FirstPractice (“we,” “us,” “our”) provides information, newsletters, blogs, expert advice and coaching, career advancement courses and job opportunities (the “Services”) through our website www.firstpractice.com (the “Website”) for physicians looking to start and/or further their career. This Privacy Policy explains, in plain English, what information we collect on our Website, and how we collect, use, maintain, protect and disclose information obtained from you when you visit and/or use any portion of the Website. For clarification, this Privacy Policy only governs the data that we may collect through the Website, or that we might receive from you in connection with any of the Services. All other terms and provisions associated with the Website will be provided to you in the Terms of Use, which is incorporated into this Privacy Policy by reference.

As with our Terms of Use, which directly incorporates this Privacy Policy, you must agree to our entire Privacy Policy in order to use the Website and Services. If you do not agree to any portion of this Privacy Policy or our Terms of Use, please stop using our Website and Services immediately. By registering with FirstPractice or using our Services, you are consenting to our practices, as described in this Privacy Policy, regarding the collection, use, processing and disclosure of your Personal Information. You are also agreeing to comply with the requirements contained herein.

This Privacy Policy applies to information we collect:

• On this Website. • In e-mail, text and other electronic messages between you and FirstPractice and/or this Website. • Through events, seminars, fairs and programs provided by FirstPractice, its Affiliates or other unaffiliated third parties and/or business partners that you register for through the Website; • Through mobile and/or desktop applications or solutions you download and/or access from this Website. • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Website. • Through your responses to surveys that we might ask you to complete for research purposes, or other sweepstakes or contests we may offer.

It does not apply to information collected by:

• us offline (other than as described above) or through any other means, including on any third party website; or • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Welcome to FirstPractice!

While we use plain English, it’s important that we all understand the same meaning of certain important terms used in our Privacy Policy and Terms of Use. Capitalized terms used in this Privacy Policy but not defined in this Privacy Policy have the meaning set forth in the Terms of Use.

Accessing, Controlling, Updating, and Deleting Data

When you use FirstPractice, we work to provide you the ability to access, review, correct, edit, or remove the Personal Information and related content that you have provided to us. You can do this by logging into FirstPractice and accessing your Profile. You must identify yourself before we can process any request to access, review, correct, edit, or remove such information. Although most changes will occur immediately, some information may stay stored on your browser’s web cache. We take no responsibility and are not liable for information stored in your cache or on any other electronic devices through which you may access FirstPractice.

We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical. In some instances, a request that requires disproportionate technical effort to accommodate may be processed for an additional fee.)You authorize us to use and disclose, in accordance with this Privacy Policy and the Terms of Use, any new or modified information that you provide. Please note our data retention practices identified above.

Choices for Personal Information

We will ask for your consent prior to collecting or using Personal Information for any purpose other than those described in this Privacy Policy or other supplementary privacy notices. You may be given the option to opt out of some of our data-collection practices. If we propose to use Personal Information for any purpose other than those described in this Privacy Policy or other supplementary privacy notices, we will provide you with an effective way to opt out of such use. Please note that declining to submit Personal Information for any Service may prevent us from being able to provide that Service to you.

Opt-Out/Changing Your Account

You may unsubscribe or opt out of any of our email lists, electronic newsletters, bulletins, guides or marketing campaigns at any time by following the instructions included in such email or other communication, or by contacting our service team by phone at (800) 776-8383 (select Option 2) or emailing them at helpdesk@FirstPractice.com.

If you wish to change the status of your Profile, you may so do by calling our service team by phone at (800) 776-8383 (select Option 2) or emailing them at helpdesk@FirstPractice.com. If you no longer wish to use our Services or maintain your Profile as active, upon your request, we will, as soon as practicable and in accordance with all applicable laws, deactivate your Profile and login information. After we have deactivated your Profile, information about your Profile may remain on the Website and/or in our databases and we may continue to use log information in accordance with this Privacy Policy. We may also retain your information to comply with any applicable laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any lawful investigations, enforce our Terms of, or to take any other actions permitted by law.

If you are a European Union resident, in addition to our general Privacy Policy, we would like to bring the following to your attention:

Data Controller/Processor. For purposes of the EU General Data Protection Regulation (“GDPR”), if you are located in the European Economic Area, FirstPractice processes Personal Information both as a Processor and as a Controller, as defined in the GDPR.

Data Protection Officer: FirstPractice has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at helpdesk@FirstPractice.com or 415 2nd Avenue, Hinton, WV 25951.

Cookies. Our Website generally uses Cookies to distinguish you from other users of our Website. This helps us provide you with a good experience when you browse our Website and also allows us to improve our Website. A fuller discussion of what cookies are and how we use them appears above in this Privacy Policy. When you created a Profile you checked a box allowing us to use cookies. You may also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

Your Rights as a Data Subject. The GDPR may provide you the right to:

• Make a Data Subject Access Request to access your Personal Information at any time. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it. • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us. • Request erasure / deletion / removal of your Personal Information. This enables you to ask us to delete or remove your Personal Information where we do not have a valid reason to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Please Note: we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. • Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to process it. • Data Portability / Request the transfer of your Personal Information to you or directly to another controller. This right only applies to automated information which you initially provided consent for us to use or where we used the Personal Information to perform a contract with you. We will (unless there is an exemption) assist you by securely transferring your Personal Information directly to another controller where technically feasible or by providing you with a copy in a structured commonly used machine readable format. • Withdraw consent at any time where we are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Legal Basis for processing your Personal Information. We have set out a short description of main ways we will collect, store, process, share and disclose your Personal Information and the legal basis we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

We will only use your Personal information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

• To fulfill a contract we are about to enter into or have entered into with you; • Where it is in our legitimate interests; • When it is our legal or regulatory duty; and • When you consent.

A legitimate interest is when we have a business or commercial reason to use your information in conducting and managing our business. We will consider and balance any potential impact on you and your legal rights when we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required for compliance with a legal or regulatory obligation or permitted to by law).

Marketing Messages. Generally we do not rely on consent as a legal basis for processing Personal Information except in relation to sending direct marketing communications via email or text message. However, where we are providing you with the Services, you will receive email marketing communications from us even if you have not given us consent as we rely on a soft opt-in form of consent.

You may receive marketing communications from us if you provided us with your details when you registered for the Services, a job fair, seminar, promotional or networking event or attended a course and you have given us consent to send you marketing. We may also use your identity, contact details, technical data, usage data and profile data to form a view and decide which services may of interest or relevant for you.

You have the right to withdraw your consent to marketing at any time by following the procedures outlined in the Opt-Out/Changing Your Account section of this Privacy Policy.

We will never sell or disclose your Personal Information to any third parties to use for marketing.

Where We Store Your Personal Information

The data that we collect from you may be transferred to, and stored at, a destination outside of your country of domicile. It may also be processed by employees, subcontractors and sub-processors (“Our Providers”) operating outside of your country of domicile who work for us, or on our behalf. Our Providers may be engaged in, among other things, the fulfilment of any requests and the provision of support services. By submitting your Personal Information, you agree to this transfer, storing or processing. We take steps we believe reasonably necessary so that your Personal Information is treated securely and in accordance with this Privacy Policy.

Data Retention

We retain your personal information and information stored and collected through the Website for as long as we have a business or tax need or as applicable laws, regulations, or government orders require. When your information is no longer necessary or relevant for the identified purpose or to fulfill a legal or business requirement, we will use reasonable commercial efforts to securely dispose of and destroy your information collected through the Website.

In accordance with industry standards, we have implemented security safeguards to protect FirstPractice and its users against unauthorized accessing, disclosure, alteration, or destruction of Personal Information. Some of the safeguards may include:

• Requiring passwords in order to access sections of the Website or certain data; • Employing firewalls to prevent unauthorized Website and data access; • Encrypting communications between your browser and the FirstPractice Website through HTTPS (Hyper Text Transfer Protocol Secure); • Restricting access to Personal Information to certain FirstPractice employees, contactors, agents, and operators; and • Requiring FirstPractice employees, contactors, agents, and operators to agree to and comply with strict confidentiality agreements, the violation of which include discipline, termination, and criminal prosecution.

While we are always looking to take reasonable steps to improve our security, the Internet can never be completely secure, and we cannot guarantee the security of the information transmitted to FirstPractice. In particular, emails, messages, and other communications between FirstPractice users are not encrypted, and you should never use these communication methods to convey personal information that you wish to keep private. Ultimately, you are responsible for protecting the security of your password and login information.

Data Breach

While FirstPractice employs multiple security measures to maintain data security, data breaches can occasionally happen, even to the most secure of systems. In the event of such a situation, FirstPractice will, in compliance with any applicable federal and state data breach laws, endeavor to timely notify all users whose Personal Information FirstPractice knows or has clear reason to believe was accessed by an unauthorized person.

Borders

Your Personal Information will be processed in conformance with this Privacy Policy. However, that processing may occur in countries with different laws as regards to your privacy. By using FirstPractice and providing any Personal Information, you consent to the transfer of data from your country to a country that may have different privacy laws. For citizens of the United States, your data may leave the territorial boundaries of the USA.

Your Responsibilities

As a user of our Website, you owe certain obligations to FirstPractice and other users, including potential legal obligations. You are also expected to extend to all other users of FirstPractice’s services various common courtesies broadly accepted by the professional community. You must:

• Abide by the terms and conditions of the governing and most current Privacy Policy, Terms of Use, and other applicable FirstPractice policies; • NEVER provide false or fraudulent information when setting up a Profile; • NEVER set up an a Profile for illegal or nefarious purposes; • Respect all intellectual property rights (e.g., trademarks or copyrights) that may belong to FirstPractice, other users, or third parties; • Refrain from uploading, posting, or disseminating any personal information that may infringe on the rights of others or be deemed offensive, injurious, discriminatory, prejudiced, or bigoted; and • Safeguard your username and password by not sharing it with others.

Physician retains sole discretion to restrict, suspend, or terminate any user’s Account for any violation of the obligations or requirements set forth in our Terms of Use or other governing policies.

Miscellaneous

Indemnification. Please refer to the Terms of Use for the indemnification requirements.

Acceptance of These Terms. By using the FirstPractice Website and agreeing to the Terms of Use and your Contract, you acknowledge and agree to the terms and conditions of this Privacy Policy. If you object to these terms, please immediately stop using this Website.

Children’s Privacy. FirstPractice is committed to protecting the privacy of children and encourages parents and guardians to take an active role in their children’s online activities and interests. FirstPractice is not directed to children or designed to attract them. You must be at least 18 years of age to use our Website and Services. FirstPractice does not knowingly collect, use, or disclose personal information about users that are under 18 years of age. If we later learn that a user is under 18 years of age, we will remove that user’s personal information from our databases and prevent the user from further using the FirstPractice Website and its Services. If you become aware that a user is under 18 years of age, please notify us immediately at helpdesk@FirstPractice.com. If you are a user who is identified in this manner, we may require you to submit suitable proof of age, such as a copy of government-issued identification, in order to continue using the FirstPractice Website.

Your California Privacy Rights. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes. California residents who are registered users of the Services and are under the age of 18 are entitled, in accordance with California law, to request and obtain removal of content and information that they themselves post on the Services.

Changes to the Privacy Policy. FirstPractice reserves the right, at any time, to change, modify, or revise this Privacy Policy and the privacy and security practices discussed herein. We will post any revised version of the Privacy Policy on our Website. We will not reduce your rights under this Privacy Policy without your explicit consent. If we make any significant, material changes to the Privacy Policy, we will prominently note such changes on the Site and may also send notification to the last email address you have provided to us. Continued use of the FirstPractice Website and our Services following such notice of changes constitutes your acknowledgement of them and agreement to be bound by their terms and conditions.

Monitoring and Enforcement. In accordance with applicable laws, you may request access and raise concerns or complaints regarding your personal information processed by us with by contacting us: by email helpdesk@FirstPractice.com; or by mailing FirstPractice at 415 2nd Avenue, Hinton, WV 25951.

If you file a complaint, we will investigate the matter or suspected failure to comply with this privacy policy. It is our practice to respond to you within 45 days of receiving the complaint. We will take all appropriate action to remedy any such issues.

Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us by sending an email to helpdesk@FirstPractice.com.

Effective July 19, 2015

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