February 20, 2018

Privacy Policy

Our Privacy Policy

This Privacy Policy was last updated on November 1st, 2018.

Introduction

This Privacy Policy is designed to inform all users of the MedCohere Inc. (“MedCohere” , “we”, “us” or “our”) technology platform, websites and services (collectively, the “Platform”) about how we gather and use personal information collected by us in connection with your use of our Platform. This Privacy Policy covers how MedCohere treats your Personally Identifiable Information (“PII”) and Protected Health Information (“PHI”) (PII and PHI, collectively hereafter “Personal Information”) that MedCohere collects, receives, maintains, stores or transmits, including information you transmit or submit to our Platform. Your Personal Information includes information that individually identifies you or is information about you that can be traced back to you, your IP address, or your location. It may include, but is not limited to your name, address, email address, phone number, and information about your health.

References in this Privacy Policy to “you” or “your” refer to both you and any person or entity on whose behalf you act, including without limitation, patients whose care is being coordinated through our Platform, as applicable.

 Purpose

Our Platform enables dental providers, other providers and their staff to better coordinate the care of patients during referrals. Our goal is to facilitate referral management, collaboration, coordination, communication and the exchange of Personal Information among your patients, dental providers, and other providers, including without limitation, through the use of e-fax, secure email, referral system, patient forms, analytics and e-consults.

Consent

By using the Platform, you consent to the use of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time by emailing us info@medcohere.com. However, withdrawing consent may result in your inability to continue using certain Platform features.

 Confidentiality of Health Information

Dental providers and other providers using the Platform are subject to laws and regulations governing the use and disclosure of health information they create or receive. Included among those laws is the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health of 2009 (“HITECH”), and the regulations adopted thereunder (collectively the “HIPAA Rules”). When we store, process or transmit PHI (as such term is defined by the HIPAA Rules) on behalf of such a dental or health care provider, we do so as its “business associate” (as also defined by the HIPAA Rules). When we operate as a business associate, we are also subject to such laws and regulations governing the use and disclosure of PHI, and we are prohibited from, among other things, using PHI in a manner that the dental or health care provider itself may not. We are also required to, among other things, apply reasonable and appropriate technical, physical and administration safegaurds to protect the confidentiality, integrity and availability of PHI we store and process on behalf of such dental or health care providers. For example, we limit the dissemination of your PHI to only such designated staff as is minimally necessary to carry out the stated purposes we have communicated to you.

To the extent the HIPAA Rules require us to create and/or publish a notice of privacy practices; the Notice of Privacy Practices in Schedule 1 is hereby incorporated into this Privacy Policy as an integral component of our privacy practices.

 Changes to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version online, as indicated by the last updated date at the end of the Privacy Policy. You should check this page occasionally to review any changes. If we make any material changes affecting you as determined by MedCohere and you are a registered user of our Platform, we will provide notice to you through our Platform. This helps you to always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. We may request you to agree to the new terms, otherwise your continued use of the Platform, and/or continued provision of Personal Information to us, will be subject to the terms of the then-current Privacy Policy.

 Information Collection and Use

MedCohere collects Personal Information when you register with MedCohere or when you upload Personal Information into MedCohere’s Platform. It is always your choice whether or not to provide us with your Personal Information. Whenever you visit our websites, MedCohere also receives and records information on our server logs from your browser, including your IP address, MedCohere’s cookie information, and the pages you request.

Below is a detailed list of what Personal Information MedCohere may collect when you use the Platform and how we may utilize your Personal Information with your consent:

  1. Registration — When you register for the Platform, we may collect certain Personal Information as part of the registration process, including for example, your name, company name, email addresss, phone number and other related contact information. We may use your contact information to send you information about our Platform or other services we may provide to you. We may also use your phone number for security verificiation purposes (i.e. to validate you are the correct user). We may collect your billing address and credit card information for billing purposes.
  2. Analytics — We collect analytics data related to your use of the Platform such as the number of referrals or e-faxes received, number of econsults, or number of your patients in the Platform. We may use your analytics data in de-identified form for any lawfully premitted purpose as described under this Privacy Policy.
  3. Social Information — We collect information that you provide to us through the Platform pertaining to the patients and providers with whom you consent to share (or from whom you have received proper consent to share) Personal Information, as well as communications within the Platform between you and such individuals.
  4. Demographic Information — We may collect demographic information, such as geographic location, as part of your profile in the Platform. We may utilize your demographic information and other data derived through your utilization of the Platform to help us improve the Platform.
  5. Surveys and General Feedback — From time to time, we may send you survey questions or contact you with questions related to your experience to provide us with feedback on our Platform. We collect any responses that you provide. Participation in surveys or general feedback questions are elective and do not otherwise impact your access to the Platform.
  6. Marketing Communications and Advertisements — We may occasionally use your Personal Information to contact you about new product and features. You may affirmatively opt-out of receiving future marketing messages or advertisements and remove your name from our mailing lists. The opt-out provisions do not apply to information collected by cookies or used internally to recognize you and/or facilitate your utilization of the Platform, or information we may retain to comply with legal requirements.
  7. Audit Logs — We may collect or generate systems operations data incidentally including your Personal Information for the purposes of logging access/activity in our Platform. Audit logs help keep our Platform secure, including identity management, fraud prevention and the investigation of other illegal activities such as cyber-attacks or to detect bots.

De-identified and Aggregated information

In addition to the uses of Personal Information above, we may remove the identifiable parts of your information to create de-identified forms (“De-identified Information”). De-identified Information may be compiled with other data in aggregated forms (“Aggregated Information”). We may use this data in the following ways:

 Disclosure for Business Purposes — We may license, sell or otherwise share De-identified and Aggregated Information with corporate partners, insurance companies, health care providers, institutional clients, investors and contractors for any purposes related to our business practices.

  1. Product Improvement — We may use De-identified and Aggregated Information for product improvement purposes (e.g., data analytics to monitor the use of the Platform or to increase the Platform’s functionality and user-friendliness).
  2. Research — We may use De-identified and Aggregated Information for research whether scientific, marketing, or business in nature. This research may be made public through publication such as within a scientific journal.

Personal Information Sharing and Disclosure

MedCohere does not rent, sell, or share your Personal Information with other people or non-affiliated companies, except to provide products or services you have requested, when we have your authorization to share such information, or when we provide the information to companies or consultants working on our behalf under confidentiality agreements. These companies and consultants (i.e., our cloud service provider or software developers) do not have any independent right to share your Personal Information.

We may be required to disclose your Personal Information in response to a legal process, for example, in response to a court order or a subpoena. We also may disclose your Personal Information in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, to verify or enforce compliance with our Privacy Policy, or as otherwise required by law. In addition, we may transfer your Personal Information to an entity or individual that acquires, buys, or merges with MedCohere, or our other business units. In such case, your Personal Information would remain subject to the promises and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you.

 Accessing, Changing, and Deleting Your Personal Information

You may request access, changes, or deletions to your Personal Information and request information about our collection, use and disclosure of such information by contacting us at info@medcohere.com. We use best efforts to keep our records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your Personal Information as soon as possible. Your rights to access, change, or delete your Personal Information are not absolute. We may deny you such rights due to technological contrainsts, when required by law or if the request would likely reveal Personal Information about a third party.

Right to Data Portability

You have the right to receive the Personal Information that you provided to MedCohere in a structured, commonly used and machine-readable format. You also have the right to transfer your Personal Information to another referral management system without hindrance from MedCohere. Your right to data portability is not absolute. We may deny you such right when required by law or where technically infeasible.

Retention of your Personal Information

We will retain your Personal Information for, at minimum, as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as, account recovery. All retained Personal Information will remain subject to the terms of this Privacy Policy.

General Information

  1. Links — The MedCohere Platform may contain links or deep links to other websites, open search results, public feeds, or curated channels. Users should be aware of this when they leave our Platform and are encouraged to review the privacy policies of each third party website. Moreover, MedCohere is not responsible for any disclosures to third parties to whom you choose to disclose your Personal Information directly. This Privacy Policy applies solely to information collected by MedCohere in relation to the Platform.
  2. Termination — You may unenroll from our Platform at any time by emailing us at info@medcohere.com. MedCohere reserves the right to decide, at its sole discretion, to no longer offer you the Platform at any time.
  3. Children — MedCohere does not knowingly collect Personal Information from children under the age of 13, and our Platform is not directed at users under the age of 13. If we find that Personal Information has inadvertently been collected for an individual under the age of 13, we will immediately delete it.

United States Jurisdiction and Governing Law

Our servers are located in the United States and are subject to the applicable U.S. local and national laws. Those who choose to access the Platform do so on their own initiative and understanding that their use of the Platform is subject to U.S. laws and regulations. If you choose to access or use the Platform, you consent to the use and disclosure of information in accordance with this Privacy Policy and subject to such laws. Accordingly you hereby acknowledge that your Personal Information may be available to the United States government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

California Online Privacy Protection Act Notice

  1. Do Not Track — We currently do not support the Do Not Track (DNT) browser setting or respond to DNT signals. DNT is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you.

 

  1. Third Party Marketing — If you are a California resident then under Cal. Civ. Code § 1798.83 you may request and obtain from us once a year, free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the contact information provided below. In your request, please attest to the fact that you are a California resident and provide a current California address for your response.

 Contact Us

If you have questions, suggestions, or complaints about your privacy please email MedCohere at info@medcohere.com.

We are committed to resolving complaints about your privacy and our collection or use of your Personal Information in a timely fashion.  If you submit a reasonable complaint or inquiry concerning your data privacy, we will promptly investigate and we will respond to the inquiry or complaint within 45 days. If it is justified, we will take appropriate remediation measures.

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