Social Media Policy

• BY POSTING ON ANY PENTAX Medical SOCIAL MEDIA SITE YOU AGREE TO THESE TERMS.

• Because of the evolving nature of social media platforms, these guidelines do not attempt to name every current and emerging platform. Rather, they apply to those cited and any other online platform available and emerging, including social networking sites and sites with user-generated content. Examples include, but are not limited to the following:
    o YouTube
    o Facebook
    o Flickr
    o LinkedIn
    o Twitter
    o Blogs
    o Social media content that is hosted internally and protected by PENTAX Medical ID/Password

• PENTAX Medical has opened publicly facing pages on social media sites for viewing content and/or videos and posting comments about PENTAX Medical. These social media sites include but are not limited to various blogs, bulletin boards, networks, multi-media and news media sites or other user generated content sites (“PENTAX-Hosted Media Site”). By accessing, viewing and/or posting any content related directly or indirectly to PENTAX Medical on any PENTAX-Hosted Media Site on the internet, you accept, without limitation or qualification, the following terms of use. If you do not agree to the terms of this Policy, you may not view or post any content to any PENTAX-Hosted Media Sites on the internet. Your use of PENTAX-Hosted Media Sites is acceptance of this Policy and has the same effect as if you had actually physically signed an agreement.

• By posting any content on any PENTAX-Hosted Media Site, you grant to PENTAX Medical the irrevocable right to reproduce, distribute, publish, display such content and the right to create derivative works from your content, edit or modify such content and use such content for any PENTAX Medical purpose.

• As a guest posting content to any PENTAX-Hosted Media Site on the internet, you agree that you will not: (i) violate any local, state, federal, and international laws and regulations, including but not limited to copyright and intellectual property rights laws, disclosures, and not reveal proprietary financial, patient care, or similar sensitive or private content, regarding any content that you send or receive via this Policy; (ii)transmit any material (by uploading, posting, email or otherwise) that is unlawful, disruptive, threatening, profane, abusive, harassing, embarrassing, tortious, defamatory, obscene, libelous, or is an invasion of another's privacy, is hateful or racially, ethnically or otherwise objectionable as solely determined in PENTAX Medical’s discretion; (iii) impersonate any person or entity or falsely state or otherwise misrepresent your affiliation with a person or entity;(iv) transmit any material (by uploading, posting, email or otherwise) that you do not have a right to make available under any law or under contractual or fiduciary relationships; (v)transmit any material (by uploading, posting, email or otherwise) that infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party; (vi)transmit (by uploading, posting, email or otherwise) any unsolicited or unauthorized advertising (including advertising of non-PENTAX Medical services or products), promotional materials, "junk mail," "spam," "chain letters," "pyramid schemes" or any other form of solicitation;(vii) transmit any material (by uploading, posting, email or otherwise) that contains software viruses, worms, disabling code, or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; (viii)harass another; or (ix)collect or store, or attempt to collect or store, personal data about third parties without their knowledge or consent; or to share confidential pricing information of any party.

• Employees may not post content that may be construed as political lobbying, solicitations or contributions. An Individual may not use a PENTAX-Hosted Media Site to link to any sites for political candidates or parties or use PENTAX-Hosted Media Site to discuss political campaigns, issues or for taking a position on any product, service, legislation, law, elected official or candidate, political party or movement.

• PENTAX Medical reserves the right to monitor, prohibit, restrict, block, suspend, terminate, delete, or discontinue your access to any PENTAX-Hosted Media Site, at any time, without notice and for any reason and in its sole discretion. PENTAX Medical may remove, delete, block, filter or restrict by any other means any materials in PENTAX Medical’s sole discretion. You understand and agree that PENTAX Medical may disclose your communications and activities with PENTAX Medical in response to lawful requests by governmental authorities, including U.S. Patriot Act requests, judicial orders, warrants or subpoenas, or for the protection of PENTAX Medical rights. You agree that in the event that PENTAX Medical exercises any of its rights hereunder for any reason, PENTAX Medical will have no liability to you.

• You shall defend, indemnify, and hold PENTAX Medical and its corporate affiliates and their respective officers, directors, employees, contractors, agents, successors and assigns harmless from and against, and shall promptly reimburse them for, any and all losses, claims, damages, settlements, costs, and liabilities of any nature whatsoever (including reasonable attorneys' fees) to which any of them may become subject arising out of, based upon, as a result of, or in any way connected with, your posting of any content to a PENTAX-Hosted Media Site, any third party claims of infringement or any breach of this Policy.

• You expressly acknowledge that you assume all responsibility related to the security, privacy, and confidentiality risks inherent in sending any content over the internet. By its very nature, a website and the internet cannot be absolutely protected against intentional or malicious intrusion attempts. PENTAX Medical does not control the third party sites and the internet over which you may choose to send confidential personal or health information or other content and, therefore, PENTAX Medical does not warrant any safeguard against any such interceptions or compromises to your information. When posting any content on an internet site, you should think carefully about your own privacy in disclosing detailed or private information about yourself and your family.

• You must not share confidential or proprietary information about PENTAX Medical and you must maintain customer and patient privacy.

• Write in the first person; Where your connection to PENTAX Medical is apparent, make it clear that you are speaking for yourself and not on behalf of PENTAX Medical. In those circumstances, you should include this disclaimer: "The views expressed on this [blog; website] are my own and do not reflect the views of PENTAX Medical." Consider adding this language in an "About me" section of your blog or social media profile.

• If you identify your affiliation to PENTAX Medical, your social media activities should be consistent with PENTAX Medical’s high standards of professional conduct.

• If you communicate in the public internet about PENTAX Medical or PENTAX Medical-related matters, you must disclose your connection with PENTAX Medical and your role at PENTAX.

• Ensure that your social media activity does not interfere with your work commitments.

• PENTAX Medical discourages staff in management/supervisory roles from initiating “friend” requests with employees they manage.  Managers/supervisors may accept friend requests if initiated by the employee, and if the manager/supervisor does not believe it will negatively impact the work relationship.

• For personal social media accounts where your connection to PENTAX Medical is apparent, you should be careful to avoid implying that an endorsement of a person or product is on behalf of PENTAX Medical, rather than a personal endorsement. As an example, LinkedIn users may endorse individuals or companies, but may not use PENTAX Medical's name in connection with the endorsement, state or imply that the endorsement is on behalf of PENTAX Medical, or state specifically that the endorsement is based on work done at PENTAX Medical.

• Unless approved by PENTAX Medical’s Marketing and Communications Department, your social media name, handle and URL should not include PENTAX Medical’s name or logo.

• THIS POLICY MAY BE UPDATED AT ANY TIME WITHOUT NOTICE, AND EACH TIME A USER ACCESSES A SOCIAL NETWORKING SITE, THE NEW POLICY WILL GOVERN, USAGE, EFFECTIVE UPON POSTING. To remain in compliance, PENTAX Medical suggests that you review the Policy, as well as the other website policies, at regular intervals. By continuing to post any content after such new terms are posted, you accept and agree to any and all such modifications to this Policy.

• Remember that all content contributed on all platforms becomes immediately searchable and can be immediately shared. This content immediately leaves the contributing individual faculty/staff members’ control forever.

• If someone or some group offers to pay faculty/staff for participating in an online forum in their PENTAX Medical role or offers advertising for pay and/or for endorsement, this could constitute a conflict of interest, and you should consult with the HOYA Legal Department prior to accepting or acting upon any such offer.

• If someone from the media or press contacts faculty or staff about posts made in online forums that relate to PENTAX Medical in any way, staff should alert their manager/leadership and contact the Marketing and Communications department before responding.

• If a patient or family member posts complaints about service or other issues, only authorized members of the Marketing and Communications Department may respond.

• Absent written authorization from the PENTAX Medical Marketing and Communications department, employees may not submit any content to a PENTAX-Hosted Media Site that contains any product or service endorsements for PENTAX Medical products or services.