Privacy Policy

Privacy Policy

LAST UPDATED: JUNE 16, 2020

Evidence for Healthcare Improvement d/b/a the Institute for Clinical and Economic Review (“ICER”, “we”, “us” or “our”) is committed to protecting and preserving your privacy. This policy, together with our Terms of Use and Conditions located at https://analytics.icer.org/, https://icer-review.org/; and https://icer.org/, sets out the basis on which any Personal Information and Anonymous Information (each as defined below) we collect from you, or that you (“you” and “your”) provide to us, will be processed, stored, shared, and used by us. By accessing or using our website(s) available at https://analytics.icer.org/, https://icer-review.org/; and https://icer.org/ (each, a “Site” and collectively, the “Sites”), you are accepting the practices described in this Privacy Policy (“Privacy Policy”).

By using this Site, you consent to the use of information that you provide to us in accordance with this Privacy Policy. We may update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we may notify you by posting a notice on our Site. Your continued use of or access to the Site will be deemed your agreement that your information may be used in accordance with the new policy. BY ACCESSING OR USING THE SITE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY; IF YOU DO NOT AGREE, DO NOT ACCESS OR OTHERWISE USE THE SITE.

We have structured our Site so that you can visit it without identifying yourself or revealing any Personal Information, however some functions available on the Site may require you to disclose certain Personal Information. If you choose to provide us with Personal Information, it will be used in accordance with this Privacy Policy.

Terms of Service
Please read this Privacy Policy carefully to fully understand how we collect, share and protect information about you. This Policy is incorporated into and is a part of the Terms of Use and Conditions of this Site (the “Terms”). To access the Terms click here.

In order to deliver personalized and relevant information to you through our Site, we may collect certain information from users. Please do not provide any sensitive information. If you should do so inadvertently, we may use and disclose that information in the same manner as any other information you provide to us.

Linked Sites and Service Providers

This Privacy Policy does not address, and ICER is not responsible for, the privacy, information, or other data collection, storage, and use practices of any third party operating any site or property to which the Sites link (each, a “Linked Site”) or third parties who may provide certain services in connection with your access and use of, and ICER’s ability to provide certain products and services to you through, the Site as further detailed herein, including, without limitation, Facebook, Inc., Apple Inc., Google Inc., Microsoft Corp., Research In Motion, any wireless carriers and any third party (each, a “Service Provider”). ICER recommends you review the privacy policies of each Linked Site or Service Provider prior to accessing or using the Linked Sites or Site. The inclusion of a link to a Linked Site does not imply ICER’s endorsement of, or affiliation with, the Linked Site. TO THE FULLEST EXTENT PERMITTED BY LAW, YOU HEREBY RELEASE ICER AND EACH OF THE OTHER ICER PARTIES 9AS DEFINED BELOW) FROM ANY CLAIMS OR DAMAGES OF ANY KIND OR NATURE, KNOWN OR UNKNOWN, SUSPECTED OR UNSUSPECTED, DISCLOSED OR UNDISCLOSED, RELATING TO THE DATA COLLECTION, STORAGE, USE, AND SHARING OF YOUR OR ANY THIRD PARTY’S PERSONAL INFORMATION OR ANONYMOUS INFORMATION BY ANY SERVICE PROVIDER. YOU AGREE, UNDERSTAND AND INTEND THAT THIS ASSUMPTION OF RISK AND RELEASE IS BINDING UPON YOU AND YOUR HEIRS, EXECUTORS, AGENTS, ADMINISTRATORS AND ASSIGNS IN PERPETUITY.

Information We Collect

In operating our Site, we may collect and process Personal Information and Anonymous Information such as the following data about you:

  • Details of your visits to our Site and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, the date and time you accessed or left the Site and which pages you viewed. Some parts of our Site use cookies and other technologies to collect this information about your general internet usage. See section below, titled ‘Information We Collect Automatically,” to learn more.
  • Information that you provide directly to us. See section below titled “Information We Collect Directly From You”.

“Personal Information” is information that can be used to identify you (whether alone or in combination), such as your first and last name, email address, zip code/post code, billing address, shipping address, phone number, payment card information, age, and any other information you choose to provide.

“Anonymous Information” is aggregated or pseudonimized information which cannot be used to identify you, such as information about ICER’s users that it renders in such a way that it no longer identifies or references an individual user.

Information We Collect Directly From You. When you access our Site and Services you may provide us Personal Information directly as follows:

  • To Create an Account: When you sign up for an ICER account, you may be requested to provide your name, email address, employer or organization affiliation, phone number, address, business sector information, and if a payor, the number of covered lives.
  • To use the Evidence Compendium application in ICER Analytics: When you enter data into the Evidence Compendium program for comparison, including, without limitation, net price (“EC Data”), EC Data is stored so such EC Data is available for your next sessions. EC Data is not accessed by any third party, but may be used by ICER solely for the purposes of providing the Services by and through the Sites.  When you subscribe to ICER Analytics, you have the right to opt out of the aforementioned EC Data storage function, in which case the EC Data entered is not stored or saved.
  • To Sign Up for Our Newsletter: When you sign up for our newsletter, you may be asked to provide your name, email address, and other contact information.
  • To Contact Us: When you contact us through our Sites or otherwise, you may be requested to provide your full name, email address, and any account information.

Information We Collect Automatically.  We and our Service Providers may collect certain Personal Information automatically as the result of your use of the Site and other web analytics services. This information generally includes:

  • Usage Data: When you use the Site, we and our Service Providers may track and collect usage data and information about your interactions with the Site such as the pages that you visit, the links you click, and the date and time your device accesses the Site or our servers.
  • Cookies, Web Beacons, and Log Data: Like most companies, when you visit or interact with the Site, we and our Service Providers may use cookies and other tracking technologies for storing information, including pixels, web beacons, “clear GIFs,” local storage, and device identifiers to help provide, protect and improve the Site.
    • An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing the Site by your Internet Service Provider (ISP), and is identified and logged automatically in our server log files whenever you visit the Site, along with the time of the visit and the activity on the Site, browser type and operating system, device information, device event information, and the page you’ve viewed or engaged with before or after using the Site. We and our Service Providers use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, administering the Site and determining your approximate geographic location.
    • “Cookies” are small pieces of information that a website attaches to your browser when you visit a website. We may use both “session” Cookies (which expire once you close your web browser) and “persistent” Cookies (which stay on your computer until deleted) to provide you with a more personal and interactive experience with the Site. When you visit a website, that website’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it. We do not store Personal Information in any cookies on your computer. Persistent cookies can be removed by following your Internet browser’s directions within the help tab. However, in order to use certain aspects of the Site, your web browser must accept cookies, and therefore some aspects of the Site may not work properly if you choose to disable cookies.
    • We may also use cookies, pixels, “Web Beacons” (which are usually small, transparent graphic images) and navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of your visit, the features and information for which you searched and viewed, or the e-mail you opened. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your interests and needs.
  • Geographic Location Information: If you use any location-enabled products or services, you may be sending us location information (e.g. IP address). When you use a location-enabled service, we may collect and process information about your precise geographical location, such as GPS signals sent by a mobile device. We and our Service Providers and partners may use your device’s physical location to provide you with personalized location-based services, content and advertisements. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, we may not be able to provide you with the applicable personalized services and content.
  • Device Information: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Windows or Macintosh), screen resolution, operating system version, Internet browser type and version and the type and version of the Site that you are using. We and our Service Providers may also collect a unique device identifier assigned by us or our Service Providers to the device from which you are accessing the Site and other transactional information for the device that we and our Service Providers may use to serve content and advertisements to the device.
  • Software Development Kits (“SDK(s)”): We may use third parties including our business partners and Service Providers who use mobile SDKs to collect information and information related to how mobile devices interact with the Site. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented. A mobile SDK is in effect the mobile app version of a pixel tag or beacon. We may use this technology, for instance, to analyze how you interact with content and advertisements and to enable analytics or other features through mobile devices.
  • Aggregated Information: We may aggregate Personal Information so that the end-product does not personally identify you or any other user of the Site, for example, by using Personal Information to calculate the percentage of our users who like a particular product or service.

Information from Third Parties.  We engage third parties, such as Google Analytics, to provide analytics about the use of our Site.  These third-party ad networks and exchange providers may use third-party cookies, pixels, or similar technologies to collect information, including your device identifier, IP address, or identifier for advertising. The information these third parties collect may be used to help us in providing you with more relevant advertising that we serve on or off the Site, and as described above. We use Google Analytics, an analytics tool provided by Google, Inc., to collect and process data about your use of the Site including when you visit the Website, URLs of the websites that you visit prior to visiting the Site and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Google sets and reads cookies to collect this data and your web browser will automatically send data collected by those cookies to Google. Google uses this data to provide us with reports that we will use to improve the Site’s structure and content. For more information on how Google uses this data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ sites or apps. Furthermore, third-party cookies are covered by the third parties’ privacy policy. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit the Network Advertising Initiative at www.networkadvertising.org or the Digital Advertising Alliance at www.aboutads.info.

Use and Sharing of Your Information

We may collect such information for uses that include, but may not be limited to:

  • enabling us to provide our services to you in the best possible manner, including to help us operate, evaluate, develop, analyze, manage and improve our products, Sites and Services;
  • auditing related to a current interaction with you and concurrent transactions; certain short-term, transient uses;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, or prosecuting those responsible for that activity;
  • debugging to identify and repair errors that impair existing intended functionality; undertaking internal research for technological development and demonstration;
  • undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by us;
  • to provide you with information relating to our organization, or to monitor and conduct an analysis of our Site traffic and usage patterns;
  • to communicate with you via a newsletter or in connection with any service or information requests submitted by you;
  • administering and improving our Site, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • As ICER believes to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (iv) to enforce the Terms and Privacy Policy; (v) to protect ICER’s operations; (vi) to protect ICER’s rights, privacy, safety or property, or that of you or others; or (vii) to allow ICER to pursue available remedies or limit the damages that ICER may sustain.

We also may de-identify and/or aggregate information to create aggregate or de-identified data sets and reports in order to assess, improve, and develop ICER’s business, products, and services; prepare benchmarking reports; and for other research and analytics purposes.

ICER will not sell, share, or rent your Personal Information to others in ways different from what is disclosed in this statement, or otherwise without your consent.  Notwithstanding, ICER may disclose your Personal Information or Anonymous Information to third parties as follows:

  • To its Service Providers to (i) provide the services necessary for them to perform tasks on ICER’s behalf, including, without limitation, hosting, data analysis, process transactions, email delivery, and other similar tasks; or (ii) provide advertising, campaign measurement, online and mobile analytics, and related services. These Service Providers access and use of such Personal Information and Anonymous Information to allow ICER better reach individuals with relevant ads and measure ICER’s ad campaigns, or to better understand how individuals interact with ICER’s Sites and online services over time and across devices;
  • To courts, law enforcement agencies, and governmental authorities (i) to comply with applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (iv) to enforce the Terms; (v) to protect ICER’s operations; (vi) to protect ICER’s rights, privacy, safety or property, or that of you or others; or (vii) to allow ICER to pursue available remedies or limit the damages that ICER may sustain; and
  • As part of a sale, merger or change in control of ICER, or in preparation for any of these events. Any other entity that buys ICER or part of its business will have the right to continue to use your data as set out in this Privacy Policy unless you agree otherwise.

Notwithstanding the foregoing, ICER may share or sell aggregated or Anonymous Information to third parties in accordance with applicable law. However, ICER never sells the net pricing EC Data you enter into the Evidence Compendium program of ICER Analytics. Such pricing information is proprietary and sensitive, and ICER will not share such information with any third party. ICER may retain such information solely for the purposes of providing its services by and through the Sites, unless you opt-out of the storage and saving function of EC Data when you subscribe to ICER Analytics as otherwise outlined herein.

Security
To ensure that your information is secure, we have put in place commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect on our Site.

Nonetheless, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically on our Site, and transmission of such data is therefore entirely at your own risk.

Your choices regarding our use and disclosure of your Personal Information. In some jurisdictions, including the EEA, you may exercise certain rights to access, request copies of, change or correct, request our deletion or transfer, object to or reject certain processing of your Personal Information. You may, of course, decline to share certain Personal Information with us. In such circumstances we may not be able to provide to you some or all of the features and functionality found on the Site.

California Privacy Rights. Beginning January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with certain rights and choices regarding our use and disclosure of your Personal Information, as described below:

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the Personal Information we have collected, used, disclosed and sold (if any) about you during the past 12 months. 
  • Deletion: You have the right to request that we delete certain Personal Information we have collected from you, subject to certain exceptions provided under CCPA, such as where the information is necessary for us to complete your transaction or perform a contract between you and us.
  • Opt-Out of Sale: You have the right to opt-out of the ‘sale’ of your Personal Information.

For more details about the Personal Information we may have collected about you over the last 12 months, including categories of sources of Personal Information, please see the “Information We Collect” section above. We collect and use your Personal Information for the reasons described in the “Use and Sharing of Your Information” section above, including for those business purposes specified in the CCPA. We may disclose the categories of Personal Information outlined in the “Information We Collect” section to third parties as described in “Use and Sharing of Your Information” above. 

European Economic Area Notice: If you are accessing and using our Site and Services and are located in the European Economic Area (“EEA”), the following additional information (the “EEA Notice”) applies with respect to your Personal Information.  If you have questions about how we handle your Personal Information or would like to exercise any of your rights described in this EEA Notice, please reach out to us in writing by contacting us at: info@icer-review.org or Institute for Clinical and Economic Review, Two Liberty Square, Ninth Floor, Boston, MA 02109 with the subject line: EEA Data Rights. Each clause of this Privacy Policy shall apply to you to the maximum extent permitted under applicable law.

If you are located in the EEA, the following rights apply to you:subject to applicable law, you have the right to request access to and rectification of the Personal Information ICER maintains about you, to request the restriction of the processing of your Personal Information or to object to that processing on grounds relating to your situation. As described under ” Opting Out ” below, you have a right to unsubscribe from any marketing communications we may send to you.  In addition, you may have the right to request erasure of your Personal Information from ICER’s systems in certain circumstances provided by applicable law.  Subject to applicable law, where technically feasible and following your written request and verifiable identification, we will provide you with a copy of your EEA Personal Information in a structured, commonly used, machine readable format. 

How you can access, change or suppress your Personal Information or opt-out of other services. Subject to any limitations noted in this Privacy Policy, if you would like to review, correct, update, suppress, delete or otherwise limit our use or sale of your Personal Information that you have previously provided to us, you may contact us by mailing us at: Institute for Clinical and Economic Review, Two Liberty Square, Ninth Floor, Boston, MA 02109, and include your name, address, and e-mail address, or emailing us at info@icer-review.org with “Legal” in the subject line. In your request, please make clear what Personal Information you would like to have changed and what limitations (if any) you would like to place on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records which will not be removed. We are not responsible for changing, removing or suppressing information from the databases of unaffiliated third parties, including any of our service providers, with which we have already shared your Personal Information.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. In addition, if you exercise your right to request specific pieces of your Personal Information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

Opting Out. We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. Please note that, if you opt-out, we may not be able to remove your Personal Information from the databases of unaffiliated third parties with which we have already shared your Personal Information as of the date that we process your opt-out request. Please also note that, if you do opt-out from receiving marketing-related messages from us, we may still send administrative messages to you, such as related to pending orders, returns, or refunds.

Opting Out of EC Data Storage: When subscribing to ICER Analytics, you will be presented with the option to opt in or opt out of the saving and storage of EC Data.

Opt Out of Google Analytics. To opt out of Google Analytics, you may install the Google Analytics Opt-Out Browser found at https://tools.google.com/dlpage/gaoptout. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page found at https://adssettings.google.com/authenticated.

“Do Not Track” Signals.  Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to sites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To learn more about cookies and any “Do Not Track” features, please visit http://www.allaboutcookies.org/ and http://www.allaboutdnt.com. If you choose to decline cookies, then some or all of the features, functionality and promotions available through the Site that may not be available to you. If you do not want information collected through the use of cookies, there is a procedure on most devices through which the Site are accessed that allows you to decline the use of cookies.

Adobe Flash LSOs. If your device stores Flash LSOs, and if you do not want Flash LSOs stored on your device through which you access the Site, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your device without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Site or our content. We expect our service providers and technology suppliers to honor any decision by you to restrict or limit Flash LSOs, but we cannot guarantee that they will do so.

Mobile Device Settings. On your mobile device, enable the “Limit Ad Tracking” setting in your iOS phone’s settings, or the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To opt-out of location tracking when using our Site, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well.

For more information about analytics and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page found at http://optout.networkadvertising.org/?c=1 , the Digital Advertising Alliance’s opt-out page found at http://optout.aboutads.info/?c=2&lang=EN, or EDAA’s Your Online Choices page found at http://www.youronlinechoices.com/.

Users Only of Legal Age of Majority
Our Site is designed and intended for those who have reached the age of majority (18 years of age). By using our Site, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age.

No one under age 13 is authorized to submit any information, including personally identifying information, on our Site. Under no circumstances may anyone under age 13 use our Site. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.

Contacting Us
We welcome any queries, comments, requests or complaints you may have regarding this Privacy Policy. Please do not hesitate to contact us at:

Institute for Clinical and Economic Review
Two Liberty Square, Ninth Floor
Boston, MA 02109
(617) 528-4013
info@icer-review.org