07/2009

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