PRIVACY POLICY
AiCure, LLC, a New York Limited Liability Company having its primary address at 100 S Bedford Road, Suite 340, Mt Kisco, NY 10549 ("we") is committed to protecting and preserving your privacy. This Privacy Notice provides information about how we process any personal data we collect from you, that you provide to us, or that we obtain about you in connection with your use of our mobile application ("Application"). As used herein the term "Services" means the functionalities of our Application.
If you use this Site or Applications and you are not a resident of an EU Member State, you consent to the use of information that you provide us in accordance with this Privacy Policy. We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will notify you of such changes by contacting you through your user account e-mail address or by posting a notice on our Site. Your continued use of the Site or Application will be deemed your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the Site or Applications and you should notify us that you do not want your information used in accordance with the changes.
Certain features of the Application have been developed for clinical trial sponsors, and for clinical trial patients who are using the Application under the direction of licensed health care professionals, in order to facilitate and coordinate patient medication adherence in connection with those clinical trials. We have agreed to provide our medication adherence monitoring services to sponsors of a clinical trials and to provide you a statement concerning your privacy rights on behalf of such sponsors, who retain at all times control over the use of your data in the course of such clinical trials ("Covered Clinical Trials").
1. Data Processing on Behalf of Sponsors of Clinical Trials.
In context of providing our Services, we are collecting and processing personal data on behalf of individual clinical trial sponsors. In case such processing activities are subject to the EU General Data Protection Regulation ("GDPR") we will be acting as data processors (as such term is defined in the GDPR) pursuant to a data processing agreements meeting the requirements of the GDPR from the following categories of data subjects (collectively, "Affected Data Subjects"):
a)Individuals enrolled in a Covered Clinical Trial,
b)persons working with a clinical trial site and need access to our system.
In all those instances, the clinical trial sponsors determine the means and purposes of such processing activities, including, which patients will use an Application, the principal Application functions, the personal data it will collect, how that data will be used and by whom such data is accessed, and how long the data will be retained. The sponsor acts as controller (as such term is used under the GDPR) of the personal data and of the Affected Data Subjects and is responsible for giving them information about how the Application processes their personal data; we provide you the Application only in accordance with instructions from the sponsor. The Privacy Notices applicable to the processing of your data in connection with such Covered Clinical Trials can be found in the clinical trial material provided to you, including the Informed Consent Form reviewed in accordance with your entry into the clinical trial.
2. Processing of Personal Data for Purposes of Improvement of our Application and Meeting our Compliance Obligations.
In context of your enrollment with a Covered Clinical Trial, or if you use our system outside the context of a clinical trial, we will process certain of your personal data for purposes that may go beyond the immediate requirements of a Covered Clinical Trial. If you are a resident of an EU Member State this type of processing activity will be subject to certain special conditions and rights that you have as a data subject more particularly described in this Additional Privacy Notice for Users in Jurisdictions Subject to GDPR Regulation (see below)
3. Use of Data of Users not Subject to GDPR, General Privacy Practices
In all cases not covered by the Special Privacy Notices described in Sections 1 and 2 above the following privacy practices shall be applicable e.g., if you simply visit our website or if you are Patient using our solution, a Provider, or Authorized Personnel, as such terms are defined below.
We will use and disclose a Patient's health information only to provide Services to the Patient or the Provider, for those uses and disclosures permitted by applicable law and the agreement that we have with your Provider, and for any other purpose to which you specifically consent. In the event that there is a conflict or inconsistency about the handling of health information between (i) this Privacy Policy and (ii) our compliance obligations with applicable law and contractual commitments with Providers, then the latter will govern.
Our services have been developed for the sponsors of clinical trials and population health studies, and potentially hospitals and medical groups ("Providers") and for patients who are using the Site and/or Applications under the direction of a Provider ("Patients") to facilitate and coordinate patient medication adherence. Providers and personnel who are authorized to access and use the Site and Applications with respect to a Patient's information, including, without limitation, administrators, clinicians, physicians, nurses, and other caregivers are described here as Authorized Personnel.
We have structured your purchase or use of our Applications through third parties, so we do not obtain your personal information through the sale or registration of our Application. You should review and understand any additional privacy policy provided by the third party before you purchase or use our Applications through them.
4. Website and Applications Privacy Notice
Please read this Policy carefully to fully understand how we collect, share and protect information about you. This Policy is incorporated into and is a part of the Terms of Use of this Site.
By accessing and using the Site or Applications, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices and uses or disclosures of information about you that are described herein.
In order to deliver personalized and relevant information to you through our Site and our Applications, we collect certain information from users.
4.1. Information We Collect
If you are an Authorized Personnel user, we collect personal information about you when the Provider subscribes to the Services as well as when you register to use the Services. The Personal Information about Providers and Authorized Personnel that we collect includes, without limitation, the Provider's and Authorized Personnel's name, position, specialty, email address, phone number, and business postal address. We do not collect health information about Providers or their Authorized Personnel.
If you are a Patient, we collect Personal Information about you when you register to use the Services as well as:
Details of your use of our Site and Applications, the date and time you use our site or application to confirm medication administration or other actions you perform while interacting. Some parts of our Site may use cookies and other technologies to collect this information about your general internet usage. See section below "How We Use Cookies" to learn more.
Your mobile phone number, the IMEI identifying number associated with your mobile device, and video images, including video images of your face captured by a 3D video sensor, of you performing one or more sequences of steps, such as administering medication, or answering questions in response to prompts presented to you. This data is initially collected in a non-anonymized, non-pseudonymized format. The data is stored in an encrypted format, both when in motion and at rest.
Information that you provide directly to us by filling in forms on our Site or in our Application (for example, to contact us, you must provide your name and e-mail address on the site, or a mobile phone number in the application).
Health information that you provide directly to us, including but not limited to your sensitive health care information which may include, but is not limited to, HIV/AIDS information, sexually transmitted disease information, genetic testing information, medication adherence information, mental/behavioral health information, and alcohol and/or drug treatment information. This information may be submitted in text form, recorded video, or photos.
Information provided to us when you communicate with us for any reason.
4.2. How We Use Cookies
A "cookie" is a piece of text, which asks permission to be placed on your computer's hard drive. Once you agree, this cookie file is stored on the hard drive of your computer. They help us and our affiliates to improve our Site and Applications. They ensure that the content from our Site and Applications is presented in the most effective manner for you and your computer.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser, which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Site or Applications.
The third parties who sell our Applications may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click links from our Site or purchase and/or use our Applications through other third party interfaces.
We do not track our users across time or across websites.
4.3. Use of Your Information
The information that we collect and store relating to you is primarily used to enable us to provide our services to you in the best possible manner. In addition, we may use the information for the following purposes:
to provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
for the purpose of improving the functionality and performance of the algorithm underlying our Application so as to improve its usefulness to future patients and medical science in general. In particular, we may use collected facial images, including those collected by 3D sensor, to analyze facial movement for this purpose.
to tailor the content and information that we may send you, to offer personalized help and instructions, and to otherwise personalize your experiences while using the Site and Applications.
to better understand how users access and use our Site and Applications, both on an aggregated and individualized basis, in order to improve our Services and respond to user desires and preferences, and for other research and analytical purposes.
to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information.
for our business purposes, such as data collection and analysis, audits, developing new products, and enhancing and improving our Site, Applications, and the Services.
as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your state or country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your state or country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
4.4. Security
We have put in place commercially suitable administrative, technical, and physical safeguards for the information we collect on our Site or through our Applications. Nonetheless, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically on our Site or through our Applications, and transmission of such data is therefore entirely at your own risk.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
4.5. Disclosing Your Information
Where applicable, we may disclose your personal information to any affiliated business entities or third parties necessary to provide products and services to you. This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries (if any), as well as third parties involved in the administration and operation of our products and services, including, but not limited to our cloud service provider, ClearData, Inc.
We may disclose your Personal Information, including Health Information (defined below) as follows:
if you are a Patient, to your Provider, and its Authorized Personnel, without further authorization for purposes of treatment, payment or operations; for other uses or disclosures permitted by law; or for purposes related to such uses or disclosures.
to our third party service providers who provide services such as website hosting, data gathering, data analysis, customer service, email delivery services, auditing services and other similar services.
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).
as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your state or country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your state or country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
to third parties for research or similar purposes, but only if such Personal Information has been de-identified.
We will not disclose or share captured facial images, including those captured by a 3D sensor, to any third parties (other than as required for administration as noted above), and will not use these images to identify any additional personal information.
4.6. Third Party Website and Interaction
By accessing other third party websites or applications through our Site or Applications, you are consenting to the terms and privacy policies of those websites. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
4.7. Users Only of Legal Age of Majority
Our Site and Applications are designed and intended for those who have reached the age of majority (18 years of age). By using our Site or Applications, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user's misrepresentation of age. Parents or legal guardians of children over 13 but under 18 years of age can agree to this Privacy Policy on their behalf.
No one under age 13 is authorized to submit or post any information, including personally identifying information, on our Site. Under no circumstances may anyone under age 13 use our Site. Parents or legal guardians of children under 13 cannot agree to this Privacy Policy on their behalf or use of our site. Individuals under the age of 13 can use our Application, subject to the additional Privacy Notice for Users under 13 years of age (see below).
4.8. Access to My Personal Information
You may modify Personal Information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Application for a period of time.
You may also contact us directly if you would like to review, correct, update, delete or otherwise limit our use of your Personal Information that has been previously provided to us by sending us an email at info@aicure.com. In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable. Please note that in order to comply with certain requests to limit use of your Personal Information we may need to terminate your account with us and your ability to access and use the Services, and you agree that we will not be liable to you for such termination. Although we will use reasonable efforts to do so, you understand that it may not be technologically possible to remove from our systems every record of your Personal Information. The need to back up our systems to protect information from inadvertent loss means a copy of your Personal Information may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.
4.9. Data Retention
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. We will retain captured facial images, including those captured by a 3D sensor, to any third parties, only as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law, or your consent to such retention.
By use of the AiCure system I understand that collected data from the use of the AiCure system be retained by AiCure to improve the predictive algorithms and usability of AiCure's software, to maintain a biometric database to allow for comparison of collected data to determine duplicate enrollment between multiple studies and sponsors, and for other diagnostic purposes, to categorize adherence activity by disease state or other useful categories, to report high level statistics, to or to support regulatory filings by AiCure for future applications of AiCure's product.
By use of the AiCure system I hereby authorize AiCure to use the device to photograph, film, and/or record my image, voice, likeness, and testimonial opinions and ideas. I authorize AiCure to share the photographs, film and/or recordings with those who have entered into an agreement of confidentiality with AiCure. I further grant AiCure a royalty-free, worldwide, perpetual, and assignable right, commencing on the date set forth below, to edit, use, and reproduce, the recordings, either in whole or in part, whether alone or in conjunction with other matter, for any and all purposes. I understand and agree that AiCure may do so with no additional notice to me. I understand that personnel associated with AiCure and the Study site will see and hear the recordings. AiCure will not release the photographs, film and/or recordings in identifiable format outside of AiCure without permission.
By use of the AiCure system I agree that AiCure shall have a right to edit or modify the recordings at its sole discretion. I hereby waive any right to inspect or approve the finished photographs/video footage, advertising copy, or printed matter that may incorporate the recordings for the eventual use to which it may be put by AiCure or any other person or entity to whom AiCure may disclose it, and any claims I may have now or in the future based on that use. I further agree that AiCure has the right to copyright, and indeed does own the copyright to, any finished product incorporating the recordings. I also acknowledge that AiCure may choose not to use the recordings at this time, but may do so at its own discretion at a later date.
By use of the AiCure system I acknowledge that nothing has created in or vested in me any ownership, copyright or other rights in the data collected during this Study. Instead, all rights in the recordings, including all copyrights or other proprietary interests of whatever kind, shall belong exclusively to AiCure. I release and discharge AiCure and any parties with which AiCure shares the recordings from any and all claims and demands arising out of or in connection with the use of the recordings and related materials, including, without limitation, any and all claims for libel or violation of publicity or privacy.
4.10. Contacting Us
We welcome any queries, comments, complaints or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us at:
AiCure
Attn: Gordon Kessler, General Counsel, Corporate Security Officer
100 S Bedford Road
Suite 340
Mt Kisco, NY 10549
+1 800 570 0448
info@aicure.com
ADDITIONAL PRIVACY NOTICE FOR USERS IN JURISDICTIONS SUBJECT TO GDPR REGULATION
In context of your enrollment with a Covered Clinical Trial, we will seek your explicit separate consent if we intend to process certain of your personal data for purposes that may go beyond the immediate requirements of a Covered Clinical Trial. You may revoke this consent at any time free of charge in the same manner as such consent was given or in any other form of communication that makes sure we receive your communication. If you withdraw your consent we will no longer process your data unless we are relying on grounds different from your consent for processing the data in question. Also, the withdrawal of your consent does not affect the lawfulness of any processing based on your consent that occurred prior to your withdrawal.
1. Data We May Be Processing:
Such data are: your mobile phone number, the IMEI identifying number associated with your mobile device, and video images of you performing one or more sequences of steps, such a administering medication, or answering questions in response to prompts presented to you. This data is initially collected in a non-anonymized, non-pseudonymized format. The data is stored in an encrypted format, both when in motion and at rest. Purpose of Supplemental Processing:
We use your data for the purpose of improving the functionality and performance of the algorithm underlying our Application so as to improve its usefulness to future patients and medical science in general.
2. Retention of Data
We will retain your data for the purposes described in the preceding paragraph (typically no longer 2 years after the end of any clinical trial in which you are enrolled, but in any event no longer than required for the making the above mentioned improvements. FDA regulations require us retain a clinical trial related data after the completion of a study as defined by the entity conducting the Covered Clinical Trial).
3. Third Party Access to Data
We will not share your data with third parties unless we have obtained your consent or there is another legal basis recognized by the applicable data protection laws of the European Union or its Member States, such as the fulfillment of a contract you may have entered into with us. Moreover, as we are regulated by the U.S. agency overseeing the medical device industry, the FDA, we may be compelled to disclose such data to the FDA in the context of regulatory investigations.
In addition we may be granting third parties access to your data as we reasonably believe to be necessary (a) to comply with applicable law, including laws outside your state or country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your state or country of residence; provided that in all instances mentioned in (a) – (c) the subject request is based upon an international agreement, such as a mutual legal assistance treaty, in force between a requesting third country and the European Union, or a Member State, or is lawful based on other grounds recognized by the GDPR or applicable laws of EU Member States. We may also share your data with third parties to the extent that is reasonably required for us (a) to enforce our terms and conditions; or (b) taking into account your fundamental rights and freedoms, (i) to protect our operations or those of any of our affiliates; (ii) to protect your rights, privacy, safety or property, and/or ours or that of our affiliates or others; and (iii) to allow us to pursue available remedies or limit the damages that we may sustain.
4. Transfers of Personal Data to Countries Outside the EU
We are located in the United States and are EU-US and Swiss-US Privacy Shield certified. This means that we are committed to treating any data you transmit to us from the EU, United Kingdom or Switzerland to the US in accordance with the Privacy Shield Principles (https://www.privacyshield.gov/EU-US-Framework). Entities like ours that certify to the Privacy Shield principles are considered to offer adequate protection to personal data, as determined by the European Commission. By submitting your personal data via the Application, your personal data will be transferred to us pursuant to these EU-U.S. and Swiss-US Privacy Shield principles. For information with respect to the enforcement mechanisms available to protect your rights under the EU-U.S. and US-Swiss Privacy Shield Mechanism, see the respective statements on our main website.
5. Your Rights as a Data Subject
You may exercise your rights as a data subject listed in this Section 2.6 by contacting us at privacy@aicure.com or by writing to us at the address listed in Section 5 of this Privacy Statement. We will respond to any such inquiries within one month from the date we receive your inquiry either by fulfilling request or informing you about any obstacles or questions in relation to your request. Depending on the circumstances, we may need up to two additional months to complete our response to your request.
You have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data by us or the way we respond to your inquiries infringes applicable data protection laws. A list of data protection supervisory authorities is available here. http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
5.1. Accessing your Data
You have the right to request access to your personal data (including receiving a copy thereof) as well as additional information about the processing.
5.2. Correction
In case you discover factual inaccuracies with the respect to the personal data we hold with respect to you, you may request a correction to make such data factually accurate.
5.3. Right to Erasure
You are entitled to have your personal data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we do not have overriding legitimate grounds (see below) or where personal data is unlawfully processed, provided that applicable law does not provide otherwise. Please be advised that it may not be technologically possible to remove from our systems immediately every record of your personal data. The need to back up our systems to protect information from inadvertent loss means that a copy of your personal data may exist in a non-erasable form that may make it difficult or impossible for us to locate or remove immediately.
5.4. Right to Restriction of Processing
You have the right to restrict the processing of your personal data (that is, allow only its storage) where:
- you contest the accuracy of the personal data, until the Sponsor or we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want the Sponsor or us to erase the personal data;
- where the Sponsor no longer needs your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defence of legal claims; or
- where you have objected to processing justified on legitimate interest lawful grounds (see below), pending verification as to whether the Sponsor has compelling legitimate grounds to continue processing.
Where your personal data is subject to such a restriction of processing, we will only process it with your consent or for the establishment, exercise or defence of legal claims.
5.5. Right to Object to Processing
5.5.1. Processing based on legitimate interest grounds
Where we rely upon legitimate interests to process personal data (which includes processing of all data for which we have not obtained your explicit consent), you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we needs to process the personal data in question for the establishment, exercise or defence of legal claims, or applicable law requires otherwise.
5.5.2. Right to object to direct marketing (including profiling)
While we do not use your personal data for direct marketing, you have the right to object to our use of your personal data (including profiling) for direct marketing purposes.
5.6. Data Portability
You have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine-readable format, and may also require us to transmit such data to another controller where this is technically feasible.
6. Contacting Us
We welcome any queries, comments, complaints or requests you may have regarding this Privacy Notice. Please do not hesitate to contact us at:
AiCure
Attn: Gordon Kessler, General Counsel, Corporate Security Officer
100 S Bedford Road
Suite 340
Mt Kisco, NY 10549
+1 800 570 0448
privacy@aicure.com
AiCure has appointed 2B Advice GmbH as its European GDPR Data Protection Officer. You can reach them by sending an email to dsb@aicure.com.
Changes to this Notice
If we alter our Privacy Notice, you can review any changes at this web location.
PRIVACY NOTICE FOR USERS UNDER 13 YEARS OF AGE
Under the Children's Online Privacy Protection Act ("COPPA"), AiCure ("we," "us," or "our") is required to provide you with notice of our information collection practices before we collect any personal information from your child under 13. In this Children's Privacy Policy, we explain how we collect, use, and disclose personal information from your children under 13 years old via the AiCure mobile application (the "Application") and the services available through our Application (collectively, the "Services").
We have agreed to provide our medication adherence monitoring services to sponsors of clinical trials and to provide you a statement concerning your child's privacy rights on behalf of such sponsors, who retain at all times control over the use of your child's data in the course of such clinical trials ("Covered Clinical Trials").
What Information Do We Collect About Children and Why?
Before you or your child can use the Services, you, as the parent or guardian, must provide your consent by signing the consent form provided during the clinical trial registration process for your child. Please review our Privacy Policy for more information about the information we collect about you and how we use and disclose it.
We collect Personal Information about children when they register to use the Services. To register, we collect only a child's clinical trial study ID number, and their mobile phone number, if you choose to provide it.
We also collect:
Use of Your Child's Information
The information that we collect and store relating to children is primarily used to enable us to provide our Services in facilitating coordinating medication adherence for medical treatment, research, and clinical trial programs your child participates in. We use your child's information in order to provide our Services, respond to your inquiries and requests, analyze and improve the Services, and for other internal business purposes.
How We Disclose Children's Information
We do not sell children's personal information, and a child may not make his or her personal information public through our Services. We may share children's personal information as follows:
Access to Your Child's Personal Information
You have the right to access your child's personal information that has been submitted to us by contacting us directly, and you may also update your child's profile information. You have the right to tell us to stop collecting personal information from your child. Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Application for a period of time.
You may contact us directly if you would like to additionally review, correct, update, delete or otherwise limit our use of your child's personal information that has been previously provided to us by sending us an email at info@aicure.com. In your request, please make clear what information you would like to have changed, whether you would like to have your child's personal information deleted from our database or otherwise let us know what limitations you would like to put on our use of your child's personal information. We will try to comply with your request as soon as reasonably practicable. Please note that in order to comply with certain requests to limit use of your child's personal information we may need to terminate your child's account with us and you and your child's ability to access and use the Services, and you agree that we will not be liable to you for such termination.
Contact Us
The AiCure Application is operated by:
AiCure
100 S Bedford Road
Suite 340
Mt Kisco, NY 10549
+1 800 570 0448
info@aicure.com
In certain instances, the clinical trial [sponsor/study site] or the health care provider that is using the Application for medication adherence monitoring will operate the Application. If you have questions about how these parties use the Application to collect your child's personal information, please contact us using the contact information above or contact [the clinical trial [study site] for the trial your child is participating in] or the healthcare provider who requested your child use the Application.
Please go to our Privacy Policy (see above) for more information about our privacy practices, or to obtain copy of this Children's Privacy Policy.