To provide you confidence that we adhere to accepted healthcare industry privacy standards and comply
with our own privacy practices, we participate in the following external, independent verification
▪ URAC – We are seeking being awarded e-Health accreditation from URAC, the American HealthCare
Accreditation Association. URAC is an independent accrediting body that reviews and approves websites
for compliance with its more than 50 quality and ethics standards that are based on the high ethics
principles. Hi-Ethics is an organization of health websites committed to a set of ethical principles designed
to ensure that consumers can confidently realize the full benefit of the Internet to improve their health and
the health of their families.
▪ TRUSTe – we will become a licensee of the TRUSTe Privacy Program. TRUSTe is an independent,
nonprofit organization whose goal is to build users' trust and confidence in the Internet by promoting the
use of fair information practices. As required of TRUSTe licensees, we will inform you of the following in
▪ What Personal Identification Information of yours is collected;
▪ What organization is collecting the information;
▪ How the information is used;
▪ With whom the information may be shared;
▪ What choices are available regarding collection, use and distribution of the information;
▪What kind of security procedures are in place to protect the loss, misuse or alteration of information under
our control; and,
▪ How you can correct any inaccuracies in the information.
▪ Health on The Net Foundation – We will comply with the principles of the HON Code of Conduct
established by the Health on the Net Foundation.
Once you enter another website (whether through an advertisement, service, or content link), be aware
that Pain Relief for Pain is not responsible for the privacy practices of such other sites. We encourage you
to look for and review the privacy statements of each and every web website that you visit through a link
or advertisement on Pain Relief for Pain.
While you may use most of our functionality without registration, some of the specific tools and services on
our website require registration. If you use our website without registering, the only information we collect
certain Interactive Tools or other services, we require you to submit Personal Identification Information.
Depending on the tool or service you have selected, we may also collect Personal Health Information BUT
we will inform you before we do so.
You are responsible for ensuring the accuracy of the Personal Identification Information and Personal
Health Information you submit to this web site, if any. Inaccurate information will affect the
information you receive when using our site and tools and our ability to contact you as contemplated in
communicate with you.
NON-PERSONAL INFORMATION WE COLLECT ABOUT YOU
Even if you do not register with forheadachepain.com , we will collect non personal information about your use of
our website, special promotions and newsletters.
We collect Non-Personal Information about your use of our website and your use of the websites of
Cookie by Pain Relief for Pain. The information collected by Cookies…
(i) helps us dynamically generate advertising and content on web pages or in newsletters,
(ii) allows us to statistically monitor how many people are using our website and selected
sponsors' and advertisers' sites,
(iii) how many people open our emails, and
(iv) for what purposes these actions are being taken. We may use Cookie information to target
certain advertisements to your browser or to determine the popularity of certain content or advertisements.
Cookies are also used to facilitate a user's log-in, as navigation aides and as session timers, but not to
retain Personal Health Information about you.
Your browser software can be set to reject all Cookies. Most browsers offer instructions on how to reset
the browser to reject Cookies in the "Help" section of the toolbar. If you reject our Cookies, certain of the
functions and conveniences of our website may not work properly but you do not have to accept our
Cookies in order to productively use our site. We do not link Non-Personal Information from Cookies to
Personal Health Information about you.
We also may use Web Beacons to collect Non-Personal Information about your use of our website and the
websites of selected sponsors and advertisers, and your use of special promotions or newsletters. The
information collected by Web Beacons (i) allows us to statistically monitor how many people are using our
website and selected sponsors' and advertisers' sites, (ii) how many people open our emails, and (iii) for
what purposes these actions are being taken. Our Web Beacons are not used to track your activity outside
of our websites or those of our sponsors'. We do not link Non-Personal Information from Web Beacons to
Personal Identification Information without your permission and do not use Web Beacons to collect or
store Personal Health Information about you, if any.
PERSONAL IDENTIFICATION INFORMATION WE MAY COLLECT ABOUT YOU
We collect Personal Identification Information that you provide to us when you register as a member of
Pain Relief for Pain and/or when you update your member profile. We use the Personal Identification
Information that you provide to respond to your questions, provide you the specific services you select,
send you emails about website maintenance and updates, and inform you of significant changes to this
Newsletters & Emails to You
At registration and at various times as you use Pain Relief for Pain, you will be given the option of receiving
recurring informational/promotional newsletters via email from Pain Relief for Pain and/or directly from
third parties. These emails will be of a general nature and will not disclose your unique health characteristics.
At the time you sign up for our email newsletters or any time thereafter, you can choose to Opt-out of
receiving additional promotional emails from Pain Relief for Pain.
In order to subscribe to such newsletters via email, we need your contact information, such as name and
email address. You can unsubscribe from the newsletters by simply clicking on the "unsubscribe" link at
the bottom of any email newsletter. An email to our automated unsubscribe service will be created on your
computer. Click the "send" button. You will then be unsubscribed from that newsletter within two to three
You may also unsubscribe or change any of your email preferences by clicking on the applicable links in
your email newsletter or by changing your profile within the Pain Relief for Pain site. If you are experiencing
difficulties with our automated unsubscribe service, please use the Contact Us section of our web site. We
will unsubscribe you from our newsletter in two to three business days.
In some cases, when you click on a link or an advertisement in an e-mail or newsletter, your browser may
be momentarily directed to the website of a third party which, acting on behalf of Pain Relief for Pain,
notes or "counts" your response to the e-mail or newsletter before re-directing your browser to its proper
destination; this re-direction process will not be apparent to you.
When you use Pain Relief for Pain "Pain Relief e-Mail to a Friend", Pain Relief for Pain emails the article or
other content you designate to your friend's email address and lists your email address as the sender.
Pain Relief for Pain uses the friend's email address only for the purpose of sending your friend the email
you requested. While we store both email addresses, we do not use them for any other purpose unless
disclosed to you at the time you send the email.
Emails You Send to Pain Relief for Pain
inventions to Pain Relief for Pain by email. If you want to keep content or business information, ideas,
concepts or inventions private or proprietary, do not send them in an email to Pain Relief for Pain. We try
to answer every email within 48 business hours, but are not always able to do so.
Message Boards and other Public Forums
As a service to our users, Pain Relief for Pain features chat rooms and other public forums where users
with similar interests or medical conditions can share information and support one another or where
users can post questions for experts or other non-experts to answer. We also may offer online
discussions moderated by medical or healthcare experts from time to time.
Any information shared (including Personal Identification and Personal Health Information) that you reveal
in a chat room, and/or message board, is by design open to the public and is not a private, secure service.
You should think carefully before disclosing any Personal Identification or Personal Health Information in
any public forum. What you have written may be seen, disclosed to or collected by third parties and may
be used by others in ways we are unable to control or predict, including to contact you for unauthorized
Website Registration and Interactive Tools on Pain Relief for Pain
After you have registered as a member of Pain Relief for Pain, you may choose to use certain of our
interactive content, tools and services that may ask you to voluntarily provide other types of information
about yourself including Personal Health Information. None of the tools we may offer from time to time
(like certain we use on the Pain Relief for Pain will retain your Personal Health Information.
From time to time, Pain Relief for Pain may offer users the opportunity to register for paid subscription
services. Each subscription service has its own Service Agreement that governs your use of the service
and the information we collect to provide the service, including your credit card information. Any Service
Agreement you may be interested in will be disclosed to you at the time of registration for that subscription
We are committed to protecting the privacy of children. None of our services are designed or intended to
attract children under the age of 13. We do not collect Personal Identification Information from any person
we actually know is under the age of 13. The parent or guardian is solely responsible for providing
supervision of the minor's use of Pain Relief for Pain.
The parent or guardian assumes full responsibility for ensuring that any registration information is kept
secure and that the information submitted is accurate. The parent or guardian also assumes full
responsibility for the interpretation and use of any information or suggestions that may appear on the Pain
Relief for Pain web site as applicable to a minor.
From time to time, the Pain Relief for Pain market research department, or its operations contractors acting on its behalf, conducts online research surveys in order to gather feedback about our site, our sponsors and opinions on important healthcare issues, through email invitations, pop-up surveys and online focus groups.
When participating in a survey, we may ask you to submit Personal Identification Information.
This PI Information is used for research purposes, and is not used for sales solicitations. When a survey is
sponsored by a third party, Aggregate Information of the survey results is reported to the sponsor.
Personal Identification Information collected through market research will only be used by Pain Relief for
Pain and its operations contractors and will not be given or sold to a third party without your consent.
While this site is not intended for anyone under the age of 13, for market research surveys we will not
knowingly accept survey responses from or conduct interviews with any person under the age of 18.
Some surveys may provide remuneration to participants such a small cash fee for your time or an entry
into a sweepstakes for a larger prize. Each survey will disclose whether or not there it is a paid survey.
In addition to collecting survey responses from our members, Cookies may be used to authenticate
respondents or to help you pick up where you left off in a survey. If you have Cookies disabled you may
not be able to participate in some studies. Cookies may be used to connect survey data with Pain Relief for
your consent will be requested for these Cookies.
Secure Message Center
Pain Relief for Pain has the ability to use Personal Identification Information that you provide to send you
personalized emails or secure electronic messages. We do not use this ability.
Information Collected by Third Parties Not Acting on Pain Relief for Pain Behalf
Sponsors or advertisers on Pain Relief for Pain may use their own Cookies or Web Beacons in the banner
advertisements served on Pain Relief for Pain and in emails, special promotions or newsletters we send
Some advertisers use companies other than Pain Relief for Pain to serve their ads and to monitor users'
responses to ads, and these companies ("Ad Servers") may also collect Non-Personal Information through
facilitated by momentarily directing your browser to the website of an Ad Server or other third party acting
on behalf of the sponsor, partner, or advertiser before re-directing your browser to its proper destination
(e.g., back to Pain Relief for Pain to show the ad, or to the advertiser's website); this re-direction process
will not be apparent to you.
non-personal information they gather through them. However, we do require sponsors, advertisers and
Ad Servers who collect cookie or web beacon information through our Website to agree that they will not
collect any Personal Information from our site without your consent. They have promised us they will not
link any non-personal cookie or web beacon information collected by them on our site to Personal
Information they or others collect in other ways or from other sites except as may be described in
connection with a particular program.
For example, in connection with "Ad Links" furnished by Google, non-personal information sent by your
browser to Google when you click on an ad link or submit a query may be used by Google as described
will provide additional detail about our relationship with advertisers and the companies that serve ads.
web beacons on their own sites. Certain Ad Servers allow you to prevent them from collecting data
Currently, you can Opt-out of Cookies for several Ad Servers by visiting the Network Advertising Initiative
gateway Opt-out site. This website will also allow you to review the Ad Server's privacy policies.
DISCLOSURE OF YOUR INFORMATION
disclose any Personal Identification or Personal Health Information it gathers from you on our website, if
any. We will only release Personally Identifiable or Personal Health Information to third parties:
(1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court
(2) in special cases, such as a physical threat to you or others.
In the event that we are legally compelled to disclose your Personally Identifiable or Personal Health
Information to a third party, we will attempt to notify you unless doing so would violate the law or court
order. In addition, we may disclose Personal Information as described below.
Disclosure to Pain Relief for Pain Health Op’s and Maintenance Contractors
Our operations and maintenance contractors sometimes have limited access to your Personal
Identification Information in the course of providing products or services to Pain Relief for Pain. These
contractors include vendors and suppliers that provide us with technology, services, and/or content
related to better operation and maintenance of our website.
These contractors also may have access to your email address to send newsletters or special promotions
to you on our behalf or to send emails to you for purposes such as conducting market research on our
behalf. Access to your Personal Identification Information by these contractors is limited to the information
reasonably necessary for the contractor to perform its limited function for Pain Relief for Pain.
We also contractually require that our operations and maintenance contractors…
2) do not disclose your Personal Identification Information to us for any purpose other than providing us with
the information we need to meet your request for information on our products and services and
information we need to process your orders and ship products to you.
Disclosure to Third Party Contractor Websites
Certain content and services offered to you through our website are served on websites hosted and
operated by a company other than Pain Relief for Pain ("Third Party Contractor Websites"). Pain Relief for
Pain does not disclose your Personal Identification Information to any Third Party Contractor Websites
without your consent, but you should be aware that any information you disclose once you access these
Contractor Website collects and uses your Personal Identification Information. Pain Relief for Pain makes
an effort to make it obvious to you when you leave our website and enter a Third Party Contractor Website,
either by requiring you to click on a link or by notifying you on the site before you visit the third party site.
In addition, if you see a phrase such as "Powered by" or "in association with" followed by the name of a
company other than Pain Relief for Pain, then you are on a website hosted by a company other than Pain
Relief for Pain.
Pain Relief for Pain also provides links to sites provided by Third Party Contractor Websites that have
business arrangements with Pain Relief for Pain to pay commissions based on sales of products or
services generated through Pain Relief for Pain.
Disclosure to or by Co-branded Channel Partners
Pain Relief for Pain is a contractor and provides co-branded content and services to websites hosted and
operated by companies other than Pain Relief for Pain Channel Partner Websites. You can only access
these co-branded content and services through the Channel Partner Website, and usually from the health
section of these other websites.
The co-branded Pain Relief for Pain pages that you may access through a Channel Partner Website have
different registration processes and opportunities for information collection, and Personal Identification
Information that you provide on these pages may be shared with the Channel Partners. Pain Relief for Pain
does not share Personal Health Information with Channel Partner Websites without your consent.
which explains what information is disclosed by Pain Relief for Pain to the Channel Partner and vice versa.
Disclosure to Linked Sites
In addition to the Third Party Contractor Websites that you may access as described above, for your
convenience there are links to websites operated by companies other than Pain Relief for Pain ("Third
Party Websites") that are not contractors who provide content or services through our website.
These links may be found in advertisements, referenced within content, or placed beside the names or
logos of sponsors. Pain Relief for Pain does not disclose your Personal Information to these Third Party
Websites without obtaining your consent. Pain Relief for Pain does not endorse and is not responsible for
the privacy practices of these sites.
this other website to understand how that Third Party Website collects and uses your Personal
Disclosure of Aggregate Information
Pain Relief for Pain may provide Aggregate Information to third parties. For example, we might inform third
parties regarding the number of users of our website and the activities they conduct while on our site. We
might also inform a pharmaceutical company (that may or may not be an advertiser on our site) that "10%
of our users are from New York" or that "50% of our users have tried alternative medicine."
Depending on the circumstances, we may or may not charge third parties for this Aggregate Information.
We require parties with whom we share Aggregate Information to agree that they will not attempt to make
this information personally identifiable, such as by combining it with other databases.
HOW WE HANDLE PRIVACY AND SECURITY INTERNALLY
Listed below are some of the security procedures that Pain Relief for Pain uses to protect your privacy:
▪ Requires both a personal username and a password in order for users to access their Personally Identification
Information or Personal Health Information.
▪ Uses firewalls to protect information held in our servers.
▪ Utilizes Secure Socket Layer (SSL) encryption in transmitting Personal Identification Information to our
server host. In order to take advantage of encryption technology, you must have an Internet browser
which supports 128-bit encryption.
▪ Closely monitors the limited number of Pain Relief for Pain employees who have potential access to
your Personal Identification Information.
▪ Back-up our systems to protect the integrity of your Personally Identification and Personal Health
Pain Relief for Pain provides additional protection for your Personal Health Information as follows:
▪ Provides secure messaging tools so that information related to your personal health related
characteristics is sent through a secure, encrypted connection.
▪ Our site maintains physical security through pass code locked door access and pass code authority.
▪ Limit access to Personal Identification Information to authorized users. Pain Relief for Pain enables you to
have full control over who has access to your Personal Health Information.
For example, you may decide to permit your physician or other health care professional access to the
personal health information you maintain within our tools, if any. Only the person who creates a record
can grant access to other users.
Despite Pain Relief for Pain efforts to protect your Personally Identification Information and Personal
Health Information, there is always some risk that an unauthorized third party may find a way around our
security systems or that transmissions of your information over the Internet will be intercepted.
UPDATING YOUR INFORMATION AND CONTACTING PAIN RELIEF FOR PAIN
Updating Your Personal Identification Information
If we collect and store self-reported data about you, we will contact you in order to allow you to correct,
update or review information you have submitted by going back to a specific tool we will provide to assist
you in logging-in and making the desired changes.
Removing your Personal Information
If you have a complaint or problem, please use our Contact Us page on our web site. Our customer service
department will forward your complaint to the appropriate internal Pain Relief for Pain personnel for a
response or resolution. We try to answer every email within 48 business hours, but may not always able to
If you want to…
(1) delete your Personal Identification Information from our systems,
(2) update the Personal Identification Information that you have provided to us, or
(3) change your preferences with respect to marketing contacts or other activities, you can email us at
If you do not receive adequate resolution of a privacy related problem, you may write to our Help Desk
Internet ReSeller Corp.
dba Pain Relief Inc.
420 W. 42nd St., 17H
New York, NY 10036
Limitations on Removing or Changing Information
Upon your request, we will delete your Personal Identification Information from our active databases and
where feasible from our back-up media. You should be aware that it is not technologically possible to
remove each and every record of the information you have provided to Pain Relief for Pain from our host
If you have contacted Pain Relief for Pain about a privacy related concern and you do not believe that the
problem has been addressed, you may file a complaint with TRUSTe.
that would involve the use of your Personal Identification Information.
Your continued use of the Pain Relief for Pain Web site will indicate acceptance of the changes. You may of
course choose to Opt-out of continuing to use the Pain Relief for Pain Web site. Please exit the site
Pain Relief for Pain reserves the right to discontinue or limit functionality in all its products on this web site
or any subsidiary web site it may launch from time to time.
that do not affect Personal Identification Information. For these instances, Pain Relief for Pain may not
notify the user of such non-significant changes.
Aggregate Information or Data: As a website gathers individual pieces of Non-Personal Information
(see definition below) from its users, it may combine similar data from many or all the users of the website
into one big "batch". For example, the site may add up the total number of people in New York City, NY,
(but not their names) who are seeking information about weight loss and compare that to the number of
people in Dallas, Texas seeking the same information.
This sort of statistical information is called aggregate data because it reflects the habits and characteristics
of a large group of anonymous people. Websites may use aggregate data or share it with their business
partners so that the information and services they provide best meet the needs of the users. Aggregate
data also helps advertisers and sponsors on the Web know how effectively they are reaching and meeting
the needs of their target audience.
Browser: Short for web browser, a browser is software application used to locate and display web (Internet)
pages. The three most popular browsers are AOL, Microsoft Internet Explorer, and Netscape Navigator. In
addition, most modern browsers can present multimedia information, including sound and video, though
they require plug-ins for some formats.
Cache (also called cache memory): Once your web browser accesses a web page, it references that page
and the graphics on it within your computer's "cache" (or more simply, your computer takes a "snapshot"
of every page you visit and stores it in the "cache".) The next time you visit that same page, your download
time will be quicker as the images and much of the page is already available on your computer for your
browser to reference instantly instead of waiting for the page and images to download again. We do not
Channel Partner Website: A third party website to whom Pain Relief for Pain provides content and services
for that website's health channel.
Click Stream Information: A record of all the pages you have visited during your visit to a particular website
or the services you accessed from the site or from an email. Click Stream Information is associated with
your browser and not with you personally. It records the archives of your browser.
Cookie: A small data file that is stored on the hard drive of the computer you use to view a website.
Cookies are placed by that site or by a third party with a presence on the site, such as an advertiser using
a Web Beacon (see definition below) and are accessible only by the party or site that placed the Cookie
(i.e. a Cookie placed on your computer by Pain Relief for Pain isn't accessed by any other site you visit but
a Cookie placed on your computer by an advertiser may be accessed by any site on which that same
advertiser has a presence). Cookies can contain pieces of Personal Identification Information (PII).
Pain Relief for Pain encrypts any PII it stores in its Cookies. These Cookies often are used to make the site
easier to use. For example, if you check a box to ask that we store your user name on your computer so
that you don't have to enter it each time you visit the site, it's stored in a Cookie on your computer.
Encryption: The translation of data into a secret code. Encryption is the most effective way to achieve data
security. To read an encrypted file, you must have access to a secret key or password that enables you to
decrypt it. This is typically done by secure computer systems.
Firewall: A system designed to prevent unauthorized access to or from a public or private network.
Firewalls can be implemented in both hardware and software, or a combination of both. Firewalls are
frequently used to prevent unauthorized Internet users from accessing private portions of public
networks. All messages entering or leaving the network pass through the firewall, which examines each
message and blocks those that do not meet the specified security criteria.
Non-Personal Information: Information that is not traceable back to any individual and cannot be used to
identify an individual. For example, Click Stream Information is Non-Personal Information, as is information
such as gender, age, city and state when not linked with other Personal Identification Information.
Opt-In: Means you are actively indicating your preference to participate in a program, email, feature, tool,
or enhancement on a website.
Opt-Out: Means that if you do not take some action you are indicating your preference to participate in a
program, email, feature, tool or enhancement on a website.
Password: A secret series of characters, typically alphanumeric (meaning it consists of both letters and
numbers) that enables a user to access a file, computer, or program. The user must enter his or her
password before the computer or system will respond to commands. The password helps ensure that
unauthorized users do not access the system. In addition, data files and programs may require a
password. Ideally, the password should be something that nobody could guess. In practice, many people
choose a password that is easy to remember, such as their name or their initials. This is one reason it is
relatively easy to break into many computer systems.
Personal Health Information (PHI): When your Personal Identification Information (PII) is combined with
known health characteristics. For example, if you indicated that you have a certain disease or condition,
when that information is combined with your PII, it becomes Personal Health Information.
Personal Identification Information (PII) (also called Personal Information): Information that can be traced
back to an individual (contrast with Non-Personal Information and Aggregate Information). Examples of PII
include your name, home address, telephone number, email address, and Social Security number.
If other pieces of information are linked to PII, they also become PII. For example, if you use a nickname to
chat online and give out your real name while chatting, your nickname becomes PII when linked with other
Server: A computer that provides services to other computers. A "web server" stores web site files and
"serves" them to people who request them.
SSL (Secure Sockets Layer): A security protocol developed by Netscape for transmitting private
information via the Internet. SSL works by using a private key to encrypt data that's transferred over the
SSL connection. Both Microsoft Internet Explorer (http://www.webopedia.com/TERM/S/Internet_Explorer.htm)
and Netscape Navigator (http://www.webopedia.com/TERM/S/Navigator.htm) support SSL, and many Web
sites use the protocol to obtain confidential user information, such as credit card numbers. By convention,
URLs that utilize an SSL connection start with https: instead of http.
Username: A name used to gain access to a computer system or program. Usernames, and often passwords,
are required in shared systems, such as the Internet. In most such systems, users can choose their own
usernames and passwords. Usernames are also required to access some bulletin board and online
Virus: A program or piece of code that is loaded onto your computer without your knowledge and runs
against your wishes. Viruses can also "replicate" themselves by copying their code to other computers.
Web Beacons: (also often referenced as "clear GIFs", "web bugs", "1-by-1 GIFs", "Single-Pixal GIFs",
"1 x 1 Pixals", or "clear Pixals"): Tiny graphic image files, imbedded in a web page in GIF, jpeg or HTML
format, that provide a presence on the web page and send back to its home server (which can belong to
the host site, a network advertiser or some other third party) information from the Users' browser, such as
the IP address, the URL of the page on which the beacon is located, the type browser that is accessing the
site and the ID number of any Cookies on the Users' computer previously placed by that server.
Web Beacons can also be used to place a Cookie on the Users' browser.
Effective: October 5, 2004
© Copyright 2004. Internet Reseller Corp. All rights reserved.