1. INTRODUCTION

This is the privacy policy (“Privacy Policy”) that governs how Two Wish Stars and our affiliated companies (“we”, “our” or “us”), use Personal Data (defined below) that we collect, receive and store about individuals in connection with the use of this website or websites, apps, or other online media under our operation and control (collectively the “Site”). You may choose whether or not to provide or disclose Personal Data in connection with your use of the Site. If you choose not to provide the Personal Data we request, you may still visit and use parts of the Site, but may be unable to access or use certain features, options, programs, and services. The Site may contain links to third-party websites and services that are not owned or controlled by Two Wish Stars. We are not responsible for the privacy practices or the content of third-party websites, services and advertisements, and you visit them at your own risk. We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using the Site. As used in this Privacy Policy, “Personal Data” means any information that may be used, either alone or in combination with other information, to personally identify an individual.

2. CHANGES TO THIS PRIVACY POLICY.

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE.

3. INFORMATION COLLECTED.

We may receive and/or collect Personal Data in the following ways:

3.1. Personal Data You Provide To Us On the Site.

If you send us a “Contact Us” request or feedback, or in connection with setting up an account on the Site, or if you buy or receive products or services on the Site or otherwise enter into a contract with us, or if you fill in forms or upload documents on the Site, you may provide us with certain information that may constitute Personal Data, such as:

  • Your name;
  • Email address;
  • Address;
  • Phone number;
  • Profession;
  • Password;
  • Marketing and communication preferences;
  • Content of the forms and documents you fill in or post on the Site;
  • Information you post on any public forums on the Site; and
  • Communications you send to us. When buying or receiving products or services on the Site, we may require you to provide billing information, such as billing name and address, and credit card number (collectively “Billing Information”). We use third party vendors such as Stripe, to process Billing Information and we do not collect or store Billing Information.

3.2. Personal Data You Provide To Third Parties On the Site.

Please note that we use certain third party service providers and business partners on the Site to enhance your experience or deliver certain services. These third parties may collect Personal Data in performing their services and/or functions on the Site. For a list of the third parties, the services they provide to us, and to learn about their privacy practices, please visit:

3.3. Information Provided By Third Parties.

We may collect information about you through non-affiliated third parties. For example, you may be able to access the Site through a social networking account. If you access the Site through your social media account, you may allow us to have access to certain Personal Data in your social media profile. If you access our Site from another website that provides Personal Data about you in accordance with their privacy policy, then we may collect such Personal Data. We may also receive Personal Data from third party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.

3.4. Information Collected Automatically.

Certain information on the Site is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of the Site. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers (described in Section 3.2 above) and business partners may use cookies or other methods to gather information regarding your use of the Site. For additional information about cookies, please see Section 3.4 (b). Business partners may use these cookies or other tracking methods for their own purposes by relating information about your use of the Site with any of Personal Data about you that they may have. The use of such information by a third party depends on the privacy policy of that third party.

a) Log Files On The Site. The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

b) Cookies: We use cookies to make interactions with our Site easy and meaningful. When you visit our Site, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. We may use cookies that are session-based and persistent. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate our Site, but you may not be able to successfully use all of the features of our Site.

4. THE PURPOSES FOR WHICH WE USE PERSONAL DATA.

If you submit or we collect Personal Data through the Site or otherwise as described above, then such Personal Data may be used in the following ways:

  • To provide, analyze, administer, improve, and personalize the Site;
  • To communicate with you in connection with the Site, notifications, events, programs or offerings that you may have registered for;
  • To send you updates and promotional materials;
  • To provide personalized advertising to you;
  • To identify and authenticate your access to the parts of the Site that you are authorized to access;
  • For recruiting and human resources administration purposes;
  • For research and development relating to the Site and the products and services we provide to you;
  • For advertising purposes;
  • For electronic direct marketing in compliance with applicable laws; and
  • To protect our rights and/or our property and to ensure the technical functionality and security of the Site.

5. HOW WE DISCLOSE PERSONAL DATA.

We do not sell, lease, rent or otherwise disclose the Personal Data collected on and through the Site to third parties unless otherwise stated below or with your consent.

5.1. Our Third-Party Providers.

We transfer Personal Data to our third-party service providers and business partners to perform tasks on our behalf and to assist us in providing the Site, as discussed in Section 3.2. above. We use commercially reasonable efforts to only engage or interact with third-party service providers and business partners that post a privacy policy governing their processing of Personal Data. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers.

5.2. Business Partners.

From time to time, we may partner with other companies to jointly offer products or services or to improve existing products or services. If you purchase or specifically express interest in a jointly-offered product or service from us, we may share Personal Data collected in connection with your purchase or expression of interest with our joint promotion partner(s). The Site is a member of the DMD Healthcare Communications Network (the “HCN”). HCN is owned and managed by DMD Marketing Corp (“DMD”). We do not control our business partners’ use of Personal Data we collect, and their use of the information will be in accordance with their own privacy policies.

5.3. In the Event of Merger, Sale, or Change of Control.

We may transfer or assign this Privacy Policy and any Personal Data to a third-party entity that acquires or is merged with as part of a merger, acquisition, sale, or other change of control.

5.4. Social Media Plugins.

The Site uses social media plugins (e.g. Facebook) to enable you to easily share information with others. When you visit the Site, the operator of the social plugin can place a cookie on your device, enabling that operator to recognize individuals who have previously visited the Site. If you are logged into the social media website (e.g. Facebook, Twitter) while browsing the Site, the social media plugins allow that social media website to share personal information about your activities on the Site with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on the Site. We do not control any of the content from the social media plugins. For more information about social plugins from other media websites you should refer to those sites’ privacy and data/information sharing statements/policies.

5.5. Other Disclosures.

We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Two Wish Stars, our users, or the public.

6. RETENTION OF PERSONAL DATA.

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 4 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law.

7. YOUR RIGHTS.

7.1 Rights Relating to Personal Data.

If you have an account on the Site, we provide access to—and the ability to edit or delete—certain categories of Personal Data through your account on each of our supported domains. We also permit you to:

  • Delete all content browsing information and opt-out of further participation in data associated with the current device you use to browse the Site; and
  • Delete all information related to email/newsletter subscriptions.
  • Subject to applicable law, if you would like to otherwise access, amend, correct, delete, export (e.g. data portability), object to the processing of Personal Data collected in and through the Site, or withdraw your consent (as applicable). Because our internal systems only make use of first party cookies and cannot associate user data between the domains we control, you must submit any such request to whichever domain you have used. We will promptly review all such requests in accordance with applicable laws. Depending on where you live, you may have a right to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at email so we have an opportunity to address your concerns directly before you do so.

7.2. Opting-Out of Promotional Emails.

You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us, or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to email. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

8. DATA SECURITY.

The security of Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Data from unlawful use, unauthorized access, or disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

9. TRANSFERS OF PERSONAL DATA FROM THE EU, THE UK, OR SWITZERLAND TO THE UNITED STATES.

In the event Personal Data is transferred from the European Union, the United Kingdom, or Switzerland to the United States, we implement adequate legal and technical safeguards to protect Personal Data, such as Standard Contractual Clauses adopted by the Commission of the European Union.

10. CHANGES TO THIS PRIVACY POLICY.

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING.

11. CHILDREN’S PRIVACY.

The Site is not intended for children under the age of 18. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 18 years of age.

12. HOW WE RESPOND TO DO NOT TRACK SIGNALS.

As explained above in Section 3.4, the technologies used on the Site may be used to track Site users’ activity on the Site. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform so a standard technological response has not yet been developed. For this reason, the Site may not respond to Do Not Track signals at this time.

13. YOUR CALIFORNIA PRIVACY RIGHTS.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data by Two Wish Stars to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email. California residents have the following rights with respect to Personal Data we may have collected about them:

(i) Requests to Know

You have the right to request that we disclose:

  • The categories of Personal Information we have collected about you;
  • The categories of Personal Data about you we have sold or disclosed for a business purpose;
  • The categories of sources from which we have collected Personal Data about you;
  • The business or commercial purposes for selling or collecting Personal Data about you;
  • The categories of Personal Data sold or shared about you, as well as the categories of third parties to whom the Personal Data was sold, by category of Personal Data for each party to whom Personal Data was sold; and
  • The specific pieces of Personal Data collected. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

(ii) Requests to Delete

You have the right to request that we delete any Personal Data about you that we have collected. Upon receiving a verified request to delete Personal Data, we will do so unless otherwise authorized by law.

(iii) Right to Opt Out of the Sale of Personal Data

You have a right to opt out of the sale of Personal Data. You may, at any time, direct us to not sell Personal Data about you to third parties. If you exercise your right to opt out of the sale of Personal Data about you, we will not sell Personal Data about you. Any Personal Data collected in connection with your request to opt-out of the sale of Personal Data about you will be used only to facilitate that request. You may submit opt-out requests by emailing us.

We have sold the following categories of Personal Data during the last 12 months:

  • National Provider Identifier, name, time stamp of Site visits relating to healthcare professionals;
  • Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or other electronic network activity information, a consumer’s interaction with an Internet Web site or advertisement; and
  • Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes. (vii) The Right to Non-Discrimination You have the right not to be discriminated against for the exercise of your California privacy rights described above.