Effective Date: July 20, 2017
We believe we are the authority on the patient experience, which means that we are committed to protecting your privacy and we take great care with your personal information. This policy will help you understand how we use and protect your data. If you have any questions, feel free to contact us at firstname.lastname@example.org. Thank you so much for choosing CKH CONCIERGE KEY Health.
2. Information We Collect
2.1 Personal Information Generally
Some of the Services require us to learn more about you so that we can best meet your needs. When you access the Services, we may ask you to voluntarily provide us certain information that personally identifies you or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information: (1) contact data (such as your e-mail address and phone number); (2) demographic data (such as your gender, your date of birth and your zip code); (3) insurance data (such as your insurance carrier, insurance plan, member ID, group ID and payer ID); (4) medical data (such as the doctors, dentists or other healthcare specialists, professionals, providers, or organizations (collectively, “Healthcare Providers”) you have visited, your reasons for visit, your dates of visit, your medical history, and other medical and health information you choose to share with us); and (5) other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, and Personal Information in emails or letters that you send to us. We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You may still access and use some of the Services if you choose not to provide us with any Personal Information, but features of the Services that require your Personal Information will not be accessible to you.
2.2 Billing, Collection and Payment Information
2.3 Traffic Data
We also may automatically collect certain data when you use the Services, such as (1) IP address; (2) domain server; (3) type of device(s) used to access the Services; (4) web browser(s) used to access the Services; (5) referring webpage or other source through which you accessed the Services; (6) geolocation information; and (7) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.
2.4 HIPAA and PHI
Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some demographic, health and/or health-related information that CKH collects as part of providing the Services may be considered “protected health information” or “PHI.” Specifically, when CKH receives identifiable information about you from or on behalf of your Healthcare Providers, this information is considered PHI.
3. How We Collect Information
We collect information (including Personal Information and Traffic Data) when you use and interact with the Services, and in some cases from third party sources. Such means of collection include:
- When you use the Services’ interactive tools and services, such as searching for Healthcare Providers, searching for available appointments with Healthcare Providers and completing medical history forms (“Medical History Forms”) prior to Healthcare Provider appointments;
- When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys, questionnaires and the like;
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices;
- If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable;
- Through cookies, web beacons, website analytics services and other tracking technology (collectively, “Tracking Tools”), as described below; and
- When you use the “Contact Us” function on the Site, send us an email or otherwise contact us.
4. Tracking Tools and “Do Not Track”
4.1. Tracking Tools
We may use tools outlined below in order to provide our Services to, advertise to, and to better understand users.
- Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).
- Website Analytics: We may use third-party website analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Site. We use the information collected from these services to help make the Services easier to use and as otherwise set forth in Section 5 (Use of Information).These website analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across websites that do not use their services.
- Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help CKH learn more about our users’ demographics and internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data.
- Cross Device Matching: To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we may also provide de-identified data these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.
4.2. Tracking Tools
We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools to display CKH ads on other websites or services based on information about your use of the Services or your interests (as inferred from online activity). Such partners may include third-party service providers, advertisers, advertising networks or platforms, and agencies. Other Tracking Tools used by our partners may collect information when you use the Services, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help CKH learn more about our users’ demographics and internet behaviors.
4.3. Options for Opting out of Cookies and Mobile Device Identifiers
Some web browsers (including some mobile web browsers) allow you to reject Cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept CKH’s Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
You may opt out of receiving certain Cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) consumer opt-out page or by installing the DAA’s AppChoice app (for iOS; for Android) on your mobile computing device. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete Cookies on your computer, tablet or mobile computing device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device/. You will need to opt out of each browser and device for which you desire to apply these opt-out features.
Please note that even after opting out of interest-based advertising, you may still see CKH advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that CKH is no longer using Tracking Tools — CKH still may collect information about your use of the Services even after you have opted out of interest-based advertisements and may still serve advertisements to you via the Services based on information it collects via the Services.
4.4. How CKH Responds to Browser “Do Not Track” (DNT) Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. If a website operator elects to respond to a particular DNT signal, the website operator may refrain from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many website operators, including CKH, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.
5. Use of Information
We may use information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) to better understand who uses CKH and how we can deliver a better healthcare experience (for example, testing different kinds of emails has helped us understand when and how patients prefer to get Wellness Reminders for preventive care), or otherwise at our discretion.
We use information, including Personal Information, to provide the Services and to help improve the Services, to develop new services, and to advertise (for example, to display CKH ads on other websites). Such use may include:
- Providing you with the products, services and information you request;
- Responding to correspondence that we receive from you;
- Contacting you when necessary or requested, including to remind you of an upcoming appointment;
- Providing, maintaining, administering or expanding the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
- Customizing or tailoring your experience of the Services, which may include sending customized messages;
- Notifying you about certain resources, Healthcare Providers or services we think you may be interested in learning more about;
- Sending you information about CKH or our products or Services;
- Sending emails and other communications that display content that we think will interest you and according to your preferences;
- Showing you advertisements, including interest-based or online behavioral advertising;
- Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts; and
- Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
6. Disclosure of Information
In certain circumstances, and in order to perform the Services, we may disclose certain information that we collect from you:
- We may share your Personal Information with Healthcare Providers with whom you choose to schedule through the Services. For example, if you complete a Medical History Form using the Services in advance of an appointment and elect to share it with your selected Healthcare Provider, we may share your Medical History Form with such selected Healthcare Providers.
- Provided that you choose to use the applicable Services, we may share your Personal Information with your Healthcare Providers to enable them to refer you to and make appointments with other Healthcare Providers on your behalf or to perform analyses on potential health issues or treatments.
- We may share your Personal Information with Healthcare Providers in the event of an emergency.
- To make your information more securely and easily accessible to your Healthcare Providers, we may share your Personal Information with Health Information Exchanges and related organizations that collect and organize your information (such as Regional Health Information Organizations). The goal of such organizations is to facilitate access to health information to improve the safety, quality, and efficiency of patient-centered care. More information on Health Information Exchanges can be found here and here.
- We do not sell email addresses to third parties. We may share your Personal Information with our partners to customize or display our advertising.
- We may share your Personal Information and Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, Website analytics, or ad serving) and/or who make certain services, features or functionality available to our users.
- We may share your Personal Information with the insurance provider you identify to us (and via our partners) to determine eligibility and cost-sharing obligations, and otherwise obtain benefit plan information on your behalf.
- We may transfer your information to another company in connection with a merger, sale, acquisition or other change of ownership or control by or of CKH (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to: (1) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process; (2) protect the rights, property or safety of you, CKH or another party; (3) enforce the Agreement or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.
We may disclose information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) at our discretion.
7. Public Information
You agree that any information that you may reveal in a review posting or online discussion or forum is intentionally open to the public and is not in any way private. We recommend that you carefully consider whether to disclose any Personal Information in any public posting or forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.
8. Storage and Security of Information
The security of your Personal Information is important to us. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, when you enter sensitive information on our Site, we encrypt that information using Secure Socket Layer (SSL) technology.
We store and process your information on our servers in the United States and abroad. We maintain industry standard backup and archival systems.
Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can update that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification.
9. Controlling Your Personal Information & Notifications
If you are a registered user of the Services, you can modify certain Personal Information or account information by logging in and accessing your account. If you wish to close your account, please email us at email@example.com. CKH will deactivate your account and the related information at your request as soon as reasonably possible. Please note, however, that CKH reserves the right to retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Agreement and take other actions permitted by law.
You must promptly notify us if any of your account data is lost, stolen or used without permission.
10. Information Provided on Behalf of Children and Others
If you are less than 18 years of age, you may not use the Services or submit any information about yourself, unless you are under the supervision of a parent or legal guardian. We do not knowingly allow individuals under the age of 18 to create user accounts that allow access to our Site, and we do not knowingly collect Personal Information submitted by individuals under the age of 18. Only a parent or legal guardian of an individual under the age of 18 may create a user account for and submit Personal Information related to such minor. If we discover that any Personal Information about a minor has been submitted by someone other than a parent or legal guardian, we will remove such information from our server(s) and database(s) as soon as possible.
11. Other Websites
CONCIERGE KEY Health, LLC
4040 MacArthur Blvd., Suite 310
Newport Beach, CA 92660
Phone: (949) 260-1700