Privacy Notice

Effective Date: January 1, 2019

PURPOSE AND SCOPE

This Privacy Policy explains Premier’s online information practices and the choices you can make about the collection and use of information you submit or we collect:

• online, through our websites, mobile applications, social media pages,
• offline, in connection with sales, marketing, partner and supplier engagement,
• from third party sources, including ad networks and lead brokers, and
• Premier’s other online services and tools that link to this Privacy Policy (collectively the “Services”).

This Privacy Policy applies to Premier Inc. and its wholly and majority-owned entities. “Premier”, “we”, “us” and “our” are references to the entity responsible for the processing of your personal information, which generally is the entity that obtains your personal information.

This Privacy Policy describes the types of personal information we obtain through the Services, how we may use that personal information, which whom we may share it, and how you may exercise your rights regarding our processing of the information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

THIS PRIVACY POLICY DOES NOT APPLY TO YOUR PROTECTED HEALTH INFORMATION. “Protected Health Information” is information that is protected by the U.S. Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). We may receive your Protected Health Information when we, for example, perform services on behalf of your health care providers. Protected Health Information is not handled in accordance with this Privacy Policy. Rather, Protected Health Information is treated in accordance with our Notices of Privacy Practices. If you have any questions about the uses and disclosures of your Protected Health Information, please review the Notice of Privacy Practices or contact us at PremierPrivacy@PremierInc.com.

PERSONAL INFORMATION WE OBTAIN

We may obtain personal information through the Services. The types of personal information we may obtain include:

• contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g. principals in your business);
• information used to create your online account (such as username, password and security questions and answer);
• biographical and demographic information ( such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
• purchase and customer service history;
• financial information (such as payment information, including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income and credit score);
• location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
• contact information you provide about friends or other people you would like us to contact;
• clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Site and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies; and
• other personal information contained in content you submit to us.

In addition, we may obtain government-issued ID numbers and Tax ID numbers, such as US Social Security numbers.

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and Services, and you may not be able to access certain features of the Services.

HOW WE USE PERSONAL INFORMATION

We may use the personal information we obtain to:

• provide and administer our Services;
• process and fulfill orders and keep you informed about the status of your order;
• communicate about and administer our Services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
• conduct and facilitate surveys, contests, focus groups and market research initiatives;
• perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
• engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
• provide customer support;
• process, evaluate and respond to requests, inquiries and applications;
• create, administer and communicate with you about your account (including any purchases and payments);
• conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
• operate, evaluate and improve our Services (such as by administering, enhancing and improving our tools/resources and Services; developing new Services);
• performing accounting, auditing, payment processing, billing, reconciliation;
• detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches;
• maintain and enhance the safety and security of our Services, network information systems, information resources and employees; and
• for other purposes for which we have obtained your consent.

We may combine personal information we obtain through Services with other information for the purposes described above. We may aggregate or anonymize personal information and use it for the purposes described above and for other purposes to the extent permitted by laws applicable to us.

HOW WE DISCLOSE PERSONAL INFORMATION

Personal Information collected through the Services may be shared for and with the following purposes:

• We may share with our affiliates and subsidiaries to provide joint content and Services; to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and, to guide decisions about our products, sites, applications, services, tools, and communications.
• We may share your personal information to service providers under contract to perform services on our behalf (such as, but not limited to, fraud investigations, fulfilling orders, delivering packages, removing repetitive information from customer lists, software development, providing customer support, email delivery, marketing communications, bill collection, payment processing, site analytics and business operations).
• We may also disclose your personal information as required by law, such as to comply with a subpoena, law or other legal process, when we believe in good faith that disclosure is necessary to comply with such legal process, to establish, exercise or defend our legal rights, to protect your safety or the safety of others, to investigate fraud, or respond to a government request, or otherwise with your consent.
• If we are involved in a merger, acquisition, joint venture, financing, reorganization, divestiture, dissolution, liquidation or sale of business or assets we may share personal information collected from and about users to one or more third parties involved in such transaction. In such case, we will require the relevant third parties to provide comparable levels of protection that Premier provides with respect to the information we share.

HOW WE PROTECT PERSONAL INFORMATION

We maintain reasonable administrative, technical and physical safeguards to protect against unauthorized access, disclosure, alteration or destruction of the personal information we collect through the Services. However, you should keep in mind that no Internet transmission is ever completely secure or error-free. While we endeavor to safeguard your personal information please take steps to prevent unauthorized access to your account and personal information. You can do this by, for example selecting and protecting your password appropriately, limiting access to your device and browser and signing out of your account at the end of your session.

RETENTION OF PERSONAL INFORMATION

To the extent permitted by applicable law, we retain the personal information we collect about and from you for as long as necessary to fulfill a business purpose or comply with a legal request. We may also choose to anonymize the personal information you provide to us if we would like to retain it for longer periods of time.

YOUR RIGHTS AND CHOICES

We offer the ability for you to update your personal information preferences, limit the communications you receive from us or submit a request by contacting the Privacy Team at PremierPrivacy@PremierInc.com.

If you ever decide to terminate your use of the Services and wish to delete your account, you may do so by contacting the Privacy Team at the email address above.

We may send various marketing promotions, offers, invitations and other communications to you about our Services, special offers and promotions or invitations to our events. If at any time you no longer wish to receive such special offers or promotions, you can unsubscribe at the following link: https://www.premierinc.com/email-preference-center.

We may use vendors to serve advertisements on our behalf across the Internet. You may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising for products and services available from us. To learn how to opt out of ad network interest-based advertising in the United States, please visit the Network Advertising Initiative (“NAI”) at http://optout.networkadvertising.org/#!/.

In certain circumstances, you may: (1) access certain personal information we maintain about you; (2) request that we update, correct, amend, erase or restrict how we use your personal information; or (3) ask for a copy of your personal information to be sent to a third party. You may also withdraw consent you previously provided to us or object at any time to the processing of your personal information for a particular purpose. We will take reasonable steps, where appropriate under the laws applicable to us, to honor your requests and apply your preferences on a go-forward basis.

COOKIES

Premier uses cookies (and other data collection technologies, such as web beacons and pixel tags) to provide all of the features and functions of the Services to you. By using the Services, you consent to the use of cookies. Our Cookies Policy, as outlined here, explains what cookies are, how we use cookies, how third parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are Cookies?

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.

How Premier Uses Cookies

When you use and access the Service, we may place a number of cookies files in your web browser. We use cookies for the following purposes: to enable certain functions of the Service, to provide analytics, to store your preferences, and to enable advertisement delivery, including behavioral advertising. We use both session and persistent cookies on the Services and we use different types of cookies to run the Services. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

Third-Party Cookies and Third-Party Advertising

In addition to our own cookies, we may engage third party vendors to use their cookies to report to us usage statistics of the Services, deliver Premier advertisements on and through the Services, and so on. For example, we partner with Google Analytics, who uses cookies to track your interactions with our Services. Google then collects that information and reports it to us, without identifying individual users. This information helps us improve our Services so that we can better serve users like you. For more information on Google Analytics, visit https://support.google.com/analytics.

Note that we do not control and are not responsible for the advertising practices of third parties that are not our vendors. If you allow third party websites, such as Facebook, to track your activity across the Internet, those third parties may collect information about your visit to and use of our Services. This is because that third party has, for example, placed a cookie on your browser that remembers the pages you visited, including pages that may contain sensitive health information, like information about breast cancer. To learn about how third parties use cookies to show you advertisements, review that third party’s privacy notice.

Social Media Plug Ins

On certain webpages of our Services, we may include social media plugins, such as the Facebook “like” button or Twitter “share” button. When you visit a page that displays one or more these plug ins, your browser will establish a direct connection to the social media server to load the plug in. If you are logged into your social media account when you access these pages, the social media site may collect certain Activity Data, such as your IP address. If you wish to prevent this, please log out of your social media accounts before visiting our Services. Clicking a button may also lead to a collection of certain Activity Data, such as your IP address. If you wish to obtain more information about social plugins, please visit the social media sites’ privacy policies.

Do Not Track Signals

Some web browsers incorporate a “Do Not Track” feature (“DNT”) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com.

What are your choices regarding cookies?

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

CHILDREN UNDER THE AGE OF 13

The Services are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information of children under the age of 13 via the Services. If we become aware that a child has provided Premier with personal information without prior parental consent, we will remove all information provided by such underage user from our database.

CALIFORNIA RESIDENTS PRIVACY RIGHTS

California residents have a right to request an information-sharing disclosure from a business to which they have provided Personal Information and which has disclosed the information to any third party for third party direct marketing uses in the prior calendar year. If you are a California resident, you may send such request by emailing us at PremierPrivacy@PremierInc.com with the subject line “California Privacy Rights”. Please note that, under this law, we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any requests that are not sent to the above-designated email address.

NOTE TO INTERNATIONAL USERS

Our Services are intended for individuals located in the United States. If you are located outside of the United States and access the Services or submit your Personal Information to us, you do so at your own risk and choice. U.S. law may not offer the same privacy protections as the law of your jurisdiction. If you visit our Services or contact us from outside of the United States, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy and U.S. law.

THIRD PARTY WEBSITES AND LINKS

The Services may provide links to other third-party websites and features, or contain third-party cookies, operated by organizations not affiliated, owned or controlled by Premier. We do not have access to or control over cookies or other features that third-party websites may use, and the information practices of these advertisers and third party websites are not covered by our Privacy Policy. We are not responsible for the privacy practices of these third party websites, which are subject to their respective privacy policies. When linking to another website, you should read the privacy notice stated on that website and please contact them directly for more information about their privacy practices. This Privacy Policy only governs personal information collected by us via the Services.

CHANGES TO THIS PRIVACY POLICY

Changes in this policy will be posted on this page so that you may always be aware of what information is being collected, how it is being used, and under what circumstances it is being disclosed. If we make material changes that would impact your use of the Services or your privacy, we will endeavor to notify you of the changes prior to the changes taking effect, such as by posting a notice directly on the Services, by sending an email notification (if you have provided your email address to us), or by any other reasonable method.

This Privacy Policy was last updated on January 1, 2019.

CONTACT US

For further questions regarding the Privacy Policy, Notice of Privacy Practices, or other HIPAA concerns, please e-mail our Privacy Team at PremierPrivacy@PremierInc.com.

You can also visit the “Contact Premier” page.