Privacy Policy

HC Concierge, Inc.

Privacy Policy

Revision Date: August 31, 2017

 

For more information or if you have any questions about these terms of use, please contact us at support@hcconcierge.com.

  1. Personal Information

Your privacy is very important to all of us at HC Concierge, Inc., an Oregon corporation (“Company”, ‘we”, or “us”). We have established this privacy policy (“Privacy Policy”) to explain to you how your personal information is protected, collected, and used. Personal information is information about you that is personally identifiable, such as your name, email address, insurance data, medical data, and other information, that is not otherwise publicly available (“Personal Information”).

The privacy practices of this Privacy Policy apply to our Services (as defined in our Terms of Use) accessible through the Company website, www.hcconcierge.com, and related websites, applications, services and mobile applications (collectively, the “Website”), and your use of the Website. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the Website, and our practices for collecting, using, maintaining, protecting, and disclosing that information. 

This policy applies to information we collect:

  • On this Website;
  • In email, text, and other electronic messages between you and this Website; and
  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website or using Company Services, you agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.  By submitting Personal Information to us through the Services, you expressly consent to our use and disclosure of your Personal Information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Company Terms of Use.

  1. Information Collection & Use

Company collects Personal Information from you through the Services to allow us to provide the Services that will most likely meet your needs and preferences.  We only collect Personal Information about you that we consider necessary for achieving this purpose.

In general, you can browse Company and “opt-out” from providing us with any Personal Information.  Once you agree to provide us with Personal Information, you are no longer anonymous to us. If you choose to use and/or purchase certain Services we may require you to provide contact and identity information, billing information, and other Personal Information as indicated on the forms throughout Company. Where possible, we indicate which fields are required and which are optional. You always have the option to not provide information by choosing not to use or purchase a particular service.

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number or any other information the Website collects that is defined as Personal or Personally Identifiable under an applicable law (collectively, ”personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • Directly from you when you provide it to us;
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and/or
  • From third parties, for example, our business partners.

We may track certain information based upon your behavior on Company. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand our customers. This information may include, but may not be limited to, the URL that you just came from, which URL you go to next, your computer browser information, and your IP address. 

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on Company, we may collect and retain such information in a file specific to you.

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website;
  • Records and copies of your correspondence (including email addresses), if you contact us; and/or
  • Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Under some circumstances we may require some additional financial information. We use your financial information, including credit card information, to verify the accuracy of your name, address and other information, as well as to bill you for your use of our services and products.

  1. Use of Your Personal Information

We use your Personal Information, and other information we obtain from your current and past activities on Company to: present our Website and its contents to you; resolve disputes; troubleshoot problems; measure consumer interest in our products and services; inform you about online and offline offers, products, services, and updates; customize your experience on Company; detect and protect us against error, fraud and other criminal activity; to provide you with notices about your account or subscription, including expiration and renewal notices; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; enforce our Terms of Use; and as otherwise described to you at the time of collection. We may compare and review your Personal Information for errors, omissions, and accuracy.

You agree that we may use your Personal Information, including your email address, to improve our marketing and promotional efforts, to analyze Company usage, to improve the Services, and to customize Company’s content, layout, and services. These uses improve Company and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe, and customized experience while using Company and/or the Services.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

  1. Communications from Company

We may occasionally send you information on products, services, special deals, and promotions. Out of respect for your privacy, we provide you a way to unsubscribe from each of these communications.  If you no longer wish to receive our promotional communications, you may opt-out of receiving them by following the instructions included in each such communication or by contacting us.

You will be notified when your Personal Information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if access to our products is temporarily suspended for maintenance, we might send you an email or text message. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, please do not submit your Personal Information through Company.

  1. Information Sharing and Disclosure

As a matter of policy, we do not sell, rent, or share any of your Personal Information, including your email address, to third parties for their marketing purposes without your explicit consent. However, the following describes some of the ways that your Personal Information may be disclosed in the normal scope of business to provide our services and products to customers:

  • Purpose: We may disclose your Personal Information to fulfill the purpose for which you provide it. [For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.]
  • External Service Providers: There may be separate services offered by third parties that we refer to as external service providers that may be complementary to your use of Company. If you choose to use these separate services or products, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policy. We do not disclose your Personal Information, including your email address, to external service providers unless you provide your explicit consent. With your consent we may provide some of your Personal Information to the external service provider offering such services, for your convenience. To prevent our disclosure of your Personal Information to an external service provider, you can decline such consent or simply not use their services or products. Because we do not control the privacy practices of these third parties, you should evaluate their practices before deciding to use their services. [We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.]
  • Internal Service Providers: We may use third parties that we refer to as internal service providers to facilitate or outsource one or more aspects of the business, product and service operations that we provide to you and therefore we may provide some of your Personal Information, including your email address, directly to these internal service providers. These internal service providers are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced Company related operation, unless you have explicitly agreed or given your prior permission to them for additional uses. If you provide additional information to an internal service provider directly, then their use of your Personal Information is governed by their applicable privacy policy.
  • Buyers or Successors: To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
  • Legal Requests: Company cooperates with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights, to help protect you, other users, and Company from bad actors. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, state, telephone number, email address, username history, and fraud complaints without a subpoena. Without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss, or report suspected illegal activity.

 

  • Other Disclosures: We may also disclose your Personal Information: (1) to enforce or apply our terms of use and other agreements, including for billing and collection purpose; or (2) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose Personal Information, including your email address, to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Information that they collect from Company. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should neither rely upon nor expect, that your Personal Information or private communications will always remain private.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  • We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

You can review and change your personal information by logging into the Website and visiting your account profile page.

 You may also send us an email at support@hcconcierge.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@hcconcierge.com.

  1. Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track users’ movements around the Website and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information. We track trends in users’ usage and volume statistics to create a more efficient and usable Website and product offerings, and to determine areas of the Website or our Services that could be improved to enhance the user and customer experience. Log files are used on Company, and in any link to Company from an email.

  1. Cookies and Related Technologies

When you use the Services, we collect certain information by automated or electronic means, using technologies such as cookies, browser analysis tools, and web server logs. As you use the Services, your browser and other electronic devices communicate with servers operated by us and our services providers to coordinate and record the interactivity and fill your requests for services and information.

The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to Company by your computers or mobile devices. These servers are operated and the cookies managed by us or our service providers.

For example, when you visit the Website, Company and our service providers may place cookies on your computers or mobile devices. Cookies allow us to recognize you when you return, and track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account and preferences.

Some cookies are temporary, whereas others may be configured to last longer.  “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided, and storing your preferences.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including [traffic data,] [location data,] [logs,] and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

 The information we collect automatically is statistical, and may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our the Website [and our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies. 

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We may use third parties such as network advertisers to serve advertisements on our Website and on third-party websites or other media (e.g., social networking platforms) that enable us and third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors, and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website, App, or on other websites or applications. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

We may use third-party analytics companies, such as Google Analytics, to evaluate use of our Website and Services. We or our service providers use these tools to help us understand use of, and to improve, our Website and Services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (“LSOs”), to perform their services.

  1. Manage Your Security Settings

You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain third party advertising companies online at http://www.networkadvertising.org/choices/.

You may manage how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

If you wish to opt out of receiving offers directly from Company service providers, you can follow the opt-out instructions in the emails that they send you.  

  1. Links to Other Company Platforms

Company may contain links that are not owned or controlled by Company.  Please be aware that we are not responsible for the privacy practices of such third parties. We encourage you to read the privacy statements of each and every third-party platform that collects personally identifiable information. This Privacy Policy applies only to information collected by Company.

  1. Security

We follow generally accepted industry standards to protect Personal Information, including your email address, submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.  Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. [We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.]

  1. Notice to Residents of Countries outside the United States of America

Company is headquartered in the United States of America. Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored

  1. Changes in this Privacy Statement

If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate 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 Policy at any time, so please review it frequently.

  1. Children Under the Age of 13  

We do not knowingly collect information from minors. Our Website is intended for and directed towards adults. Our Services are not directed to minors and we do not knowingly collect Personal Information from minors.  Our Website is not intended for children under 13 years of age. No one under age 13 may provide any [personal] information to [or on] the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not [use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use]. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@hcconcierge.com.

  1. How we Comply with HIPPA and Protect your PHI.

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some of your Personal Information, such as demographic, health and/or health-related information that we collect as part of providing the Services, may be considered “protected health information” or “PHI.” Specifically, when we receive identifiable information about you, such as identifiable health information, including without limitation, information about your past, present, or future physical or mental health condition, the name and license number of your recommending physician, contact information of that physician, the method to verify the recommendations authenticity, the expiration date of the recommendation, and the details of orders placed through the website is considered PHI. Further, a healthcare provider’s medical data is considered PHI and includes information provided by doctors or other healthcare specialists, professionals, or providers (collectively, “Healthcare Providers”) you have visited, the reasons for your visit, the dates of your visit, your medical history, and other medical and health information you choose to share with us.

HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. We may only use and disclose your PHI in the ways permitted by you and your Healthcare Providers and such permission may be revoked at any time.

The following describes the circumstances in which we may use or disclose your PHI:

  • Treatment, Payment and Healthcare Operations. We are permitted to use and disclose your PHI for purposes of treatment, payment and healthcare operations. For example:
    • Treatment. We may disclose your PHI to another physician or healthcare provider for purposes of a visit or in connection with the provision of follow-up treatment.
    • Healthcare Operations. We may use and disclose your PHI in connection with our healthcare operations, such as providing customer services, storing your purchase and delivery history, and conducting quality review assessments. We may engage third parties to provide various services for us. If any such third party must have access to your PHI in order to perform its services, we will require the third party enter into an agreement that binds the third party to the use and disclosure restrictions outlined in this Policy.
  • Authorization. We are permitted to use and disclose your PHI upon your written authorization, to the extent such use or disclosure is consistent with your authorization. You may revoke any such authorization at any time.
  • As Required by Law. We may use and disclose your PHI to the extent required by law.
  • Research and Marketing. We may under certain circumstances, use or disclose PHI that is necessary for research or marketing purposes. Such disclosure will deidentify you from your PHI.

You have the following rights regarding the PHI maintained by us:

  • Confidential Communication. You have the right to receive confidential communications of your PHI. You may request that we communicate with you through alternate means or at an alternate location, and we will accommodate your reasonable requests. You must submit your request in writing.
  • Restrictions. You have the right to request restrictions on certain uses and disclosures of PHI for treatment, payment, or healthcare operations. You also have the right to request that we restrict its disclosures of PHI to only certain individuals involved in your care or the payment of your care. You must submit your request in writing. We are not required to comply with your request.
  • Inspection and Copies. You have the right to obtain a paper copy of this Policy from us at any time upon request. We may charge a fee for the costs of copying, mailing, or other supplies associated with your request. To obtain a paper copy of this notice, please contact the Company by sending an email to support@hcconcierge.com.  We may deny your request to inspect and/or copy your PHI in certain limited circumstances. If that occurs, we will inform you of the reason for the denial, and you may request a review of the denial.
  • Amendment. If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You must provide a reason that supports your request. We may deny your request if: (i) it is not in writing or does not include a reason to support your request; (ii) information is not part of the medical information stored by us; (iii) the information was not created by us; (iv) information is not part of information you are permitted to inspect and copy; or (v) the information is complete and accurate.
  • Breach Notification. You have the right to be notified in the event that the Company (or one of our business associate) discovers a breach of unsecured PHI.
  • Accounting of Disclosures. You have a right to receive an accounting of all disclosures we have made of your PHI. However, that right does not include disclosures made for treatment, payment or healthcare operations, disclosures made to you about your treatment, disclosures made pursuant to an authorization, and certain other disclosures. You must submit your request in writing and you must specify the time period involved (which must be for a period of time less than six years from the date of the disclosure). Your first accounting will be free of charge. However, we may charge you for the costs involved in fulfilling any additional request made within a period of 12 months.

 

 

© 2017 HC Concierge, Inc.