Effective Date: 5 November 2019
- WHAT INFORMATION WE COLLECT
- HOW WE COLLECT YOUR INFORMATION
- HOW WE USE YOUR INFORMATION
- Biometric Data
- DATA COLLECTION TECHNOLOGIES
- HOW WE SHARE YOUR INFORMATION
- YOUR CHOICES; INTEREST-BASED ADS
- YOUR CALIFORNIA RIGHTS
- CHILDREN’S INFORMATION
- LINKS TO OTHER SITES
- HOW WE PROTECT YOUR INFORMATION
- NOTE TO INTERNATIONAL VISITORS
- CONTACTING US
- Modernizing Medicine, Inc. and its affiliates (including Modernizing Medicine Gastroenterology, Inc., Modernizing Medicine Billing Services, LLC, Modernizing Medicine Data Services, Inc., and Modernizing Medicine Retail Solutions, Inc.) (collectively, “Modernizing Medicine”, “we”, “our”, or “us”), collect information from you when you visit, interact with, or use any of our websites (“Sites”), mobile applications (“Apps”), cloud-based or licensed on-premise electronic health records systems, including our Electronic Medical Assistant® or EMA® and gGastro® systems and associated systems such as practice management systems (collectively, “Systems”), or other products and services, including our reminder and other text messages services, self-service user portals, and patient portals (together with the Sites, Apps, and Systems, referred to collectively as the “Services”).
WHAT INFORMATION WE COLLECT
When you access and use the Services, we may collect the following types of information from you:
- “Personal Information” is information that can be used to identify, contact, or locate you. Examples of Personal Information include your name, address, email address, telephone number, employer, medical specialty, profession, biometric information such as your voice print and recordings, and practice and business information. Personal Information includes Location Information and may include Usage Data, but does not include Protected Health Information.
- “Location Information” is a subset of Personal Information that can be used to locate the device you use to access the Services. Location Information includes (i) the location of the device derived from GPS or Wi-Fi use, (ii) the IP address of the device or internet service used to access the Services, and (iii) any other information made available by you or others that indicates your current or prior location. If you do not want us to collect Location Information from your device, please disable the location setting(s) on your device or, if you are using an App, delete the App. Please note that disabling the location setting on your device may affect certain features of the Services and Apps.
- “Usage Data” is information that we automatically collect about your use of the Services and your device. This type of information does not usually, by itself, uniquely identify an individual, but nonetheless may include your IP address; your device’s MAC address, web browser, operating system, device model and manufacturer; performance issues; or your activity on the Services. With your consent, we may also collect information from certain native applications on your device (such as your device’s camera and photo album) to facilitate your use of certain features of the Services.
- “Protected Health Information” is personally identifiable health information that is protected by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”).
HOW WE COLLECT YOUR INFORMATION
- We collect the information you provide to us when you use our Services, for example when you:
- Register with our Services,
- Request a demo or support, whether on a Site, through a Service, or otherwise,
- Contact us with inquiries and comments,
- Complete and submit forms offered on the Services,
- Apply for employment,
- Register for webinars or events, whether on a Site, through a Service, or otherwise,
- Access or use the Services, or
- Enable the location services on your device.
- We may also obtain information about you from other sources, including the Internet and commercially available sources such as data aggregators, public databases, or other third parties. For example, if you are on a third-party website and you opt in to receive information from us, that website will forward your contact information to us so we may contact you as requested. In certain cases, we may combine this information with the information we collect from you to help us tailor our communications or improve our Services.
HOW WE USE YOUR INFORMATION
- We may use your information in the following ways:
- Provide you the Services and fulfill your requests. We may use your information to verify your identity, register you, administer your account, or provide you the information, products and services that you request. For example, we provide demos of our Services when you request them, respond to your questions when you contact us, and assist with any problems you report about our Services.
- Provide Services to our Providers. If you are a patient of a Provider, we use your information in connection with provision of our Services to the Provider.
- Communicate with you. We may contact you to share information and promotional materials that we think might be of interest to you. You may unsubscribe from receiving marketing emails from us by emailing us at firstname.lastname@example.org or using the unsubscribe link included in marketing emails.
- Enhance your experience. We use your information to personalize and enhance your experience when you use the Services, such as tailoring content and advertising and remembering your preferences.
- Improve our Services. Your information helps us improve the content and functionality of our Services. For example, we may (i) use our users’ demographics, interests, or behaviors to create new features and content, (ii) recreate a user session to improve the user experience, or (iii) use your information in the event of a Service performance issue.
- Products and Services. We may contact you to share and offer to you our products or Services, or products or services of our third-party vendors or service providers. We may use your information to try to identify if you may be interested in any of our products or Services.
- In addition to those purposes listed above, we may use your information for any other purpose disclosed to you at the time of collection, in a Transaction Document, in an authorization or consent, or via other means we may offer.
- Your practice and Modernizing Medicine may utilize the voiceprint in your recordings to transcribe text for a patient’s medical record, to improve the microphone feature and for other product improvement and development purposes of your practice and Modernizing Medicine. Your biometric data will be retained and destroyed, as applicable, in accordance with our policies.
DATA COLLECTION TECHNOLOGIES
- Web Beacons. A web beacon (also referred to as clear gif, pixel tag or single-pixel gif) is a transparent graphic image used in tandem with cookies that enables us to record a user’s actions. We use web beacons to count and track users who have visited those pages, verify system and server integrity, and for other statistical measures.
- User Experience and Support Products. We use third-party products that track and recreate user experiences using the Services. We use these products to improve the Services and to provide support for the Services.
- You can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, or to omit images (which will disable any pixel tags that may be included in them). Note that the opt-out will apply only to the browser that you are using when you elect to opt out of cookies. Please note, without cookies or pixel tags, you may not be able to take full advantage of all features of our Services.
- Some web browsers incorporate a “Do Not Track” feature (“DNT”) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not respond to web browser DNT signals. For more information about DNT signals, please visit allaboutdnt.com.
HOW WE SHARE YOUR INFORMATION
- We may share your information for the reason(s) disclosed to you at the time we collect it, as specified in any authorization or consent we may obtain from you, or in the following ways:
- At Your Direction: We will share your information with third parties if and when you direct us to. For example, if you request that we share your information with one of our business partners to take advantage of a feature that partner offers, we will share your information with that business partner.
- With our Affiliates, Business Units and Brands: We may share your information internally among our business units, brands, and our affiliates in order to provide you our Services, to provide our Services to the Providers, to offer you other products or services of ours or our third parties, and to improve our products and services or develop new ones.
- With Vendors: We may share your information with our vendors (including third-party hosting providers) that provide services on our behalf, such as for online account access, email marketing, advertising, promotions, newsletters, notices and other communications, or that assist us in monitoring, improving, and hosting the Services, and such third-party vendors may contact you regarding their own products and services.
- With Business Partners and Parties to Whom We Provide Services: We may share your information with our business partners and other third parties for whom we provide services in order to provide you our Services, to provide Services to the Providers, or generally to improve our products and services or develop new ones. Such business partners and other third parties may contact you in connection with providing their services that comprise part of our Services (e.g., an SMS (text) message reminder for an appointment) or to offer you their products or services that complement our Services (e.g., services to facilitate scanning of drivers’ licenses and insurance cards).
- In the Event of a Business Transaction: In the event we are exploring or go through a business transition or financial transaction, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, securities offering, or sale of all or a portion of our assets, we may disclose your information to a party or parties in connection with exploring or concluding such transaction.
- For Legal Purposes: We will disclose your information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant or similar legal process; or if necessary to assert or protect our rights or assets.
- We may share De-Identified Information in all legally permissible ways.
YOUR CHOICES; INTEREST-BASED ADS
- We encourage you to communicate your preferences to us about how we use your information.
- You may opt-out of receiving marketing communications from us by following the instructions included in a communication or by emailing us at email@example.com. If you opt out, we may still send you non-marketing communications, such as those about your account or our ongoing business relations.
- You may review and request changes to the Personal Information we have collected about you by contacting us as provided in the Contacting Us section below.
- We may use third-party service providers to serve advertisements on our behalf across the Internet. These advertising service providers may collect (through the use of Data Collection Technologies) information about your visits to and interactions with our Services. In addition to the information about your visits to our Site, our service providers may also use the information about your visits to other websites to target advertisements for products and services available from us. If you would like more information about this practice and to know your choices for not having this information used by third-party service providers, please visit networkadvertising.org. You may manage your third-party advertising preferences by clicking here.
- Some features of our Apps may require access to certain native applications on your mobile device, such as the camera and photo storage applications (e.g., to take and upload photos and videos). If you decide to use these features, we will ask you for your consent prior to accessing the applications and collecting information. Note that you can revoke your consent at any time by changing the settings on your device.
- With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our Apps.
YOUR CALIFORNIA RIGHTS
California Civil Code Section 1798.83 gives California residents the rights to request certain information regarding our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes. We may share your Personally Identifiable Information with affiliated third parties, some of which do not share the name of Modernizing Medicine, for their own direct marketing purposes. You may request information regarding the disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes by sending an email to: firstname.lastname@example.org or writing us at:
Modernizing Medicine, Inc.
4850 T-Rex Avenue, Suite 200
Boca Raton, Florida 33431
Attention: Privacy Officer
LINKS TO OTHER SITES
HOW WE PROTECT YOUR INFORMATION
The security of Personal Information is important to us. We use reasonable safeguards aimed to protect against unauthorized use, disclosure, alteration or destruction of the Personal Information we collect and maintain. You should keep in mind, however, that no data transmitted over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. We cannot be responsible for the transmission, storage, processing, or retention of data on or over the internet or on or by your or third parties’ systems, networks, hardware, or software. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to or from our Services.
NOTE TO INTERNATIONAL VISITORS