Privacy Policy

FEMM understands how important the privacy of personal information is to our users. This Privacy Policy will tell you what information we collect about you and about your use of FEMM and its services. It will explain the choices you have about how your personal information is used and how we protect that information. We urge you to read this Privacy Policy carefully.

If you have signed up for a course with FEMM, requested to be added to our mailing list, used the FEMM App, or otherwise provided personal information to us, it will be used in accordance with this policy and applicable legal guidelines.

You have rights related to your data. FEMM has updated its consent request and Privacy Policy to reflect these rights and respect your right to make informed decisions about how your data is collected and used. More information about how your data may be used follows in this section. If you do not grant FEMM consent, then your data will not be used or stored. This may affect your ability to access FEMM’s site and App.

This Privacy Policy contains information about what data we collect, how we collect it, what we do with it, and other aspects of data privacy.

Your rights related to your information:

You can correct the information we have, such as through updating your information in the App or by contacting us.
You can request a full copy of all your information. (Note: Information stored in the App is visible within the App.)
You can ask us to stop processing your information, such as by unsubscribing from our emails or contacting us, request a restriction of how your data is processed, or request that only natural persons make decisions concerning your data. (Note that continued use of the App requires data processing.)
We have appointed a Data Protection Officer (DPO) a to ensure data privacy rights are respected.
You can request deletion of your personal information by contacting our support team at [email protected], or the Data Protection Officer at [email protected].
You can revoke your consent.
You can request that a copy of your data be sent to a third party of your choosing in a readable format.

Requests to delete user data will be carried out within one month of the request.

FEMM is a USA-based organization. All data therefore will be transmitted to and stored in the U.S.A. Full contact information can be found at the end of this policy.

FEMM will retain personal information shared for at least six years as described in this Policy unless you request deletion of your information.

Part 1: About This Privacy Policy

This Privacy Policy applies to Web sites owned and operated by FEMM, including FEMMHealth.org. This Privacy Policy also applies to the FEMM Mobile Device Application (or “App”) for the iPhone, the iPad, and mobile devices operating with the Android operating system. Except where noted, statements in this Privacy Policy with respect to our Web sites also apply to our FEMM Mobile Device App.

Reference to “FEMM” means FEMM Foundation, Inc., including any company that FEMM Foundation, Inc. controls. “FEMM Web sites” include any site that FEMM owns or controls. FEMM may share information among its subsidiaries or sites that it owns or controls, but this is always protected under the terms of this Privacy Policy.

The FEMM Web sites contain links to other sites. Please be aware that we do not control other Web sites and that, in any case, this Privacy Policy does not apply to those Web sites. We encourage you to read the privacy policy of every Web site you visit.

We hope that reading our Privacy Policy helps you understand how we manage information about you.

While you may use some of the functionality of FEMM without registration, many of the specific tools and services on our website require registration. If you use our Web site without registering, the only information we collect will be Non-Personal Information through the use of Cookies or Web Beacons. If you choose to register with our Web site for certain Interactive Tools or other services, we require you to submit Personally Identifiable Information. Depending on the tool or service you have selected, we may also collect Personal Health Information. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to FEMM. Inaccurate information will affect the information you receive when using our site and tools and our ability to contact you as described in this Privacy Policy. For example, your email address should be kept current because that it is how we communicate with you.

Part 2: Non-Personal Information Collection

Even if you do not register with FEMM, we collect Non-Personal Information about your use of our Web site, special promotions, and newsletters.

Cookies

We collect Non-Personal Information about your use of our website and your use of the websites of selected sponsors and advertisers through the use of Cookies. Every computer that accesses a FEMM Web site is assigned a different Cookie by FEMM. 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 aids and as session timers. Cookies used by FEMM may also be used to restrict underage use of the tools.

Most 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 functions and conveniences of our Web site may not work properly. However, users who register with our site to use our tools and view our educational materials are required to accept our Cookies for proper operation. We do not link Non-Personal Information from Cookies to Personally Identifiable Information without your permission and do not use Cookies to collect or store Personal Health Information about you.

Web Beacons

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 Personally Identifiable Information without your permission and do not use Web Beacons to collect or store Personal Health Information about you.

Third Parties Collecting Non-Personal Information on FEMM’s Behalf

Third parties under contract with FEMM may use Cookies or Web Beacons to collect Non-Personal Information about your usage of FEMM’s sites. These third parties may use this information, on our behalf, to help FEMM target our advertising on their sites within their network, and FEMM may further tailor the advertising on these third party sites based on your geographic location, gender, and/or age range to the extent known by these third parties. These third parties have agreed not to use Non-Personal Information they collect from our sites except to deliver advertisements on our behalf. If your browser is set to reject cookies, the Non-Personal Information will not be sent to these third parties.

Mobile Device Applications (Apps)

When you download and install our FEMM Mobile App onto your mobile device we assign a random number to your App installation. This number cannot be used to identify you personally, and we cannot identify you personally unless you choose to become a registered user of the App. We use this random number in a manner similar to our use of Cookies as described in this Privacy Policy. Unlike Cookies the random number is assigned to your installation of the App itself and not a browser, because the App does not work through your browser. Therefore the random number cannot be removed through settings. If you do not want us to use the random number for the purposes for which we use Cookies, please do not use the Mobile Device App and please use your mobile device browser to access our websites or our mobile optimized sites. We do not obtain any information about your mobile device, other than the brand, make and model and type of operating software your device uses.

Physical Location

FEMM obtains your consent (via an opt-in) before using information from pin-pointing technology like GPS or cell tower information. You can withdraw your consent (opt-out) for the use of “location” by FEMM at any time by changing your location services in the “Settings” function on your mobile device.

Part 3: Personally Identifiable Information Collection

We may ask you to provide Personally Identifiable Information, like your name, email address, date of birth, and gender, when you register as a member of FEMM and/or when you update your member profile. We use the Personally Identifiable 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 Privacy Policy.

The FEMM App uses data which you, the user, input. The data you put in is available to you through the App at any time. That data is stored securely via FEMM and secure, third-party data storage services. These third parties do not access, view, or share your information. FEMM will not share any identifiable information with anyone. In line with the provisions below, FEMM may share anonymized/de-identified information for the purposes of medical research. No researcher will receive any information that could identify you.

Newsletters and Emails

At registration and at various times as you use FEMM, you will be given the option of receiving recurring informational/promotional newsletters via email from FEMM and/or directly from third parties. These emails will not contain Personal Health Information. When you sign up for our email newsletters or at any time, you can choose to opt in to receiving additional promotional emails from FEMM or our Sponsors. In order to subscribe to FEMM newsletters via email, we need your contact information, like name and email address. You can unsubscribe from the newsletters by simply following the directions included at the bottom of each email newsletter you receive from FEMM.

If you have difficulties with our unsubscribe or subscribe service, please email us at [email protected]. FEMM Customer Service will manually unsubscribe you from that newsletter in two to three business days. Unsubscribing does not automatically delete FEMM’s records of your contact information. If you would like that information deleted from our records, please contact us at [email protected]. If you have any concerns about your data, [email protected].

In some cases, when you click on a link or an advertisement on our site, in an email or in a newsletter, your browser may be momentarily directed to the website of a third party which, acting on behalf of FEMM, notes or “counts” your response to the email or newsletter before re-directing your browser to your selected destination; this re-direction process may not be apparent to you.

Emails You Send to FEMM

This Privacy Policy does not apply to content, business information, ideas, concepts, or inventions that you send to FEMM 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 FEMM.

Email a Friend

If you use our Email a Friend service to tell a friend about our site or newsletter, we will ask you for your name, your email address, and your friend’s email address. We will automatically send your friend a one-time email inviting him or her to visit the site using your name and email address as the “from” email address. FEMM does not use your name, your email address, or your friend’s email information for any other purpose. We will only use the information you provide to send the email you request.

Community, Blogs, and other Public Forums

FEMM features public areas where users with similar interests or medical conditions can share information and support one another or where users can post questions for experts to answer. Our public areas are open to the public and should not be considered private.

Any information you share in any online community area (including Personally Identifiable and Personal Health Information) like a chat room, forum posting, or online discussion is by design open to the public and is not private. You should think carefully before posting any Personally Identifiable or Personal Health Information in any public forum. What you post can be seen, disclosed to or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, Bing, etc.

Website Registration and Interactive Tools on FEMM

After you have registered as a member of FEMM, you may choose to use certain FEMM interactive content, tools, and services that may ask you to voluntarily provide other types of information about yourself including Personal Health Information. Some of the tools do not retain your Personal Health Information, while others store your Personal Health Information in accordance with the authorization you provide at the time you use the tool.

Protecting Children

We are committed to protecting the privacy of children. Neither FEMM nor any of its services are designed or intended to attract children under the age of 13. We do not collect Personally Identifiable Information from any person we actually know is under the age of 13. A parent or guardian, however, may use FEMM to establish a fertility record for a minor. The parent or guardian is solely responsible for providing supervision of the minor’s use of FEMM. The parent or guardian assumes full responsibility for ensuring that the 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 provided through FEMM for the minor. EU citizens aged 13-15 must have a parent or guardian consent to the use of data as outlined in this policy and needed for use in the App.

Market Research

From time to time the FEMM market research department, or its operations contractors acting on its behalf, conducts online research surveys through email invitations, pop-up surveys, and online focus groups. When participating in a survey, we may ask you to submit Personally Identifiable Information. This Personally Identifiable 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. Personally Identifiable Information collected through market research will be used only by FEMM and its service providers and contractors and will not be given or sold to any other third party without your consent or as otherwise permitted by this Privacy Policy. 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 as a small cash fee for your time or an entry into a sweepstakes for a larger prize. Each survey will disclose whether or not 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 FEMM site usage characteristics. You will be notified when we would like to use Cookies in this way and your consent will be requested for these Cookies.

Part 4: FEMM Health System

The FEMM Health System allows you a secure place to store Personal Health Information related to your health and fertility and provides tools and services in order to better manage your health. FEMM Health System use requires additional registration. The FEMM Health System includes the FEMM App.

The following applies to your access to the FEMM Health System through this site or the mobile device App:

FEMM Health System Home Page

Personal Health Information that you enter into the FEMM Health System tool is used to provide you personalized and clinically relevant information on your personalized FEMM Health System home page and throughout the FEMM Health System product. FEMM Health System creates a personal home page specifically for you. You control and authorize who can gain access to this page.

Aggregate Data

FEMM Health System may combine, in a non-identifiable format, the Personal Health Information you provide with information from other users to create Aggregate Data that may be disclosed to third parties. Aggregate Data does not contain any information that could be used to contact or identify you. For example, FEMM Health System may use information gathered to create a composite profile of all the users of a particular third party site. These third party Web sites may use this information to understand community needs and to design appropriate programs and activities on their site. FEMM Health System will not disclose your Personal Health Information to any third party without your prior permission, except as otherwise permitted by this Privacy Policy.

Research Data

FEMM Health System may disclose, in a non-identifiable way, Personal Health Information provided by Users to FEMM researchers and third party researchers. Third party researchers will in no way be able to contact or identify you from this information. Data help FEMM researchers understand how FEMM can teach clients more effectively. Data are also used to study the effectiveness of the FEMM Health System.

Newsletter Service

FEMM Health System may offer the ability to use Personally Identifiable Information that you provide to send you personalized newsletters using email. . You have the option of choosing whether or not you wish to receive newsletters pertaining to your health interests, including news and opportunities. The FEMM Health System email service requires an “opt-in” authorization from you. If you decide that you would prefer not to receive personalized newsletters from the FEMM Health System tool, you may opt out of the newsletter service.

Email Service

Upon registering on the FEMM Health System to use our tools and services, Personally Identifiable Information that you provide may be used by us to send you personalized emails regarding announcements or reminders. You will be asked to consent to receive these emails. You can change your subscription preferences or be removed entirely from our database upon request.

Interactive Tools on FEMM Health System

Interactive tools within the FEMM Health System gather self-reported Personal Health Information. In addition, certain of these tools can store Personal Health Information coming from third party data interchange agreements between your employer, health plan, pharmacy benefits manager, and other third parties that provide data interchange services. We maintain and limit the use of that information to the opt-in permission you have provided at the time you use the tool.

FEMM does not knowingly engage in business with a company that uses Spyware. We do not provide Users with downloadable software that collects or uses any Personally Identifiable Information or Personal Health Information without full disclosure and opt-in consent.

Part 5: Information Collected by Third Parties Not Acting on FEMM’s Behalf

Sponsors or advertisers on FEMM may use their own Cookies, Web Beacons, or other online tracking technologies in the banner advertisements served on FEMM and in emails, special promotions, or newsletters we send you. Some advertisers use companies other than FEMM to serve their ads and to monitor users’ responses to ads, and these companies (“Ad Servers”) may also collect Non-Personal Information through the use of Cookies or Web Beacons on our Web site. In certain situations, information collection may be facilitated by momentarily directing your browser to the Web site of an Ad Server or other third party acting on behalf of the sponsor, partner, or advertiser before re-directing your browser to its selected destination (e.g., back to FEMM to show the ad, or to the advertiser’s website); this re-direction process will not be apparent to you.

We do not control these third parties’ use of Cookies or Web Beacons, or how they manage the 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 Web site to agree that they will not collect any Personally Identifiable 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 Personally Identifiable 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 Yahoo, non-personal information sent by your browser to Yahoo when you click on a sponsored link or submit a query may be used by Yahoo as described in its privacy policy. In addition, FEMM’s Advertising Policy is posted on our Web site and will provide additional detail about our relationship with advertisers and the companies that serve ads. You should review the privacy policy of other sites you visit or link to from our site to understand how these other sites use Cookies and how they use the information they collect through the use of Cookies or Web Beacons on their own sites. Certain Ad Servers allow you to prevent them from collecting data through the use of Cookies. In order to do so, you must opt out of such data collection with each individual site. 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. You can find additional information and resources about how to opt out of advertising and related cookies by visiting the World Privacy Forum’s Site.

FEMM does not knowingly engage in business with any company that uses Spyware or Maleware. We do not provide users with downloadable software that collects or uses any Personally Identifiable Information or Personal Health Information without full disclosure and opt-in consent.

Part 6: Disclosure of Your Information

Except as described in this Privacy Policy or as specifically agreed to by you, FEMM will not disclose any Personally Identifiable or Personal Health Information it gathers from you on our website. We may 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 order; or (2) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. 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 FEMM Operations and Maintenance Contractor

FEMM operations and maintenance contractors sometimes have limited access to your Personally Identifiable Information in the course of providing products or services to FEMM. These contractors include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of our Web site. Unless you have opted out of receiving emails and newsletters from FEMM, 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 Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for FEMM. We also contractually require that our operations and maintenance contractors 1) protect the privacy of your Personally Identifiable Information consistent with this Privacy Policy, and 2) not use or disclose your Personally Identifiable Information for any purpose other than providing us with products and services as required by law.

Disclosure to FEMM Researchers and Third Party Researchers

Disclosure to Third Party Contractor Websites

Certain content and services offered to you through our website are served on Web sites hosted and operated by a company other than FEMM (“Third Party Contractor Web sites”). FEMM does not disclose your Personally Identifiable Information to these Third Party Contractor Web sites without your consent, but you should be aware that any information you disclose once you access these other Web sites is not subject to this Privacy Policy. FEMM does not endorse and is not responsible for the privacy practices of these Third Party Contractor Web sites. You should review the privacy policy posted on the other Web site to understand how that Third Party Contractor Website collects and uses your Personally Identifiable Information. FEMM makes an effort to make it obvious to you when you leave our website and enter a Third Party Contractor Web site, 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 FEMM, then you are on a Web site hosted by a company other than FEMM.

FEMM also provides links to sites provided by Third Party Contractor Websites that have business arrangements with FEMM to pay commissions based on sales of products or services generated through FEMM. An example of this would be “Ad links” from Yahoo on our Search pages.

Disclosure to Linked Sites

In addition to the Third Party Contractor Web sites that you may access as described above, for your convenience there are links to Third Party Web sites operated by companies that are not affiliated with the FEMM Web site and that do not have contracts to provide content or services through the FEMM Web site. These links may be found in advertisements, referenced within content, or placed beside the names or logos of sponsors. FEMM does not disclose your Personal Information to these Third Party Websites without obtaining your consent. FEMM does not endorse and is not responsible for the privacy practices of these sites. If you choose to link to one of these Third Party Web sites, you should review the privacy policy posted on this other website to understand how that Third Party Web site collects and uses your Personally Identifiable Information.

Part 7: How FEMM Handles Privacy and Security Internally

Here are some of the security procedures that FEMM uses to protect your privacy:

Requires both a personal username (log-in name) and a password in order for users to access their Personally Identifiable Information or Personal Health Information.
Requires a public ‘nickname’ different from the username and password, used for any public forums.
Uses firewalls to protect information held in our servers.
Utilizes Secure Socket Layer (SSL) encryption in transmitting Personally Identifiable Information to our servers. 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 FEMM employees who have potential access to your Personally Identifiable Information.
Requires all FEMM employees to abide by our Privacy Policy and to be subject to disciplinary action if they violate it.
Backs-up our systems to protect the integrity of your Personally Identifiable and Personal Health Information.

FEMM Health System provides additional protection for your Personal Health Information as follows:

Maintains Audit Trails so you can know who has accessed your FEMM Health System record. This can be viewed by clicking on “Activity” in the Settings window, which is accessible from your FEMM Health System home page.
Provides secure messaging within the FEMM Health System tool so that information related to your personal health related characteristics is sent through a secure, encrypted connection.
Provides geographic redundancy of FEMM Health System servers, which enhances your ability to access your information by storing identical information at two separate, secure locations. Both sites maintain physical security through pass code locked door access and pass code authority.
Limits access to Personally Identifiable Information to authorized users. FEMM 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. Only the person who creates a record can grant access to other users.

Despite FEMM’s efforts to protect your Personally Identifiable 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 may be intercepted.

Part 8: Updating Your Information and Contacting FEMM

Updating Your Personally Identifiable Information

FEMM tools that collect and store self-reported data allow you to correct, update, or review information you have submitted by going back to the specific tool, logging in, and making the desired changes. FEMM may store user submitted data (Personally Identifiable Information and/or Personal Health Information) in an active database for a period of six (6) months. After six (6) months, user submitted data, including Personally Identifiable Information and/or Personal Health Information will be held in an active database or on an inactive back-up medium for a period of not less than six (6) years.

Removing your Personal Information

If you have a complaint or problem, please contact us at [email protected]. Our customer service department will forward your complaint to the appropriate internal FEMM department for a response or resolution. We try to answer every email within 48 business hours, but may not always be able to do so.

Limitations on Removing or Changing Information

Upon your request, we will delete your Personally Identifiable or Personal Health 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 FEMM from our servers.

Part 9: Changes to This Privacy Policy

Personally Identifiable Information: We will inform you if a material change is made to the Privacy Policy, which means a change that expands the permissible uses or disclosures of Personally Identifiable Information allowed by the prior version of the Privacy Policy. Your continued use of the FEMM Web site will indicate acceptance of the changes. You may of course choose to opt out of continuing to use the FEMM Web site. Please exit the site immediately if you do not agree to the terms of this Privacy Policy or any revised policy.

Personal Health Information: We will inform you if a material change in the Privacy Policy is made that involves the use of your Personal Health Information, and your express opt-in authorization will be requested. If you choose not to accept the new privacy policy, then the current privacy policy conditions will remain in effect, so long as FEMM continues to make the functionality available. FEMM reserves the right to discontinue or limit functionality in all its products including FEMM and FEMM Health System.

Non-Significant Changes: FEMM may make non-significant changes to the Privacy Policy that do not affect Personally Identifiable Information or Personal Health Information. For these instances, FEMM may not notify you of such non-significant changes.

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places appropriate throughout our site so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, and by means of a notice on our home page.

Contacting Us

If you have any questions about our privacy policy, please contact us at the following:

FEMM Foundation
228 East 71st Street
New York, NY 10021
[email protected]

Part 10: Glossary

Non-Personal Information: Information that is not traceable back to any individual and cannot be used to identify an individual. For example, information such as gender, age, city and state when not linked with other Personally Identifiable Information is Non-Personal Information.

Personal Health Information (PHI): When your Personally Identifiable 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 Personally Identifiable Information, it becomes Personal Health Information.

Personally Identifiable 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 Personally Identifiable Information include your name, home address, telephone number, email address, and Social Security number.

If other pieces of information are linked to Personally Identifiable Information, they also become Personally Identifiable Information. For example, if you use a nickname to chat online and give out your real name while chatting, your nickname becomes Personally Identifiable Information when linked with other Personally Identifiable Information.