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Last Updated: 03-21-2019

I. INTRODUCTION

This Online Privacy Policy (“Policy”) explains how information about you is collected, used, protected and disclosed by Loma Linda University Health (“LLUH”, “our” “we” or “us”) with respect to your use of the LLUH websites, any mobile versions of the websites, and any other electronic platforms where this Policy is posted (hereafter referred to as "Sites").

This Policy also informs you of our specific data handling practices and guidelines that protect the security and confidentiality of your personal data. Please read this Policy carefully.

This Policy excludes those websites and online services operated by LLUH that have separate privacy policies and do not include a link to this Policy. Our Policy applies only to activities we engage in on the Sites and does not apply to activities that are “offline” or unrelated to the Sites. 

By continuing to use the Sites and providing your personal data and other information through the Sites, you acknowledge that your personal data will be processed pursuant to the terms of this Policy. Please do not use the Sites or provide us with your personal data if you do not agree to all of these terms.

II. Information Collected by LLUH

We collect information from and about users of our Sites, which will include information defined as personal data (“Personal Data”). Personal Data means any information relating to an identified or identifiable natural person or as defined under applicable law. The Personal Data we gather about you generally can be categorized as either information you give to us or information we collect about you.

A. Information You Give to Us

During your visit to the Sites, we may request and collect Personal Data from you such as:

  • Your name,
  • E-mail address,
  • Physical address,
  • Telephone number,
  • Your curriculum vitae or resume and contact details when you apply for a position with us,
  • Educational History,
  • Social media profile,
  • Credit card details,
  • Health Insurance Type,
  • Medical Condition when seeking treatment or care,
  • Location data (for example, a location is derived from your Internet Protocol (IP) address or data such as a zip code or name of a town or city), and
  • Any other personal, financial, or demographic information you voluntarily choose to share with us.

To the extent that you provide personal information about others, you acknowledge that you have obtained permission for the provision of their data.

Any medical information voluntarily provided to us is governed by the terms of the Notice of Privacy Practices. (Spanish)

B. Information We Collect About You

As with many other websites, as you navigate through and interact with our Sites, we use automatic data collection technologies to collect certain information about your browsing actions and patterns. This information includes Non-Personal information, which is information that cannot be traced back to a specific individual.

The information we collect about you includes:

  • Your device type, operating system, IP address;
  • Date and time of access, frequency, and other communication data;
  • Website that referred you to us (URL);
  • Browser type;
  • Language; and
  • Your usage and activity on our Sites.

We use this information to obtain a better understanding of how visitors use our Sites and to make decisions on how to improve its usefulness, including by enabling us to:

  • Determine Site traffic patterns;
  • Count the number of Site visits;
  • Share such information with vendors, contractors, consultants and other service providers who are working on our behalf and need access to your information to carry out their work for us;
  • Determine the frequency and last date of your visit to our Sites;
  • Use cookies and other technologies to collect information about your general internet usage when you visit our Sites or use our services. For more information, please visit Section IV.

In addition, we may combine Personal Data that we have collected about you with other information about you obtained from other sources (both online and offline), such as from third parties and public sources. For example, if you connect with us on social media, including Twitter, Facebook and LinkedIn, we may use the platforms’ data analytics and advertising tools to obtain Personal Data about you such as your demographics, interests, location and other characteristics, to use for research and analytical purposes, as well as for targeted or online behavioral advertising on other websites.

We also may collect your Personal Data from companies with whom we have partnered with, for example when you apply for a job with LLUH. We may associate this information with other Personal Data you have submitted and that we have collected about you.

III. E-mail Lists and Newsletters

When a form on one of our Sites provides the ability to opt-in to receive future e-mail messages from LLUH and if you choose to opt-in, then you will be added to the e-mail list you have selected. When we send you marketing materials based on your consent or as permitted by applicable laws, you have the right to unsubscribe via the opt-out link included in each e-mail. If you would like additional assistance with opting out of receiving e-mail messages, then please contact us at websupport@llu.edu.

If you have an account with us, LLUH will continue to send you with account-related e-mails and other service-linked communications, even if you opt-out of receiving other commercial marketing materials from LLUH.

IV. Cookies and Other Technologies

A. Cookies

When you visit our Sites, you may be issued a "cookie," which helps track your session while online. Our Sites use single-session (temporary) and multi-session (persistent) cookies. Session cookies last only as long as your web browser is open, and are used for technical purposes such as enabling better navigation on our LLUH Sites. Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our site and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics.

Among other things, cookies help to make your visit to our LLUH Sites more relevant and personalized for you. Cookies, by themselves, will not be used by LLUH to disclose your individual identity. This information identifies your browser to our servers when you visit the Sites.

Most web browsers are initially set to accept cookies, but you may choose to set your web browser’s settings to refuse cookies or to alert you when cookies are being used. It is possible that some portions of our Sites will not function properly if you choose to turn off web cookies.

Additional information about the use of cookies and how cookies can be disabled in your web browser can be found in our Cookie Policy and in Section IX below.

B. Web Beacons

In order to determine a user’s ability to receive HTML e-mail as well as to learn whether or not an e-mail has been opened, a “web beacon” is included in a majority of the HTML e-mail messages sent. This capability helps us send e-mail in a format users can read and enables us to track e-mails opened. We use this capability to track when a hyperlink has been clicked or when images have been loaded inside of an e-mail message as well as the aggregate number of links clicked.

C. Social Media Plug-In

We may use social media plug-ins on our Sites to enable you to easily share information with others. We use the information collected from the plug-ins to learn about your interests and to help us better understand how to serve you. This information may include your preferences about how to contact you or further develop a business or professional relationship with you, your product preferences, languages, marketing preferences, and some demographic data. These plug-ins may include those from companies like Instagram, Twitter, Facebook, YouTube, and LinkedIn. The social media plug-ins may allow these companies to receive directly identifiable Personal Information about you and your visit to our Sites. When you visit the Sites, the operators of the social media plug-ins on our Sites place cookies on your computer that enable them to recognize you on websites belonging to them and their affiliates and partners after you have visited our Sites, or that enable them to add the information collected from your visit to our Sites with your prior activity on those websites. The social media plug-ins collect this information about users whether they specifically interact with the plug-in or not, and it may enable social media companies to share information about your web-browsing navigational information with some of their other users.

LLUH does not control what information is collected by the social media plug-ins or the information practices adopted by those social media companies. For more information about social plug-ins from social media websites, you should refer to those companies’ privacy and data sharing statements. 

D. Cross-Tracking Devices

LLUH uses data analytics companies, advertising networks, or social media companies, and features offered by Google Analytics services or pixels such as from Facebook and LinkedIn to engage in “cross-device tracking,” which occurs when platforms, publishers, and advertising technology companies try to connect a user’s activity across smartphones, tablets, desktop computers, and other connected devices. The goal of cross-device tracking is to enable companies to link a user’s behavior across devices.

E. Google Analytics

We use Google Analytics to measure the web traffic on different parts of our Sites to improve it. Google Analytics, which anonymously tracks users who have JavaScript enabled, uses technical tools like first-party cookies and JavaScript code to collect information about your interactions with our Sites. The tracking information may include detailed data about what you do on our Sites, such as the web pages you visit and for how long and the websites you visited directly before and after coming to our Sites. In addition, first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) are used to report how your ad impressions, uses of ad services, and other interactions are related to visits to our Sites.

We use information from Google Analytics to administer and update our Sites, assess whether our Sites users match the expected Site demographics, and determine how key audiences are navigating the content. Google and its wholly owned subsidiaries may retain and use, subject to the terms of its Privacy Policy (located at https://policies.google.com/privacy or such other URL as Google may provide from time to time), information collected in your use of the Google Analytics Information Disclosures and Sharing. Google Analytics offers website visitors the ability to prevent Google from recording, processing, and using the data generated by the Google Analytics cookie. You may take advantage of this opt-out by downloading and installing the browser plug-in available through Google at the following link: http://tools.google.com/dlpage/gaoptout.

V. How We Use Your Information

LLUH collects and processes Personal Data about you where we have a legal basis to do so, including for the following reasons:

To render services to you or to fulfill a contractual agreement with you when you visit the Sites. This includes to:

  • Provide you with information, e-mails, or services that you request from us;
  • Recruit employee applicants for job openings, communicate with applicants and process applications; and
  • Communicate and provide additional information that may be of interest to you about LLUH and our third-party partners at your request.

When we have legitimate business reasons to do so. This includes to:

  • Respond to your questions, comments, feedback, or inquiries, including those concerning technical and customer support;
  • Share your Personal Data amongst the LLUH organization;
  • Ensure that content from our Sites is presented in the most effective manner for you and for your device;
  • Operate, maintain, improve, and develop our Sites and services;
  • Allow you to interact with certain third-party content service providers (for example, to enable you to link to, or view content from, third-party sites within our Sites, or view our content on a third-party site);
  • Allow you to participate in interactive features of our Sites when you choose to do so;
  • Identify your preferences so we can notify you of new or additional information or, that might be of interest to you; and
  • In the event there is a transfer of ownership or sale.

When we have your consent. This includes to:

  • Send you e-mails, newsletters or information about LLUH, or subscribe or unsubscribe you to one of our mailing lists upon your request; and
  • Manage your Personal Data via the MyChart Platform;
  • Obtain information about your medical condition.

Note: You will be requested to provide your consent prior to submitting information to us.

To comply with legal obligations to which we are subject. This includes to:

  • Comply with legal obligations, regulatory investigations or litigation and protecting LLUH against injury, theft, legal liability, fraud, abuse or other misconduct;
  • For fraud prevention, public safety, and enforcement of our reporting obligations and Terms of Use; and
  • To comply with the law, regulation, court order, subpoena or other legal process.

VI. Disclosure of Your Information

We do not share your Personal Data with third parties except as described in this Policy or as otherwise disclosed to you on our Sites. We may share your Personal Data as follows:

  • With our Financial Aid partners or government agencies for the purpose of offering aid and services to our students or prospective students;
  • When you give us your consent to do so, including if we notify you on our Sites that the information you provide will be shared in a particular manner and you provide such information to us;
  • With vendors, contractors, consultants and other service providers who are working on our behalf and need access to your information to carry out their work for us;
  • With another party, such as law enforcement officials, to comply with legal requirements, court orders, government or law enforcement agency requests, to protect or defend LLUH, or where we perceive an immediate danger of death or serious physical injury to someone as a result of activity on our Sites;
  • To protect our rights and property and those of our agents, customers and others, including to enforce our agreements and policies.

Our disclosures may occur under circumstances where we may not be authorized to advise you of such action.

We may also share with trusted third parties your IP addresses and your aggregated information that does not directly identify you. By browsing our Sites, you agree that LLUH may monitor your use of the Sites and may use the results of such monitoring without limitation.

VII. International Data Transfers of Personal Data

If you access or use the Sites outside of the United States (including the European Economic Area and Switzerland), and you use the Sites to provide us with your Personal Data, you do so on your own initiative and are responsible for compliance with United States federal, state, and local laws. Your information will be handled in accordance with this Policy and will be transferred and stored on our servers in the United States. Please note that the data protection laws of the United States may differ from those of your home country. All reasonable steps will be taken to protect your privacy in accordance with all applicable data protection laws.

VIII. Data Retention

We keep your information for as long as needed to fulfill the particular purpose for which it was collected. We may also retain your records if legally required or to fulfill a legitimate interest.

Unless otherwise required by law, LLUH will also erase Personal Data when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your Personal Data has been unlawfully processed; and when it is necessary to comply with legal obligations.

If you hold an account with LLUH, then we do not delete the data in your account. There are controls in your account where you can edit or delete certain data; however, LLUH retains any data related to classes you have taken at Loma Linda University or treatment you have received at one of the LLUH medical care facilities as they are relevant and necessary in relation to the purposes for which they were collected or otherwise processed.

IX. Your Rights and Choices

A. Cookies

You can disable cookies at any time by adjusting your browser settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. Please be aware, however, that if you turn off cookies, you may not be able to take full advantage of all of our Sites’ features. For more information, please visit our Cookie Policy.

B. Do Not Track

LLUH does not track its users over time and across third party websites to provide targeted advertising, and therefore does not respond to Do-Not-Track (DNT) signals.

C. European Economic Area Residents

In the European Economic Area, you have additional rights with respect to the Personal Data that we collect.

You may at any time exercise the following rights:

  • The right to request access to your Personal Data, which includes the right to obtain confirmation from us as to whether or not Personal Data concerning you is being processed, and where that is the case, access to the Personal Data and information related to how it is processed.
  • The right to rectification or erasure of your Personal Data, which includes the right to have incomplete Personal Data completed, including by means of providing a supplementary statement, certain rights to request us to erase your Personal Data without undue delay. Refer to section VIII for more information regarding erasure of Personal Data.
  • The right to restrict to processing concerning your Personal Data, which includes restricting us from continuing to process your Personal Data under certain circumstances (e.g., where you contest the accuracy of your Personal Data, processing is unlawful, your Personal Data is no longer needed for the purposes of processing, or you have otherwise objected to processing related to automated individual decision-making).
  • The right to object to processing concerning your Personal Data, where your Personal Data is processed for direct marketing purposes, where processing is necessary for the performance of a task carried out in the public interest, or where processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, unless we demonstrate compelling legitimate grounds for the processing which override such interests.
  • The right to data portability, which includes certain rights to have your Personal Data transmitted from us to another controller.
  • Where data processing is based on your consent, the right to withdraw consent at any time.
  • The right to lodge a complaint with a supervisory authority.

Any requests related to the above rights may be made by sending an e-mail to websupport@llu.edu.

X. Information Security

We take reasonable measures to protect Personal Data and other information we may receive from you in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction of such information.

Unfortunately, the transmission of information online is not completely secure. Although we do our best to protect all information collected through the Sites, we cannot completely guarantee the security of your Personal Data collected and/or transmitted through the Sites. Any transmission of information is at your own risk.

For more information about our security or if you feel that your information has been compromised, contact us immediately via at websupport@llu.edu.

XI. Third-Party Links

Our Sites may contain links to websites that are not operated by LLUH and these websites may have their own privacy policies which should be reviewed. LLUH is not responsible for the privacy practices of these websites, nor any adverse consequences that may result from your interaction with third party websites. These other websites may send their own cookies to users, collect data or solicit Personal Data. LLUH has no control or influence over the privacy practices of third party websites. Please exercise caution and consult the data protection policies posted on each third-party website for further information.

XII. Children

Our website is not intended for children under 16 years of age. We do not collect Personal Data from children under 16. If you are under 16, please do not provide any information on our Sites. If we learn we have collected or received Personal Data from a child under the age of 16, we will delete that information. If you believe that a child under the age of 16 has sent any information to us, please contact us at websupport@llu.edu.

XIII. Updates to the Online Privacy Policy

LLUH reserves the right to change, modify, add, or delete portions of this Privacy Policy at any time. If we make material changes to how we treat your Personal Data, we will notify you through a notice on the Sites home page. Your continued use of the Sites following any changes to the Policy will mean that you accept those changes. If LLUH makes any changes to this Policy, we will change the “Last Updated” date at the top of this Policy.

XIV. Comments or Questions

Unless otherwise indicated on a specific Site, LLUH is the data controller for all information collected under this Notice.

Should you have any questions regarding this Policy or the practices of the Sites, you may contact us at websupport@llu.edu.