Last Updated: June, 2022
Collection and Use of Personal Information
When you use or register with the Website, we may, with your consent, collect certain “Personal Information,” which is information that identifies you as an individual or relates to an identifiable individual, including information considered “personal data” under the European Union’s General Data Protection Regulation (“GDPR”), in order to carry out our business purposes of providing our recruiting, employment, and consulting services. Personal Information includes: your name and contact information (email, address and phone number), your gender, any pseudonymous data, your job search criteria and preferences, your employment experience, educational history, your skills, reference information, background information, other information contained in your resume, or any login ID or email address and password created by you. The majority of this Personal Information is provided by you directly when you contact us, submit an employment application, through phone conversations or e-mail exchanges, contact with us about our services, or during your employment relationship. We also collect data about individuals who are employed or engaged by our customers in connection with our provision of consulting services to those customers. We do not collect Personal Information from third-party sources.
We use Personal Information to register you with the Website, to provide you with information regarding employment opportunities and career-related information, and to otherwise provide you with requested information or services. We may from time to time use your Personal Information to send you automated email messages, or marketing materials regarding our services, including employment information. We may also use Personal Information for our business purposes, such as data analysis, audits, and improving our services.
Disclosures of Personal Information
SolomonEdwards may disclose Personal Information to third parties in the following circumstances: (1) to our third-party service providers who perform business functions and services on our behalf; (2) to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of SolomonEdwards or its affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of the users or the public. We also may disclose or transfer information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Collection and Use of Other Information
We may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Website functions properly.
- IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Website, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Website. We may also derive your approximate location from your IP Address.
We do not collect Other Information from third-party sources, other than through Google Analytics and Net-Results. Please note that we may use and disclose Other Information for our business purposes.
Storage of Personal Information
We will retain your information for as long as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Third Party Services
This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links.
We use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Withdrawal of your Consent
If your Personal Information changes, if you no longer desire our service, or if you want to limit the use or disclosure of your Personal Information beyond what is set forth in this Policy, then you may correct, update, amend, delete/remove, request portability of or use or disclosure restrictions on or withdraw your consent to our collection and/or use of your Personal Information (including for direct marketing purposes) by emailing us or by contacting us by postal mail at the contact information listed below. We will respond to your request within 30 days, but we may not be required to honor your request in all cases. Please note that if you withdraw your consent to our collection and/or use of your Personal Information, then certain portions of our Website may be inaccessible to you and/or you may not be able to receive our recruiting, employment, and/or consulting services.
Our Website includes links to our brochures, white papers, case studies, and other marketing materials. If you wish to download certain materials or sign-up for events/webinars, we will use your name and email address to send such materials to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in such emails or by contacting us at the email address provided below. When your interactions with us have resulted in your registration for multiple services or resources it may be necessary to opt out from each service separately.
Because processing your information is necessary to the performance of the recruiting, employment, and consulting services that we provide to you, a request to exercise certain rights may result in us being unable to continue providing one or more of our services to you. Subject to applicable law, we also may limit requests or charge reasonable fees.
Use of Site by Minors
The Website is not directed to individuals under the age of eighteen (18) and, we do not knowingly collect Personal Information from individuals under 18.
The Website is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Where required, SolomonEdwards implements Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties. You can request a copy of the EU Standard Contractual Clauses by emailing us at email@example.com.
Revisions to the Policy
If we change this Policy we will post any updates here for your review. The “Last Updated” line at the top of this page indicates when this Policy was last revised. Any changes will become effective when we post the revised Policy on the Website and it is provided to you.
If you have any questions about this Policy, or if you would like to update any personal information you have provided to us, please contact us at:
Attention: Lito Abiva
1255 Drummers Lane, Suite 200
Wayne, PA 19087
Email Address: firstname.lastname@example.org
Local Data Protection Authority
You may, depending on where you are located, have the right to make a complaint with your local data protection authority based on issues you may have with this Policy. You can find the contact information for your local data protection authority at the following website: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Consolidated Appropriations Act (CAA) and Transparency in Coverage Rule (TCR)
The Consolidated Appropriations Act, 2021 (CAA) was signed into law in December 2020. Among other provisions, the CAA includes many provisions that affect how health insurers and group health plans health care coverage. Since the CAA was enacted, the federal government issued guidance about the CAA. Recently, the federal government issued guidance that it is delaying enforcement of certain provisions of the CAA and will take a good faith compliance approach to other provisions. The CAA includes the following provisions: Surprise Medical Billing Patient Protections, Advanced Explanation of Benefits, Price Comparison Tool, Continuity of Care, Enhanced Provider Data Requirements, Changes to ID Cards, Broker and Consultant Compensation Disclosure, Pharmacy Benefit and Drug Cost, Air Ambulance Reporting, External Review/Complaint Process, Remove Gag Clauses on Price and Quality Information, Mental Health and Substance Abuse Parity.
On November 12, 2020, the Departments of Labor (DOL), Health and Human Services (HHS), and Treasury (collectively, the Departments) published the “Transparency in Coverage” final rule (Final Rule), imposing new requirements on group health plans and health insurers in the individual and group markets to disclose cost-sharing information, in-network provider negotiated rates, historical out-of-network allowed amounts, and drug pricing information. It also applies to Qualified Health Plan (QHP) issuers and the Federal Employees Health Benefits Program. The Rule follows the Hospital Price Transparency final rule, which required hospitals to make public a variety of pricing information and went into effect on January 1, 2021.
The Rule’s core requirements are to:
- Disclose to the public: 1) in-network provider negotiated rates, 2) historical out-of-network allowed amounts, and 3) drug pricing information, which has been postponed, pending further rulemaking, through three separate machine-readable files posted on an internet website
- Disclose cost-sharing information upon request to a participant, beneficiary, or enrollee – including an estimate of the individual’s cost-sharing liability for covered items or services via an online tool, and in paper if requested; and
The Rule adopts a three-year, phased-in approach for compliance with the Rule, which requires Plans and Issuers to provide:
- Public access to in-network provider negotiated rates and historical out-of-network allowed amounts for plan years that begin on or after July 1, 2022;
- Cost-sharing information to participants, beneficiaries, or enrollees for all covered items and services for plan years that begin on or after January 1, 2024; and
- Pending further rulemaking, public access to drug pricing information.
The Rule also allows health insurance issuers to receive credit in their Medical Loss Ratio calculations for programs that create shared-savings for members resulting from their shopping for, and receiving care from lower-cost, higher-value providers.