/Privacy
Privacy2019-01-03T16:04:12+00:00

CommonWell Health Alliance Online Privacy Policy

Last Updated and Effective: December 21, 2018

CommonWell Health Alliance (“Alliance”, “we”, “us,” or “our”), as the operator of this website, understands that the privacy of your information is important to you. We have published this Privacy Policy to help you understand our privacy practices with regard to how we collect, use, and share information about you when you register for and or use the Alliance website, community, or its online materials located at https://www.commonwellalliance.org/ (the “Site”).

Definitions. The following terms are referred to in this Privacy Policy.

(a) “Personal Information” means information that identifies you or could reasonably be used to identify you and which is submitted to or collected by Alliance and maintained by Alliance in an accessible form. (b) “PHI” means protected health information as defined under the Health Insurance

Portability and Accountability Act of 1996, Pub. L. No. 104-191 (“HIPAA”). (c) “Services” means the services provided by Alliance. (d) “User Data” means all the information we use, send or collect, including but not

limited to Personal Information, PHI, and other information described in this Privacy Policy.

Informed Consent. By providing User Data to us or our affiliates, as further defined below, you acknowledge that you have been provided the opportunity to review this Privacy Policy and consent to the use of your User Data as described in this Privacy Policy. Please read this Privacy Policy carefully before accessing this Site or using our Services. If you do not agree to the terms and conditions of this Privacy Policy, you may not use the Site or our Services.

Changes to Privacy Policy. The Alliance reserves the right to change or modify this Privacy Policy, including but not limited to our information collection, use and disclosure practices, at any time, without prior notice. If we change our Privacy Policy, we will post the updated Privacy Policy on the Site so that our users and customers are always aware of what information we collect, use and disclose. The Privacy Policy will indicate the date it was last updated. Your continued use of the Site following an update to the Privacy Policy constitutes your assent to the updated terms and conditions, including with respect to information provided by you prior to such change. You should check the Site periodically to ensure that you are aware of our current Privacy Policy.

Categories Of Personally Identifiable Information And Other Information We May Collect.

We collect the following types of information:

  • Your Personal Information. We may collect Personal Information when you use or access the Site and certain pages of our business partners or if you send us correspondence or information.
  • Medical Information. Alliance’s Services may include the use and transfer of PHI and you agree that our use of such information is allowed. Our Services may also include the collection of medical information, patient medical records, medical facility information, medical provider information, and other information that may be related to or necessary to support the Services.
  • Non-Personal Information. Non-personal information refers to information that originates from but cannot be used to identify a specific individual. Alliance may collect non-personal information from you during your use of the Site, including your IP address, referral data, browser type, browser language, platform type, type of mobile or other computing device, and geographical data, such as zip code and geographic location. Your browser or device typically sends non-personal information to our servers without your intervention whenever you visit our website. For example, your browser or device may tell us your IP address (which may tell us generally where you are located) and the type of browser and device you are using. When you visit our website, your browser may also tell us information such as the page that led you to our website and, if applicable, the search terms you typed into a search engine that led you to our website.

Alliance collects non-personal information for purposes of tracking and analyzing user preferences and trends in order to improve the quality and design of the Site and Services and to create new features, promotions, and functionalities; for editorial and feedback purposes; for marketing and promotional purposes; for content improvement; and to customize the Services. This information may also be shared with our business partners on an aggregated personally anonymous basis. We use IP addresses for diagnostic and statistical purposes, to administer the Site, and to track and aggregate non-Personal Information.

  • Cookies. We may also use “cookies” to store your preferences in order to make your use of the Site more productive. Cookies are small files created by the Site that reside on your computer’s hard drive and store information about your use of a particular Site. We also use cookies to track the usage of our Site in order to enhance your use of the Site. When you visit the Site, our servers may send multiple cookies to your computer. Alliance uses cookies that are session-based and persistent-based. Session cookies allow us to continually verify your identity once you are logged into the Site and to process your online transactions and requests. All cookies are secured using encryption. We may use information from session and persistent cookies in combination with User Data to provide you with information about Alliance and offerings from us and our partners, and for other uses. You will not be able to access certain portions of the Site If you do not accept cookies from the domain https://www.commonwellalliance.org.
  • Third-Party Cookies. We may engage third parties to track and analyze usage and statistical information from users who visit the Alliance network. Alliance may also use other third-party cookies to track the performance of advertisements. The information provided to third parties does not include Personal Information, but this information may be re-associated with Personal Information after Alliance receives it. Alliance may also contract with third-party advertising networks that collect IP addresses and other website navigational information on the Alliance network and within emails and on third-party web sites. Ad networks follow your online activities over time by collecting website navigational information through automated means, including through the use of cookies. This information may be used to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process may also help us manage and track the effectiveness of our marketing efforts.
  • Web Beacons. We use web beacons alone or in conjunction with cookies to compile information about your usage of the Alliance networks and interaction with e-mails from Alliance. We use the information from web beacons to operate and improve the Services and our email communications, and to provide you with information about Alliance and our Services or our partner’s services.

How does the Alliance use the information it collects?

Alliance uses User Data in the following ways:

  • To Contact You. We may use your Personal Information to contact you. Using your contact information, we may also send you e-mail messages under the following circumstances, among others:

o to respond to an inquiry or request for information; o to thank you for contacting us; o to welcome you to the Site; o to explain new offerings and features of Site; and o to communicate with you regarding your use of the Site. o Your contact information may also be made available or provided to third-party service providers and contractors (such as the Site webmaster), including those who provide our services and services to our members.

  • To provide the Services. User Data may be used to fulfill your requests for our Services and to provide account access, service notifications, and for other purposes related to use of the Site and Services and other offerings.
  • To Improve Operations. User Data is used in connection with marketing, operating and improving our Services, creating new services or offerings, support, troubleshooting, and debugging.
  • For Medical Purposes. User Data may also be used for health care operations purposes and may include PHI.
  • For Other Purposes. User Data may also be used:

o For internal business purposes, such analyzing your information and other uses; o As necessary for Alliance to conduct its business; o To fulfill a contract or take steps associated with a contract; o In order for Alliance to comply with a court order, law, regulation or request of a

government agency; o To maintain the security and integrity of the Site.

Categories Of Third Parties With Whom We May Share Your User Data.

We May Share And Disclose Your Information In The Following Ways:

  • Aggregated Information. We may share certain aggregated demographic information with our business partners regarding the users of the Site. The aggregated information that we provide is not directly linked to any personally identifiable information.
  • Service Providers. Alliance may work with other companies that help us run our business. These companies, including third party vendors and other service providers, provide services such as delivering customer support, processing credit card payments, and sending e-mails on our behalf. Some service providers will have access to your User Data in order to provide services to you on our behalf. If the applicable information is to be provided or service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing the applicable service. Such third parties will be precluded from using your personal information for any purpose other than as authorized by Alliance. In addition, we may partner with other companies to jointly offer products or services. If you purchase or express interest in such a jointly-offered product or service, we may share User Data collected in connection with your purchase or expression of interest with those partners. We do not control our business partners’ use of User Data. If you do not wish for your information to be shared in this manner, you should not purchase or inquire about such jointly-offered products or services. Service providers who manage credit card processing will store, retain, and use billing information for the purpose of credit card

processing on our behalf. To facilitate our global operations, we may transfer and/or access User Data to or from locations outside the United States.

  • Government Entities. Alliance reserves the right to disclose User Data to respond to authorized information requests from government authorities, to address national security situations, or when otherwise required by law. Alliance may also use or disclose User Data if Alliance believes that use or disclosure is necessary to protect Alliance’s rights, to comply with applicable regulations, or to comply with a judicial proceeding, court order, or other legal process.

Does the Alliance transfer my personal information across national borders? The Site and the Alliance Services are designed for and authorized to be used and accessed solely from within the United States.

How to access and control your User Data You may update or change their registration information by logging into your Account on the Alliance network. Requests to Alliance to modify or delete your information will be handled within thirty (30) days after account ownership has been verified.

Internet, Email and Texting Usage and Confidentiality Risks. The Services may include communication through, access to, or operation of the Services by Alliance, you, or others, over the Internet, or through email and text messages, and other mediums of communication, and you authorize such communications. The confidentiality of User Data transmitted over the Internet, or through texting or email, or through other communication mediums, cannot be guaranteed. We urge you to exercise caution when transmitting User Data, including Personal Information and PHI, via text message, over the Internet, or through email, especially Personal Information and PHI related to a person’s health. You may be required to create or be given a user name and password related to the Services, and Alliance may transmit such information to you via unencrypted email, text message, or other delivery system. Such communications may be accessed by unauthorized parties, including due to incorrect contact information, intentional unauthorized access, or otherwise.

Is my personal information secure? We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security measures to protect your personal information. However, despite our efforts, no security controls are 100% effective and Alliance cannot ensure or warrant the security of your personal information.

Where does the Alliance store my personal information? Your personal information and files are stored on Alliance servers and the servers of companies we hire to provide services to us.

Communication Preferences. You may manage your receipt of marketing and non-transactional email communications by clicking on the “Unsubscribe” link located at the bottom of our marketing emails, ad additional opt out mechanisms may be utilized for services transmitted via text message. Additionally, you may send a request specifying your communications preferences to info@commonwellalliance.org. Users cannot opt out of receiving transactional emails related to their activities with Alliance or the Services.

How long does Alliance retain my information? We typically retain personal information related to our contract and business transactions with you for as long as you interact with us. Information and date related to the Services may be stored for six years or longer, and as required by law. Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests).

California Online Privacy Protection Act Notice. The California Online Privacy Protection Act also known as CalOPPA requires that online privacy notices disclose how a site responds to “Do Not Track” signals (“DNT”). There is no consensus yet on how the companies you encounter should interpret DNT signals. As a result, most websites, including this Site, have not changed their practices when they receive a DNT signal. You may send related requests to info@commonwellalliance.org.

Change of Control. In the event Alliance is involved in a merger, acquisition, or other change of control event, including but not limited to a sale of all or a portion of its assets, a change of control, or the sale of one of its product lines or divisions, User Data may be transferred to the buyer so that the buyer can continue to provide you with the Services.

Questions. Questions, concerns or requests regarding this Privacy Policy or the information practices of Alliance should be directed to: to info@commonwellalliance.org.