83Bar, LLC (the “Company”) is committed to protecting your privacy online.  We have prepared this Privacy Policy to describe our practices regarding the User Data (as defined below) we collect from users of our website, located at www.restoremycontrol.com (the “Site”) and the Services (as defined below).  While the Company anticipates that users of this Site and any Services shall be (or represent) healthcare providers and organizations, all visitors are welcome to this Site and shall be subject to this Privacy Policy (as well as the Site’s Terms of Use). Capitalized terms not defined in this Privacy Policy shall have the meanings given in our Terms of Use located www.restoremycontrol.com.  

1.               Consent.  By submitting User Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your User Data in accordance with this Privacy Policy.  For purposes of this Privacy Policy, Services consist of the following: contacting you / your organization about the Company’s expertise and services; (as applicable) pursuant to an agreement or engagement, establishing relevant surveys and/or questionnaires for prospective patients and other leads within healthcare educational and informational programs on behalf of your organization; conducting data review and analytics of your and other organizations’ User Data for purposes of research, product/service development, marketing, and/or healthcare educational and informational programs; and facilitating electronic or telephonic outreach with prospective patients of healthcare providers and organizations for educational and informational purposes; and other relevant services as a hub for healthcare education, guidance, awareness, and connections with healthcare providers/organizations.
2.              Children.  We do not intentionally gather User Data from visitors who are under the age of 13.
3.              Users Outside of the United States.  Your User Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of User Data may be less stringent than the laws in your country.
  4.              Types of Data We Collect.  “User Data” means data that allows the Company to identify or contact you, including, for example, your name, address, telephone number, e-mail address, and any other non-public information, including personal and health information (as applicable), and information about your profession, your organization, and your organization’s needs/interests. “Anonymous Data” means data that is not associated with or linked to your User Data in a way that allows the Company or any other party to readily identify you; Anonymous Data consists of de-identified or non-personal information that does not, by itself, necessarily permit the identification of individual persons. 
5.              How We Collect Your Data.  We collect User Data and Anonymous Data in a manner described below.
            (a)            Information You Provide to Us.  We will collect User Data related to you when you visit and communicate with us through the Site, including in the following ways:

• We may collect User Data from you, such as your first and last name, e-mail address, phone number, and your professional organization, when you access the Site and expressly ask questions or seek information from the Company through any methods or programs for contact and communication.  
  
• When you request or seek Services on or through our Site, we may collect all information necessary to complete the request, including your age, gender, zip code, professional, organization, and other relevant information.
  
• If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
  
• We may also collect User Data, such as at other points in our Site that state or indicate that User Data is being collected. 
  
  You may choose not to provide us with certain information, but this may limit the responsiveness of the Company in providing you with relevant information, or limit the features and benefits of the Site or any Services that you seek. 

            (b)            Information Collected via Technology.  We will passively collect User Data and Anonymous Data related through your use of technology in visiting the Site and communicating with us, including in the following ways: 

• To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) may collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date and time stamp of your visit(s).
  
• We may also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.  Persistent Cookies can be removed by following Internet browser help file directions.
  
• We use Google Analytics or a comparable program (“Analytics Program”) to help analyze how users use the Site.  The Analytics Program may use Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we receive from the Analytics Program only to improve our Site and Services. The Analytics Program collects only the IP address assigned to you on the date you visit the Site, rather than your name or other personally identifying information.  We do not combine the information generated through the use of the Analytics Program with your User Data. Although the Analytics Program may plant a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, the Cookie cannot be used by anyone but the Analytics Program organization.  The Analytics Program’s ability to use and share information collected about your visits to the Site is restricted by appropriate privacy standards and terms of use applicable to the Analytics Program.   
  

6.              Use of Your User Data
(a)            General Use.  In general, User Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better.  We use your User Data in the following ways:

• to facilitate the creation of and maintenance of our network;
  
• identify you as a user in our system;
  
• provide improved administration of our Site and Services;
  
• provide the Services you request;
  
• improve the quality of experience when you interact with our Site and Services, including tailoring the features to you;
  
• send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
  
• send you administrative e-mail notifications, such as security or support and maintenance advisories;
  
• respond to your inquiries or other requests; and/or
  
• send you relevant educational and informational communications with respect to healthcare news, services, providers, organizations, and treatments.
  

 (b)            Creation of Anonymous Data.  We may create Anonymous Data records from User Data by excluding information (such as your name) that make the data personally identifiable to you.  We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Site and Services.  The Company reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion. 
(c)            Junk Mail or Spam.  As a general policy, the Company shall not under any circumstances send any communication (electronic or otherwise) that constitutes or represents junk mail, Spam emails, or unsolicited marketing on topics unrelated to this Site or the Company’s Services (e.g., messages involving chain mail, multi-level marketing, pharmaceutical sales, etc.), to any individual, organization, or third party, including any visitors and users of this site. This Company policy against junk mail, Spam emails, and unrelated marketing, also applies to any and all communications sent to patients, prospective patients, customers, and any other leads that the Company may contact (either directly or through other communication service companies) on behalf of healthcare providers and organizations who have engaged the Company for certain Services (e.g., healthcare surveys, questionnaires, education, outreach, awareness, etc.). 

7.              Disclosure of Your User Data.  We disclose your User Data only as described below and as described elsewhere in this Privacy Policy.
(a)            Third Party Service Providers.  We may share your User Data with third party service providers to:  provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company.  These third party service providers are subject to appropriate data privacy & security standards, and prohibited from using your User Data other than to provide the services requested by the Company. 

(b)            Affiliates and Acquisitions.  We may share some or all of your User Data with our parent company, subsidiaries, joint ventures, or other companies under common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.  If another company acquires our company, business, or our assets, including in the event of our bankruptcy, that company will possess the User Data collected by us and will assume the rights and obligations regarding your User Data as described in this Privacy Policy. 

(c)            Additional disclosures: We may share some or all of your User Data with third party service providers when necessary to complete relevant tasks and services, as a result of your response to our online advertisements, landing pages, surveys, qualification questionnaires, or when requesting information. 

(d)            Other Disclosures.  Regardless of any choices you make regarding your User Data (as described below), the Company may disclose User Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal order, requirement, or investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on the Company; (c) to protect or defend the rights or property of the Company or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Site’s Terms of Use. 

8.              Information You Share With Third Parties.  This Privacy Policy addresses our use and disclosure of information we collect from and/or about you on the Site or through any Services.  If you disclose information to others, including, for example, one of our partners providing goods and services, different rules may apply to their use or disclosure of the information you disclose to them.  The use and disclosure restrictions contained in this Privacy Policy will not apply to any third party.  We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.  

9.              Your Choices Regarding Your User Data
(a)            Choices.  We offer you choices regarding the collection, use, and sharing of your User Data.   
              (i)              We may periodically send you free newsletters, e-mails, or similar communications that discuss or promote the use of our Site or Services.  When you receive any such communications from us, you may indicate a preference to stop receiving further communications from us in the future by “opting-out” through the “unsubscribe” instructions provided in our communications (or by contacting us directly through the contact information below). 
              (ii)            Despite your indicated e-mail preferences, we may send you necessary or important service-related communication, including notices of any updates to our Terms of Use or Privacy Policy.
(b)            Changes to User Data in Accounts (as applicable).  You may change any of your User Data in your Account (as applicable) by editing your profile within your Account or by sending an e-mail to us at the e-mail address set forth below.  While you may request deletion of your User Data, please note that we may be required to keep this information and not delete it due to legal, regulatory and/or contractual reasons (or to keep this information for a certain time period, in which case we will comply with your deletion request only after we have fulfilled such requirements).  When we delete any information, it will be deleted from the active database, but may remain in our archives.  We may retain your information for fraud prevention or similar purposes. If/when we disclose any of your User Data to third parties (as described above), it is possible that we may not be able to force the deletion or modification of any such information by such third parties.  Although we may delete User Data as requested or necessary, we will retain Anonymous Data and may continue to use the Anonymous Data as permitted under this Privacy Policy.
10.           Security of Your User Data.  The Company is committed to protecting the security of your User Data.  We use a variety of industry-standard security technologies and procedures to help protect your User Data from unauthorized access, use, or disclosure.  No method of transmission over the Internet or method of electronic storage is 100% secure, however. Therefore, while the Company uses reasonable and all legally required efforts to protect your User Data, we cannot guarantee its absolute security.  You should report any perceived data privacy or security violations to us by sending an email to the address below.
11.           Contact Information.  The Company welcomes your comments or questions regarding this Privacy Policy.  Please e-mail us at: Privacy@go83bar.com or contact us at the following address or phone number:
11130 Jollyville Road, Ste 200
Austin, TX 78759
(512) 872-2457  
12.           Changes to This Privacy Policy.  This Privacy Policy may be revised from time to time. If we make any material changes in the way we use your User Data, we may notify you by sending you an e-mail to the last e-mail address you provided to us, and/or by prominently posting notice of the changes on our Site.  Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you, or thirty (30) calendar days following our posting of a notice on our Site.  These changes will be effective immediately for new users of our Site or Services.  Please note that at all times you are responsible for updating your User Data to provide us with your most current e-mail address.  In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes to this Privacy Policy.  If you do not agree with the changes to the Privacy Policy and/or our use of your User Data, you must notify us prior to the effective date of the changes (and terminate your Account with us, if applicable).  Continued use of our Site or Services following notice of any changes shall represent your acceptance and agreement with such changes to this Privacy Policy and/or our use of your User Data.   

Last Revised: October 20, 2017  

Data Use Policy

This site and its survey/questionnaire are administered by 83bar, LLC (“83bar”) on behalf of the healthcare organization identified on this site (“Restore My Control”), for your health information and education purposes. By utilizing the site and agreeing to receive information, communications, and/or contact, as applicable, you are agreeing to this Data Use Policy and the terms below. 

As you navigate this site and communicate with us electronically, you may be asked to disclose certain health and personal information through surveys and/or questions, so that you may receive appropriate health-related services and informational materials. In order for you to make an informed decision about whether to disclose your health and personal information via this site, please review the following information about how we collect and use such information. Personal information may include data that is unique to an individual, such as a name, address, e-mail address, or telephone number, and health information may include data involving your medical records, conditions, history, prognoses, and health interests/goals. Your health and personal information shall be collected, maintained, stored, and protected in accordance with all appropriate data privacy and security standards, including as applicable the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The following examples illustrate the ways in which 83bar (or when appropriate, Restore My Control) may utilize your personal and health information obtained through this site:

• Verifying your identity to ensure all communications are secure and confidential;
  
• Responding to your inquiries or requests;
  
• Delivering web-based information, products and services to you, including that which may be relevant or helpful based on your answers and feedback through surveys and questionnaires (you will always have the ability to “opt out” of any such communications or programs).
  
• To that extent your information is subject to HIPAA privacy and security standards (for example, if at a later time you choose to receive services from Restore My Control), disclosures of your information may also be made for HIPAA permitted purposes including the core health care functions of treatment, payment for care, and health care operations. HIPAA also permits information use and disclosure without the individual’s authorization for certain public policy and benefit purposes, such as in cases of emergencies, court orders/subpoenas, law enforcement purposes, or clinical research, with specific conditions and limitations applicable to such uses and disclosures.

Your personal and health information will not be collected unless you provide it voluntarily through this site. In some cases where required by law or regulation, or if the information you provided has changed, you may update your information by sending us an e-mail or by updating your profile online where applicable.

Under no circumstances shall 83bar or Restore My Control use your personal or health information to sell to third parties without your authorization, for marketing or sales programs that are completely unrelated to your healthcare interests or requests (as specified through this site), or for “junk mail” or SPAM purposes. 

Please note that 83bar and/or Restore My Control may engage other parties to carry out the activities described above and, in such cases, will contractually require any such third parties to maintain appropriate data privacy and security safeguards to protect your personal and health information. (For example, under applicable HIPAA standards, any third party shall be required to enter into a Business Associate Agreement and comply with specific data protection obligations.)

This Data Use Policy may be updated or revised periodically. When updates are made, the version date located at the bottom of this Policy will also be updated accordingly to reflect when revisions have been made. It is advisable to revisit this page and reread this Policy to see if any revisions may affect you. This Policy is not intended to, and does not, create any contractual or other legal rights in or on behalf of any party.

Last Update: 10/18/2017