Date of Last Revision: December 28, 2022.

Welcome to our website (“www.ihce.org”) (the “Website”).

1.  Introduction

1.      Institute for Health Care Ethics, Inc. (collectively “IHCE” or “us” or “our” or “we”) is the owner and operator of www.ihce.org and any related sub-domains (the “Service”). This privacy policy (“Privacy Policy” or “Policy”) applies to the Service in its entirety but does not apply to entities that IHCE does not own or control.

2.                  IHCE is committed to the privacy and protection of information provided to us by our users. This includes any information provided to us through our Service, including any information submitted to us through various forms and through other mechanisms.  Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By using our Service you are accepting the privacy practices contained in this Policy.  If you do not agree with our policies and practices, your choice is not to use our Website.

3.   The purpose of our Privacy Policy is to inform our users regarding the information that we collect, utilize, and share. If you have any questions about our Privacy Policy, or our privacy practices in general, please contact us using the contact information provided below:

Privacy, c/o Institute for Health Care Ethics, Inc. 424 Main Street

1600 Liberty Building

Buffalo, NY 14202 Email: contact@ihce.org Phone: 716-222-3865

2.                       Information Collected About You

1.      There are various types of information that IHCE collects about you when you register with, interact with, or otherwise use our Service. Some of this information is provided voluntarily by you and other information is provided through automated processes under IHCE’s control.

Information Provided By You: In addition to personally identifiable information(“PII”) provided during the IHCE registration process, you may also provide us PII during

the following non-exhaustive list of representative classes of interactions on our Service:

a.    requesting customer support and sending IHCE similar communications;

b.      making payments to IHCE for various offerings;

c.       signing up for IHCE email alerts, newsletters, and similar special offers;

d.      responding to IHCE surveys and other special information requests; and

e.       communicating with IHCE regarding our compliance with applicable law.

2.   Information Provided By Automated Processes: IHCE may automatically collect non- PII pertaining to you when you use our Service including, but not limited to, when you use our Service via mobile and other access devices. IHCE may use cookies, web beacons, log files, and similar methods to collect non-PII:

a.    A cookie is data stored in a small text file on your local access device that contains data about you. The information in the cookie is used to uniquely identify you and other users of our Service. The cookie may contain a token linked to our databases in order to provide you an enhanced feature set. It identifies a particular user at a particular point in time.

b.      A web beacon is used to enable communications with third parties. It is a small image in an HTML page with all dimensions set to one (1) pixel. Because of its insignificant size, it is not visible. It is used to pass certain non-PII anonymously to third-party sites, usually advertisers;

c.       A log file is a system created file that captures certain interactions between you and our Service.

3.                  Non-PII Reservation of Rights: IHCE reserves the right to adopt alternative methods for collecting non-PII consistent with the provisions of this Policy and without providing further notification to you, other than what is contained herein.

3.              Implications Regarding Collected Information

1.      Consent Regarding Data Storage and Transfer: Your use of our Service implies your consent to have your PII and non-PII (“Data”) (i.e. any data provided by you to IHCE via our Service or through other mechanisms) stored, transferred and processed within the United States, or in any other country in which IHCE or its affiliates, subsidiaries or agents maintain facilities. By providing us with your Data and using our Service you consent to any such transfer of Data outside of your country of origin, at IHCE’s sole discretion.

2.      Control and Access to Data: IHCE respects both the need for you to control your Data, and our need to use it in order to provide an enhanced experience on our Service. IHCE is diligent in ensuring that it has implemented appropriate administrative, technical, and physical safeguards to prevent the unauthorized or unlawful use of your Data, and to prevent any accidental loss, destruction, or damage to such information.

3.                  Use of Data Collected: IHCE is the sole business owner of the Data (i.e. as represented by the aggregate content and arrangement of the information collected about you on our Service) and will not sell, rent, or share the information collected in a manner that differs from what is disclosed in this Policy. IHCE collects this information in order to:

a.      accomplish the objectives of our Service;

b.      provide you with a high-quality user experience on our Service;

c.      offer you a personalized feature set on our Service; and

d.      to improve our Service.

4.                  Sharing of Data in General: PII provided by you will not be shared with third parties, without your permission, for any purpose other than those enumerated below. IHCE, in its sole discretion, reserves the right to share with third parties aggregated non-PII for the purpose of compiling information that is relevant to our business interests. IHCE, in its sole discretion, reserves the right to disclose any information that it obtains through our Service to appropriate governmental or regulatory authorities or governmental agencies, if required by law. IHCE, in its sole discretion, may share any information collected, stored and processed, if it has a good faith belief that to do so is reasonably necessary to:

a.       enforce our Terms of Use;

b.      detect, investigate, and otherwise address fraud, security or technical breaches or related matters; or

c.       protect against imminent harm to the rights, property, or safety of IHCE, its users, or the public at large, as required or permitted by law.

5.                  Sharing of Payment Data: IHCE may share transaction information with our third-party payment processor (“Payment Processor”) when you pay for or renew your License on our Service. The information shared with our Payment Processor is limited to the information required by our Payment Processor to complete the payment transaction. IHCE does not capture or store the financial information provided by you to our Payment Processor. IHCE only stores the results of said transactions as provided via notifications from our Payment Processor to us upon the completion of a payment transaction.

Sharing of Data with Other Third Parties: In addition to disclosing information to our Payment Processor, IHCE may disclose your personal information to other third- party service providers (“Providers”) who perform services on our behalf. Examples of such Providers may include, but are not limited to, data storage and web hosting companies, as well as consultants we may engage for various reasons. IHCE requires Providers to use and protect your personal information consistent with the provisions of this Policy.

4.              Security of Information

1.      Any information sent by you to IHCE through Internet email or through our Service may not be secure and is therefore done on a non-confidential basis and at your own

risk. Once such information is received, IHCE takes appropriate security safeguards to prevent its unauthorized use, alteration, disclosure, or destruction. These safeguards include periodic review of our internal processes, and benchmarking of same with industry best practices.

2.                  Access to PII is restricted to IHCE employees, contractors, and agents on a need to know basis. Such individuals are generally bound by confidentiality agreements and may be subject to termination and criminal prosecution should they fail to comply as required by said agreements and/or with the contents of this Policy.

3.                  The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

4.                  Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website.  Any transmission of personal information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

5.              Data integrity

1.      IHCE processes PII only for the purposes for which it was collected and in accordance with the provisions in this Policy. Reasonable steps are taken to ensure the quality of the PII that IHCE collects, processes, and stores. IHCE depends on its users to keep their PII current and accurate. IHCE conducts periodic reviews to ensure that only the PII required by our Service is captured and used consistent with the provisions of this Policy. The maintenance of data integrity is a joint collaborative effort between IHCE and our users.

2.                  IHCE may delete Data, from time to time, upon the request of an individual user. IHCE requires that a user present proper credentials for authentication before honoring all such requests. Good faith attempts are made to work with individual users regarding Data related issues. IHCE reserves the right to refuse such requests when they prove unduly burdensome and/or are impractical. IHCE will not delete Data required to be kept by applicable law or Data otherwise required by IHCE for legitimate business reasons.

6.              Choices Regarding PII

Should IHCE decide to use PII other than for the purpose originally collected, IHCE will do so only with your consent. You will be given the opportunity to opt out of any such use. Should IHCE become involved in a sale, acquisition, or any form of transfer of some or all of its assets, then IHCE will provide notice to you before your PII is subject to a new or different privacy policy.

1.      You always have the option of contacting IHCE should you have questions regarding your PII. Please contact IHCE using the contact information provided above.

7.              Protecting Children

Our Website is not intended for children under the age of 18 years of age.  No one under age 18 may provide any information, personal or otherwise, to the Website.  IHCE restricts the use of our Service to individuals of legal age and above. IHCE does not knowingly collect or solicit PII from anyone under the age of 18, with or without parental consent.  If you are under the age of 18, do not use or provide any information on this Website.

8.              Links

Our Service may contain hyperlinks to third-party websites that may collect or solicit information. Our Privacy Policy does not cover information collected or solicited by these third-party websites. IHCE is not responsible for the privacy practices of such sites. IHCE users are encouraged to pay attention when they leave our Service and to read the respective privacy policies of each website that collects personally identifiable information. This Policy only applies to information provided by you to IHCE via our Service or through other mechanisms.

9.              Enforcement

Because we are committed to protecting our users’ PII, IHCE conducts periodic reviews of our internal processes to ensure that we remain in compliance with this Policy. We will cooperate with the appropriate authorities to resolve any user complaints regarding the transfer of PII.. IHCE will initially try to resolve the complaint with the individual user. Formal complaints should be sent to IHCE using the contact information provided above.

10.       Policy Changes

 In the future, we may make changes to our Privacy Policy to reflect changes in our privacy practices and/or changes to our Service. IHCE’s goal is to keep our users aware of what information we collect, use, and under what circumstances, if any, we disclose it. When changes are made to this Policy the “last updated date” will be modified accordingly. If changes are made to our Privacy Policy then IHCE will provide notification on our Website. In addition, further notification will be provided to users that have registered with our Service.