IntelliCentrics

IntelliCentrics SEC3URE Platform Privacy Policy

OVERVIEW

IntelliCentrics, Inc. (collectively “IntelliCentrics,” “we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information about you in relation to the www.sec3ure.com platform (the “Platform”).

This IntelliCentrics SEC3URE Privacy Policy is effective from December 19, 2018

ACCEPTING THIS PRIVACY POLICY

By accepting our Terms of Use, you are confirming that you have read and understand this Privacy Policy including how and why we use your personal information. If you do not want us to collect or process your personal information in the ways described in this Privacy Policy, you should not use the Platform. We are not responsible for the content or the privacy policies or practices of any of the Platform’s users (“Users”), third-party websites imbedded or linked through the Platform or third-party applications.

WHAT INFORMATION WE COLLECT OR RECEIVE

We collect your personal information in the course of your use of the Platform in a few different ways. Here are some of the types of information we gather:
  • information you give us, such as your name, password, employer, credentials, facilities, in order to register and participate in the IntelliCentrics community; credit card information you send to our payment processor in order to carry out transactions; and other personal information you may choose to provide us, to provide the services you are requesting;
  • information we collect from third parties who perform services you choose or authorize, such as information from your authorized representatives (such as an employer), from medical training, licensing, regulatory, or credential verification organizations and public records, from third-party service providers, from payment facilities, or others (note that for many third-party services, you will provide your information directly to that service provider and not to us);
  • information about your computer for system administration purposes, such as your IP address, operating system and browser type, which we may combine with data collected via “session cookies,” but this information is statistical data about our User’s browsing patterns and generally does not identify our Users; and
  • non-personal information that is collected on an aggregate basis as you browse our Site.
This may include the following "Personal Information:"
  • Identification information such as name, log-in, password, organization, mail and email addresses, phone number(s), For medical staff specifically: former name(s), Social Security number, place and date of birth, gender, or other responses to security questions, driver’s license number, photographs or bio-identifiers for proof of identity;
  • Employment-related information, such as your employment status, employers, positions, and lengths of employment;
  • Credentials and other records of your education, training, certifications, professional history, and qualifications;
  • Authorizations and purchase orders for products or services, such as Confirmation of acceptable background checks on a pass/fail basis based on the requirements set by IntelliCentrics, our third-party service provider, and/or by each healthcare provider or facility you select (we only collect or store details for those such as practitioners with expressed authorization); Vaccination appointments, histories and/or proof of immunization; Pass/fail records of titer or other medical tests, based on Center for Disease Control standards, and other medical records as you authorize; Radiation dosimeter purchases and exposure histories; records of Training and Continuing Education; and Certificates of Insurance coverage which may be provided to us;
  • Access history, training records, and other information regarding your previous interaction(s) at facilities;
  • Any other information or documents you may upload to your profile, such as photos, or in questions, comments, complaints, or inquiries submitted to us; and
  • Website traffic data and data from emails, attachments, email addresses, metadata, and URLs. (For more information, see the section “How We Use Cookies and Similar Technologies” below, and our Cookie Policy.)
We only collect Personal Information which you choose to submit to us or authorize us or others to obtain. You may choose not to submit information to us, or to permit us or others to obtain it. If you choose not to do so, however, we will not be able to provide the corresponding service to you.

The information we collect does not qualify as “protected health information” as defined by the Health Insurance Portability and Accountability Act of 1996, as amended from time to time (“HIPAA”), because the information is (i) willingly disclosed by Users to IntelliCentrics, either directly by a User or indirectly by another person who has been granted valid authorization by the User or third party to disclose such information; (ii) not used or disclosed by IntelliCentrics for purposes of healthcare treatment by a healthcare provider or health plan, thus not qualifying as a use or disclosure by a “covered entity” under HIPAA; and (iii) not used by IntelliCentrics for or on behalf of a covered entity for purposes of a User’s healthcare or treatment services, thus not qualifying as a use or disclosure as a “business associate” under HIPAA. IntelliCentrics takes extra precautions with respect to the User information it collects, however, and has implemented this Privacy Policy and related security safeguards to protect such information from inappropriate access or use.

HOW WE USE YOUR INFORMATION

We use your Personal Information to operate, provide, and improve the Platform. Our purposes for using your personal information include:
  • Providing the Platform to you, along with products and services that you request through the Platform, including providing healthcare providers and facilities you select with access to your profile, assistance with their credentialing processes and databases, and access tracking and control services, and responding to questions, comments, complaints, and other inquiries;
  • Assisting third-party service providers in providing products and services that you request on the Platform, such as vaccinations, medical tests and histories, background checks, training, insurance, radiation dosimeters and reports, and other products and services;
  • Administering the Platform and running our business, including protection and improvement of the Platform, account management and analysis, customer support, communication, and market analysis;
  • Marketing of our products and services that we think may be of interest to you; and
  • Otherwise as we have a legitimate interest. For example, we may use it to communicate with you, to administer our Site and run our business, to protect ourselves and others, for our own individual or market research, or in connection with a corporate transaction such as a merger or acquisition. We may also use it when, in our judgment, we believe it is necessary, appropriate, or required, such as communicate with third parties such as insurers, service providers, consultants, advisors, or agents, or to comply with and enforce legal and regulatory requirements, agreements, and policies, or to protect a person’s vital interests. We may also use it for any other purpose disclosed to you at the time you provide personal information or with your consent.

HOW WE SHARE YOUR INFORMATION

Information about our Users is an important part of our business, but we are not in the business of selling our Users’ personal information to others. We share personal information only as described below.

We may share your Personal Information with others, as follows:
  • Employees, contractors, and agents who “need to know” in order to serve you: We may share your personal information with our employees, contractors, and agents who “need to know” in order to serve you. These may include third-party service providers who perform services for us, such as our payment processor, but their use of such information is limited to the performance of their duties and is consistent with our purposes for using such information;
  • Third-party service providers you choose or authorize: We may share your personal information with the third-party services providers you select, who provide services to you as you choose or authorize including credential records, background checks, vaccination appointments and records, titer tests and other medical records, radiation dosimeters and reports, education and training, insurance coverage, and payment processing. In most cases, you will be directed to their websites and provide your information yourself. We require our service providers to maintain the confidentiality and security of your Personal Information and to use it only to provide services on yours or our behalf or as otherwise required or permitted by applicable law;
  • Other third parties you choose or authorize: We may share certain of your personal information with other third parties whom you have chosen or authorized, who are permitted by law to receive it, and who need that information in order to manage their accounts with us (such as your employer, or other entity on whose behalf you work); and
  • Protection of ourselves or others: We may share your personal information when we believe release is appropriate: to (a) comply with a law, legal process or regulations; (b) protect the vital interests of a person; (c) protect our property, Platform, services or legal rights; or (d) support our audit, compliance and governance functions.
  • Business Transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information may be one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the individual consents otherwise). Also, in the unlikely event that IntelliCentrics or substantially all of its assets are acquired, your information will be one of the transferred assets.
  • At Your Option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

LINKS TO THIRD-PARTY SERVICE PROVIDERS

We provide links to websites of third-party service providers in order to make their services available to you through the SEC3URE Platform (“Linked Website”).

Linked Websites are independent from us and are not governed by this Privacy Policy. We do not manage or control them or the products or services they provide, and consequently, accept no liability for them.

All of the Linked Websites use tracking “cookies.”

As a convenience to you, links to the privacy notices of the Linked Websites are provided below, together with certain information taken from them as of November 2018. But the descriptions below are not complete and may not include information which is important to you. You should consult their privacy notices before electing to receive products or services from them: IQ Data Systems, Inc. d/b/a Backgrounds Online (“BGO”) provides background screening services. It states that it uses the ClickTale web analytics service to improve navigation and forms on its website; may place “advertising cookies” on a visitor’s computer so that when they visit another site that has an agreement with its advertising network, the other side will use the cookie to display an advertisement to them on the other site; and provides personally-identifying information to third parties such as courts, state agencies, employers, schools, references, credit bureaus, and other information sources, in order to prepare background reports. It states that it recognizes its responsibilities under the Fair Credit and Reporting Act; uses information only for purposes allowed by law; requires written authorization before conducting searches; provides pre-adverse action notification; provides full report only to (and allows discussion with) the user, not IntelliCentrics; commits to data security; that information is only to be used exclusively by BGO; and that it requires affiliates to handle information in accordance with its policies. ClearStar Inc. provides medical testing services and related reports. It states that it uses tracking “cookies,” and may disclose personally-identifying information to third parties in order to provide the service its user has requested. It may also “engage third-parties in processing services requested by customers, such as screening for…occupational health.” ClearStar states that it requires such third parties to abide by ClearStar privacy policy and institute safeguards to protect the confidentiality of that information; recognizes its responsibilities under Fair Credit and Reporting Act; commits to compliance with applicable law; requires written authorization before performing services, including notice that report may be re-disclosed by client outside of HIPAA; disclaims responsibility for links to third-party Site; reports only status and “pass-fail” result to IntelliCentrics; allows access and correction; commits to data security; and is Privacy Shield-compliant. CVS/MinuteClinic provides vaccination services and related reports. It states that it uses cookies of its own and third parties for website improvement and for advertising; commits to comply with applicable law; requires written authorization before services; disclaims coverage of HIPAA and requires IntelliCentrics to maintain security and confidentiality as well as MinuteClinic. Landauer provides radiation dosimeters and related services, including records of radiation exposure. It states that it is the data controller of information submitted to it, and “may allow others to serve advertisements on our behalf across the Internet and to provide analytics services through cookies, web beacons and other technologies;” commits to comply with applicable law; has two privacy policies, one for European and one for U.S. residents; disclaims responsibility for links to third party Site; commits to data security; may use information for own marketing unless opt out or law requires opt in; does not distribute to outsiders for their own direct marketing. Zuora provides payment processing services. Even though Zuora is embedded in the Platform, it performs its services through its own portal and website and according to its own privacy policies. Its Privacy Statement provides in part that it “partner[s] with third parties to display advertising on our Web site or to manage our advertising on other Site. Our third-party partners may use technologies such as cookies to gather information about your activities on this Site and other Sites to provide you advertising based upon your browsing activities and interests. If you do not wish to have this information used for the purpose of serving you interest-based ads, you may opt out by clicking here (or if you are located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads. InContact, Inc. (“inContact”) provides live-chat functionality on the Platform. Even though customer-service provided through such feature is provided by us, inContact requires Users to provide their RepID#, Email, and Phone Number directly to inContact. Medical Sales Advocates (“MSA”) provides insurance procurement services through Nicholas Hill Benefits Group, Inc., which states that it reports only when and what services have been completed; does not share any personal data or underwriting information with any third party without express permission; uses industry-standard data protection; disclaims responsibility for links to third party Site; supplies information to insurance companies only with approval, and not for marketing or other purposes without permission (or as required by law); and will not sell personal information to third parties. Medcom, Inc. provides training and education services. It states that it commits to take “all measure necessary” to preserve and protect any personally identifiable information of (or privacy obligations related to) IntelliCentrics, its customers, or those of their respective patients or customers of which Medcom may become aware or to which it may gain access.” For professionals, Medcom states that it will report to credentialing agencies, only for purposes of providing continuing-education credits or maintaining accreditation.

If you decide to access any of the Linked Websites, or obtain any of their services, you do so at your own risk.

HOW WE PROTECT YOUR INFORMATION

We maintain physical, technical, organizational, and administrative safeguards designed to protect your personal information from unauthorized access or use. Among many other steps, these include unique user names and passwords for all Users; use of international industry standards for encryption; and control of information availability according to a User’s role, permissions, and associations within the Platform. User account information is shared only with authorized IntelliCentrics administrators and persons whom a User has authorized to see it. We also train employees to safeguard Personal Information and restrict access to Personal Information to those employees who need it in order to perform their duties, and we contractually require business partners with whom we share your Personal Information to safeguard it and to use it only for the purpose for which it was shared. We use Personal Information only for the purpose it was provided and as described in this Privacy Policy. Once it is no longer reasonably necessary for business purposes, we will destroy it in accordance with our record retention policy. However, we cannot ensure or warrant the security of any Personal Information you or others in relation to the Platform. Therefore, we cannot guarantee that the Platform is immune to unauthorized access to the personal information stored therein or to other information security risks.

We also contractually require business partners with whom we share your Personal Information to safeguard it and to use it only for the purpose for which it was shared.

HOW WE USE COOKIES AND SIMILAR TECHNOLOGY

  • Cookies: When you visit the Platform, we may send “session” cookies to your computer, to remember if you are logged in, to manage the session on our service provider’s server, and to balance website loads. We may also use “web beacons” to enable us to know whether you have visited a page or received a message, understand whether you came to our website in response to advertising and thus measure marketing campaigns and improve website performance, and/or relate your viewing of a web page or receipt of a message to other information about you, including your personal information. For the IntelliCentrics Site itself, we also employ Google Analytics and Google Adwords, whose cookies are set by Google, not IntelliCentrics, and which may use the data collected to contextualize and personalize the ads of its own advertising network. You may refuse to accept cookies by altering the settings on your internet browser. For details about our “cookies,” please see our Cookie Policy, which is part of this Privacy Policy.
  • Do not track signals and requests: ‘Do not track signals and requests’ are sent from your browser to the website you visit indicating that you do not want to be tracked or monitored. Websites are not required to accept these requests, and many do not. At this time, our Platform does not honor do not track signals or requests.

HOW YOU CONTROL YOUR INFORMATION

You may view, update, and delete certain information about your account at any time through the Platform. You may not, however, amend, delete or correct Personal Information which has been submitted by or obtained from a third party such as a credentialing company, records provider, or similar agency through the Platform. If you feel you need to challenge the accuracy of such information, you may contact that third-party provider directly, or you may contact us for assistance at Privacy@IntelliCentrics.com.

California, Canada, the European Economic Area (under the General Data Protection Regulation (“GDPR”)), and some other jurisdictions provide individuals with specific rights. For example, you may click on this link to find out more about these rights under the GDPR: To exercise any rights your jurisdiction may provide, contact us at Privacy@IntelliCentrics.com. We may require you to verify your identity before exercising your individual rights.

We are a data “controller” as provided under the GDPR.

HOW YOU OPT-OUT OF MARKETING MATERIALS

You may opt-out of marketing and informational materials at any time. Either click on the “unsubscribe” feature at the bottom of an email or other electronic material, or contact us at Privacy@IntelliCentrics.com and indicate your wish. If you do so, we may still contact you regarding transactional or administrative topics, such as service requests.

INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

We store information received through or by the Platform in the United States. If you are providing information from another country, you understand and agree that it will be transferred, used, and stored in the United States.

CAN CHILDREN USE THE PLATFORM?

No. The Platform is not directed to children under 18. If you are under 18, you should not submit information to the Platform.

We do not knowingly collect information from children. If we obtain actual knowledge that we have collected information from a child under 18, we will promptly destroy it, unless we are legally obligated to retain it. If you believe we have mistakenly collected information from a child under 18, please contact us at Privacy@IntelliCentrics.com.

CHANGES TO THIS Privacy Policy

We may change this Privacy Policy at any time, effective when we post the revised Privacy Policy on the Platform. Your use of the Platform means you accept our revised Privacy Policy. If, however, IntelliCentrics plans to use personal information in a manner that is materially different from that which is stated at the time such information was collected, IntelliCentrics will post notice of the change on the Platform for at least fifteen (15) days before the change will take effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and share Personal Information.

CONTACT US

If you have questions, concerns or complaints about our privacy practices, please email us at Privacy@IntelliCentrics.com or contact us at (817) SEC3URE (732-3873)




4815-1079-5139.1/15556/1390/121818