Privacy Policy


PRIVACY POLICY

This privacy policy (“the Policy” or “Privacy Policy”) describes how Healthcelerate Inc., (“we,” “us,” or “Healthcelerate”), and its subsidiaries and affiliated companies, may collect, use, and share information about you that we obtain through www.healthcelerate.com (“the Website”) and through www.caremesh.com (the “careMESH Services”). We take the private nature of your personal information seriously and this Privacy Policy describes how we treat the information we collect. This Policy does not apply to third party websites to which we provide links.


Section 1: The Website - www.healthcelerate.com

1A. INFORMATION WE COLLECT

The following types of information may be collected on the Website:

  • We may collect information you provide us if you sign up for or request certain services from us on our Website. If you are interested in learning more about Healthcelerate and our careMESH services, we may ask for personal information, such as your name, practice name and size, email address, telephone number, state, and other information needed to contact you.

  • We may collect your IP address and other data about the equipment used to visit the Website, the patterns of searching and browsing that preceded access to the Website, and the patterns of searching and browsing on the Website.

1B. HOW WE USE YOUR INFORMATION

We use information collected through tracking technologies, such as cookies and web beacons, to improve the functionality of the Website. For example:

  • We track the number of visitors using certain portions or features of the Website to make changes that may be necessary to improve functionality;

  • We track the popularity of features on the Website to guide the development of new ones;

  • We assess the ways in which users become aware of or access the Website to gauge the quality and methods of our advertising.

We also use this information, along with other Personally Identifiable Information collected through the Website, for statistical and analytical purposes, for improving the Website, and for marketing purposes.  We use this information to provide you Healthcelerate services and products, send you further information regarding Healthcelerate, and to better collect information that allows us to analyze and improve the features and performance of our website and our other products and services.

Unless you affirmatively elect not to receive (“opt out”) communications from us, Personally Identifiable Information we collect from you may be used to respond to inquiries you submit to us; facilitate your access to Healthcelerate resources and materials; send you general informative announcements, electronic newsletters, and marketing-related emails about us or our products; and aid us in serving you better. At the bottom of every newsletter or general informative email we send you, you will be given the opportunity to opt out or unsubscribe from future email communications.

1C. SHARING YOUR INFORMATION

We may share your Personal Information with third parties who perform functions or services on our behalf as outlined in this Privacy Policy and as otherwise permitted by law. In the event we share Personal Information with third parties, we take reasonable measures to ensure such parties observe the relevant portions of the Privacy Policy, restrict the use and retention of the information to the purposes and timeframe of such outsourcing, and take other measures to require the observance of the relevant portions of the Privacy Policy.

We also engage certain service providers for purposes of tracking and associating internet search and browsing behavior with our advertisements and to provide functionality on the Website. We enable them to use tracking technologies, such as cookies and web beacons, on or in conjunction with the Website. These companies may use non-personally identifiable information about your visits to other websites, together with non-personally identifiable information about your purchases and interests from other online and offline sources, to provide ads about goods and services of interest to you. The use and collection of information by these service providers is governed by their respective privacy statements and thus is not covered by this Policy. In addition, we may share Website usage information with these service providers to manage and target ads and for market research purposes.  Finally, information obtained through these processes may be combined with personally identifiable information to analyze our marketing efforts.

We will only share Personally Identifiable Information with third party vendors, consultants, agents, partners, and other service providers with whom we contract to help us provide or improve our services.

Please note that Healthcelerate will only share your information in accordance with this Policy, except in the following situations:

  • You have given us your consent to share or use information about you;

  • We believe that we need to share information about you to provide a service that you have requested from us or from others;

  • We may disclose any information we deem necessary, in our sole discretion, to comply with any applicable law, regulation, court order, subpoena, legal process, or government regulation. We may work with law enforcement officials in investigating activities that are illegal or that violate Healthcelerate's rules.

  • We believe that it is necessary to protect our rights or to avoid liability or violations of the law.

1D. UPDATES TO THIS PRIVACY POLICY

We reserve the right to make periodic updates and revisions to the Policy. Any changes will be posted on this page. Please check this page to review whether any changes have been made to the Policy.

1E. WHAT ELSE DO YOU NEED TO KNOW?

This Website is not intended for minors under the age of eighteen, and Healthcelerate does not wish to obtain any information from or about them through this website. If you are under eighteen years old, do not use this Website.  Our Website includes social media features, such as “sharing” functions on LinkedIn and Twitter. Your interactions with these features are governed by the privacy policies of the companies providing these features, and we do not control and are not responsible for the privacy practices of, or the data available on, the websites of third parties.

1F. KEY TERMS

The following key terms apply to this Privacy Policy:

  • TRACKING TECHNOLOGIES: Tracking technologies include technologies such as “cookies” and “web beacons,” which are used to analyze trends, administer the Website, and help us provide you with a more personalized experience and improve our services. Cookies are small amounts of text files that are sent from a website to your computer’s browser when you visit the site, and serve several useful purposes, like letting you navigate between pages more efficiently, saving your preferences, and enhancing your user experience with the website. Web beacons (also called transparent GIFs, web bugs, pixels, or action tags) are strings of code that deliver a tiny graphic image on a web page or in an email which is used to monitor the behavior of the user visiting the website or sending the email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page on which the web beacon is placed. In general, any file served as part of a web page can act as a web beacon.

  • INTERNET PROTOCOL (“IP”) ADDRESS: A numerical label separated by periods that identifies every device (e.g., computer, printer) that participates in a network. IP addresses allow these devices to communicate with one another and transmit relevant information.

  • PERSONALLY IDENTIFIABLE INFORMATION (“PII”): For purposes of this Policy, PII includes: first and last name; physical mailing address including street name and city/town; email; and telephone number.


Section 2: The careMESH Services - www.caremesh.com

2A. SCOPE AND PURPOSE

Healthcelerate, Inc. ("Healthcelerate") is committed to protecting your privacy and ensuring you have a positive experience in using our secure, cloud-based communications platform for exchanging health information (the "careMESH Services"). This portion of the Privacy Policy covers the privacy practices employed when individual users access and use the careMESH Services. This Privacy Policy is incorporated into the careMESH Service Terms of Use.

2B. DEFINITIONS

Defined terms used in this Privacy Policy shall have the following meaning:

  • “Account Information” includes your name, username, phone and fax numbers, email addresses, date of birth, geolocation, postal address and/or postal code, mobile phone numbers, the unique National Provider Identifier (NPI) for the covered health care provider with whom you are affiliated, the last four digits of your social security number and your account preferences.

  • "User Content” is any data, file, record, information, document, picture, video, correspondence, including without limitation any PII, PHI or electronic health record, that users upload, collect, store, copy, and share with other users of the Caremesh Services.

  • “Host Information” means certain information about your computer, device, browser, your device ID, related device identifier information and systems, IP address along the network path, operating system type and version, and browser type, client version, the MAC address of your internet connection MAC address, and geographical location.

  • “Personally Identifiable Information” (or “PII”) means information that alone or when in combination with other information may be used to readily identify, contact, or locate an individual, such as: name, address, email address, phone number, social security number, insurance-issued ID numbers and PHI. PII does not include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.

  • “Profile Information” includes your gender, office or practice address and contact information, practice specialty areas, profession, credentials, medical school, year of graduation, practice type, taxonomy, place of employment, hospital affiliations, insurance accepted, languages spoken, and clinical interests.

  • “Protected Health Information (or “PHI”) has the meaning given to this term in 45 CFR 160.103. which is part of the Health Insurance Portability and Accountability Act (“HIPAA”) of 1996.

  • “Usage Information” means the information we record about your usage of, and interactions with, the careMESH Services, including actions taken, date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to logins, clicks, and other feature usage information.

Any other initially capitalized terms not defined in this Privacy Policy shall have the meaning defined in the careMESH Service Terms of Use.

2C. WHAT IS COVERED BY THIS PRIVACY POLICY

This Privacy Policy outlines how we monitor, collect, use, track, protect and share your Personally Identifiable Information when you access and use the careMESH Services, your interactions with careMESH Services, and the Personally Identifiable Information of other users of the careMESH Services. By using the careMESH Services, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you may not be able to access the careMESH Services.

Healthcelerate will not disclose, move, access or use User Content except as provided in this Privacy Policy and the careMESH Service Terms of Use.

Healthcelerate does not control and is not responsible for the privacy practices of, or the data saved on or accessed through, the systems or applications of third parties, and we urge you to evaluate the soundness of these practices for yourself.

This Privacy Policy does not apply when:

  • You have given us your consent to share or use Personally Identifiable Information;

  • We believe that we need to share Personally Identifiable Information to provide a service that you have requested from us or from others; 

  • We may disclose any information we deem necessary, in our sole discretion, to comply with any applicable law, regulation, court order, subpoena, legal process, or government regulation. We may work with law enforcement officials in investigating activities that are illegal or that violate Healthcelerate’s rules;

  • We believe that it is necessary to protect our rights or to avoid liability or violations of the law.

2D. HIPAA AND BUSINESS ASSOCIATE AGREEMENTS

Any User Content submitted or accessed through the careMESH Service will be held in accordance with applicable law, including but not limited to HIPAA. Unless your sponsoring organization has entered into an enterprise agreement with Healthcelerate that contains a specific Business Associate Agreement (BAA) , the BAA incorporated into the careMESH Service Terms of Use shall apply.

Healthcelerate does not make any representations or guaranty about whether the careMESH Services are adequate to meet your own organization’s privacy and security standards, laws, rules or regulations. You are responsible for assessing your privacy and security needs and determining whether your use of the careMESH Service is appropriate to comply with your obligations.

2E. WHAT INFORMATION DO WE COLLECT?

The following types of information may be collected through the careMESH Services:

  • During the account set-up process, we will ask for your Account Information. Healthcelerate cannot provide the careMESH Services without this information.

  • When you set up your account profile, we may ask for your Profile Information. During this process, we may also request your photograph to be used in connection with the careMESH Services.

  • Whenever you use the careMESH Services, we automatically collect Host Information and Usage Information.

  • When a user sends a message using the careMESH Services, the sender will be able to view if the receiver has viewed the message.

  • When you use the Services, we may ask for contact information on other individuals to enable you to send messages to those contacts through the Services.

  • We may collect data about the equipment used to visit the Services and the patterns of utilization of the Services.

2F. MESSAGES AND PATIENT RECORDS

A key differentiator of the careMESH Services is the ability to securely and efficiently share information and patient records with other users of the careMESH Services and to send private messages to other users regarding the same. Healthcelerate considers these messages and patient records transmitted and or shared via the careMESH Service to be the private correspondence between the sender and the recipient.

Healthcelerate does not monitor, edit or disclose the contents of a user’s private communications, except as set forth in this Privacy Policy. However, if your use and access to the careMESH Services is through an enterprise agreement with your employer or a third-party sponsoring entity, that sponsoring organization will have administrative privileges for all of its associated users and may be able to access their messages, patient records, user information, transaction logs and User Content.

You acknowledge and agree that Healthcelerate does not endorse the content of any user communications and is not responsible or liable for any unlawful, harassing, libelous, privacy invading, abusive, threatening, harmful, vulgar, obscene, tortuous, or otherwise objectionable content, or content that infringes or may infringe upon the intellectual property or other rights of another.

2G. HOW DO WE USE YOUR INFORMATION?

Use of Personally Identifiable Information. In addition to the uses identified elsewhere in this Privacy Policy, we collect your Personal Information that is necessary in order for us to provide the careMESH Services, such as your name, phone number, employer (covered entity), email address and authentication information. By using and accessing the careMESH Services, you are consenting to our collection, storage, transmission and use of this Personal Information as outlined in this Privacy Policy and solely in order to permit us to make available the careMESH Services to you. We will not sell or transfer this Personal Information to any third party for marketing activities unrelated to the careMESH Services.

Use of Your Profile Information. We make your Profile Information available to all other users of the careMESH Services in our Directory of Users, regardless if those users are affiliated with your, your practice, your employer(s) or any other covered entity with which you are associated. We may also supplement your Profile Information with information about you that we obtain from third parties and other users of the careMESH Services.

Use of Host and Usage Information. We also collect and record Host Information and Usage Information, such as the features and functionality of the careMESH Services that you access, as well as the frequency with which you access certain features and functionality and other attributes regarding how you use (or don’t use) the careMESH Services. We use this information in order to operate, improve, and optimize the careMESH Services. We may also use Host Information and Usage Information alone or in combination with your Personal Information to (a) provide you with personalized information about Healthcelerate, (b), to gauge the quality and methods of our advertising and (c) for statistical and analytical purposes to improve the careMESH Service.

Unless you affirmatively elect not to receive (“opt out”) communications from us, Personally Identifiable Information we collect from you may be used to send you (a) careMESH Service notifications informing you of Messages or Patient Records that have been sent to you, (b) communications about certain features of the Service, (c) notifications about careMESH Service availability, and (d) responses to inquiries you submit to us. 

2H. SHARING YOUR INFORMATION OR INFORMATION SUBMITTED BY YOU

We may share information contained in the Directory of Users with other users of the careMESH Services.

We may share Personally Identifiable Information with third parties who perform functions or services on our behalf as outlined in this Privacy Policy and as otherwise permitted by law. If we share PII with third parties, we take reasonable measures to ensure such parties observe the relevant portions of the Privacy Policy, restrict the use and retention of the information to the purposes and timeframe of such outsourcing, and take other measures to require the observance of the relevant portions of the Privacy Policy.

We will only share PII with third party vendors, consultants, agents, partners, and other service providers with whom we contract with to operate or support our Services.

2I. USE OF COOKIES AND OTHER WEB TECHNOLOGIES.

Cookies are commonly used, automated data collection tools comprised of a small text file that are copied to your computer (hard disk) or device when you use and access the careMESH Services, or when you open certain HTML-formatted emails. Web beacons (also called transparent GIFs, web bugs, pixels, or action tags) are strings of code that deliver a tiny graphic image on a web page or in an email which is used to monitor the behavior of a user of the careMESH Services.

Together with our third-party partners, we use “cookies,” web beacons, pixel tags, scripts or other similar technologies to help us personalize your experience. In addition, these technologies permit us to do the following:

  • Analyze trends and collect statistics regarding the usage of the careMESH Services;

  • Administer the careMESH Services;

  • Tailor information presented to you based on your browsing preferences, such as language and geographical region;

  • Track visitors’ and users’ movements around the careMESH Services to better understand features of the careMESH Services that are used more frequently than others;

  • Gather demographic information about our visitors, users and customers;

  • Ensure that users can stay logged into the careMESH Service until he/she affirmatively decides to log out; and

  • Improve the performance and efficiency of the careMESH Services.

These technologies store Account Information and Usage Information, and we only use these technologies using transport encryption.

Reconfiguring Your Web Browsers to Reject Cookies. You have the ability to accept or decline cookies. Most web browsers are configured to automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. You can refuse cookies by turning them off in your browser. If you’ve set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. If you re-configure your browser settings to decline cookies so that we cannot collect and record any Account Information, you will not be able to access and use any of the careMESH Services.

2J. OPTING OUT AND UNSUBSCRIBING

Reviewing, Correcting and Removing Your Personal Information. Upon request, Healthcelerate will provide you with information about whether we hold any of your Personally Identifiable Information. If you provide us with your Personally Identifiable Information, you have the following rights with respect to that information:

  • To review the user information that you have supplied to us;

  • To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us;

  • To request that your user information not be used to contact you;

  • To request that your user information be removed from any solicitation list that we use;

  • To request that your user information be deleted from our records; and

  • To opt out of being solicited by Healthcelerate.

To exercise any of these rights or if you have any other question, please contact us at info@healthcelerate.com or by mail to Healthcelerate Inc., c/o Chief Compliance Officer, 12110 Sunset Hills Road, Suite 600, Reston, VA 20190 USA. We will respond to your request to change, correct, or delete your information within a reasonable timeframe (usually within sixty (60) days).

2K. DO-NOT-TRACK

There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you or the way you interact with that website. This is referred to as a Do-Not-Track (“DNT”) signal.

Please note that our websites may not recognize or take action in response to DNT signals from web browsers. At this time, there is no universally accepted standard for what a company should do when a DNT signal is detected. In the event a final standard is established, we will assess how to appropriately respond to these signals.

For more detailed information about cookies, Do-Not-Track and other tracking technologies, please visit http://www.allaboutcookies.org/ and https://allaboutdnt.com/.

2L. UPDATES TO THIS PRIVACY POLICY

We reserve the right to make periodic updates and revisions to this Privacy Policy. Any changes will be posted on this page. Please check this page to review whether any changes have been made to the Policy.

2M. INFORMATION RETENTION

Healthcelerate may retain archived information for a period of seven years (or longer if required by law) or as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Privacy Policy.


YOUR COMMENTS AND CONCERNS

If you have any questions or comments, please contact us by:

Healthcelerate Inc.
c/o Chief Compliance Officer
12110 Sunset Hills Road, Suite 600
Reston, VA 20190 USA

 

Last Updated: October 16, 2018