Effective Date: May 6, 2016
The Chiasm Network (“us,” “we,” or “Chiasm”) is committed to respecting the privacy rights of our Clients and other users of THE CHIASM NETWORK (the “Site”) and related websites, applications, services and mobile applications provided by THE CHIASM NETWORK and on/in which this Privacy Policy is posted or referenced (collectively, the “Services”). Our site uses 128-bit GCM encryption (the standard used by most banks to protect their customers information) and all data is transferred over SSL and TLS 1.2 (FIPS compliant security standards used by the U.S. Government for secured traffic) We created this Privacy Policy (“Privacy Policy”) to give Client confidence as Client uses the Services and to demonstrate our commitment to the protection of privacy. All data is stored in a physically and electronically secure facility behind firewalls. Data backups are protected by high-grade encryption (FIPS 140-2 certified) which means that your data stays secure and unreadable. Our intrusion detection system monitors our data 24/7 and alerts us to any unusual activity. We engage third party security experts to periodically test our service and processes and we run the SSAE-16 Type audit annually. This Privacy Policy is only applicable to the Services. This Privacy Policy does not apply to any other website or digital service that Client may be able to access through the Services or any website or digital services of THE CHIASM NETWORK business partners, each of which may have data collection, storage and use practices and policies that may materially differ from this Privacy Policy. Client’s use of the Services is governed by this Privacy Policy and the Agreement (as the term “Agreement” is defined in our Terms of Use). Any capitalized term used but not defined in this Privacy Policy shall have the meaning in the Agreement.
BY USING THE SERVICES, CLIENT AGREES TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND CLIENT HEREBY CONSENTS TO THE COLLECTION, USE, AND SHARING OF CLIENT’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF CLIENT DOES NOT AGREE WITH THIS PRIVACY POLICY, CLIENT CANNOT USE THE SERVICES. IF CLIENT USES THE SERVICES ON BEHALF OF SOMEONE ELSE CLIENT’S PATIENT) OR AN ENTITY , CLIENT REPRESENTS THAT CLIENT IS AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.
2.1 Personal Information
2.1.1 Personal Information Generally
We help you find and learn about nearby healthcare providers, booking appointments with the healthcare providers of your choice (each “Your Healthcare Provider”) and managing and forwarding your patient’s health history forms and other health-related information to share with other Healthcare Providers (the “Services”). As part of providing the Services we may collect, use, share and exchange health history forms and other health-related information with the selected Healthcare Providers. Some of the Services require us to know more about Client so that we can best meet Client’s needs. When Client accesses these Services, we may ask Client to voluntarily provide us certain information that personally identifies (or could be used to personally identify) Client (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information: (1) contact data (such as Client’s e-mail address and phone number); (2) demographic data for Client (such as gender, date of birth and zip code); (3) insurance data (such as insurance carrier, insurance plan, member ID, group ID and payer ID); (4) medical data (such as the doctors, dentists or other health care providers (“Healthcare Providers”) to whom Client has referred its patients or been contacted by Client for an appointment, reasons for visit, dates of visit, patient’s medical history, and other medical and health information Client chooses to share with us), and (5) other information that Client voluntarily chooses to provide to us, including without limitation SSN, unique identifiers such as passwords, and Personal Information in emails or letters that Client sends to us. Client may still access and use some of the Services if Client choose not to provide us with any Personal Information, but the features of the Services that require Personal Information will not be accessible to Client.
2.1.2 Billing, Collection and Payment Information [tbd]
2.2 Traffic Data
We also may automatically collect certain data when Client uses 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 Client accessed the Services; (6) geolocation information; and (7) other statistics and information associated with the interaction between Client’s browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.
We may also collect additional information, which may be Personal Information, as otherwise described to Client at the point of collection or pursuant to Client’s consent.
2.3 HIPAA and PHI
Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some of the demographic, health and/or health-related information that THE CHIASM NETWORK collects as part of providing the Services may be considered “protected health information” or “PHI”. All of our staff is HIPAA trained to ensure that we remain focused on a patient’s privacy. All of our employees are required to regularly complete security training administered by a third party completely familiar with all HIPAA guidelines. Specifically, when THE CHIASM NETWORK receives identifiable information about Client or Client’s patient (severally and collectively referred to as “Client”) from or on behalf of Client’s Healthcare Providers, this information is PHI. HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed by Healthcare Providers and health plans (“Covered Entities”) as well as companies like THE CHIASM NETWORK, that provide certain types of assistance to Covered Entities (called “Business Associates”).. THE CHIASM NETWORK may only use and disclose Client’s PHI in the ways permitted by Client’s Healthcare Provider(s). In addition, Client have been or will be asked to e-sign the THE CHIASM NETWORK User Authorization (the “THE CHIASM NETWORK Authorization”). As a condition of creating this account, you are required to read and agree to our Privacy Policy. This Privacy Policy explains how we process and share information received by you that is not covered by HIPAA. Client’s decision to e-sign the THE CHIASM NETWORK Authorization is entirely voluntary. If Client chooses to e-sign the THE CHIASM NETWORK Authorization, Client agrees that THE CHIASM NETWORK may use and disclose Client’s PHI in the same way it uses and discloses Client’s Personal Information that is not PHI. These uses and disclosures are described in this Privacy Policy. To the extent any provision in the THE CHIASM NETWORK Authorization is inconsistent with this Privacy Policy or other provisions of the Agreement, then the provision in the THE CHIASM NETWORK Authorization only controls with respect to Client’s PHI. If Client do not e-sign the THE CHIASM NETWORK Authorization, then Client’s Personal Information that is not PHI is governed by this Privacy Policy and Client’s Personal Information that is PHI is used and disclosed only as permitted by Client’s Healthcare Provider(s)
We collect information (including Personal Information and Traffic Data) when Client uses and interacts with the Services, and in some cases from third party sources. Such information includes:
4.2. Options for Opting out of Cookies and Mobile Device Identifiers
Some web browsers (including some mobile web browsers) allow Client to reject Cookies or to alert Client when a Cookie is placed on Client’s computer, tablet or mobile device. Client may be able to reject mobile device identifiers by activating the appropriate setting on Client’s mobile device. Although Client are not required to accept THE CHIASM NETWORK’s Cookies or mobile device identifiers, if Client block or reject them, Client may not have access to all features available through the Services.
Client 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. When Client use these opt-out features, an “opt-out” Cookie will be placed on Client’s computer or tablet indicating that Client do not want to receive interest-based advertising from NAI or DAA member companies. If Client delete Cookies on Client’s computer or tablet, Client may need to opt out again. For information about how to opt out of interest-based advertising on mobile device identifiers, please visit http://www.applicationprivacy.org/expressing-Clientr-behavioral-advertising-choices-on-a-mobile-device. Please note that even after opting out of interest-based advertising, Client may still see THE CHIASM NETWORK’s advertisements that are not interest-based (i.e., not targeted toward Client). Also, opting out does not mean that THE CHIASM NETWORK is no longer using Tracking Tools — THE CHIASM NETWORK still may collect information about Client’s use of the Services even after Client have opted out of interest-based advertisements and may still serve advertisements to Client via the Services based on information it collects via the Services.
4.3. How THE CHIASM NETWORK Responds to Browser “Do Not Track” 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 THE CHIASM NETWORK, do not take action to respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.]
We use Client’s information, including Personal Health Information, to provide the Services to Client and to help improve them, including to:
We may disclose certain information that we collect from Client:
You expressly agree that we may use your PHI to:
You also agree that THE CHIASM NETWORK can disclose your PHI to:
If THE CHIASM NETWORK discloses your PHI, THE CHIASM NETWORK will require that the person or entity receiving you PHI agrees to only use and disclose your PHI to carry out its specific business obligations to THE CHIASM NETWORK or for the permitted purpose of the disclosure (as described above). THE CHIASM NETWORK cannot, however, guarantee that any such person or entity to which THE CHIASM NETWORK discloses your PHI or other information will not re-disclose it in ways that you or we did not intend or permit.
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